While waiting for the new Vessel General Permit (VGP) to be finalized, operators must file a Notice of Intent with the U.S. Environmental Protection Agency (EPA) prior to December 18, 2018 in order for vessels to continue to operate under their current VGP also after this date.
According to a recent Regulatory Update published by the classification society American Bureau of Shipping (ABS), the EPA has further delayed the release its new Vessel General Permit (VGP 3.0).
The proposed VGP 3.0 was originally scheduled to be issued for comment in late 2017 but is now expected to be made available in March 2019 - with at least a 30-day comment period.
The VGP provides for National Pollutant Discharge Elimination System (NPDES) permit coverage for incidental discharges into U.S. waters from commercial vessels greater than 79 feet in length and for ballast water discharges from commercial vessels of all sizes.
The permit contains effluent limits for different types of discharges including ballast water, deck runoff, bilge water and grey water, as well requirements for the use of environmentally acceptable lubricants (EALs) in all oil-to-sea interfaces.
Each individual vessel in a fleet requires its own permit and the NOI requirements apply to vessels of 300 gross tons or more or vessels that have the ability to hold or discharge more than eight cubic meters of ballast water.
Operators of smaller vessels and of vessels with less ballast water capacity must instead complete a PARI Form (Fill and Print) and keep a copy of that form on board the vessel at all times.