The deadline for the submission of the Vessel General Permit (VGP) annual report to the Environmental Protection Agency (EPA) is fast approaching. Vessels calling, or soon to call at US ports must be ready. Tanker at anchor ( Source: Skuld) The deadline By 28 February 2015 vessels must file their annual report documenting VGP activities to the EPA. This will apply to ships as follows: vessels that have a VGP Notice of Intent (NOI) for the period of 19 December 2013 to 31 December 2014 this applies whether or not the vessel actually called in the US during 2014 it also applies if the vessel was sold or left the management Warning:   failure to submit an annual report is a non-compliance and can result in the USCG noting a PSC deficiency on the vessel. Further information, including on how to submit the report, can be found in the ECM Maritime Services LLC Client Alert 06-2015, republished alongside this bulletin. The Vessel General Permit The VGP system applies to all commercial vessels of 79 feet / 24.08 metres in length, or greater, and which operate in the capacity of "a means of transportation". Further it specifically focuses on vessel "discharges" which may occur within 3 nautical miles of the US coastline or inland water. First introduced in December 2008, the system was revised as of December 2014, and it affects a full range of member's vessels including fishing boats, barges and even emergency response vessels. Recreational craft and those of armed forces are not subject to these requirements. The documents accompanying the system are quite extensive (re-published alongside this bulletin), but owners and technical managers will have to ensure they are read and understood, as a failure to comply will come with consequences, that includes fines and prosecutions. It must also be kept in mind that there are a number of liquids and items that are not eligible for coverage under the VGP, including: used or spent oil garbage and trash photo-processing effluen