EPA's Vessel General Permit and Small Vessel General

actions of the proposed action. Interdependent actions are actions having no independent utility
apart from the proposed action (50 CFR 402-02 1 ). They are typically a consequence of the
proposed action. For example, if our consultation were evaluating the effects of building a road,
an interdependent action would be the planned construction of homes and other structures that
would not be accessible without the presence of that road. Interrelated actions are actions that
are part of a larger action and depend on the larger action for their justification (50 CFR 402-
02 3 ). They are actions that are typically associated with the proposed action.
In this consultation, NMFS addresses the potential effects of the proposed action for marine,
coastal, estuarine, or anadromous endangered species, threatened species, and critical habitat that
has been designated for those species in those ecosystems under its jurisdiction.
Action Area
We determine the degree of geographic and temporal overlap between the activities that would
be authorized by the proposed VGPs and endangered and threatened species and designated
critical habitat.
Exposure Analyses
Before assessing an agency’s decision-making process (as described above), the NMFS first
establishes whether the proposed action could expose listed species and critical habitat to
potentially harmful stressors and whether listed species and critical habitats are likely to respond
adversely. If exposure to stressors and adverse responses are not likely to occur, we do not
assess the agency’s decision-making process.
Our assessment focuses on whether and to what degree the EPA structured the VGPs in ways
that would prevent or minimize endangered or threatened species or critical habitat that has been
designated for those species from being exposed to harmful discharges of pollutants into waters
of the United States and other harmful activities because such exposures commonly trigger
responses that are difficult to prevent. For example, once individual plants and animals are
exposed to a discharge containing pollutants, their responses to the exposure is controlled by the
concentration, duration, and frequency associated with the exposure, their sensitivity to the
discharged materials, other physical, chemical, or biotic stressors they are exposed to in the same
time interval, their pre-existing physiological state, and their constitutional endowment. Because
it is so difficult to prevent free-ranging organisms from responding to anthropogenic stressors
once they have been exposed, the most effective management measures are designed to influence
the exposure itself. For that reason, our assessment focuses on whether and to what degree the
VGPs prevent or minimize endangered and threatened species and designated critical habitat
from being exposed to harmful discharges and other harmful activities that would be authorized
by the proposed VGPs. Rather than discuss the literature for each species, it would be only be
necessary to discuss the risks of exposing species groups (for example, Pacific Salmon;
Sturgeon; Sea Turtles; etc.).
1 See: http://cfr.vlex.com/vid/402-02-definitions-19895209
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