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www.marinelink.com MN19(NOI) or the electronic version, the eNOI. The Electronic Notice of Intent system allows notices to be sent to the EPA from the operator regarding intent to discharge, and also allows the NOI form to be creat- ed by one entity and be certified by the operator separately. The EPA requires at least 30 days to process a complete and accurate NOI submit-tal and allow coverage under the VGP for vessels, which have not previously been covered under the VGP. The EPA may require additional time and paper submission of NOIs can take approximately 60 days to process. The key lesson to be learned here is that if a vessel is planning to operate in areas covered by the CWA, advance planning is critical. Interestingly, the NPDES vessels program does not regulate discharges from military vessels or recreational vessels. Instead, those vessel dis- charges are regulated by other EPA programs under section 312 of the Clean Water Act. Incidental dis- charges from the normal operation of vessels include, but are not limited to ballast water, bilge water, graywater (e.g., water from sinks, showers) and anti-foulant paints. These discharges may result in negative environmental impact via the addition of traditionalpollutants or, in some cases, by con- tributing to the spread of Aquatic Invasive Species. EXCEPTIONSTOTHE RULE?: NOTSOFAST ?Through intensive lobbying, Congress allowed exceptions to the permitting requirement for recre- ational vessels, fishing vessels, and commercial vessels under 79-feet in length. President Obama signed Public Law (PL) 111-215 (Senate Bill The EPA may require additional time and paper submission of NOIscan take approximately 60 days to process. The key lesson to be learned here is that if a vessel is planning to operate in areas cov- ered by the CWA, advance plan- ning is critical. MN#9 (18-31):MN 2011 Layouts 9/6/2011 4:15 PM Page 19