EPA's Vessel General Permit and Small Vessel General

suspected to produce physical, physiological, behavioral, or ecological responses that have
potential individual or cumulative adverse consequences for individual organisms or constituent
elements of critical habitat?
5. Responses of Listed Resources
Does the general permit have an 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?
6. Compliance
Does the general permit have a mechanism to reliably determine whether or to what degree
operators have complied with the conditions, restrictions or mitigation measures the proposed
permit requires when they discharge to waters of the United States?
7. Adequacy of Controls
Does the general permit have a mechanism to prevent or minimize endangered or threatened
species or designated critical habitat from being exposed to stressors from discharges:
a) at concentrations, durations, or frequencies that are potentially harmful to individual
listed organisms, populations, or the species, or;
b) to ecological consequences that are potentially harmful to individual listed organisms,
populations, the species or Primary Constituent Elements of designated critical habitat?
As with all of our consultations, we conduct our section 7 analyses through a series of steps.
These include: examination of the action; identification of the action area; exposure analyses;
response analyses; analyses of aggregate impacts; and risk analyses. These steps are described
below.
Proposed Action
In reviewing the proposed action and biological evaluation, the Services examine the activities
that would be authorized by the proposed VGPs. This step of our analyses identifies spatial and
temporal patterns associated with each category of activity; specifically (a) the geographic
distribution of the different activities; (b) the number activities; (c) the amounts of pollutants that
are likely to be discharged; and (d) the rate of discharges.
Our analysis evaluates the effects of all discharges of biological and chemical pollutants to
waters of the US incidental to the normal operation of all eligible vessels that would be
authorized by the VGPs. In addition, we consider the effects of interrelated and interdependent
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