Which vessels must submit a NOI to the U.S. under the VGP?

• A. All vessels entering U.S. ports
• B. Vessels over 300 gross tonnes intending to enter a U.S. port and discharge any VGP-covered water
• C. Vessels traveling exclusively in U.S. territorial waters
• D. Only tankers and bulk carriers

Answer: (B)

The key idea is who must file an NOI under the Vessel General Permit: that requirement applies to vessels large enough to be subject to VGP coverage and that will discharge VGP-regulated waters in U.S. waters. Specifically, any vessel that is 300 gross tons or more and that intends to enter a U.S. port and discharge any VGP-covered water must submit a Notice of Intent to EPA to obtain VGP coverage. This threshold and condition ensure that only ships capable of producing regulated discharges in U.S. waters seek permit coverage, rather than all vessels. Smaller vessels, or those that do not discharge VGP-regulated waters, don’t have to file. It isn’t limited to tankers and bulk carriers, and it isn’t automatically required for every vessel just traveling in U.S. territorial waters—the requirement hinges on the size and the discharge activity.