Challenges of vessel general permit

The U.S. Environmental Protection Agency (EPA) issued the Vessel General Permit (VGP) for discharges incidental to the normal operation of vessels on February 5, 2009, under the Clean Water Act. This permit set forth requirements for most vessel discharges within 3 nautical miles of the U.S. shore. The requirements include filing for a notice of intent, meeting VGP effluent limits, inspecting and monitoring, record keeping, and reporting. To understand the impact of this permit, data were solicited from EPA. On the basis of the results of the analyzed data and discussion with individuals from the maritime industry and various government agencies, this paper discusses five aspects of challenges that the VGP may encounter: EPA's roles, states' additional requirements, onshore facilities, compliance issues, and economic impact.