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SPECIAL REPORT ter from commercial vessels of all sizes. The EPA estimates 18, 2017, sVGP requirements only apply to discharges of bal- that approximately 61,000 domestically ? agged commer- last water from commercial vessels less than 79 feet, including cial vessels and approximately 8,000 foreign ? agged vessels all commercial ? shing vessels. Given this long delay, and simi- require VGP coverage for such incidental discharges. lar delays with the additional Ballast Water Treatment (BWT)

For commercial vessels of 79 feet or less, the EPA's sVGP requirements, many vessel owners deferred taking action on program applies. The EPA issued the sVGP regulations on sVGP compliance. Now, with US Coast Guard (USCG) ap-

September 10, 2014. The initial sVGP program was to be proval of three different BWT systems and uncertainty with effective for ? ve years between December 19, 2014 and the proposed VIDA solution, delaying compliance with the

December 18, 2019. Similar to VGP, the sVGP program sVGP’s December 18, 2017 deadline is no longer an option.

authorizes discharges incidental to the normal operation of commercial vessels less than 79 feet, including com- Apples & Oranges mercial ? shing vessels. However, the Howard Coble Coast It is important to note that the VGP and sVGP require-

Guard and Maritime Transportation Act of 2014 (Senate ments are very different. The EPA recognizes that small bill S.2444, P.L. 113-281), which was enacted after issu- commercial vessels are substantially different in how they ance of the 2014 sVGP requirement, included an exemp- operate than their larger counterparts, and as such, the tion for all incidental discharges from these “small” vessels, sVGP is much shorter and simpler than the VGP. The with the exception of ballast water, from having to obtain a sVGP speci? es best management practices for several broad

Clean Water Act (CWA) sVGP until December 18, 2017. discharge management categories including fuel manage-

The 2014 Maritime Transportation Act also exempted ment, engine and oil control, solid and liquid waste main- commercial ? shing vessels of all sizes from having to obtain tenance, graywater management, ? sh hold ef? uent man-

NPDES permits for those incidental discharges, except ballast agement, and ballast water management.

water, until December 18, 2017. As a result, until December Vessel discharges eligible for coverage under the sVGP are sVGP Regulated Discharge Streams

Bilgewater / Oily Water Separator Ef? uent Cathodic Protection Washdown and Runoff

Propeller, Rudder, stern tube Oil-to-Sea InterfacesChain Locker Ef? uent Anti-fouling hull coatings

Motor Gasoline and Compensating Discharge Elevator Pit Ef? uent Boiler/Economizer Blowdown

Refrigeration and Air Condensate Discharge Firemain Systems Gas Turbine Wash Water

Exhaust Gas Scrubber Washwater Discharge Freshwater Layup Non-Oily Machinery Wastewater

Seawater Cooling Overboard Discharge Welldeck Discharges Underwater Ship Husbandry

Seawater Piping Biofouling Prevention Ballast Water Small Boat Engine Wet Exhaust

Aqueous Film Forming Foams (AFFF) Graywater Sonar Dome Discharge

Distillation or Reverse Osmosis Brine Fish Hold Ef? uent Graywater Mixed with Sewage www.marinelink.com 29

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