Table 1 – General Comments

PLEASE PROVIDE GENERAL COMMENTS ON HOW TO IMPROVE THE NEXT PERMIT
Your general comments:

Table 2 – Specific comments/answers

Please note that under each question of this Table, we have included examples of issues (highlighted in italics) that may be raised. Please feel free to elaborate on these and add any other suggestion you may have.

PLEASE ANSWER THE FOLLOWING QUESTIONS FROM THE EPA NOTICE
  1. Were parts of the 2008 VGP confusing? Do certain sections need to provide additional guidance?

Ex: Confusing or unclear terminology: the next permit should avoid using ambiguous wording and provide clear definitions.
Your answer:
  1. Is there any guidance, supporting documentation, or other communication strategies that you would recommend EPA develop to help vessel owner/operators better understand and comply with the next VGP? If so, please suggest your approaches.

Ex. The permit regulations and requirements should be more user-friendly (Members could identify tools and guidance to make the permit requirements more user-friendly)
Your answer:
  1. Did the 2008 VGP accurately identify and capture all the categories of discharges incidental to the normal operation of a vessel in the vessel universe? Are there additional discharge categories EPA should explore for the next VGP?

Ex.: Do not recommend addition of new discharges categories under the new permit.
Your answer:
  1. Are there effluent limitations or best management practices in the 2008 VGP you would recommend revising and if so, what are your suggestions and why do you suggest making those revisions?

Ensure coordination between current US or international applicable regulations, including effluent limitations, and those to be covered by the next permit.
Your answer:
  1. Are there reporting, monitoring, and inspection requirements you would recommend revising, and if so, what are your suggestions? Are there additional forms or guidances EPA should consider in assisting permittees in meeting their reporting, monitoring, and inspections requirements?

Decrease the shipboard workload/paperwork by simplifying the VGP recordkeeping compliance system.
Your answer:
  1. Did EPA accurately identify and capture additional requirements needed for specific vessel classes and if not, what are your suggestions? Are there additional specific vessel classes EPA should explore for the next VGP and why?

Do not recommend additional requirements for specific vessel classes nor include additional specific vessels classes in the next VGP, unless these integrate the necessary flexibility to take into account vessel type, voyage type and other variables.
Your answer:
  1. Are there additional Federal, state, or international permits, rules, or guidance that EPA should consider when developing the next VGP and why?

Avoid conflicts among federal and state requirements by harmonizing the VGP requirements with the existing USCG regulatory requirements. Avoid fragmentation of regulatory framework by ensuring coherence of federal requirements with international standards. Harmonize VGP compliance criteria with those of the existing IMO based certifications.
Your answer:

1