The California Office of Spill Prevention and Response (OSPR) announced on 20 June they are delaying the implementation date for the requirements to identify salvage, firefighting and emergency lightering resources in California Non-tank Vessel Contingency Plans (C-Plan). The regulations will now take effect 28 October 2002.

We were advised that one of the reasons for the delay is to allow California OSPR time to consider an amendment to their regulations that would allow them to accept a “Letter of Intent” as an alternative to the “valid contract” that is currently required under California regulations.  OSPR has not yet determined the specific form of an acceptable “Letter of Intent”.


The possibility of accepting “Letters of Intent” had been discussed previously with OSPR who advised that the regulations did not permit this alternative.  OSPR has now decided to propose an amendment to the regulation that would allow acceptance of additional approved means to demonstrate a “valid contract”, including a “Letter of Intent”.  OSPR advised us they are fairly confident that the amendment will be approved, at which time they will begin to accept “Letters of Intent”. 


If you have already entered into a contract with a salvage, firefighting and emergency lightering service provider you are in compliance with California regulations and need do nothing more.


Source: Corbett & Holt/Gallagher Marine Systems