EPA's Vessel General Permit and Small Vessel General

under the VGP. They did not estimate the location and timing of discharges, nor did the account
for the vessels that do not submit NOIs; for this they should use the annual reports in the future.
The sVGP is a new permit; unlike the VGP, it will not require NOIs or annual reports.
Therefore, even after the permit goes into effect, EPA will not know or be able to reliably
estimate the number or location of the vessels authorized to discharge under the sVGP. Instead,
EPA uses (and would continue to use) the U.S. Coast Guard’s MISLE database to search for
vessels that are less than 79 feet in length, except for recreational and military vessels. They
estimate that 115,000 to 138,000 vessels would be eligible for coverage under the sVGP. They
do not estimate how many vessels of these vessels are likely be covered under the sVGP, nor
how many vessel owners/operators will consider themselves to be covered under the sVGP or
self-identify (i.e., have the knowledge that they are discharging wastes under a Federal permit).
Accurate self-identification is an acknowledged problem among general permits. For example,
self-identification by municipal and industrial storm water dischargers was among the metrics
evaluated in a study of 136 facilities subject to stormwater General Permit requirements (Cross
and Duke 2008). Among these facilities, approximately 21% were aware that their discharges
were subject to the permit even though stormwater permits had been in place over 15 years. The
authors suggested that outreach might improve compliance among dischargers. The rates of selfidentification
among municipal and industrial storm water dischargers do not necessarily apply
to vessels authorized to discharge under the either of the VGPs. Cultural differences among
these regulated communities and the well-defined vessel populations and discharges specified
under the VGPs should lead to greater awareness of vessel operator obligations under these
permits. An online query for information on the VGPs indicated information sharing activity
during and after the VGPs comment period among professional associations, service providers,
state and federal agencies within the US and US trading partners.
Although there is evidence that self-identification rates for the VGPs may be greater than that for
other General Permits, EPA has not at this time reliably estimated the actual number, location,
and timing of discharges authorized by the sVGP. One way in which EPA will address these
estimates is through inspection of a random sample of small vessels and extrapolation to the
larger population of small vessels. As described below (under the compliance section, number
6), one question that will be asked during small vessel inspections is whether vessel
owners/operators consider their vessels to be authorized under the sVGP and perform actions
(e.g., signing a PARI form and quarterly inspections) required of the permit.
We conclude that EPA is aware of the scope of their Action and has reliably estimated the
probable number of discharges that it would authorize under the VGP. Though EPA has not
reliably estimated the probable number of discharges that it would authorize under the sVGP, we
expect that their proposed inspection and compliance plan will allow them to do so.
(2) Stressors
Here we ask whether the EPA has reliably estimated the physical, chemical or biotic stressors
that are likely to be produced as a direct or indirect result of the vessel discharges that would be
authorized by the VGPs. We also ask whether the EPA would know or be able to reliably
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