Ms. Tinka G. Hyde, Director 

Water Division 

U.S. Environmental Protection Agency- Region 5 

77 West Jackson Boulevard (W-15J) 

Chicago, IL 60604-3507 

Dear Ms. Hyde: 

On September 7, 2012, the Minnesota Pollution Control Agency (MPCA)sent you a certification under 

Section 401 of the Clean Water Act (CWA) for the general permit for Commercial and Large Recreational 

Vessels (2013 VGP) and Small Vessel General Permit (sVGP). Afte.r review of the letter we sent you, an 

error was discovered. On page 4 of the September 7, 2012, letter under the heading number 3, 

"Exchange and flushing for voyages originating beyond the Exclusive Economic Zone (EEZ)," the MPCA 

misidentified the units for salinity. The correct units should be parts-per-thousand, not parts-per-trillion. 

This letter restates the MCPA's 401 certification for EPA 2013 VGP and sVGP in its entirety, with the 

corrected units for salinity, and should be adopted by EPA when the final2013 VGP and sVGP are issued. 

As requested in your letter dated November 16, 2011, the MPCA has examined the U.S. 

Environmental Protection Agency's (EPA) proposed 2013 National Pollutant Discharge Elimination 

System (NPDES) general permit for 2013 VGP and sVGP t o determine whether it can certify the 

permits under Section 401 of the CWA. The MPCA bases its certification upon an evaluation of the 

information provided in the proposed permit, technical fact sheet, other materials contained in 

Docket ID Nos. EPA-HQ-OW-2011-0141 and EPA-HQ-OW-2011-0150, and consultation with other 

Great Lakes States. This letter is submitted by the MPCA under authority of Section 401 of the CWA 

(33 USC 1251 et seq.), Minn. Stat. chs. 115 and 116, and Minn. R. 701.1400 through 7001.1470. 

The State of Minnesota takes its responsibility to protect Lake Superior very seriously. We support the 

spirit and practice of eliminating pollutant discharges to Lake Superior, including pollutant discharges 

from vessels. The United Nations, the International Join Commission (IJC), the Great Lakes states, the 

U.S. Government, Canadian provinces and federal governments agree that Lake Superior's fragility and 

protection are a global priority. The IJC called on the governments to designate "Lake Superior'' as a 

demonstration zone for the zero discharge concept in 1990. Since answering that ca ll, the sates and 

federal governments have invested millions of dollars and thousands of staff hours to develop policies 

and practices to protect this Lake. 

Minnesota was one of t he original signatories to the 1991 Lake Superior Binational Program. It was also 

one of the first states to adopt the Great Lakes Compact, the Great Lakes Initiat ive and to regulate 

ballast water discharges. The state has supported its U.S. and Canadian partners in their effort to restore 

degraded areas and to designate and permanently protect islands, bays, and open water areas of Lake 

Superior. Our Canadian partners recently designated 3,861 square miles of Lake Superior as Marine 

Conservation Area. Isle Royale, a national park off Minnesota's coast, has also been designated a United 

Nation's Biosphere Reserve, adding further credence to the notion that Lake superior is unique and 

internationally significant. 
Ms. Tinka G. Hyde, Director 

Page 2 

February 19, 2013 

The MPCA and the Minnesota Department of Natural Resource (DNR) have worked closely in assessing 

the proposed federal permit. We agree that invasive species are a serious problem for Minnesota and 

this permit presents an opportunity to address this threat to our waters. While the primary focus of the 

federal permit is vessels that travel in salt water, the vast majority of ballast water discharged in 

Minnesota comes from vessels that travel in fresh water. To adequately protect Minnesota waters from 

ballast water discharged from both fresh and saltwater vessels, the MPCA has included additional 

regulatory requirements to supplement the proposed federal permit. These requirements will further 

protect Minnesota waters. 

The 2013 VGP, as proposed by EPA in November 2011, is applicable for all vessel discharges from all 

commercial and large recreational vessels, as defined in the permit, that take place within all waters of 

the State. Minnesota certifies there is a reasonable assurance that discharges from vessels covered by 

the 2013 VGP for discharges incidental to the normal operation of commercial and non-commercial 

vessels greater than or equal to 79 feet in length, and the NPDES Small Vessel General Permit (s2013 

VGP), will comply with the applicable provisions of 33 U.S.C §§ 1311, 1312, 1313, 1316, 1317, and 1341 

(CWA §§ 301, 302, 303, 306, 307, and 401), and that Permittees and their activities will not contravene 

applicable limitations, standards and other appropriate requirements of State law, provided the 

following conditions set forth in this Certification are met. 

Small Vessel General Permit Certification Conditions 

The conditions in the draft sVGP cannot be made less stringent without violating water quality standards 

and other requirements of State law. See 40 CFR § 124.53 (e)(3). The MPCA has not identified any 

additional conditions that are needed to meet the requirements of either the CWA or Minnesota Rules, 

provided the conditions of the final sVGP are at least as stringent as the conditions of the draft sVGP. 

The permittee shall report all instances of non-compliance with this certification as soon as possible, and 

in no case longer than 30 days of the discovery of the noncompliance (Minn. R. 7001.0150, subp.2[K][L]). 

Vessel General Permit Certification Conditiions 

The MPCA conditionally grants water quality certification for the EPA 2013 VGP subject to compliance 

with the conditions identified below. A summary ofthe basis for these conditions is also provided below. 

1. Compliance with Minnesota State Disposal System (SDS) permit for ballast water; 

Requirement 

The applicability of International Maritime Organization (IMO) D-2 ballast water discharge limits 
agency, unless the agency waives submission of the plans and specifications and a 

written permit for the disposal system is granted by the agency. 

Minnesota has adopted a General SDS permit for ballast water discharges. The MPCA's current 

ballast water discharge general permit MNG300000, which is scheduled to be considered for 

reissuance in 2013, requires vessels meeting the permit's applicability criteria to comply with 

the following biological performance standards and implementation schedule: 

a. Table A Biological Performance Standards for Ballast Water Treatment Technology 

Parameter Limit LimitType Sample Type 

Organisms >50 ~m in <10 viable 1m3 Daily average Composite minimum dimension 

Organisms 10-50 ~min <10 viable I ml Daily average Composite minimum dimension 

Escherichia coliform <250 cfu I 100 ml Daily average Composite 

Intestinal enterococci <100 cfu I 100 ml Daily average Composite 

b. For vessels constructed prior to January 1, 2012, and meeting the applicability criteria in the 

permit, treatment shall be installed and operational to meet the performance standards for 

organisms included in Table A by January 1, 2016. 

c. For vessels constructed after January 1, 2012, and meeting the applicability criteria in the 

permit, treatment shall be installed and operational to meet the performance standards for 

organisms included in Table A prior to commencement of vessel operation in the Minnesota 

waters of Lake Superior. 

The Minnesota SDS Vessel General Permit (MNG300000) currently requires the schedule above. 

During the drafting of the MNG30000 permit reissuance, the implementation schedule, as well 

as other permit conditions, may be modified. 

2. Numeric Water Quality Based Effluent Limitation (WQBEL) Determination for Ballast Water 

Discharges. 

Requirement 

No additional requirements at this time. 

Summary of the Basis 

After careful review of the available data and studies completed to further define the threshold 

at which point the introduction of nonnative species impacts the quality of Waters of the State, 

MPCA is unable to conclusively determine a numeric standard which would definitely protect 

water quality and an unaltered species composition of the ecosystem. The MPCA is very 

interested in the development of data via ongoing monitoring, which could be used to inform 

the process of establishing a water quality standard in the future. The MPCA encourages vessel 
Ms. Tinka G. Hyde, Director 

Page 4 

February 19, 2013 

owners to pursue the most efficient treatment systems possible to avoid the potential need to 

upgrade systems in the future when a numeric standard may be adopted. 

3. Exchange and flushing for voyages originating beyond the Exclusive Economic Zone (EEZ) 1. 

Requirement 

The operator of any vessel covered under the 2013 VGP whose voyage originates outside the 

exclusive economic zone and enters Minnesota waters shall not discharge ballast unless the 

following conditions are met: the vessel has conducted ballast water exchange or flushing beyond 

the EEZ, at least 200 nautical miles from any shore, and in water at least 2,000 meters in depth, 

while in oceanic waters, resulting in a salinity level of at least 30 parts per thousand (ppt) prior to 

the time the vessel enters Minnesota waters. This requirement remains in effect regardless of 

whether the vessel is equipped with a ballast water treatment system. This requirement is in 

addition to treatment required under the proposed 2013 VGP. 

All vessels entering Minnesota waters must maintain the ability to measure salinity levels in each 

tank on board the vessel so that salinities of at least 30 ppt can be ensured prior to discharge in 

Minnesota Waters. 

For vessels entering the Great Lakes from outside the EEZ and carrying only residual amounts of 

ballast water and/or sediment, the flushing requirements are equivalent to those set forth in the 

July 1, 2012, edition of the St. Lawrence Seaway regulations, 33 CFR § 401.30(f). 

This requirement does not apply to: 

a. Vessels that either have no ballast tanks or that carry only permanent ballast water, all of 

which is in sealed tanks that are not subject to discharge, or 

b. Vessels that carry only potable water that meets the requirements of section 2.2.3.5.1.3 of the 

draft 2013 VGP in their ballast tanks. 

This requirement does not apply if the master of the vessel determines that compliance with this 

condition would threaten the safety or stability of the vessel, its crew, or its passengers because of 

adverse weather, equipment failure, or any other relevant condition. If a vessel is unable to conduct 

ballast water exchange or flushing due to serious safety concerns as specified above, the operator of 

such vessel shall inform the MPCA and DNR prior to discharging ballast in state waters to allow a 

determination of whether the discharge of the ballast presents a "high risk" as described below. No 

ballast shall be discharged that does not meet the conditions in this part if the MPCA determines 

that the ballast is "high risk" and that additional treatment is necessary to protect aquatic resources. 
impairment of waters for their designated uses and are thus needed to comply with the 

Minnesota State statues and rules. In accordance with 40 CFT § 124.53 (e)(2), this condition 

cannot be made less stringent and still comply with State and water quality standards. 

This requirement adds no new requirement or deadline for ballast water treatment. The 

requirements and deadlines for ballast water treatment are those specified in the draft 

2013 VGP, Section 2.2.3.5, Table 6, and the Minnesota Ballast Water General Permit. However, 

in addition to meeting those requirements, vessel operators will need to continue performing 

exchange or flushing prior to discharging in Minnesota waters. 

This requirement, applicable to vessels entering Minnesota waters from outside the EEZ, 

effectively serves as an interim WQBEL prior to a numeric WQBEL calculation that will be 

protective of state water quality until the numeric WQBEL is fully implemented. This 

requirement requires operation of a treatment system that meets IMO D-2 requirements in 

conjunction with ballast water exchange or flushing. This interim WQBEL, justified partly by the 

known effectiveness of exchange and flushing alone2 and partly by recent research by Canada's 

Department of Fisheries and Oceans on the benefits of combining exchang.e and flushing with 

treatment,' has recently undergone land-based testing at the GSI test facility in Superior, 

Wisconsin.' Early results from the GSI land-based tests5 are consistent with the goal of reducing 

propagule pressure, at least for fresh and brackish receiving waters, in order to achieve an 

invasion risk lower than would be achieved using ballast water treatment alone.' 

Minn. Stat.§ 115.03, subd. 1 (e) provides that the MPCA has the following duty: 

(e) ta adopt, issue, reissue, modify, dney, or revoke, enter into or enforce reasonable 

orders, permits, variances, standards, rules, schedules of compliance, and stipulation 

agreements, under such conditions as it may prescribe, in order to prevent, control 

or abate water pollution, or for the installation or operation of disposal systems or 

parts thereof, or for other equipment and facilities: 

2 Most of the water and most of the organisms carried in a vessel's ballast tanks are physically expelled during midocean exchange or flushing and many of the remaining organisms are then killed by salinity shock (osmotic stress) 

from the ocean water with which the ballast tanks are refilled. See paper submitted by Canada to the IMP, BLG 

15/5/7, op. cit., paragraphs 8 and 9; S.A. Baily et al. (2022), op. cit., at 2555-56. 3 Paper submitted by Canada to the IMO, BLG 15/5/7, op. cit. Note that, in addition to the benefits derived from 

physical expulsion and salinity shock, the combined process allows treatment systems to operate on a more 

uniform and more biologically sparse feed water. 

4 Publication of test results pending. 

5 Sarah Baily, DFO Canada, pers. Comm. 

6 Paper submitted by Canada to the IMP, BLG 15/5/7, op. cit., paragraph 18. 
Ms. Tinka G. Hyde, Director 

Page 6 

February 19, 2013 

(1) requiring the discontinuance of the discharge of sewage, industrial waste or 

other wastes into any waters of the state resulting in pollution in excess of the 

applicable pollution standard established under this chapter; 

{2} prohibiting or directing the abatement of any discharge of sewage, industrial 

waste, or other wastes, into any waters of the state or the deposit thereof or the 

discharge into any municipal disposal system where the same is likely to get into 

any waters of the state in violation of this chapter and, with respect to the 

pollution of waters of the state, chapter 116, or standards or rules promulgated 

or permits issued pursuant thereto, and specifying the schedule of compliance 

within which such prohibition or abatement must be accomplished; ... 

The MPCA has adopted the following narrative standard to protect the aquatic habitat of the 

state: 

7050.0150 DETERMINATION OF WATER QUALITY, BIOLOGICAL AND PHYSICAL 

CONDITIONS AND COMPLIANCE WITH STANDARDS. 

Subpart 1. Policy and scope. The intent of the state is to protect and maintain 

surface waters in a condition which allows for the maintenance of all existing 

beneficial uses. The condition of a surface water body is determined by its physical, 

chemical, and biological qualities. The agency shall determine an exceedance of 

water quality standards or an impaired condition based on pollution of the waters of 

the state from point and non point sources that has resulted in degradation of the 

physical, chemical, or biological qualities of the water body to the extent that 

attainable or previously existing beneficial uses are actually or potentially lost. 

The narrative water quality standards in subpart 3 prescribe the qualities or 

properties of surface waters that are necessary for the protection of designated 

public uses and benefits. if the narrative standards in this part are exceeded, it is 

considered indicative of a polluted condition which is actually or potentially 

deleterious, harmful, detrimental, or injurious with respect to the designated uses of 

the waters of the state. 

Subparts 5 to 7/ist factors the commissioner will use to determine if surface waters 

are in compliance with applicable narrative standards in subpart 3. Determination of 

compliance with the narrative standards will be made for individual water bodies on 

a case-by-case basis. 
sewage, industrial waste, or other wastes to the waters. 

7050.0210 GENERAL STANDARDS FOR WATERS OF THE STATE. 

Subpart 1. [Repealed, 32 SR 1699] Subp. 2. Nuisance conditions prohibited. No sewage, industrial waste, or other 

wastes shall be discharged from either point or non point sources into any waters of 

the state so as to cause any nuisance conditions, such as the presence of significant 

amounts of floating solids, scum, visible oil film, excessive suspended solids, material 

discoloration, obnoxious odors, gas ebullition, deleterious sludge deposits, 

undesirable slimes or fungus growths, aquatic habitat degradation, excessive 

growths of aquatic plants, or other offensive or harmful effects. 

In addition to these laws, Minnesota has adopted Minn. Stat.§ 84D.06, which prohibit persons 

from introducing an unlisted nonnative aquatic plant or wild animal species without notice to 

the Commissioner of the DNR: 

84D.06 UNLISTED NONNATIVE SPECIES 

Subdivision l.Process. A person may not introduce an unlisted nonnative aquatic 

plant or wild animal species unless: 

(1) the person has notified the commissioner in a manner and form prescribed by 

the commissioner; 

(2) the commissioner has made the classification determination required in 

subdivision 2 and designated the species as appropriate; and 

(3) the introduction is allowed under the applicable provisions of this chapter. 

4. Emergency Control of Ballast Water discharge 

Requirement 

a. The MPCA, in coordination with the DNR, may prohibit discharge, require a discharge to 

occur in a particular area, or require emergency treatment of any "high risk" ballast water 

proposed to be discharged in Minnesota waters pursuant to its authority under Minn. Stat.§ 

116.11 and Minn. R. 7000.5000. 

b. A "high risk" ballast water is one that, in the opinion of the MPCA in consultation with the 

DNR, poses an imminent and substantial danger to the health and welfare of the people of 

the state related to the introduction of a nonnative species into Minnesota waters. 
Ms. Tinka G. Hyde, Director 

Page 8 

February 19, 2013 

c. If relocation of a high risk ballast discharge is required, the MPCA, coordinating with the U.S. 

Coast Guard (USCG), the DNR, and the States of Michigan and Wisconsin, as needed, will 

identify alternative locations for the discharge of the high risk ballast water. 

d. Nothing in this section relieves the vessel owner or operator of the responsibility for 

ensuring the vessel's safety and stability or the safety of the crew and passengers. 

e. As an alternative to discharging high risk ballast water, the MPCA may authorize the use of 

Ballast Water Treatment Systems (BWTS) identified as promising technology by EPA, USCG, 

neighboring states or a U.S. ballast water testing research facility. U.S. ballast water testing 

research facilities include, but may not be limited to the Golden Bear, Great Ships Initiative 

and Maritime Environmental Resource Center. 

Summary of the Basis 

See regulatory citations in Requirement 3 Summary of Basis. In addition, this requirement is 

supported by Minn. Stat.§ 116.11 and Minn. R. 7000.5000. 

5. Coverage of Lakers that operate exclusively in the Great Lakes 

Requirement 

For vessels that operate exclusively in the Great Lakes, the following Best Management Practices 

(BMPs) are required to be incorporated into the vessel's ballast management plan and 

implemented prior to discharge of ballast in Minnesota waters: 

a. Annually inspect and replace, as necessary, ballast sea chest screens. Replace screens with 

the smallest openings allowed by good engineering practice. Inspections must be 

documented by log entry, diver's report, video report, dry-docking report, marine inspection 

note, or surveyor's report. 

b. During cargo operations (while accounting for boom list, hull stress, and bending moments), 

lighten the ship as much as practical to elevate water intakes before ballasting to minimize 

sediment uptake and increase water flow. 

c. Ballast water taken aboard shall be the minimum needed to ensure the safety of the crew 

and vessel. Additional ballast water can be taken aboard, once deeper water is reached. 

d. Ballast water shall always be taken aboard or discharged via the pumps and never "gravity 

fed or drained." This ensures an organism that somehow makes it past the screen is 

pulverized by the high speed, high pressure, and tight tolerance pump. 

Summary ofthe Basis 

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approved by the commissioner. 

{b) The owner or operator of a vessel required to have a ballast water 

management plan under paragraph (a) shall maintain a copy of the vessel's 

ballast water management plan on board at all times and keep the plan readily 

available for examination by the commissioner. 

Subd. 2. Ballast water management plan approval. 

(a) The commissioner may not approve a ballast water management plan unless 

the commissioner determines that the plan: 

{1} describes in detail the actions to be taken to implement ballast water 

management; 

(2) describes in detail the procedures to be used for disposal of sediment at 

sea and on shore; 

{3} describes in detail the safety procedures for the vessel and crew 

associated with ballast water management; 

{4} designates the officer on board of the vessel in charge of ensuring that 

the plan is properly implemented; 

{5) contains the reporting requirements for vessels as prescribed by the 

commissioner; and 

(6) meets all other requirements prescribed by the commissioner. 

{b) The commissioner may approve a ballast water management plan for a 

foreign vessel on the basis of a certificate of compliance with the criteria 

described in paragraph (a) issued by the vessel's country of registration 

according to standards established by the commissioner. 

Minnesota finds that the BMP set forth in this condition are needed to prevent impairment of 

waters and to maintain such waters for their best usage and are thus needed to comply with 

the statues and rules cited under condition 3 above. In accordance with 40 CFR § 124.53 

(e)(2), this condition cannot be made less stringent and still comply with State water quality 

standards. 

6. Monitoring Requirements 

Requirement: 

a. Monitoring for vessels required to meet the 2013 VGP (numeric limits equivalent to IMO D-2) 

ballast water discharge limits: In addition to meeting the draft 2013 VGP monitoring 

requirements in section 2.2.3.5., all vessels covered under the 2013 VGP and operating in 

Minnesota waters after a Ballast Water Treatment system is installed must sample and 

analyze the ballast water discharge at least once a year (provided appropriate facilities are 
Ms. Tinka G. Hyde, Director 

Page 10 

February 19, 2013 

available) using the shipboard Environmental Technology Verification (ETV) sampling protocol, 

a protocol consistent with IMP G8/G9 protocols, or a compliance monitoring protocol 

developed by the USCG, whichever is most advanced and available. The MPCA will be 

available to interpret which method(s) are most advanced and available. This monitoring shall 

include sampling, identification and enumeration of live organisms >50 11m and between 10-

50 11m in size. The monitoring results shall be submitted to EPA and the MPCA on an annual 

basis, consistent with the mechanisms used in the 2013 VGP for all other submissions, 

provided such electronic tools are made available by EPA. In the absence of available 

submittal tools by EPA, monitoring data must be directly submitted to the MPCA. The MPCA's 

point of contact is provided at the close of this letter. Such live organism monitoring shall 

include the collection of representative discharge samples and the testing (counting) of live 

organisms in such samples by qualified personnel in accordance with standard and/or best 

available sampling and analytical methods. 

b. Monitoring for vessels not required to meet numeric ballast treatment limits because of 

2013 VGP condition 2.2.3.5.3.3 (currently addressing vessels operating exclusively upstream of 

the Weiland Canal) or similar condition: Within 24 months affinal issuance of the 2013 VGP, 

all vessels not required to meet numeric ballast treatment standards, and that discharge 

ballast in Minnesota waters, shall have the capacity to collect at the request of the MPCA, EPA 

or other regulatory authority representative samples of organisms in ballast water discharges. 

Beginning 24 months after final issuance of the 2013 VGP, all vessels not required to meet 

numeric ballast treatment limits shall complete the following ballast discharge monitoring: 

1) A minimum of once annually, sample and analyze for organism density and composition 

(based on broad taxonomic categories). Sampling and analysis methods shall be 

consistent with protocols described above. Samples must be analyzed for total 

organisms (live or dead) greater than or equal to 10 micrometers in size. The ballast 

discharge subject to sampling must be taken on the ship in a Great Lakes port for 

discharge into Minnesota waters. You must report the uptake locations and volumes 

subject to sampling, as well as the volume you plan to discharge in Minnesota's waters, 

best management practices employed, and other factors affecting the composition of 

the sample; or 

2) Complete, individually or in partnership with other permittees, a ballast discharge 

biological study approved by the MPCA. The study must include actual discharge data 

representing designated vessels that may discharge native and non-native organisms 

into Minnesota waters. The purposes of the study must include an evaluation of the risk 

that ballast discharges pose to Minnesota waters. 
responsible for sewage, industrial waste, or other waste disposal systems that are 

adjacent to or that discharge effluents to waters of the state shall submit a report to 

the agency upon request on the operation of the disposal system, the effluent flow, 

and the characteristics of the effluents and receiving waters. Sufficient data on 

measurements, observations, sampling, and analyses, and other pertinent 

information must be furnished as may be required by the agency to adequately 

evaluate the condition of the disposal system, the effluent, and the waters receiving 

or affected by the effluent. 

Minnesota finds that the monitoring requirements set forth in this condition are needed to 

prevent impairment of waters and preserve such water for their best usage and are thus needed 

to comply with the authorities cited in Condition 3. In accordance with 40 CFR § 124.53 (e)(2), 

this condition cannot be made less stringent and still comply with State water quality standards. 

The protocol for sampling ship discharges as described in the Great Ships Initiative Ballast 

Discharge Monitoring Guidebook, published November 2011, 

(http://www.nemw.org/GSI/BallastDischargeMonitoringGuidebook.pdf) is a feasible and 

cost-effective approach for sampling vessel ballast discharges. Vessels which ply the Great Lakes could use this protocol or propose another method to assure representative sampling of ballast 

discharges. 

7. Biocide Usage 

Requirement: Discharges of residual biocides are authorized as defined by the September 24, 2008, Minnesota 

General Ballast Water Permit or subsequent reissuances, whichever is most recent. Discharge 

limitations for residual oxidants, and procedures for obtaining authorization to use other 

chemical additives are established by the permit. Obtaining coverage under the 2013 VGP does 

not release any person from the duty to obtain a permit required by state law. Vessels covered 

by the EPA's 2013 VGP must obtain any permits required by the state of Minnesota for vessel 

discharges and comply with all requirements in the applicable permit at the time of compliance 

review. 

Summary of the Basis 

Minnesota law prohibits discharges without a permit. Minn. Stat.§ 115.07 provides: 

115.07 VIOLATIONS AND PROHIBITIONS. 

Subdivision 1.0btain permit. (a) Except as provided in paragraph (b), it is unlawful 

for any person to construct, install, or operate a disposal system, or any part thereof, 

until plans and specifications for the disposal system have been submitted to the 

agency, unless the agency waives submission of the plans and specifications and a 

written permit for the disposal system is granted by the agency. 
Ms. Tinka G. Hyde, Director 

Page 12 

February 19, 2013 

8. Other State Regulations 

Requirement: 

All vessels must comply with the requirements of Minn. Stat. 115.1703 and any other applicable 

state law, statue or rule. 

Summary of the Basis 

Obtaining coverage under the 2013 VGP does not release any person from the duty to comply 

with state laws, statues and rules. 

The contact for compliance submittal questions is John Thomas, WQ Compliance Specialist, MPCA, 

Suite 400, 525 Lake Avenue South, Duluth, Minnesota 55802 (e-mail john.thomas@state.mn.us). 

Should you require further information regarding this Certification, please contact Kate Frantz at 

651-757-2370, or you may contact me. 

Si]J 11 

Supervisor, 

David Richfield 

Agency 

~ 

Rules U 

SSTS, Land Treatment, and Rules Section 

Municipal Division 

DR/KF:rm