EPA's Vessel General Permit and Small Vessel General

make data submitted to the Agency in electronic form available to the public in electronic form.”
For vessels covered under the sVGP, self-monitoring reports are kept on board; though never
sent to EPA, these reports could be checked during an inspection. Though plans for sVGP
inspections are still under development, EPA assured the Services that a small subset of vessels
covered under the sVGP would be inspected annually (Senior Manager’s Meeting, dated October
19, 2012). In comparison, the U.S. Coast Guard program includes mandatory reporting and an
existing system for receiving and archiving report information; they conduct inspections of
nearly every vessel under their jurisdiction to corroborate report claims (NAS 2011). Thus,
EPA’s monitoring program is not as well-developed as that of the U.S. Coast Guard.
We conclude that EPA is likely to identify, collect, and analyze important information about its
authorized discharges under its VGP. Their ability to collect monitoring data on vessel
discharges authorized under the sVGP is dependent on the development of inspection plans,
described below (under compliance, section 6). This monitoring information is essential because
it will provide EPA with data needed to reliably estimate stressors and exposure throughout the
life of the permit. It will also provide EPA with a means to determine the efficacy of its permit
in protecting waters of the U.S. and the listed resources that depend upon them (as discussed
further below, number 7).
(5) Effects on Listed Resources
Here we ask whether EPA has used analytical methodology that considers:
a) the status and trends of endangered or threatened species or designated critical habitat;
b) the demographic and ecological status of populations and individuals of those species
given their exposure to pre-existing stressors in different drainages and watersheds;
c) the direct and indirect pathways by which endangered or threatened species or designated
critical habitat might be exposed to the discharges to waters of the United States; and
d) the physical, physiological, behavior, sociobiological, and ecological consequences of
exposing endangered or threatened species or designated critical habitat to stressors from
discharges at concentrations, intensities, durations, or frequencies that could produce
physical, physiological, behavioral, or ecological responses, given their pre-existing
demographic and ecological condition.
As with uncertainties in its exposure analysis, EPA also identified uncertainties in the response
analysis. In section 5.2.6.2 of the BE, EPA provided a comprehensive discussion of
uncertainties associated with the selection of chronic toxicity values. In order to address whether
EPA has demonstrated sufficient knowledge of the effects on listed resulting from exposures to
discharges authorized by the VGP, we must first review these uncertainties for the BE’s
assessment and how EPA addressed them, then evaluate the additional uncertainties identified by
the Services.
Uncertainty in Effects Analysis Identified by EPA
EPA acknowledged the uncertainty added to its analysis by the interspecies extrapolations
necessary to fill data gaps in response toxicity threshold information for threatened and
endangered species. The use of chronic effects data from tests with surrogate species
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