Small Vessel General Permit (sVGP)

 There is currently a moratorium against permitting incidental discharges on vessels less than 79 feet. Translation – the current vessel general permit does not apply to vessels less than 79 feet. However, the current moratorium expires on December 18, 2014. According to the website govtrack.us, on November 19, 2014, Sen Marco Rubio introduced a bill to extend the moratorium, Public Law 110-299. The website gives the bill only a 7% chance of being enacted.

If the moratorium is not extended, on December 19, 2014 the Small Vessel General Permit (sVGP) will go into effect. Non-recreational vessels less than 79 feet will have to comply with the provisions of the sVGP beginning on that date. Here are some of the highlights. Vessel owner/operators will have to: read the permit, sign and carry a copy of the Permit Authorization and Record of Inspection (PARI) form on each vessel, comply with the best management practices for specific discharges, conduct inspections of certain items "frequently, daily, or quarterly," as required by the permit. They will have to keep track of all instances of non-compliance and submit them in a noncompliance report to the EPA each year prior to February 28. All this, of course, under the penalty of severe fines and/or imprisonment. All sVGP records must be kept for three years. The Coast Guard is charged with evaluating VGP compliance during vessel inspections. With Subchapter M's expected Final Rule date set for March of 2015, prudent vessel operators will recognize the potential threat and ensure full compliance beginning on December 19, 2014.