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COLUMN SPECIAL REPORT “streamlining government regulation of industry.” Hope- the EPA’s website for publication of the draft 2018 VGP fully, this tactic will work, but in the meantime, owners and submit comments to the EPA, particularly if the CV- must comply with the myriad of regulations as they cur- IDA proposed legislation does not progress in Congress. rently exist, which is no easy task. With respect to the planning and logistical aspects of

Looking more closely at EPA VGP compliance, the cur- VGP compliance for ballast water, many owners think that rent 2013 VGP is set to expire on December 19, 2018. testing laboratories are either limited in numbers and/or

EPA is currently accepting comments on what revisions altogether unavailable. In reality, there are many labora- should be made to create the new 2018 VGP (i.e., prior to tories – both in the United States and overseas – that are its issuance of a draft permit, which is expected this fall). quali