COLUMN SPECIAL REPORTThe Small Vessel General Permit (sVGP)Compliance Dif? culties Continue for the Workboat Sector.By Steve CanditoThe recent implementation (19 Jan- not relieve vessels from the underlying requirements, spe-uary 2018) of the long delayed small ci? cally the risks associated with inoperable ballast water Vessel General Permit (sVGP) require- treatment systems (BWTS). With vessel charter rates still ment has major implications for envi- generally in a down cycle, the need for vessel owners to ronmental regulations in general, and spend more money on environmental regulations does not speci? cally how the compliance dif? - come at a good time.culties continue for vessel owners with S IMELINESno real end in sight. Moreover, the U.S. VGP TCoast Guard’s (USCG) recent publica- By way of background, the Environmental Protection Canditotion of NVIC 01-18 (1 March 2018), Agency (EPA) VGP requirements ? rst went into effect while helpful in advising owners on in 2008, with permit reissuance in 2013. The VGP pro-how to comply with the ballast water regulations, does vides for National Pollutant Discharge Elimination System (NPDES) permit coverage for inciden-(NPDES) permit coverage for inciden-tal discharges from commercial (non-tal discharges from commercial (non-military and non-recreational) vessels military and non-recreational) vessels greater than 79 feet and for ballast water greater than 79 feet and for ballast water from commercial vessels of all sizes. For from commercial vessels of all sizes. For commercial vessels less than 79 feet, the commercial vessels less than 79 feet, the sVGP requirements apply.sVGP requirements apply.Previously, the Maritime Transporta-Previously, the Maritime Transporta-tion Act of 2014 included an exemption tion Act of 2014 included an exemption for all incidental discharges from “small” for all incidental discharges from “small” A typical BWTS layoutCredit: EcochlorApril 2018 MN20MN April18 Layout 18-31.indd 20 MN April18 Layout 18-31.indd 20 3/23/2018 9:17:54 AM3/23/2018 9:17:54 AM