MarineNews-2017-02

ter from commercial vessels of all sizes. The EPA estimates
that approximately 61,000 domestically fl agged commer-
cial vessels and approximately 8,000 foreign fl agged vessels
require VGP coverage for such incidental discharges.
For commercial vessels of 79 feet or less, the EPA's sVGP
program applies. The EPA issued the sVGP regulations on
September 10, 2014. The initial sVGP program was to be
effective for fi ve years between December 19, 2014 and
December 18, 2019. Similar to VGP, the sVGP program
authorizes discharges incidental to the normal operation
of commercial vessels less than 79 feet, including com-
mercial fi shing vessels. However, the Howard Coble Coast
Guard and Maritime Transportation Act of 2014 (Senate
bill S.2444, P.L. 113-281), which was enacted after issu-
ance of the 2014 sVGP requirement, included an exemp-
tion for all incidental discharges from these “small” vessels,
with the exception of ballast water, from having to obtain a
Clean Water Act (CWA) sVGP until December 18, 2017.
The 2014 Maritime Transportation Act also exempted
commercial fi shing vessels of all sizes from having to obtain
NPDES permits for those incidental discharges, except ballast
water, until December 18, 2017. As a result, until December

18, 2017, sVGP requirements only apply to discharges of bal-

last water from commercial vessels less than 79 feet, including

all commercial fi shing vessels. Given this long delay, and simi-

lar delays with the additional Ballast Water Treatment (BWT)

requirements, many vessel owners deferred taking action on

sVGP compliance. Now, with US Coast Guard (USCG) ap-

proval of three different BWT systems and uncertainty with

the proposed VIDA solution, delaying compliance with the

sVGP’s December 18, 2017 deadline is no longer an option.

Apples & Oranges

It is important to note that the VGP and sVGP require-

ments are very different. The EPA recognizes that small

commercial vessels are substantially different in how they

operate than their larger counterparts, and as such, the

sVGP is much shorter and simpler than the VGP. The

sVGP specifi es best management practices for several broad

discharge management categories including fuel manage-

ment, engine and oil control, solid and liquid waste main-

tenance, graywater management, fi sh hold effl uent man-

agement, and ballast water management.

Vessel discharges eligible for coverage under the sVGP are

Bilgewater / Oily Water Separator Effl uent Cathodic Protection Washdown and Runoff

Propeller, Rudder, stern tube Oil-to-Sea Interfaces Chain Locker Effl uent Anti-fouling hull coatings

Motor Gasoline and Compensating Discharge Elevator Pit Effl uent Boiler/Economizer Blowdown

Refrigeration and Air Condensate Discharge Firemain Systems Gas Turbine Wash Water

Exhaust Gas Scrubber Washwater Discharge Freshwater Layup Non-Oily Machinery Wastewater

Seawater Cooling Overboard Discharge Welldeck Discharges Underwater Ship Husbandry

Seawater Piping Biofouling Prevention Ballast Water Small Boat Engine Wet Exhaust

Aqueous Film Forming Foams (AFFF) Graywater Sonar Dome Discharge

Distillation or Reverse Osmosis Brine Fish Hold Effl uent Graywater Mixed with Sewage

sVGP Regulated Discharge Streams

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