EPA's Vessel General Permit and Small Vessel General

VGP Vessels
EPA’s Notices of Intent (NOI) database cannot be used alone to estimate the total number of
vessels covered by the VGP Permit because only vessels greater than 300 gross tons or with the
capacity to carry more than 8 cubic meters of ballast water were required to submit NOIs under
the 2008 VGP. To estimate the population of domestically-flagged vessels subject to the VGP,
EPA used two existing databases, the Marine Information for Safety and Law Enforcement
(MISLE) and Waterborne Transportation Lines of the United States (WTLUS) databases, to
create a master database identifying approximately 60,000 vessels eligible for coverage. Using
the Foreign Traffic Vessel Entrances and Clearances (FTVEC) database 5 , EPA estimated
approximately 12,400 additional foreign-flagged vessels also subject to the VGP requirements,
making a total estimated vessel population of 72,400 vessels. From these vessels, 43,431 active
NOIs were submitted under the 2008 VGP as of August 2010. This represents about 60% of the
estimated vessel population covered. The NOI form listed nine types of vessels under which the
vessel owners/operators could classify their vessel along with an option of selecting vessel
service class “Other,” with space to designate vessel type in writing. In addition to the vessels
identified in Table 4, about 10,000 were identified as “other.” These include 9,839 vessels for
which no vessel class was specified, while 2,044 others self-identified as some variety of cargo
vessel, 143 as tug/tow boats, 115 as crew/supply/support vessels, 83 as chemical/oil tankers, 34
as barges, and 18 as passenger vessels. These vessels are integrated into the table of relative
service class distribution and demographic properties for vessels submitting NOIs and with
tonnage/ballast water capacity (Table 4).
The EPA-provided metrics in Table 3 include median 6 values for vessel gross tonnage, ballast
capacity and maximum persons aboard along with the proportion of vessels with on board
treatment and using antifouling coatings. In addition to these metrics, NMFS used the build
dates reported in the NOI database to estimate the proportion of vessels within each service class
that are 5 years of age or younger. This provides an index of the expected implementation rate
of build date-dependent measures 7 within the permit.
Barges. Barges represent the greatest number of vessels permitted under the VGP, with 20,444
uniquely identified vessels. Barges are large, flat-bottomed boats typically used to move cargo
in inland waterways. There are many types of barges, including hopper barges, chemical barges,
5 The FTVEC database provides information on foreign vessels entering or clearing U.S. Customs ports in calendar
year 2008, the most recent year for which data are published (USACE, 2010).
6 The median of a set of observations is the center value in the dataset where half of the observations are below and
half are above. As a measure of central tendency, the median is robust against the influence of outliers and extreme
values found in skewed data, that is, not distributed symmetrically around the mean. When the mean is greater than
the median, it suggests the data are skewed such that it is influenced by a few larger values.
7 The VGP requires biannual graywater monitoring for vessels with a maximum capacity to overnight 10 or more
crewmembers and constructed on after December 19, 2013. In addition, all vessels constructed on or after
December 19, 2013 must use an environmentally acceptable lubricant in all oil-to-sea interfaces. Older vessels
technically able to use environmentally acceptable lubricants must do so and those which cannot, must report the use
of unsafe lubricants in their Annual Report to EPA.
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