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www.marinelink.com MN21ENVIRONMENTAL equipment, materials, and operationsthat contribute to the discharges, aswell as the discharge rates, duration, frequency, and location. THEBOTTOM LINE: POTENTIALLY LESSTHAN 79 FEETLONG ?Some vessel discharges from com- mercial fishing vessels and commer- cial vessels less than 79 feet in length have the potential to impact the aquatic environment and/or human health. The EPA found that the sam- pled discharges with the greatest potential to impact surface water quality included deck washdown, fish hold effluent, graywater, bilgewater, and marine engine effluent. Though these discharges may have the potential to impact surface water quality, particularly on a localized scale, a screening level model of a hypothetical large harbor by the EPA revealed that most of these discharges in and of themselves would not exceed levels set forth within the national water quality criteria in largewater bodies. While environmental groups are lobbying to end the mora- torium and exception for vessels under 79 feet, the hard data does not appear to justify additional regulation for small vessel operators, unless they are operating in restricted, sensitive waters. That said, and given the trend toward more environmental regula- tion, Congress may well utilize the EPA?s recent study to reach the small vessel and workboat force before long. All of that inevitably will lead tomore paperwork and more crew fatigue. And, yes, more acronyms. Matthew Valcourt is a Partner with Fowler White Burnett P.A. and focus- es his practice on maritime law. He handles all types of marine-related litigation and holds a USCG Unlimited Chief Mate and 1600 Ton Masters License. He is Board Certified in Admiralty and Maritime Law, is current Chair of the Florida Admiralty Law Committee and serves as a director to the Massachusetts Maritime Academy Alumni Association. He is a member of the Maritime Law Association, and the Southeastern Admiralty Law Institute. MN#9 (18-31):MN 2011 Layouts 9/6/2011 4:17 PM Page 21