Posted:
April 28, 2011
As previously reported, the U.S. Coast Guard and U.S. Environmental Protection Agency have signed an agreement and are jointly implementing and enforcing regulations on vessel discharge streams falling under the Vessel General Permit (VGP).
The regulations, implemented in February 2009, prohibit vessels from discharging any pollutant into domestic waters unless authorized to do so in accordance with the permit. The VGP covers 26 separate discharges, including ballast water, gray water, bilge water, deck runoff and engine cooling water, and affects more than 61,000 U.S.-flagged commercial vessels and more than 8,000 foreign vessels operating in U.S. waters.
Although subject to change, the U.S. Coast Guard has issued a policy letter with which all affected vessel officers should be familiar. The policy letter, available on the AMO Currents Web site, contains the Coast Guard's 'work aid' - including specific questions and areas of interest to be covered by Coast Guard inspectors related to the VGP.
The 'work aid' contained in the policy letter provides a script for Coast Guard inspectors to follow based upon officers' responses to the questions. All infractions discovered during the inspection will be entered into the Marine Information for Safety and Law Enforcement System and reported to the EPA for further investigation, even if an infraction was corrected at the time of inspection.
The Coast Guard's position is, once an infraction is reported, the EPA will be the agency to investigate, issue citations and levy fines in accordance with the VGP. The Coast Guard reserves the right to exercise enforcement authority in areas of interest to the agency, particularly bilge water discharges and ballast water discharges.
As noted above, the policy letter and 'work aid' are subject to change by the Coast Guard. Updates will be provided as they are made available.
Coast Guard 'work aid' for VGP enforcement compliance
As previously reported, the U.S. Coast Guard and U.S. Environmental Protection Agency have signed an agreement and are jointly implementing and enforcing regulations on vessel discharge streams falling under the Vessel General Permit (VGP).
The regulations, implemented in February 2009, prohibit vessels from discharging any pollutant into domestic waters unless authorized to do so in accordance with the permit. The VGP covers 26 separate discharges, including ballast water, gray water, bilge water, deck runoff and engine cooling water, and affects more than 61,000 U.S.-flagged commercial vessels and more than 8,000 foreign vessels operating in U.S. waters.
Although subject to change, the U.S. Coast Guard has issued a policy letter with which all affected vessel officers should be familiar. The policy letter, available on the AMO Currents Web site, contains the Coast Guard's 'work aid' - including specific questions and areas of interest to be covered by Coast Guard inspectors related to the VGP.
The 'work aid' contained in the policy letter provides a script for Coast Guard inspectors to follow based upon officers' responses to the questions. All infractions discovered during the inspection will be entered into the Marine Information for Safety and Law Enforcement System and reported to the EPA for further investigation, even if an infraction was corrected at the time of inspection.
The Coast Guard's position is, once an infraction is reported, the EPA will be the agency to investigate, issue citations and levy fines in accordance with the VGP. The Coast Guard reserves the right to exercise enforcement authority in areas of interest to the agency, particularly bilge water discharges and ballast water discharges.
As noted above, the policy letter and 'work aid' are subject to change by the Coast Guard. Updates will be provided as they are made available.