Coast Guard and EPA Tackle Enforcement Issues for Vessel General Permit Requirements


The Vessel General Permit (VGP) program applies to more than 61,000 commercial vessels in the United States and to more than 8,000 foreign vessels operating in the navigable waters of the United States. Upon implementation in February 2009, the VGP established operational, reporting, and record keeping requirements for 26 types of discharges incidental to the normal operation of these vessels, such as deck run-off, ballast water, and gray water. The VGP also established inspection and monitoring requirements, and requires corrective actions be taken to address compliance deficiencies.

On February 11, 2011, the Coast Guard and the Environmental Protection Agency (EPA) entered into a Memorandum of Understanding (MOU) to outline parameters on compliance assistance, compliance monitoring, and enforcement of the permit requirements on vessels. While the VGP has been in effect for two years, enforcement has been sporadic. An MOU of this nature, however, signals that the agencies responsible for enforcement have worked out any differences in terms of enforcement approaches and priorities, and that enforcement will now become more focused and aggressive.

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Published In: Administrative Agency Updates, Environmental Updates, Maritime Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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