Only 45 Days Left—Have You Commented On EPA’s Draft Vessel General Permit?

New Development

On December 8, 2011, the Environmental Protection Agency ("EPA") published two draft Vessel General Permits ("VGPs") that would authorize discharges incidental to the normal operation of commercial vessels—one to replace the existing VGP currently in force ("2008 VGP") and one that would apply to small vessels ("SVGP"), which are currently exempt from the 2008 VGP.  The draft 2013 VGP, which applies to commercial vessels greater than or equal to 79 feet in length, would replace the 2008 VGP when it expires in December 2013.  The draft SVGP, which applies to commercial vessels less than 79 feet in length, would provide such vessels with the Clean Water Act ("CWA") permit coverage they will be required to possess by December 2013 when the legislative exemption currently in place for small vessels expires.