EPA's Vessel General Permit and Small Vessel General

methodologies and understanding of the risk-release relationship, could provide a
long-term perspective about ballast water discharge standards, antifouling
technologies, and other practices to reduce invasions.
3. EPA will report to the Services once per year that they have reviewed this information
and whether notable new invasions have been recorded in the previous year that could
have been previously caused by vessel discharges. The Services note that they are
requesting a short review (approximately one hour per year) to ensure EPA continues to
track aquatic bioinvasions. As discussed above, EPA and the Services agree that these
observations are being used to inform EPA’s general understanding of continued and
ongoing invasion rates.
4. EPA will identify and implement, as appropriate, additional actions (e.g., require antifouling
coatings; require debris containment systems; require more stringent ballast water
standards) as soon as practicable (including in future permit iterations) to ensure the
protection of listed species if needed.
These ANS monitoring methods were chosen to provide an indicator of how invasion rates
change over time. For example, researchers at the Smithsonian Environmental Research Center
(SERC) 14 have conducted systematic surveys for non-native species in San Francisco Bay (past
12 years) as well as Tampa and Chesapeake Bays (past year). These studies were designed to
provide an indicator of how ANS invasion rates change over time as regulations change. Data
analyses include identifying the source location (e.g., South China Sea) of the ANS as well as the
vector for the ANS (e.g., ballast water, biofouling, etc.). The databases provide a nationwide
repository for newly reported ANS invasions in marine (NEMESIS) and freshwater (USGS
NAS) environments; they do not account for changes in effort as above.
NMFS spoke with the Senior Scientist and Primary Investigator of the SERC Marine Invasions
Research Lab and NOAA’s Senior Liaison to the ANS Task Force, to determine whether these
methods would be informative and whether they could be used as a gross measure of the efficacy
of the VGPs. Both agreed that the systematic surveys were a good method to track the
effectiveness of the permit. They acknowledged the lag time for ANS invasions (months to
years after introduction) but were confident that the metric would be meaningful within the life
of the permit (i.e., 5 years). They also saw the value in establishing base and trend lines in the
early years of the permits. Finally, they explained that EPA could ask SERC to tailor their data
analyses to link invasion rates directly to the VGPs. For example, they could restrict the dataset
to ANS introduced by transoceanic commercial vessels, whose ballast water and anti-fouling/hull
husbandry practices are authorized under the VGP.
As they pertain to ballast water, EPA’s monitoring measures can be compared to USCG’s Ballast
Water Rulemaking. Under the VGP, permittees are responsible for self-inspections and
monitoring; they are required to provide annual reports. EPA affirms “those data will be
submitted to an electronic reporting tool and database currently in development. EPA plans to
14 See: http://www.serc.si.edu/labs/marine_invasions/index.aspx
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