Circular issued by International Group clubs Background Members will recall that from 19 December 2008, all commercial vessels 79 feet (24.08 metres) in length or greater operating in a capacity as a means of transportation, that have discharges incidental to their normal operations and operating within three nautical miles of US coastlines and inland waters, were subject to the requirements of the VGP. 2013 VGP The second issuance of the VGP will become effective on 19 December 2013 for a period of five years and will supersede the first iteration of the VGP. General information on the VGP requirements, including the final 2013 VGP, can be accessed at http://cfpub.epa.gov/npdes/vessels/vgpermit.cfm . The 2013 VGP requirements will impact all vessels 79 feet (24.08 metres) in length or greater operating in a capacity as a means of transportation, that have discharges incidental to their normal operations and operating within three nautical miles of the US coastline and inland waters. The types of vessels covered under the 2013 VGP include commercial fishing vessels[1], cruise ships, ferries, barges, mobile offshore drilling units, oil tankers or petroleum tankers, bulk carriers, cargo ships, container ships, other cargo freighters, refrigerant ships, research vessels, emergency response vessels, including firefighting and police vessels, and any other vessels operating in a capacity as a means of transportation. Recreational vessels and vessels of the Armed Forces are not subject to the VGP requirements. A list of discharge types subject to coverage and a list of limitations on coverage under the VGP are contained in Annex I to this circular. Procedure Owner/Operator required to submit a Notice of Intent (NOI) To obtain VGP coverage (which will give authorisation to discharge under the VGP), the owner or operator of a vessel that is either 300 or more gross registered tons or has the capacity to hold or discharge more than 8 cubic metres (2113 gallons) of