Recently, we have received following information from ECM/Hudson (hereinafter referred as "the trustee"), who has been trusted by many of our members with preparation and application for approval of Contingency Plans and application for COFRs to California state authorities, Office of Spill Prevention and Response (OSPR).

Such members are recommended to apply with a sufficient lead-time in order to avoid unnecessary trouble or cost, bearing the following information in mind.

1.	For a full four-month-period since California's non-tank vessel contingency plan and COFR regulations came into effect, requests for plans/COFRs and processing of the same seem to be proceeding apace. So far, no vessel represented by the trustee has been delayed/detained/ penalized due to its failure to have a COFR or an approved plan.
2.	For the most part, owners have given the requisite lead-time for OSPR to process these requests within time-frames stipulated in the regulations (21 days to process a COFR and 7 days to process plan approval). However, some requests have been made to the trustee just prior to the vessel's arrival in California waters, or even after the vessel's entering California waters with no COFR/plan on board.
3.	In those instances, the trustee has had to try to obtain a one-time vessel waiver with diverting the necessary staff from their routine daily functions, while simultaneously obtaining a COFR and processing a plan. By law, the State is well within their rights to withhold processing the COFR and/or approving the plan pursuant to the time-frames mentioned in the previous paragraph.
4.	Such being the case, the trustee cannot simply charge these tasks out at its standard rate of $150/vessel. Due to the time involved, it must charge the owner at its emergency response planning rate of $90/hour.
5.	The trustee suggests that should there be any chance for the vessel to call California, owners should go ahead now and apply for a COFR/plan.