Sorry, it’s not going away… The Environmental Protection Agency (EPA) released the new Vessel General Permit (VGP) on November 30, 2011. This is a draft of the permit which will go into effect on December 19, 2013. This draft has been released for public comment, so don’t miss the opportunity to provide your input.
As most of you know the proposed regulations to make towing vessels Coast Guard inspected vessels has been on the streets for about four months. The comment period is now over and so we will wait to see how the Coast Guard decides on the many issues raised when the final rule is published.
The Coast Guard has offered the industry a compliance option in the proposed towing vessel regulation: traditional Coast Guard inspections, or the Towing Vessel Safety Management System (TSMS). The TSMS was introduced to address the human element in towing vessel incidents, justified in the proposed rule by statistics which showed that human factors accounted for 54 percent of the medium and high severity towing vessel incidents. While the members of the Towing Safety Advisory Committee (TSAC) recommended that the TSMS be the backbone of any inspection program, the Coast Guard has proposed to make the TSMS a choice and not mandatory.
Hopefully all concerned parties have had a chance to study the Notice of Proposed Rulemaking (NPRM) on towing vessel inspections, because the regulations will have a significant impact on the industry in the years to come. The Coast Guard public meetings scheduled over the next couple of months should spark some interesting commentary which will surely make the meetings worth the price of admission.
From the EPA...
Dear NPDES vessel program stakeholders,
The one time report electronic system is now available at http://cfpub.epa.gov/npdes/vessels/vesselsreporting.cfm
The public forum sponsored by Maritime Compliance International, LLC held in New Orleans on September 9 was intended to inform the industry, not just on the contents of the NPRM, but also to discuss the implications and the intent of it all. The forum provided industry stakeholders with an overview of the regulations along with some insights, based on my past experience as a Coast Guard marine inspector, as to what it all might look like when fully implemented. This spurred some interesting discussions and some great comments which will be posted to the docket.
I’m on my second reading of the 76 page Notice of Proposed Rule Making (NPRM). As a retired Coast Guard marine inspector who has issued many COIs, much of it looks very familiar, but it also leaves many questions unanswered. I spoke with the program manager at Coast Guard headquarters about many of the issues and he stressed the importance of raising all of these questions by posting them to the docket so the Coast Guard has the opportunity to consider them and respond to them before the final rule is published.