American Club Circular No. 3 8/13 1 DECEMBER 10, 2013 CIRCULAR NO. 38/13 TO MEMBERS OF THE ASSOCIATION US ENVIRONMENTAL PROTECTION AGENCY (EPA) 2013 VESSEL GENERAL PERMIT (VGP) REQUIREMENTS Dear Member: Background Members will recall that, from December 19, 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 December 19, 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 the following link: 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 ballast water, is required to submit a NOI no 1 The moratorium on coverage for commercial fishing vessels 79 feet or larger expires on December 18, 2013. American Club Circular No. 3 8/13 2 later than December 12, 2013 or seven days prior to the discharge to continue uninterrupted coverage. NOI submission deadlines and discharge authorisation dates may be found in Annex II of this Circular. The owner or operator must submit a NOI using EPA’s Electronic NOI (eNOI) system (www.epa.gov/npdes/vessels/eNOI ). Where an owner or operator meets one of the exemptions in Part 1.14 of the VGP, a paper NOI may be submitted in lieu of the eNOI. However, submitting a paper NOI may extend the waiting period for authorisation to discharge. Owners and operators are advised to check if their NOI has been processed via the following link www.epa.gov/npdes/vessels/eNOI prior to commencing discharge in order to ensure that they are not in violation of the VGP. The owner or operator must keep a copy of their NOI on board the vessel at all times. Owner/Operator not required to submit a NOI The owner or operator of a vessel less than 300 gross registered tons and which does not have the capacity to carry more than 8 cubic metres of ballast water does not need to submit a NOI. However the owner or operator must complete the VGP Permi