EPA's Vessel General Permit and Small Vessel General

Effects of the Action
The Effects of the Action is the primary focus of an Opinion. In this section, we first describe the
population of vessels covered under the VGPs. We then examine the consequences of exposing
endangered and threatened species and designated critical habitat to the discharges authorized by
EPA’s proposed VGPs. We organize our analyses by general stressor type: ANS or pollutants.
Under each section, we describe discharges authorized by the VGPs that are likely to produce
either ANS or pollutant stressors. For example, ballast water, hull fouling, and chain locker
effluent are grouped as discharges that carry ANS. We first characterize exposure of ESA-listed
species to the discharges authorized by the VGPs; we also describe the actions EPA will take to
prevent exposure of listed resources to authorized discharges. Next, we identify the physical,
chemical, and biological stressors associated with vessel discharges. Then we review the
literature describing the responses of threatened and endangered individuals, given exposure to
these stressors. Finally, we summarize the risks posed to the continued existence of populations,
species, or designated critical habitat. Our purpose is not to provide a comprehensive review of
the probable responses of and consequences to endangered or threatened species; instead, our
intention is to identify the range of representative responses and consequences we would expect
given exposure to vessel discharges authorized by EPA’s VGPs.
Vessel Populations Covered by the VGPs
The demographics of the vessels to be covered under the VGPs influence loading of stressors.
Vessel size affects discharge volume. Vessel service class and age generally determine the type
and performance of equipment used onboard vessels and therefore the characteristics of
discharges from the equipment. Vessel age structure also indirectly indicates the implementation
rate of build-date dependent protective measures over the 5-year permit period. Finally,
distribution of vessel service classes among ports and harbors influences pollutant loading from
VGP authorized discharges. The following paragraphs, describing the vessel service classes
authorized to discharge to waters of the U.S. under the VGPs, are summarized in Table 3 and
Table 4.
The types of vessels covered under the 2013 VGP include approximately 2,000 large commercial
fishing vessels greater than 79 feet along with cruise ships, ferries, barges, mobile offshore
drilling units, oil or petroleum tankers, bulk carriers, cargo ships, container ships, other cargo
freighters, refrigerant ships, research vessels, emergency response vessels, including firefighting
and police vessels, and any other vessels operating in a capacity as a means of transportation.
Approximately half of the vessels covered under the sVGP are commercial fishing vessels
involved in such activities as fish catching (e.g., longliner, shrimper, and trawler), fish
processing, fishing tendering, and charter fishing. The other half are distributed among a variety
of vessel types, including passenger vessels (e.g., water taxis, tour boats, harbor cruise ships,
dive boats), utility vessels (e.g., tug/tow boats, research vessels, offshore supply boats), and
freight barges (USEPA 2010b). These vessels and their relative abundance are described below.
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