EPA's Vessel General Permit and Small Vessel General

Study Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial
Fishing Vessels and Other Non-recreational Vessels Less than 79 Feet (USEPA 2010b). EPA’s
BE and the Report to Congress do not provide the same level of detail on the distribution of
ballast capacity, onboard treatment and the presence of antifouling coatings for sVGP vessels as
was provided for VGP covered vessels. Details for sVGP eligible vessels are provided for hull
material and horsepower (Table 4).
Approximately half of the sVGP eligible vessels are commercial fishing vessels involved in such
activities as fish catching (111,094 vessels, 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 (34,609 vessels, e.g., water taxis, tour boats, harbor
cruise ships, dive boats), utility vessels (18,743 vessels, e.g., tug/tow boats, research vessels,
offshore supply boats), freight barges (11,596 vessels), freight ships (1,102 vessels) along with
35,578 vessels with unspecified service class (USCG 2009, USEPA 2010b). Recreational
vessels are generally excluded because a separate act (the Clean Boating Act of 2008 (P.L. 110-
288)) exempts discharges incidental to the normal operation of these vessels from NPDES
permitting requirements. The Clean Boating Act defines recreational vessels as those that are
either 1) manufactured or used primarily for pleasure or 2) leased, rented, or chartered to a
person to use for pleasure. Furthermore, vessels that are subject to U.S. Coast Guard inspection
and that are either engaged in commercial use or that carry paying passengers are not considered
recreational vessels under the Clean Boating Act.
Hull Materials. According to the analysis in EPA’s report to Congress, the three most common
hull material types among sVGP eligible vessels are fiberglass, wood, and steel in order of most
common usage. Commercial fishing vessels with wood hulls account for over three quarters of
the total number of wood hulled vessels, although wood is also used in the hulls of a significant
share of freight ships and passenger vessels less than 79 feet in length. The type of hull material
affects the type of anti-foulant coatings that are applied and has implications on vessel discharges
and receiving water quality. For example, steel hulls often have an anti-corrosive as well as antifoulant
hull coatings. The type of hull material may also affect the frequency with which certain
maintenance procedures such as hull inspections are conducted(USEPA 2010b).
Vessels less than 5 years old. Vessel age, for the purposes of this Biological Opinion, is an
indicator of the implementation rate for build date dependent measures specified by the VGPs.
The sVGP requires that “All motorized vessels constructed on or after December 19, 2013 must
have a functioning fuel-air separator or a fuel tank vent to prevent a fuel spill.” In addition, for
both VGPs, 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.
Self-Propelled Vessels and Horsepower Ahead. Not all vessels covered by the sVGP are selfpropelled;
rather they are moved about by other vessels (e.g. tug boats, tow boats). Horsepower
ahead represents the rated power of a vessel’s engine in forward motion (as opposed to
horsepower astern) and is expressed as the work accomplished per unit of time (e.g., 1 hp = 550
foot-pounds of work per second). This power is transferred to the propulsion mode (e.g., jet or
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