USA - New Vessel General Permit Proposals

The United States Environmental Protection Agency (EPA) has recently redrafted the Vessel General Permit (VGP) for public review and comment. The new VGP will replace the existing 2008 VGP when the latter expires on 19 December 2013.

The proposed changes include the following:

• The addition of fish hold effluent to the 26 vessel discharges covered by the present permit
• Numeric ballast water discharge limits for most vessels
• More stringent effluent limits for oil to sea interfaces and for exhaust gas scrubber wash water
• The authorisation of electronic record keeping
• A single annual report in place of the one time report and the annual non-compliance report

In addition, a Small Vessel General Permit (sVGP) is proposed covering non-recreational vessels of less than 79 feet in length and commercial fishing vessels. This would be introduced after the present moratorium on incidental discharges for such vessels, with the exception of ballast water, expires on 18 December 2013.

As small vessel operations differ considerably from those of larger vessels, the proposed sVGP is simpler in its scope and application, covering pollutants that may arise from nine discharge management categories. The permit would also provide for more simplified inspections and reporting than is required by the VGP and would not require the owner or operator to submit a Notice of Intent (NOI). Instead, coverage would be automatic and each owner or operator would be required to sign a “Permit Authorisation and Record of Inspection Form”.

The discharge management categories which would be covered by the sVGP are as follows:

• Fuel management
• Engine and oil control
• Solid and liquid waste management
• Deck wash down and runoff and above the waterline hull cleaning
• Vessel hull maintenance
• Grey water
• Fish hold effluent
• Ballast water
• Seawater cooling overboard discharge (including non-contact engine cooling water, hydraulic system cooling water and refrigeration cooling water)

Comments must be submitted to the EPA by 21 February 2012. Details of how to do so may be found in the Proposed 2013 VGP Factsheet and Proposed 2013 sVGP Fact Sheet.

For further information please see the EPA website or contact the Loss Prevention department.