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USCG to “Evaluate Compliance” of EPA VGP March 11, 2011

Beginning March 11, 2011 during vessel boardings and inspections, the U.S. Coast Guard will begin evaluating compliance with the U.S. Environmental Protection Agency (EPA) Vessel General Permit (VGP).  A Memorandum of Understanding (MOU) was recently signed between the two agencies, and a USCG policy letter was published, requiring Coast Guard inspectors to use a job aid to evaluate the level of compliance on a particular vessel, document any discrepancies, and pass them along to the EPA.  The EPA retains enforcement authority and will take enforcement action based upon the information gathered by the USCG.


From the vessel operator's standpoint, there are a few aspects of this approach which may be problematic:

Many Coast Guard inspectors may not have received training on the VGP and so their approach and conclusions may vary significantly.  Vessel operators are accustomed to getting 30 days to correct a problem.  With this approach, inspectors are required to document all discrepancies and pass them along to the EPA for action regardless of whether the vessel has corrected the issue "on the spot" or not. Many companies may be trying to manage this VGP from the office.  However, the evaluation of compliance will be conducted on board by asking captains and crews pointed questions.

The only defense is to be in full compliance and have everyone properly trained.

USCG/EPA MOU:
http://epa.gov/compliance/resources/agreements/cwa/mou-coastguard-vesselpermitrequirements.pdf
CG Policy Letter:

 http://homeport.uscg.mil/cgi-bin/st/portal/uscg_docs/MyCG/Editorial/20110211/543 Policy ltr 11-01 VGP with enclosure.pdf?id=ee9784ac8e8fecf217d43d6fa6662f42f8c7d2ba 

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