EPA's Vessel General Permit and Small Vessel General

Anadromous fishes are threatened by the four Hs: habitat loss, harvest, hydrology alterations,
and for some species, hatcheries. These species are highly dependent upon waters of the U.S. and
thus are sensitive to the introduction of pollutants and ANS. Invasive species are likely to prey
on juveniles, compete for prey resources, alter essential habitat, and transmit infectious diseases.
Scientists estimate that ANS invasions are as great a threat as the four Hs combined because
ANS have the potential reduce the fitness of a large number of individuals through a multitude of
mechanisms. Therefore, ANS invasions are likely to reduce population and species viability.
Invasions are also likely to adversely affect the critical habitat of these species, which includes
prey resources as a principle constituent element.
In addition, the discharges of chemical pollutants that would be authorized by the permit are
known to adversely impact threatened and endangered species under NMFS’ jurisdiction.
Copper affects chemoreception of salmonids, reducing their ability to forage, migrate, avoid
predators, and find mates. It also impairs their disease resistance, respiration, osmoregulation,
blood chemistry, enzyme activity, and internal organ functions. Selenium reduces reproductive
potential in anadromous fishes. Therefore, exposure to copper and/or selenium are likely to
reduce population and species viability.
The southern resident killer whale and Cook Inlet beluga whale DPSs are isolated populations
that rely on anadromous fish as their primary prey. Because of their small population sizes and
specialized diets, these DPSs have little resilience to ecosystem perturbations, such as the
introduction of pollutants or ANS. Invasive species that reduce salmon or Pacific eulachon
abundance are likely to reduce the survival and reproduction of an individual. The reduction or
loss of their primary forage base is likely to affect many individuals, reducing population and
species viability. The North Atlantic right whale exhibits an extremely small population size and
is also vulnerable to ecosystem perturbations, including ANS invasions that produce toxic algal
blooms. Invasions would also adversely affect the critical habitat of these species, which include
prey resources as a principle constituent element.
Threatened and endangered marine invertebrates have experienced dramatic declines as a result
of ecosystem restructuring, overharvest, environmental changes, and disease. Their reproductive
strategies (e.g., broadcast spawning) make them susceptible to detrimental Allee effects at small
population sizes. They are especially vulnerable to the introduction ANS invasions which would
lower the fitness of individuals through the introduction of novel pathogens and competition for
space and prey. These mechanisms are likely to affect a large number of individuals through the
spread of disease and niche replacement. Therefore, ANS invasions are likely to reduce
population and species viability of listed invertebrates. Invasions are also likely to adversely
affect the critical habitat of these species, which includes prey resources and suitable substrate as
principle constituent elements. Copper has also been shown to reduce the survival and
reproduction of mollusks such as the endangered black and white abalone species under NMFS’
jurisdiction. Therefore, exposure to copper is likely to reduce population and species viability.
Listed plant species have declined primarily as a result of habitat modification and destruction
and altered water quality. Their limited habitat range provides little resilience to ecosystem or
environmental perturbations. Invasive species are likely to transmit infectious diseases and
compete for resources (including space). Disease is likely to spread quickly through the small
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