See the below from Holland and Knight regarding the upcoming implementation of the Vessel General Permit (VGP) Program:

The Environmental Protection Agency (EPA) issued a notice announcing the Vessel General Permit (VGP) program as part of the National Pollutant Discharge Elimination System (NPDES) under the Federal Water Pollution Control Act (FWPCA).  A federal court previously ruled that the long-standing exemption from the NPDES permitting requirement was invalid and directed that the exemption be vacated as of December 19, 2008.  The VGP program has been developed in response to that ruling.  The program addresses 28 separate discharges from ships including, but are not limited to, ballast water discharges, deck washdown and runoff, bilge water, gray water, seawater cooling overboard discharge, controllable pitch propeller hydraulic fluid, and hull husbandry.  Covered vessels (basically commercial vessels, foreign and domestic, of 79 feet in length and greater) operating on navigable waters of the United States have to adopt best management practices for each of these waste streams.  In addition, covered vessels of 300 gross tons and greater will have to submit Notices of Intent (NOIs) relating to these discharges.  The EPA also released its 162-page VGP permit and a 125-page Fact Sheet and a 179-page Economic Analysis.  Finally, to further complicate an already difficult situation, it released the State and Tribal Certifications related to the VGP program.  The EPA also issued a news release stating that the program affects approximately 61,000 domestic vessels and 8,000 foreign vessels.   73 Fed. Reg. 79473 

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