Vessel General Permit (VGP): Key Requirements and Updates
The Vessel General Permit (VGP) is a regulatory framework developed by the US Environmental Protection Agency (EPA) under the Clean Water Act (CWA). It governs discharges incidental to the normal operation of non-military and non-recreational vessels operating in US waters. Below is a comprehensive overview of the significant provisions, requirements, and changes under the latest VGP.
Ships release water and other substances into the sea during normal operations. For example:
Ballast water: Water taken in and discharged to balance the ship.
Deck runoff: Rainwater mixed with oil or dirt running off the deck.
Engine cooling water: Water used to cool engines that might carry heat or small pollutants.
These discharges can harm the environment by polluting the ocean or spreading invasive species. The VGP sets rules to:
Limit pollution in these discharges.
Protect marine life and US coastal waters.
Ensure ships operate in a way that’s safe for the environment.
The VGP applies to:
Non-military and non-recreational vessels 79 feet or longer operating in US waters, including inland waters and territorial seas extending up to three miles from the US coastal baseline.
Exceptions are outlined in Part 6 of the permit.
Unmanned and unpowered barges may qualify for exemptions under specific conditions.
The VGP introduces requirements for vessel operators by regulating discharges more effectively and enhancing monitoring and reporting standards.
Vessel masters, operators, persons-in-charge, and crew members must receive adequate training on:
Implementation of the permit's requirements
Proper response to fuel spills and overflows
stringent requirements are in place to minimize oil discharges from interfaces such as stern tubes, controllable pitch propellers, and thruster bearings.
Specific standards and enhanced monitoring for ballast water, ensuring compliance with US Coast Guard (USCG) regulations.
Monitoring is also required for bilgewater, graywater, and exhaust gas scrubber washwater.
Operators must now submit a single annual report.
Annual reports must include analytical monitoring results and be submitted electronically unless a waiver is granted.
Reports are due by 28 February of the following year.
For vessels under 300 gross tons or with ballast water capacity less than or equal to 8 m3, operators must:
Maintain a Permit Authorization and Record of Inspection (PARI) form on board.
The updated VGP addresses 26 specific discharge categories from vessels, with an additional category (fish hold effluent) potentially included pending the expiration of a moratorium. Below are the key regulated discharges and requirements:
For newbuild vessels over 400 gross tons, operators must:
Conduct annual sampling of bilgewater for oil and grease content.
Use oily water separators (OWS) capable of maintaining a 5 ppm oil and grease limit.
Monitoring:
Two consecutive years of sampling show oil levels below 5 ppm.
Equipment is calibrated annually, and readings remain below the 5 ppm threshold.
Some states (e.g., Connecticut, New York) prohibit bilgewater discharge entirely, while others (e.g., Rhode Island) require bilgewater discharge before entering their waters.
The EPA ballast water requirements to align with USCG regulations. Key elements include:
Ballast Water Management Systems (BWMS):
Vessels must use BWMS that are either USCG type-approved or have Alternative Management System (AMS) acceptance.
Systems must comply with limits for biocides such as chlorine, ozone, and hydrogen peroxide.
Monitoring Requirements:
Monthly functionality checks for BWMS components.
Annual calibration of sensors and equipment.
Periodic testing for biological indicators and biocides/residuals.
Mandatory Best Management Practices (BMPs):
Prohibition on discharging sediments from ballast tank cleaning into US waters.
Mandatory ballast water exchange or saltwater flushing for vessels operating outside the Exclusive Economic Zone (EEZ) and entering the Great Lakes.
State-Specific Regulations:
Thirteen states, including California, Michigan, and New York, have additional ballast water requirements under CWA certifications.
Tin content in hull coatings is limited to 2,500 mg/kg (total tin) to reduce harmful environmental impacts.
Restrictions apply to copper-based antifouling paints in copper-impaired waters, such as:
Shelter Island Yacht Basin (San Diego, California)
Ports of Los Angeles and Long Beach
Specific standards regulate the discharge of washwater from exhaust gas scrubbers.
Monitoring requirements are in place to ensure compliance with effluent limits.
Operators must document the choice of anode material:
In fresh water, justification is required if aluminum or zinc is used instead of magnesium.
In saltwater, operators must document why zinc was selected.
The VGP emphasizes robust monitoring and record-keeping to ensure compliance. Key requirements include:
Analytical Monitoring:
Required for bilgewater, ballast water, and exhaust gas scrubber washwater.
Results must be submitted as part of the annual report.
On-Board Records:
Ships must maintain copies of:
Training records
Monitoring results
Permit Authorization and Record of Inspection (PARI) forms (for smaller vessels)
Calibration and Equipment Maintenance:
Sensors, alarms, and monitoring equipment must be calibrated annually.
Operators must adhere to the following timelines to ensure compliance with VGP:
Notice of Intent (NOI):
For vessels 300 gross tons or greater or with ballast water capacity exceeding 8 m3, an electronic NOI must be submitted before discharges begin.
Vessels without broadband access or sufficient computer capabilities may submit paper NOIs, subject to waiver approval.
Annual Reporting:
Reports are due annually by 28 February for the previous calendar year.
No separate report is required for partial coverage periods.
Several states have added specific provisions under CWA certifications to protect local water quality. Notable examples include:
Ballast Water Discharge:
States like Michigan and California impose stricter ballast water treatment and monitoring requirements.
Bilgewater Prohibition:
Connecticut and New York prohibit bilgewater discharge.
Operators must review state-specific regulations to ensure full compliance.
The Vessel General Permit establishes a comprehensive framework to regulate discharges incidental to vessel operations, ensuring greater protection of US waters. Key changes include enhanced monitoring and reporting, stricter discharge standards, and streamlined reporting processes. Vessel owners and operators must stay informed of federal and state-specific requirements to maintain compliance and avoid potential penalties. Regular training, proper equipment maintenance, and diligent record-keeping will play a critical role in achieving compliance under the VGP.
