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P Waters during the calendar year. In-

LANNING

Failing to plan also means that an formation can be found in Section operator is planning to fail. Therefore, 4.4 of the VGP. https://www.regula- advance planning for VGP compli- tions.gov/document?D=EPA-HQ- ance is a matter of paramount impor- OW-2011-0141-0949 tance. Even though a VGP sampling The complacency that permeated event can be arranged quickly, time VGP, the delays associated with bal- is needed to ensure quali? ed labs are last water management requirements, available, arrange for lab supplies and the uncertainty of whether CVI- and a sampling technician. While it DA may resolve some of these issues, is understood that vessel schedules all combined to distract owners from ? uctuate based on a variety of fac- taking proactive compliance actions. tors, if the vessel informs the service Given that the long delayed sVGP provider/lab of the port where ballast legislation is now in force and USCG water discharge/sampling is expected BWT extensions are more dif? cult to to occur in advance, the service pro- obtain and quickly being phased out vider can better support the vessel. completely, owners have no choice

Like other husbandry services ships but to comply with these new regu- require, conducting VGP sampling lations despite the generally poor in large ports is generally easier and freight markets.

more cost effective. Although there is still hope that CV-

Vessels also need to ensure they are IDA may provide some relief, owners operating their BWTS, if required, in must make sure they are in compliance accordance with the operations man- with these various environmental regu- ual. For example, if treated ballast lations now. The sting of these compli- water requires a holding period, bal- ance costs at this uneconomical time last discharge and sampling should may hurt, but it does not outweigh the only be done after the prescribed risk of vessel delays and ? nes associated treatment process has been complet- with noncompliance. ed. If VGP sampling is conducted when the BWTS has not been oper- ated properly, the vessel is in risk of being non-compliant.

Much of the recent VGP focus has

Steve Candito is the CEO of Ecochlor, been on ballast water. However, it’s

Inc. Prior to joining Ecochlor, Steve was important for owners to know that the

Founder, President and CEO of Fore-

VGP regulates 27 different vessel dis- sea Consulting where he provided vari- charges. Owners must become famil- ous advisory services including strategic iar with the regulated discharges appli- planning, regulatory compliance and crisis management to the maritime and cable to each vessel and the respective environmental communities. Before monitoring requirements that crew

Foresea, he was President and CEO need to implement for compliance.

of National Response Corporation

Hopefully, most owners have al- (NRC). During his 20+ years at NRC ready submitted their VGP Annual he grew the business from a start-up to a leading global emergency response

Report, which was due 28 Febru- and environmental services ? rm. Steve ary 2018 for all vessels that ? led a graduated from Hofstra University

Notice of Intent (NOI) form. The

School of Law and the United States

Annual Report must be ? led even

Merchant Marine Academy.

if a vessel did not operate in U.S. www.marinelink.com

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