ECONOMIC AND BENEFITS ANALYSIS OF 

THE PROPOSED 2013 VESSEL GENERAL PERMIT (VGP)

Office of Wastewater Management

U.S. Environmental Protection Agency

November 30, 2011
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 ii

Table of Contents

1 Introduction ................................................................................................................................................... 1

1.1 Background ...................................................................................................................................................... 1

1.2 Report Organization ........................................................................................................................................ 2

2 Population of Affected Vessels ...................................................................................................................... 3

2.1 Domestic Vessel Population ............................................................................................................................ 3

2.2 Foreign Vessel Population ............................................................................................................................... 6

2.3 Vessels Subject to NOI Requirements ............................................................................................................. 7

2.4 Vessels Subject to the Bilge water Treatment Requirements .......................................................................... 8

2.5 Vessels Subject to the Ballast Water Management Requirements .................................................................. 9

2.6 Uncertainties and Limitations ........................................................................................................................ 12

3 Profile of the Water Transportation, Fishing, and Mining Industries ................................................... 14

3.1 Introduction ................................................................................................................................................... 14

3.1.1 Data Sources Used ............................................................................................................................ 15

3.1.2 Organization Of This Chapter .......................................................................................................... 15

3.2 Overview of the Water Transportation, Fishing, and Mining Industries ....................................................... 16

3.2.1 Definition of the Water Transportation, Fishing, and Mining Industries ......................................... 16

3.2.2 Water Transportation ........................................................................................................................ 16

3.2.3 Fishing .............................................................................................................................................. 21

3.2.4 Mining .............................................................................................................................................. 21

3.3 Recent Trends ................................................................................................................................................ 22

3.3.1 Number of Vessels by Industry Sector ............................................................................................. 22

3.3.2 Number of Establishments by Industry Sector ................................................................................. 23

3.3.3 Establishment and Employment Births and Deaths.......................................................................... 24

3.3.4 Financial Performance ...................................................................................................................... 26

3.4 Industry Market Structure .............................................................................................................................. 27

3.4.1 Firms and Revenues ......................................................................................................................... 27

3.4.2 Revenue by Vessel ........................................................................................................................... 30

3.4.3 Small Businesses .............................................................................................................................. 31

3.4.4 Employment and Payroll .................................................................................................................. 32

4 Cost of Best Management Practices ........................................................................................................... 36
 

November 30, 2011 iii

4.1 Technology-Based Effluent limits and related requirements applicable to All Vessels ................................ 37

4.2 effluent limits and related requirements Related to Specific Discharge Categories ...................................... 38

4.2.1 Discharges of Deck Washdown and Runoff and Above Water Line Hull Cleaning ........................ 39

4.2.2 Discharges of Bilge Water ................................................................................................................ 42

4.2.3 Discharges of Ballast Water ............................................................................................................. 55

4.2.4 Anti-Fouling Hull Coatings .............................................................................................................. 72

4.2.5 Aqueous Film-Forming Foam .......................................................................................................... 74

4.2.6 Boiler/Economizer Blowdown ......................................................................................................... 74

4.2.7 Cathodic Protection .......................................................................................................................... 74

4.2.8 Chain Locker Effluent ...................................................................................................................... 77

4.2.9 Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil Sea Interfaces Including 

Lubrication Discharges from Paddle Wheel Propulsion, Stern Tubes, Thruster Bearings, 

Stabilizers, Rudder Bearings, Azimuth Thrusters, Propulsion Pod Lubrication, and Wire Rope and 

Mecahnical Equipment Subject to Immersion .................................................................................. 78

4.2.10 Distillation and Reverse Osmosis Brine ........................................................................................... 83

4.2.11 Elevator Pit Effluent ......................................................................................................................... 83

4.2.12 Firemain Systems ............................................................................................................................. 84

4.2.13 Freshwater Layup ............................................................................................................................. 84

4.2.14 Gas Turbine Wash Water ................................................................................................................. 84

4.2.15 Graywater ......................................................................................................................................... 84

4.2.16 Motor Gasoline and Compensating Discharge ................................................................................. 90

4.2.17 Non-Oily Machinery Wastewater ..................................................................................................... 90

4.2.18 Refrigeration and Air Condensate Discharge ................................................................................... 91

4.2.19 Seawater Cooling Overboard Discharge (Including Non-Contact Engine Cooling Water, Hydraulic 

System Cooling Water, Refrigeration Cooling Water)..................................................................... 91

4.2.20 Seawater Piping Biofouling Prevention ........................................................................................... 91

4.2.21 Small Boat Engine Wet Exhaust ...................................................................................................... 91

4.2.22 Sonar Dome Discharge ..................................................................................................................... 92

4.2.23 Underwater Ship Husbandry Discharges .......................................................................................... 93

4.2.24 Welldeck Discharges ........................................................................................................................ 94

4.2.25 Graywater Mixed with Sewage from Vessels .................................................................................. 95

4.2.26 Exhaust Gas Scrubber Washwater Discharge .................................................................................. 95

4.2.27 Fish Hold Effluent ............................................................................................................................ 99

4.3 Costs of Vessel-Specific Requirements ....................................................................................................... 101
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4.3.1 Large and Medium Cruise Ships .................................................................................................... 101

4.3.2 Large Ferries ................................................................................................................................... 105

4.3.3 Unmanned Barges (Such As Hopper Barges, Chemical Barges, Tank Barges, Fuel Barges, Crane 

Barges, Dry Bulk Cargo Barges) .................................................................................................... 105

4.3.4 Oil Tankers, Petroleum Tankers or Bulk Chemical Carriers .......................................................... 106

4.3.5 Research Vessels ............................................................................................................................ 106

4.3.6 Emergency Vessels (Fire Boats, Police Boats) .............................................................................. 106

4.4 General inspection and Permit Paperwork Burden ...................................................................................... 107

4.4.1 Revised Paperwork Requirements .................................................................................................. 108

4.4.2 Paperwork Requirement Burden for Newly Covered Commercial Fishing Vessels ...................... 110

4.5 Analysis of Total National Costs ................................................................................................................. 110

4.6 Uncertainties and Limitations ...................................................................................................................... 113

5 Analysis of Impacts on Firm Revenues and Financial Performance .................................................... 115

5.1 Methodology ................................................................................................................................................ 115

5.1.1 Assign Each Vessel to a Naics Code .............................................................................................. 115

5.1.2 Estimate the Number of Vessels Per Firm ...................................................................................... 116

5.1.3 Estimate the Distribution of Costs Per Vessel ................................................................................ 117

5.1.4 Compare Firm-Level Costs to Firm-Level Revenues ..................................................................... 121

5.2 Small Entity Analysis .................................................................................................................................. 121

5.3 Uncertainties and Limitations ...................................................................................................................... 126

6 Benefits Analysis ........................................................................................................................................ 128

6.1 Ballast Water and Invasive Species Impacts ............................................................................................... 128

6.1.1 Introduction and Background ......................................................................................................... 128

6.1.2 ANS Impacts .................................................................................................................................. 129

6.1.3 Efficacy of VGP Ballast Water Management Practices ................................................................. 135

6.1.4 Benefits of Reducing ANS Introductions ....................................................................................... 135

6.2 Benefits of Reduced Pollutant Discharges from Vessels ............................................................................ 137

6.2.1 Introduction and Background ......................................................................................................... 137

6.2.2 Pollutants Commonly Found in Vessel Discharges ....................................................................... 138

6.2.3 Pollutant Impacts ............................................................................................................................ 142

6.2.4 Benefits of Reducing Pollutant Discharges .................................................................................... 144

References ............................................................................................................................................................. 147
 

November 30, 2011 v

List of Tables

Table 2-1. Domestic Vessel Population ..................................................................................................................... 5

Table 2-2. Foreign Vessel Population. ....................................................................................................................... 6

Table 2-3: Population of Vessels Required to Submit an NOI. ................................................................................. 8

Table 2-4: Population of Vessels Greater than 400 Gross Tons. ............................................................................... 9

Table 2-5: Population of Vessels Subject to Ballast Water Requirements. ............................................................. 11

Table 3-1. Principal 2007 NAICS Codes and Descriptions Relevant to Vessels Covered by the VGP. ................. 16

Table 3-2. Number of Vessels in the WTLUS Database, 2000-2008. ..................................................................... 23

Table 3-3. Number of Establishments by Industry Sector, 2002 and 2007. ............................................................ 24

Table 3-4. Establishment Births and Deaths, Five-Year Annual Average: 2002-2007. .......................................... 25

Table 3-5. Net Change in Employment: Five-Year Annual Average, 2002-2007. .................................................. 26

Table 3-6: Revenues by Industry Sector, 2002 and 2007. ....................................................................................... 27

Table 3-7. Firms and Revenues by Employment Size, 2007. .................................................................................. 29

Table 3-8. Number of Firms According to Revenue Size, 2007. ............................................................................. 30

Table 3-9: Small Businesses by Industry Sector. ..................................................................................................... 32

Table 3-10. Employment by Industry Sector, 2002-2007. ....................................................................................... 34

Table 3-11. Payroll by Industry Sector, 2002-2007. ................................................................................................ 35

Table 4-1. Vessel Counts for Practice Applicable to Deck Runoff. ........................................................................ 39

Table 4-2. Per-Vessel Costs for Practices Associated with Deck Runoff ................................................................ 40

Table 4-3. Deck Runoff Sensitivity Analysis. ......................................................................................................... 42

Table 4-4. Summary of the Potential Implications of Revised Bilge Water Discharge Requirements under 

Consideration ................................................................................................................................................... 46

Table 4-5. Vessel Counts for Practices Applicable to Option to Authorize Discharge of Treated Bilge Water (to 5 

ppm). ................................................................................................................................................................ 48

Table 4-6. Bilge Water Treatment Sensitivity Analysis. ......................................................................................... 54

Table 4-7. USCG Phase One and IMO D-2 Ballast Water Discharge Standards. ................................................... 62

Table 4-8. Vessel Counts for Practices Applicable to Ballast Water Treatment. .................................................... 63

Table 4-9. Vessel Counts for Practices Applicable to Ballast Water Treatment for Vessels Entering the Great 

Lakes. ............................................................................................................................................................... 64

Table 4-10. Discharge Sampling and Testing Requirements. .................................................................................. 66

Table 4-11. Annual per vessel cost of ballast water requirements. .......................................................................... 67

Table 4-12. Ballast Water Treatment and Exchange Costs. ..................................................................................... 68
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Table 4-13. Ballast Water Treatment Sensitivity Analysis. ..................................................................................... 71

Table 4-14. Vessel Counts for Cathodic Protection Practices. ................................................................................ 75

Table 4-15. Cathodic Protection Installation Cost Estimates (2010$). .................................................................... 76

Table 4-16. Cathodic Protection Sensitivity Analysis, Purchase of a Cathodic Protection System. ....................... 77

Table 4-17. Vessel Counts for General Oil-to-Sea Interface and Controllable Pitch Propeller Hydraulic Fluid 

Practices. .......................................................................................................................................................... 80

Table 4-18: Lubricant Consumption Rates by Vessel Class. ................................................................................... 82

Table 4-19. Environmentally Acceptable Lubricants Sensitivity Analysis. ............................................................ 83

Table 4-20. Vessel Counts for Graywater Practices. ............................................................................................... 89

Table 4-21. Graywater Monitoring Sensitivity Analysis. ........................................................................................ 90

Table 4-22. Vessel Counts for Underwater Ship Husbandry Practices.................................................................... 94

Table 4-23. Exhaust Gas Scrubber Washwater Discharge Monitoring Sensitivity Analysis. ................................. 99

Table 4-24. Vessel Counts for Fish Hold Effluent Practices ................................................................................. 100

Table 4-25. Cruise Ship Counts. ............................................................................................................................ 104

Table 4-26. Vessel Class Breakdown. ................................................................................................................... 108

Table 4-27. Incremental Burden Assumptions for General Inspection and Paperwork Requirements. ................. 109

Table 4-28. Incremental Burden (Reduction) for Combined Barge Annual Reports. ........................................... 109

Table 4-29. Incremental Burden Assumptions for General Inspection and Paperwork Requirements for 

Commercial Fishing Vessels. ......................................................................................................................... 110

Table 4-30. Total Annual Compliance Costs, by Practice Category and Vessel Class ......................................... 112

Table 4-31. Total Annual Compliance Costs for All Practices, by Vessel Type, Including Paperwork Costs...... 113

Table 5-1: Number of Vessels by Firm in Each Industry Sector. .......................................................................... 117

Table 5-2. Estimated 1% and 3% Revenue Thresholds by NAICS Code for Firms in Smallest Revenue Category.

 ....................................................................................................................................................................... 123

Table 5-3. Results of the Small Entity Impact Analysis. ....................................................................................... 125

Table 6-1: Estimates of Invasive Species in Several Major Water Systems. ......................................................... 130

Table 6-2: Estimates of Invasive Species Damages by Type of Species. .............................................................. 130

Table 6-3. Pollutants Found in Vessel Dischargesa

. .............................................................................................. 138

Table 6-4. Types of Pollutants Found in Graywater Discharges ........................................................................... 139

Table 6-5. Impairment Status of the Top 20 Ports by Annual Vessel Calls. ......................................................... 145

Table 6-6. Benefits of Reducing Pollutants Found in Vessel Discharges. ............................................................. 146
 

November 30, 2011 vii

Acronyms

ACSI Alaska Cruise Ship Initiative

ADEC Alaska Department of Environmental Conservation

AFFF Aqueous film-forming foam

AMSA Australian Maritime Safety Authority

ANS Aquatic non-indigenous species

ANSTF Aquatic Nuisance Species Task Force

APPS Act to Prevent Pollution from Ships

BWTS Ballast Water Treatment System

BMP Best management practice

BOD Biochemical oxygen demand

CCC Criterion Continuous Concentration

CDC Centers for Disease Control

CLIA Cruise Line International Association

CMC Criterion Maximum Concentration 

COTP Captain of the Port

CPI Consumer Price Index

CWA Clean Water Act

DOD Department of Defense

EEZ Exclusive Economic Zone

eNOI Electronic Notice of Intent

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

GESAMP Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection

GLERL Great Lakes Environmental Research Laboratory

GSMFC Gulf States Marine Fisheries Commission

IADC International Association of Drilling Contractors

ICCP Impressed Current Cathodic Protection

ICST International Classification of Ships by Type

IDNR Indiana Department of Natural Resources

IMO International Maritime Organization

ISA Infectious salmon anemia

MARPOL 1973/78 International Convention for the Prevention of Marine Pollution from Ships

MISLE Marine Information for Safety and Law Enforcement

MODU Mobile Offshore Drilling Unit

NAICS North American Industry Classification System

NANCPA Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990

NBIC National Ballast Information Clearinghouse

NDC Navigation Data Center

NISA National Invasive Species Act

NMFS National Marine Fisheries Service

NOAA National Oceanic and Atmospheric Administration

NoBOB No ballast on board

NOI Notice of Intent

NPDES National Pollutant Discharge Elimination System

NRDC National Resources Defense Council

NRWQC National recommended water quality criteria

OTA Office of Technology Assessment

PAH Polycyclic aromatic hydrocarbon

PARI Permit Authorization and Record of Inspection

PFOA Perfluorooctanoic acid

PFOS Perfluorooctane sulfonate
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November 30, 2011 viii

POC Pollutant of concern

RFA Regulatory Flexibility Act

RO-RO Roll-on/roll-off

RTF Ruffe Task Force

SAB Science Advisory Board

SBA Small Business Administration

SBAC Small Business Advocacy Chair

SBREFA Small Business Regulatory Enforcement and Fairness Act

SIC Standard Industrial Classification

TBT Tributyltin

UNDS Uniform National Discharge Standards

USACE U.S. Army Corps of Engineers

USCG U.S. Coast Guard

USDA U.S. Department of Agriculture

USDOI U.S. Department of the Interior

USGS U.S. Geological Survey

VDS Vessel Documentation System

VESDOC Merchant Vessels of the United States

VHS Viral hemorrhagic septicemia

VTCC Vessel Type, Construction, and Characteristics

WCSC Waterborne Commerce Statistics Center

WHOI Woods Hole Oceanographic Institute

WTLUS Waterborne Transportation Lines of the United States
 

November 30, 2011 ix

EXECUTIVE SUMMARY

EPA is revising permitting requirements for discharges incidental to the normal operation of non-recreational, 

non-military vessels into inland waters or the territorial sea of the United States under the National Pollutant 

Discharge Elimination System (NPDES).

This report presents EPA’s economic and benefits analysis of impacts of revisions to the Vessel General Permit 

on all affected vessels. Though the issuance of this Permit is not a Federal regulation, EPA is conducting this 

analysis to evaluate potential impacts of the VGP. The Executive Summary provides an overview of the costs and 

benefits of VGP revisions. 

The Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels (herein referred to as the 

Vessel General Permit or VGP) covers non-recreational and non-military vessels 79 feet or more in length.

1 The 

VGP defines effluent limits for 27 discharge categories as well as specifying certain practices and discharges for 

selected vessel categories.2

 

All vessels operating in a capacity of transportation are eligible for coverage under the VGP. The types of vessels

covered under the Permit include commercial fishing vessels, cruise ships, ferries, barges, mobile offshore drilling 

units (MODUs), oil tankers or petroleum tankers, bulk carriers, cargo ships, container ships, other cargo 

freighters, refrigerant ships, government vessels not a part of the armed forces (e.g. NOAA and USACE vessels), 

research vessels, and emergency response vessels, including firefighting and police vessels, and any other vessel 

operating in a capacity of transportation. Vessels of the armed forces of the United States are not eligible for 

coverage by this Permit. EPA estimates that is 58,602 domestic flag and 12,429 foreign flag vessels will be 

covered under the VGP, but only a subset of these vessels will incur incremental costs as a result of the revised 

requirements. Chapter 2: Population of Affected Vessels of this report presents EPA’s assessment of the numbers 

and types of vessels likely to be impacted by the revised permitting requirements. 

Water transportation accounts for a majority of the vessels sailing on U.S. waters and covered by the VGP. As of 

2007, the water transportation industry was a $48 billion industry that employed over 157,000 people on a payroll 

of over $8 billion.3

 Overall, the industry has experienced growth in the revenues, payroll and number of 

employees, but a decline in the number of establishments. The global economic crisis and U.S. recession, post 

2007, likely impacted the water transportation as a reduced overall flow of goods reduced shipping volume and 

other leisure water transportation activities decreased, it also likely also affected the fishing and mining industries. 

The fishing industry is responsible for slightly more than a quarter of all commercial vessels in the United States. 

The fishing industry is much smaller, with total revenues of $1.66 billion, employing 5,600 people on a payroll of 

$302 million. It has experienced a slight increase in number of establishments and payroll, although it has also 

experienced a decline in the number of employees. The drilling oil and gas wells sector, a subset of the mining 

industry (which includes the 131 MODUs covered under the VGP), is a $9 billion sector that employs nearly 

 

1 If auxiliary vessels or craft, such as lifeboats or rescue boats less than 79 feet onboard larger vessels require permit coverage, they are 

eligible for coverage under this permit and are covered by submission of the Notice of Intent for larger vessels. Recreational vessels as 

defined in section 502(25) of the Clean Water Act are not subject to this permit. 

2 Vessel categories with specific permit requirements include: large cruise ships; medium cruise ships; large ferries; barges; oil tankers or 

petroleum tankers; research vessels; emergency vessels; and vessels employing experimental ballast treatment systems.

3

 The 2007 Economic Census provides the most recent revenue, employment and establishment data. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 x

60,500 people on a payroll of approximately $2.5 billion. This sector has experienced strong growth with a 

115 percent increase in revenue from 2002 to 2007. On the whole, the three industries are composed of about 

93 percent small businesses. Of the 3,907 firms in the water transportation industry, 3,637 (93.1 percent) are 

small. In the fishing industry, 1,843 (96.2 percent) of the 1,916 firms are small. In the drilling oil and gas wells 

sector, 1,893 (89.9 percent) of the 2,109 firms are small. Chapter 3: Profile of Water Transportation, Fishing and 

Mining Industries provides an economic profile of these industries. 

To estimate the effect of revised Permit requirements on an industry as a whole, EPA’s analysis takes into account 

previous conditions and determines how the industry would act in the future in the absence of revised Permit

requirements. The baseline for this analysis is full industry compliance with existing federal and state regulations, 

including the 2008 VGP in the case of vessels currently covered by the permit; and existing industry practices or 

standards that exceed current regulations to the extent that they can be empirically observed. In addition, a 

number of laws and associated regulations (including the National Invasive Species Act; the Act to Prevent 

Pollution from Ships; the Comprehensive Environmental Response, Compensation, and Liability Act; the 

Organotin Anti-fouling Paint Control Act; and others) already cover certain discharges that would be covered by 

the VGP. The overlap between revised permit requirements and existing regulations and practices is discussed at 

greater length in the sections of the report that address each revised requirement. 

Chapter 4: Cost of Best Management Practices presents EPA’s analysis of compliance costs to commercial 

vessels associated with each of the practices and discharge categories identified and the paperwork burden costs. 

Incremental costs are understood to result from the inclusion of all commercial fishing vessels 79 feet or larger 

under the VGP (these vessels were largely not covered by the 2008 VGP), and from revised, more stringent 

requirements for certain discharge categories and practices. Changes in compliance costs also result from 

streamlining selected requirements, which is expected reduce compliance costs for owners of certain vessels. 

Overall, EPA finds that revisions in the VGP requirements could result in aggregate annual incremental costs for 

domestic vessels ranging between $6.5 and $20.9 million (in 2010$). This includes the paperwork burden costs 

and the sum of practice costs for applicable discharge categories for all vessels estimated to be covered by the 

revised VGP. Per vessel incremental compliance costs range between $0 to about $8,400 per year, depending on 

the number of applicable discharge categories and baseline practices. The maximum value in that range is for a 

large ship assumed to incur the maximum cost for each and all relevant practices. Most vessels covered by the 

VGP incur compliance costs that are much lower, however, as average compliance costs range between $26 and 

$3,933 per vessel. The largest share of the incremental costs is generally associated with requirements mandating 

the use of environmentally acceptable lubricants. As discussed in Section 4, there is considerable uncertainty in 

the assumptions used for several practices and discharge categories and these estimates therefore provide 

illustrative ranges of the costs potentially associated with the 2013 VGP rather than incremental costs incurred by 

any given vessel owner. Nevertheless, the estimated compliance costs generally represent a small share of per 

vessel operating revenue. Hence, EPA finds that meeting the 2013 VGP permit requirements is economically 

practicable and achievable for permittees.

To evaluate the potential economic impacts of revised VGP requirements on the water transportation, fishing, and 

mining industries, EPA performed a firm-level analysis. The firm-level analysis examines the impact of any 

incremental cost per vessel to comply with the revised VGP requirements on model firms that represent the 

financial conditions of “typical” businesses in each of the examined industry sectors. Since more than ninety

percent of the firms in the water transportation and fishing industries, and in the drilling oil and gas wells segment 

of the mining industry are small, it is unlikely that firm-level impacts would be material among large firms in this 

industry. Therefore, the firm-level analysis focuses on assessment of impacts on small businesses. To evaluate the 

potential impact of the VGP on small entities, EPA used a cost-to-revenue test to evaluate the potential severity of 

economic impact on vessels owned by small entities. The test calculates annualized pre-tax compliance cost as a 
 

November 30, 2011 xi

percentage of total revenues and uses a threshold of 1 and 3 percent to identify entities that would be significantly 

impacted as a result of this Permit. Chapter 5: Analysis of Impacts on Firm Revenues and Financial Performance 

details EPA’s assessment of the cost and economic impact of regulatory requirements on firms in the shipping 

industry, and the implications of the Permit in terms of financial viability of shipping industry firms subject to the 

Permit. According to the firm-level analysis, the total number of small entities in the fishing industry that are 

expected to exceed the one percent cost-to-revenue threshold ranges between 0 and 189 for the low end and high 

end cost assumptions, respectively. EPA believes the analysis overstates impacts to smaller firms due to modeling 

assumptions.4 The total number of small entities in the water transportation industry that are expected to exceed 

the one percent cost-to-revenue threshold ranges from 52 to 171 under the low and high end cost assumptions, 

respectively. Overall, less than 7 percent of firms have costs estimated to exceed the one percent cost-to-revenue 

threshold and less than one percent of firms have costs estimated to exceed the three percent cost-to-revenue 

threshold, based on high end cost estimates. As discussed in the Chapter, the methodology used to distribute 

compliance costs to vessel and firms of different sizes is likely to overstate impacts on small firms.

Although EPA was unable to evaluate the expected benefits of the Permit in dollar terms due to data limitations, 

the Agency collected and considered relevant information to enable qualitative consideration of ecological 

benefits and to assess the importance of the ecological gains from revisions to the VGP. EPA expects that 

reductions in vessel discharges will benefit society in two broad categories: (1) enhanced water quality from 

reduced pollutant discharges and (2) reduced risk of invasive species introduction. These effects are discussed in 

Chapter 6: Benefits Analysis. 

The VGP covers many discharges and contains special provisions for numerous vessel types (see EPA (2011) for 

information on the affected discharges and provisions by vessel type). Many of the discharges regulated by EPA’s 

VGP are associated with a wide variety of harmful pollutants in substantial concentrations. For example, 

untreated graywater may contain pathogenic bacteria, toxic and carcinogenic organic and inorganic compounds, 

nutrients, and metals (EPA, 2007a). Because many of the nation’s busiest ports are considered to be impaired by a 

variety of pollutants found in vessel discharges, strengthening the requirements contained in the VGP, as 

accomplished by the 2013 VGP revisions, is expected to have benefits associated with the reduction of 

concentrations of nutrients, metals, oil, grease, and toxics in waters with high vessel traffic. 

 

4 The distributional analysis model is likely overstates impacts to firms in this sector due methodology limitations discussed later in this 

Section and in Section 5.3, notably EPA’s conservative assumptions regarding the distribution of vessels to firms across size categories 

and relatively uniform characteristics of vessels assigned to firms with very different annual revenue.

Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 1

1 INTRODUCTION

1.1 BACKGROUND

On December 18, 2008, EPA finalized new permitting requirements for discharges incidental to 

the normal operation of a vessel into inland waters or the 3 mile territorial sea of the United States 

under the National Pollutant Discharge Elimination System (NPDES) (73 CFR 117). The 2008 

Vessel General Permit for Discharges Incidental to the Normal Operation of Non-Recreational 

Vessels (herein referred to as the Vessel General Permit or VGP) covers all non-recreational nonmilitary vessels of 79 feet or greater, and any non-recreational vessel less than 79 feet in length or 

commercial fishing vessel of any size discharging ballast water. 

With the expiration of the 2008 period of coverage, EPA is proposing changes to the VGP for the 

next five-year Permit period that will extend from 2013 through 2018. 

To obtain authorization under the VGP: 

 Vessel operators must meet the VGP eligibility requirements.

 Vessel operators must implement the effluent limits according to the requirements in Part 

2 of the VGP, and document the implementation as part of their recordkeeping 

documentation. If the vessel is equipped to carry ballast water or carries ballast water at 

any time, it must have a ballast water management plan consistent with part 33 CFR 

151.2035(a)(7). 

 Operators of some vessels will have to submit NOIs. If a vessel weighs at least 300 gross 

tons or has the capacity to discharge more than 8 cubic meters of ballast water, the 

operator must submit a complete and accurate NOI. For operators required to submit 

NOIs, submission must meet specified submission deadlines. If the vessel is not in one of 

the aforementioned categories, it automatically receives permit coverage under the VGP

and is authorized to discharge in accordance with Permit conditions. The owner of a 

vessel not subject to NOI requirements must instead maintain a Permit Authorization and 

Record of Inspection (PARI) form documenting coverage and annual inspections. 

Based on an analysis of several vessel data sources (described in Section 2), EPA estimated the 

population of vessels affected by the NPDES requirements. The total count of the domestic flag 

vessel population is 58,602. The foreign flag vessel population totals 12,429. 

The VGP defines general effluent limits applicable to all discharges; general effluent limits 

applicable to 27 specific discharge streams; narrative water-quality based effluent limits; 

inspection, monitoring, recordkeeping, and reporting requirements; and additional requirements 

applicable to certain vessel types. This report presents EPA’s economic and benefits analyses of 

the 2013 VGP. The economic analysis is being conducted to evaluate the costs that may be 

incurred by vessel owners in complying with additional requirements of the 2013 VGP and 

inform EPA’s assessment of the practicality of the technologies and practices specified in the 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 2

permit.5 The analyses focus on changes to the VGP requirements, relative to requirements 

contained in the 2008 Permit, which may result in incremental cost (positive or negative) for

vessel owners. The cost estimates for the 2008 VGP were documented in the Economic and 

Benefits Analysis of the Proposed Final Vessel General Permit (EPA, 2008). Though the issuance 

of this permit is not a Federal regulation, EPA is conducting these analyses to analyze the 

associated burden of this permit on all entities, and in particular small entities. 

1.2 REPORT ORGANIZATION 

This report is organized in seven sections and two appendices, as follows:

Section 2: Population of Affected Vessels presents an assessment of the numbers and types of 

vessels likely to be affected by the new permitting requirements. 

Section 3: Profile of the Water Transportation, Fishing, and Mining Industries provides an 

economic profile of the sectors that have vessels subject to the VGP. 

Section 4: Cost of Best Management Practices presents EPA’s analysis of compliance costs to 

commercial vessels associated with each of the practices identified by EPA in the 2013 VGP at 

the vessel level. This chapter also presents an estimation of national-level industry compliance 

costs.

Section 5: Analysis of Impacts on Firm Revenues and Financial Performance presents EPA’s 

assessment of the cost and economic impact of regulatory requirements on firms that own or 

operate vessels covered by the VGP, and the implications of the Permit in terms of the financial 

viability of these firms. 

Section 6: Benefits Analysis presents EPA’s assessment of the environmental effects associated 

with vessel discharges and the benefits of reducing these discharges. 

 

5 In developing the VGP, EPA evaluated best practicable technologies currently available (BPT). Cost is one of several 

considerations in determining practicability. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 3

2 POPULATION OF AFFECTED VESSELS

The VGP is applicable to discharges incidental to the normal operation of a vessel into the 

navigable waters within the meaning of the Clean Water Act (CWA) Section 502(7). Vessels 

operating in a capacity of transportation are eligible for coverage under the VGP. The types of 

vessels covered under the VGP include commercial fishing vessels, cruise ships, ferries, barges, 

mobile offshore drilling units, oil tankers or petroleum tankers, bulk carriers, cargo ships, 

container ships, other cargo freighters, refrigerant ships, research vessels, emergency response 

vessels, including firefighting and police vessels, and other vessels operating in a capacity of 

transportation. Vessels of the armed forces of the United States are not eligible for coverage by 

this permit as they are subject to Uniform National Discharge Standards (UNDS) under Section 

312(n) of the CWA. While all non-recreational, non-military vessels may seek coverage under 

this permit, the permit requirements are generally targeted to vessels that are at least 79 feet in 

length. A separate, streamlined permit is available for vessels less than 79 feet (Small Vessel 

General Permit for Discharges Incidental to the Normal Operation of Vessels Less Than 79 Feet).

Consequently, the analysis of the impacts of the VGP considers the population of vessels 79 feet 

or greater in length only. 

EPA used the following data sources to estimate the population of affected vessels:

 Domestic flag vessels: The Marine Information for Safety and Law Enforcement 

(MISLE) and Waterborne Transportation Lines of the United States (WTLUS) databases 

provided information on the number and type of domestic flag vessels subject to the 

Vessel General Permit. 

 Foreign flag vessels: The Foreign Vessel Traffic Entrance and Clearance records of U.S. 

Customs and Border Protection provided information on the number and type of foreign 

flag vessels operating in the navigable waters of the United States. 

 Vessels subject to ballast water management requirements: USCG estimated the number 

of domestic and foreign vessels that potentially subject to ballast water requirements 

(USCG, 2008). Additional data were obtained from the National Ballast Information 

Clearinghouse (NBIC) on U.S. port calls, traffic patterns, ballast capacity, whether a 

vessel declared ballast water on board, and whether ballast water exchange was 

performed for calendar years 2009 and 2010 (January 1, 2009 through December 31, 

2010). 

EPA also used information that was previously compiled for the analysis of the 2008 VGP. This 

includes information provided by the Cruise Line International Association (CLIA) on the 

number and size of cruise ships operating in U.S. waters. 

2.1 DOMESTIC VESSEL POPULATION

EPA used three data sources to determine the population of domestic flag vessels: (1) the MISLE 

database compiled by the U.S. Coast Guard (USCG, 2009), (2) the WTLUS data file compiled by 

the Waterborne Commerce Statistics Center (WCSC) of the U.S. Army Corps of Engineers 

(USACE) Navigation Data Center (NDC) (USACE, 2009), and (3) information submitted by the 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 4

International Association of Drilling Contractors (IADC), which provided a vessel count of 131 

MODUs as part of EPA’s analysis of the 2008 VGP. 

MISLE provides a wide range of information regarding vessel and facility characteristics, 

accidents, marine pollution incidents, and other information pertinent to U.S. Coast Guard 

operations. MISLE includes data for a total of nearly 1 million vessels that operate in U.S. waters. 

The database covers a wide ensemble of vessels (e.g., recreational vessels, commercial fishing 

vessels, freight barges, tank barges, tank ships, passenger vessels, utility vessels), and provides 

data on various characteristics for each individual vessel. These data include: Identification 

number(s); Vessel category (e.g., class, type, subtype, service); Size (e.g., tonnage, length, 

breadth, depth); Area of operation (e.g., hailing port, route type); Passenger and crew capacity; 

Propulsion (i.e., method, engine type, and horsepower); Construction material and design (e.g., 

hull material, design type, hull configuration/shape); Year built or age. 

WTLUS is a three-volume annual product that provides both an inventory of vessel companies, 

along with their American flag vessels operating in the transportation of freight and passengers, 

and a national summary of all vessels. The database lists the vessel companies in alphabetical 

sequence and provides each vessel’s name and number; Coast Guard number; net tonnage; Vessel 

Type, Construction, and Characteristics (VTCC) code and International Classification of Ships by 

Type (ICST) code; register and overall length and breadth; loaded and light draft; horsepower; 

carrying capacity in short tons or units of cargo and number of passengers; height of fixed 

superstructures; cargo handling equipment; operating headquarters; and year built or rebuilt. 

To estimate the domestic vessel population subject to the VGP, EPA created a master database by 

combining the MISLE and WTLUS data files. The combined database allows the Agency to 

obtain a comprehensive estimate of the vessel population and to minimize the number of missing 

data fields for any given vessel.

6

 The Coast Guard number, which serves as the unique vessel 

identifier, was used to merge the databases. EPA used the MISLE data as the base of the 

population and, as a general rule, used the majority of the data fields contained therein, inputting 

similar data attributes from WTLUS into this format. As shown in Table 2-1, the estimated 

number of domestic flag vessels subject to the Vessel General Permit is 58,602. 

 

6 For example, EPA used values reported in WTLUS to fill in missing MISLE information regarding vessel type, length, 

and gross tonnage for vessels reported in both databases. 
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Table 2-1. Domestic Vessel Population

Vessel Type Total Domestic Vessels

Counta Percentage of Vessels

Commercial Fishing b 2,326 4%

Freight Barge 39,760 68%

Freight Ship 812 1%

Passenger Vessel 1,970 3%

Tank Barge 7,144 12%

Tank Ship 332 1%

Utility Vessel 6,258 11%

Total 58,602 100%

Source: Determined from data compiled by the U. S. Coast Guard, MISLE database, 2009 and by 

USACE, WTLUS 2009. a Includes vessels 79 feet or greater with status noted as “active”, “unknown”, “laid up” or without 

status. Excludes vessels identified as duplicate records in the vessel name field. Vessels with 

unspecified type were assigned to a vessel type based on relative shares of vessel types.

b

 A separate estimate provided by U.S. Coast Guard personnel suggests that commercial fishing 

vessels 79 feet long or greater number approximately 1,800 to 1,900 vessels.7

This analysis examines the following vessel population groups, defined by MISLE and WTLUS 

categorizations:

 Commercial Fishing. Includes fish catching, fish processing, and other fishing vessels.

 Freight Barge. Includes open and covered hopper barges, car floats, flat/deck barges, 

pontoon barges, open and covered dry cargo barges, container barges, lash barges, and 

convertible barges.

 Freight Ship. Includes general cargo freighters, break bulk carriers, roll-on/roll-off (RORO) carriers, container ships, partial container ships, refrigerated ships (reefer), and 

vehicle carriers.

 Passenger Vessel. Includes cruise ships, combination passenger and cargo ships, ferries, 

railroad car ferries, excursion and sightseeing vessels, and passenger barges.

 Tank Ship. Includes petroleum, chemical, and liquid gas carriers, and liquid bulk tankers. 

 Tank Barge. Includes liquid cargo barges that are single hull, double hull, double sided 

only, and double bottom only. 

 Utility Vessel. Includes crew boats, mobile offshore drilling units, offshore supply 

vessels, industrial vessels, oil recovery vessels, research vessels, school ships, push boats, 

and tug/towing vessels.

As shown in Table 2-1, freight barges (68 percent), tank barges (12 percent), and utility vessels 

(11 percent) account for the majority of domestic vessels eligible for coverage under the VGP. 

 

7 Personal communication with Jack Kemerer, Fishing Vessel Safety Program, May 26, 2009. 
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November 30, 2011 6

2.2 FOREIGN VESSEL POPULATION

The Foreign Traffic Vessel Entrances and Clearances (FTVEC) database provides information on 

foreign vessels entering or clearing U.S. Customs ports in calendar year 2008, the most recent 

year for which data are published (U.S. Army Corps of Engineers, 2010). The data are compiled 

by the U.S. Army Corps of Engineers from information originally collected by U.S. Customs and 

Border Protection. They include entrance/clearance characteristics such as the date a vessel made 

entry into or cleared the U.S. Customs port or waterway, as well as vessel characteristics such as 

the name, type by rig or ICST code, flag of registry, last (for entrances) or next (for clearances) 

port of call, whether foreign or domestic, Net and Gross Registered Tonnage, and draft in feet. 

The database includes both foreign flagged and domestic vessels. However, only foreign flagged 

vessels are included in the estimate of the foreign vessel population. The estimate of the foreign 

vessel population also excludes several other Permit-exempt boats. EPA estimates that 12,429 

foreign flagged vessels are subject to the VGP requirements.

EPA used ICST codes to group foreign flagged vessels into the classes used in the analysis of the 

domestic vessel population (i.e., commercial fishing, freight barge, freight ship, passenger vessel, 

tank barge, tank ship, and utility vessel). Table 2-2 presents the number of foreign flagged vessels 

by vessel class. As shown in Table 2-2, the majority of foreign flagged vessels entering U.S. ports 

are freight ships (66 percent), followed by tank ships (27 percent). Of the 12,429 foreign flagged 

vessels that entered U.S. waters in 2008, 12,351 weigh more than 300 gross registered tons and 

therefore needed to submit an NOI to EPA based on this applicability criterion. This number 

appears generally consistent with the number of NOIs that were actually submitted in the 

following year. For instance, eNOI data as of August 2010 show that 13,832 foreign vessels 

submitted an NOI electronically in the 13 months during which the NOI system had been in 

place. Since vessel owners do not need to re-submit an NOI upon returning to the United States

from an overseas voyage, the number of NOI submitted in any given year is expected to be only a 

fraction of the number of vessels that enter U.S. waters during the year. 

Table 2-2. Foreign Vessel Population. 

Vessel Type Total Foreign Vessels 

Count Percentage of Foreign Vessels

Commercial Fishing 47 <1%

Freight Barge 149 1%

Freight Ships 8,218 66%

Passenger Vessel 225 2%

Tank Barge 25 <1%

Tank Ships 3,375 27%

Utility Vessel 389 3%

Total 12,429 100% a The count of vessels required to submit an NOI is based on data reported in the Foreign Traffic Vessel Entrances and 

Clearances database. Only vessels greater than 300 gross tons are assumed to be required to submit an NOI. Data 

from EPA’s eNOI system indicate that 13,832 vessels had submitted an NOI through August 5, 2010.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 7

The foreign flagged vessels are excluded from the analysis of the total costs of implementing 

pollution prevention and control practices for the relevant discharge categories because the cost to 

foreign flagged vessels does not have a direct impact on U.S. firms.

2.3 VESSELS SUBJECT TO NOI REQUIREMENTS

The VGP requires owners of vessels meeting the requirements under Part 1.5.1.1 (300 gross tons 

or greater or has the capacity to hold or discharge more than 8 cubic meters of ballast water) to

submit an NOI to EPA to receive permit coverage. In the case of vessels that were authorized to 

discharge under the 2008 VGP, the NOI must be submitted within 6 months of the effective date 

of the revised VGP, while vessels not previously covered must submit an NOI at least 30 days 

before discharging into waters subject to the permit.

EPA estimated the number of vessels required to submit an NOI (e.g., vessels greater than 

300 gross tons) using the data sources described above for domestic and foreign vessels and 

information available from the vessels that submitted an NOI under the 2008 VGP. 

As of August 2010, EPA had received 43,110 NOIs for active vessels, including 29,278 domestic 

and 13,832 foreign vessels. These numbers are generally consistent with foreign vessels 

characterized in the FTVEC databases, which show vessels greater than 300 gross tons 

numbering 12,351. The number of NOIs received is lower than the 48,502 vessels 

MISLE/WTLUS identifies as 300 gross tons or greater. The difference may be due to inactive 

vessels being included in MISLE.8 Table 2-3 summarizes the counts of domestic and foreign 

vessels that may be required to submit an NOI to obtain coverage under the 2013 VGP. 

 

8

 MISLE does not report the status of 29,736 vessels. EPA conservatively assumed that these vessels are active and 

may potentially seek coverage under the 2013 VGP.
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November 30, 2011 8

Table 2-3: Population of Vessels Required to Submit an NOI.

Vessel Type Domestic Vessels Required to 

Submit NOIa

Foreign Vessels Required to Submit 

NOIb

Count Percentage of

NOIs for

Domestic Vessels

Count Percentage of 

NOIs for Foreign 

Vessels

Commercial Fishing 463 1% 42 <1%

Freight Barge 37,516 77% 147 1%

Freight Ships 668 1% 8,202 66%

Passenger Vessel 301 1% 225 2%

Tank Barge 6,466 13% 24 <1%

Tank Ships 283 1% 3,374 27%

Utility Vessel 2,805 6% 336 3%

Total 48,502 100% 12,351 100%

Source: Determined from data compiled by the U. S. Coast Guard, MISLE database, 2009; USACE, WTLUS 2009; and 

USACE FTVEC 2008. Estimates are based on the number of vessel 300 gross tons or greater. 

a Count based on the number of vessels 300 gross tons or greater. Data from EPA’s eNOI system indicate that 29,278 

domestic vessels had submitted an NOI through August 5, 2010.

b The count of vessels required to submit an NOI is based on data reported in the Foreign Traffic Vessel Entrances and 

Clearances database. Only vessels 300 gross tons or greater are assumed to be required to submit an NOI. Data from 

EPA’s eNOI system indicate that 13,832 foreign vessels had submitted an NOI through August 5, 2010.

2.4 VESSELS SUBJECT TO THE BILGE WATER TREATMENT REQUIREMENTS

The VGP contains requirements to limit the discharge of oily bilge water. For vessels greater than 

400 gross tons, the Permit authorizes the discharge of oily bilge water provided that these 

discharges meet specified conditions for maximum oil content, monitoring, and alarms. 

EPA estimated the number of vessels greater than 400 gross tons using the data sources described 

above for domestic and foreign vessels. The data are summarized in Table 2-4. 
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November 30, 2011 9

Table 2-4: Population of Vessels Greater than 400 Gross Tons. 

Vessel Type Domestic Vessels Greater than 400 

Gross Tons

Foreign Vessels Greater than 400 

Gross Tons

Count Percentage of 

Domestic Vessels

Count Percentage of 

Foreign Vessels

Commercial Fishing 405 1% 41 0%

Freight Barge 36,764 78% 145 1%

Freight Ships 663 1% 8,198 67%

Passenger Vessel 275 1% 223 2%

Tank Barge 6,286 13% 24 0%

Tank Ships 281 1% 3,374 27%

Utility Vessel 2,474 5% 312 3%

Total 47,148 100% 12,318 100%

Source: Determined from data compiled by the U. S. Coast Guard, MISLE database, 2009; USACE, WTLUS 2009; and 

USACE FTVEC 2008. 

2.5 VESSELS SUBJECT TO THE BALLAST WATER MANAGEMENT REQUIREMENTS 

The VGP contains requirements to minimize the risk of introducing invasive species into waters 

of the U.S. from ballast water discharges. The performance requirements are similar to those 

proposed by the U.S. Coast Guard for the “Phase I discharge standard”, which follow the 

International Maritime Organization (IMO) “Regulation D-2” standard of the Ballast Water 

Management Convention (USCG, 2009). These standards are described later in this report 

(Section 4.2.3).9 The 2013 VGP also specifies additional monitoring, sampling, testing, and 

reporting requirements for vessels with ballast water treatment systems (BWTS).

The USCG National Ballast Information Clearinghouse provides data from ballast water reports 

submitted to the USCG by all ballast tank-equipped vessels bound for ports or places of the U.S., 

in accordance with the National Invasive Species Act of 1996, P.L. 104-332 (NBIC, 2011). This 

includes those ships that declare no ballast onboard (NOBOB) and ships not discharging ballast

water. The NBIC database provides information on each arrival, including vessel name and type, 

port, state, arrival date, the vessel’s last port of call, and information on ballast water management 

practices (i.e., ballast capacity, volume discharged, whether ballast water exchange was 

performed, and treatment methods). For calendar years 2009 and 2010, the database has data for 

164,235 arrivals by 8,610 vessels. No ballast water discharge was reported for approximately 70 

percent of arrivals (112,841 arrivals by 3,279 vessels). For vessels that reported discharging 

 

9 The standards specify the following maximum discharge limits: (1) For organisms greater than or equal to 50 

micrometers in minimum dimension: discharge must include fewer than 10 living organisms per cubic meter of ballast 

water; (2) For organisms less than 50 micrometers and greater than or equal to 10 micrometers: discharge must 

include fewer than 10 living organisms per milliliter (mL) of ballast water; (3) Indicator microorganisms must not 

exceed: (i) For Toxicogenic Vibrio cholerae (serotypes O1 and O139): a concentration of less than 1 colony forming 

unit (cfu) per 100 mL (ii) For Escherichia coli: a concentration of fewer than 250 cfu per 100 mL (iii) For intestinal 

enterococci: a concentration of fewer than 100 cfu per 100 mL.. 
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November 30, 2011 10

ballast water (5,331 vessels), about 4,012 vessels conducted ballast water exchange by emptying 

and refilling their tanks (3,443 vessels) and/or using a flow-through exchange method (1,857 

vessels). Finally, 76 vessels reported using an alternative ballast management system approved 

under the USCG Shipboard Technology Evaluation Program (STEP). While the NBIC database 

provides a unique identifier (IMO Number) for each vessel that submitted ballast water 

management reports, the corresponding field in the MISLE/WTLUS database is often empty

(these databases generally use the Coast Guard vessel number to uniquely identify each vessel). 

Because of these data gaps, EPA was able to match only a small subset of the NBIC records 

(approximately 800 domestic vessels) to corresponding records in MISLE/WTLUS. 

Instead, EPA used estimates developed by USCG for the number of vessels potentially affected 

by ballast water discharge standards, by type of vessel (USCG, 2008). These estimates exclude 

vessels that are unlikely to have ballast water tanks, namely those vessels less than 100 feet in 

length and certain vessel types (e.g., towing vessels, river vessels, crew boats, barges).10 Since 

these estimates were developed in 2007, we applied net growth rates assumed in the USCG 

analysis for each vessel type to estimate the vessel population in 2009, consistent with the data 

provided in the MISLE/WLUS database. As shown in Table 2-5, a total of 8,148 vessels as 

estimated to be potentially subject to the VGP ballast water requirements, including 2,878 

domestic vessels and 5,269 foreign vessels. The estimate is consistent with the number of unique 

vessels that submitted ballast water management reports to NBIC in calendar years 2009 and 

2010: 8,609 vessels. 

The 2,878 domestic vessels potentially subject to the ballast water requirements represent 

approximately 5 percent of the total number of vessels covered by the 2013 VGP, but account for 

essentially all freight ships and significant shares of commercial fishing vessels (35 percent), tank 

ships (19 percent) and passenger vessels (9 percent). 

 

10 This is reflected in the NBIC data for 2009 and 2010. Bulker and tanker vessels represented 57 percent of vessels 

that submitted ballast water management reports to NBIC. General cargo and container vessels accounted for 

another 24 percent. Other vessels included RoRo (6 percent of vessels), reefer (3 percent), passenger (2 percent) and 

other/unspecified vessels (8 percent).
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November 30, 2011 11

Table 2-5: Population of Vessels Subject to Ballast Water Requirements. 

Vessel Type Domestic Vessels Subject to Ballast 

Water Requirements

Foreign Vessels Subject to Ballast 

Water Requirements

Count Percentage of 

Domestic Vessels

Count Percentage of 

Foreign Vessels

Commercial Fishing 819 28% 18 0%

Freight Barge

Freight Shipsa 1,672 58% 1,560 30%

Passenger Vessel 185 6% 144 3%

Tank Barge

Tank Shipsb 102 4% 3,491 66%

Utility Vesselc 101 3% 57 1%

Total 2,878 100% 5,269 100%

Source: USCG (2008). See Table 2.2. The number of vessel was projected from the 2007 estimates using growth and 

replacement rates provided in Table 2.3.

a Category includes container ships, RoRo, combination vessels, and general cargo vessels. The number of freight 

ships estimated to be potentially subject to the ballast water requirements exceeds the total number of freight ships in 

the MISLE/WTLUS database. 

b Category includes bulk carriers, tank ships, gas carriers, and chemical carriers.

C Category includes offshore supply vessels.

Because the 2013 VGP provides several ballast water management options in addition to onboard 

treatment (use onshore treatment, carry freshwater ballast, hold while in regulated waters), it is 

likely that only a subset of the 8,148 vessels subject to the requirements will choose to install a 

BWTS. At present, not all ballast tank-equipped vessels required to submit a report to the USCG 

actually discharge ballast water in U.S. waters. The number of vessels that reported any ballast 

water discharge to the NBIC in 2009 and 2010 (5,331 vessels) was significantly less than the total 

number of ballast tank-equipped vessels that submitted reports. USCG’s estimates of the number 

of vessels subject to ballast water requirements therefore likely overestimates the number of 

vessels that would ultimately need to install a BWTS or chose this approach to manage their 

ballast water discharge. According to an analysis conducted by King et al. (2010), only about 

1,239 U.S. flag vessel would be subject to the ballast water treatment standards, or less than half 

the number of vessels estimated using USCG (2008) figures. In developing these estimates, King 

et al. considered factors such as the subtypes of vessels that carry ballast water, ballast water 

capacity, and area of operation.11 

 

11 For example, King et al. (2010) excluded commercial fishing vessels less than 300 gross tons and vessels that 

operate within one captain of the port zone. They also excluded vessels that routinely treat less than 70,000 metric 

tons of ballast water annually as these vessels were determined to be more likely to use another method to comply 

with discharge regulation (exchange where allowed, take on freshwater, or foregoing discharge when in regulated 

waters). Similarly, commercial fishing vessels less than 300 gross tons were determined to be unlikely to use onboard 

ballast water treatment and more likely to use some other method to comply with discharge regulations.
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November 30, 2011 12

2.6 UNCERTAINTIES AND LIMITATIONS

This section discusses limitations and uncertainties in the estimation of the affected vessel 

population. Whether these limitations and uncertainties, taken together, are likely to lead to an 

understatement or overstatement of the estimated vessel population is not known. 

The domestic vessel population was estimated using the MISLE database, supplemented with 

data from WTLUS. The main limitations of the MISLE data include:12

 Incomplete data. While MISLE represents the most comprehensive national dataset 

currently available, it does not capture the entire universe of vessels operated on U.S. 

waters. Only limited information is available for certain classes of vessels due to the way 

in which vessel data are gathered since these vessels are not subject to documentation or 

regular inspection requirements. In compiling MISLE data, the U.S. Coast Guard largely 

relies on documents submitted by vessel owners or operators in accordance with vessel 

documentation requirements (e.g., certificate of documentation) or on information 

gathered by U.S. Coast Guard staff directly (e.g., during inspections, vessel boardings, or 

accident investigations).13 The scope of the MISLE database is not limited to a certain 

size or class of vessel, but the content of the database is nonetheless driven in part by the 

regulatory requirements to which different types of vessels are subject or by activities 

conducted by Coast Guard offices. MISLE therefore, is generally considered to be most 

comprehensive for those vessels that are documented, state registered, and/or subject to

inspection requirements. Data omissions are believed to affect primarily recreational and 

smaller commercial vessels. Since the VGP is targeted to larger, non-recreational vessels 

79 feet or greater in length, EPA believes that the MISLE data limitations are not 

consequential for this analysis. 

 Missing or outdated data. While MISLE captures a wide range of characteristics for each 

vessel it records, the information is at times incomplete (e.g., length may be missing or 

recorded as zero) or may be outdated (e.g., a vessel may no longer be operating while its 

status in the database may not have been updated). Even after merging databases and 

using methods to maximize the amount of available data, several data fields remained 

with non-negligible deficiencies. Some but not all of these fields were populated using 

assumptions. For example, EPA conservatively included in the potentially affected vessel 

population a proportional share of vessels for which the length was unknown and all 

vessels that met the VGP applicability criteria. By including all vessels in MISLE even 

when these vessels were not also reported in WTLUS, EPA generally erred on the side of 

a more inclusive VGP population. It is likely, however, that some vessels recorded in 

MISLE are no longer active and therefore the vessel population may be overestimated.

 

12 See EPA (2010) for a more detailed discussion of the limitations of MISLE data. 

13 The MISLE database incorporates data reported separately in VESDOC for documented vessels. VESDOC is a data 

file of merchant and recreational vessels documented under the laws of the United States by the U.S. Coast Guard. 

That dataset was used for the economic analysis of the 2008 VGP (Abt Associates, 2008).
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November 30, 2011 13

 Conflicting vessel classifications. A relatively small number of vessels were found to be 

classified by MISLE and WTLUS differently. In these cases EPA used the WTLUS 

classification and ignored the classification provided in MISLE since the WTLUS data 

are published and therefore assumed to have been subjected to closer accuracy review. 

 Estimate of vessels required to submit an NOI: The count of vessels required to submit an 

NOI is a conservative estimate since data on gross tonnage are not complete. Thus, this 

count is based on the number of vessels that are either >78’ in length or >299 Gross 

Tons.

The estimated number of foreign vessels affected by the VGP was estimated using vessel 

entrances and clearances data for 2008. The data source does not include vessel length. EPA 

imputed the vessel length based on a relationship previously derived between tonnage (as gross 

registered ton) and length (in feet) for different classes of vessels, based on NOI data (see EPA, 

2010b). It is possible that some vessels are larger or smaller than estimated using the relationship.

The estimated number of vessels affected by the ballast water management requirements is based 

on estimates developed by the USCG (2008), complemented by information from NBIC (2011). 

NBIC identifies vessels by their IMO number as compared to the Coast Guard identifier used in 

the MISLE/WTLUS databases. Because of the different identifiers, EPA was not able to match a 

significant fraction of the NBIC records to MISLE/WTLUS and therefore used USCG estimates 

as the primary information source. While the number of vessels estimated to be potentially 

subject to ballast water requirements is generally similar to vessels that submitted reports to the 

NBIC in 2009 or 2010, the number is greater than the number of vessels that reported any ballast 

water discharge during the two years. Therefore, the number possibly overestimates the vessels 

that would need to implement additional practices to comply with ballast water requirements in 

the 2013 VGP. Further, only a subset of vessels that presently discharge ballast water will install 

ballast water treatment systems and would have to implement the related permit practices. 

Finally, the estimate of the population of affected vessels is also subject to the reporting accuracy 

of the data providers. Typographical errors and incorrect entries (including potential duplicate 

entries) exist to an unknown extent. Those that were discovered were corrected. 
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November 30, 2011 14

3 PROFILE OF THE WATER TRANSPORTATION, FISHING, AND MINING 

INDUSTRIES

3.1 INTRODUCTION

The water transportation, fishing, and mining industries consist of the establishments that own 

and operate the commercial vessels subject to the revised VGP. This section describes the 

characteristics of these industries that may be relevant to evaluating the economic impacts of 

revised permit requirements. 

According to the Bureau of Transportation Statistics (BTS), maritime transportation carries over 

three quarters of the weight of all U.S. international freight, and 14 percent of all commercial 

freight in the United States. While domestic waterborne ton-miles and tonnage declined in the 

period of the early 1990s through 2003, the value, tons, and ton-miles as international trade grew 

during this period.

As of 2007, the water transportation industry was a $34 billion industry that employed nearly 

150,000 people on a payroll of just over $6 billion. The fishing industry was much smaller, with 

total revenues of $1.65 billion, employing just over 6,500 people on a payroll of $253 million. 

The drilling oil and gas wells sector (a subset of the mining industry) was a $9 billion sector that 

employs nearly 60,500 people on a payroll of approximately $2.5 billion. 

Water transportation accounts for a majority of the vessels sailing on U.S. waters and is made up 

of several industry sectors, described in Section 3.2.2: Water Transportation. Overall, the 

industry has experienced mild growth in the number of establishments, revenues, and payroll, but 

a decline in the number of employees.

The fishing industry is responsible for slightly more than a quarter of all commercial vessels in 

the United States, although a relatively small fraction of these vessels are greater than 79 feet and 

would therefore be covered under the VGP. The industry has experienced a decline in the number 

of establishments, employees, and payroll, although its revenue grew. 

The drilling oil and gas wells sector, which covers the 131 MODUs covered by the VGP, has 

experienced robust growth, demonstrating a 15 percent increase in revenues from 2002 to 2007.14

The number of domestic vessels operating in U.S. waters has remained relatively constant over 

the last few years, with the total number of documented vessels going from 39,641 vessels in 

2000, to 41,354 in 2005, and 40,301 in 2008, the most recent year with published statistics 

(USACE, 2009). 

 

14 The 131 MODUs only account for a small percentage of establishments reported in the 2007 Economic Census for 

the drilling oil and gas wells sector overall: 131 out of 2,109 establishments. Other establishments classified in the 

drilling oil and gas wells sector conduct operations that do not involve the use of MODUs; for example, these firms 

may drill oil and gas wells on land. 
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November 30, 2011 15

3.1.1 DATA SOURCES USED

EPA developed overviews of the various industry sectors using information from industry groups, 

trade associations, and other reference sources.

Data for the number of vessels were extracted from the combined vessel information of MISLE

and WTLUS (detailed further in Section 2: Population of Affected Vessels) and from information 

submitted by the IADC on the number of MODUs. NAICS codes were assigned to vessels 

according to the NAICS codes of their owner/operators, which were obtained from the Dun & 

Bradstreet (2006), ReferenceUSA (2006) or manta.com databases. In selected instances where it 

was not possible to match a vessel owner or operator to a record in these other databases, EPA 

assigned the most likely NAICS code based on key words in the reported name of the vessel 

owner where it could do so with reasonable confidence.15 In cases where owner/operator 

information was unavailable, no corresponding entry could be found in the business databases, or 

the name of the owner was not descriptive enough to assign a NAICS sector, the most likely 

NAICS code was assigned to a vessel using information on vessel type and area of operation. 

Finally, any remaining unassigned vessels were distributed to the NAICS sectors proportionally 

to the population analyzed for the 2008 VGP (EPA, 2008). 

Overviews of the various industry sectors were developed using information from industry 

groups, trade associations, and other reference sources. Data for numbers of firms, 

establishments, revenues, and employment were obtained from the U.S. Census Bureau and are 

current as of 2007, with the exception of data for NAICS code 11411: Fishing which is not 

covered by the Economic Census. In this case, the data come from the U.S. Small Business 

Administration (SBA). 

3.1.2 ORGANIZATION OF THIS CHAPTER

This chapter presents an overview of the water transportation, fishing, and mining industries. 

Section 3.2 provides definitions and overviews of the industries and their sectors, as well as the 

number of vessels associated with each industry, as classified by NAICS. 

Section 3.3 summarizes recent trends in these industries, including changes in the number of 

establishments and financial performance.

Section 3.4 describes the industries’ market structures, including details of performance according 

to employment size, numbers and percentages of small businesses, employment trends, and 

payroll trends.

 

15 For example, companies whose name contained the terms “charter”, “tour”, or “adventure” were associated with 

establishments operating in the sector NAICS 487210: Scenic and Sightseeing Transportation, Water. 
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3.2 OVERVIEW OF THE WATER TRANSPORTATION, FISHING, AND MINING 

INDUSTRIES

3.2.1 DEFINITION OF THE WATER TRANSPORTATION, FISHING, AND MINING 

INDUSTRIES

The water transportation industry, for the purpose of this chapter, includes NAICS codes 483: 

Water Transportation; 4872: Scenic and Sightseeing Transportation, Water; and 4883: Support 

Activities for Water Transportation. The fishing industry includes NAICS 1141: Fishing. The 

mining industry includes NAICS 213111: Drilling oil and gas wells. Table 3-1 lists the relevant 

NAICS codes for the water transportation, fishing, and mining industries. 

Table 3-1. Principal 2007 NAICS Codes and Descriptions Relevant to Vessels Covered by the 

VGP. 

Industry Group/NAICS Code Description

Fishing 

1141 Fishing

114111 Finfish Fishing

114112 Shellfish Fishing

114119 Other Marine Fishing

Water Transportation 

4831 Deep Sea, Coastal, and Great Lakes Water Transportation

483111 Deep Sea Freight Transportation

483112 Deep Sea Passenger Transportation

483113 Coastal and Great Lakes Freight Transportation

483114 Coastal and Great Lakes Passenger Transportation

4832 Inland Water Transportation

483211 Inland Waterways Freight Transportation

483212 Inland Waterways Passenger Transportation

4872 Scenic and Sightseeing Transportation, Water

4883 Support Activities for Water Transportation

488310 Port and Harbor Operations

488320 Marine Cargo Handling

488330 Navigational Services to Shipping and Salvage

488390 Other Support Activities for Water Transportation

Support Activities for Mining 

2131 Support Activities for Mining

213111 Drilling Oil and Gas Wells sector

213112 Support Activities for Oil and Gas Operations

Source: U.S. Census Bureau, 2007

3.2.2 WATER TRANSPORTATION

Establishments in the water transportation industry provide water transportation of passengers 

and cargo using watercraft, such as ships, barges, and boats. The industry is composed of two 

industry groups: (1) one for deep sea, coastal, and Great Lakes water transportation; and (2) one 
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for inland water transportation. This split typically reflects the difference in equipment used (U.S. 

Census Bureau, 2007a).

Scenic and sightseeing water transportation services are also included under this industry 

heading, as are support activities for water transportation. These two industry groups are 

technically classified outside of Water Transportation (NAICS 483) by the Census Bureau, but 

are included under water transportation for the purposes of this chapter.

Total waterborne commerce in the United States has increased steadily over the past 50 years, 

fueled mostly by growth in foreign commerce, which overtook domestic shipments (in terms of 

weight) in the mid-1990s. Foreign commerce accounted for over 60 percent of total waterborne 

commerce by weight in 2009, amounting to 1.4 billion short tons out of total U.S. waterborne 

commerce of 2.2 billion short tons (USACE, 2009). 

DEEP SEA, COASTAL, AND GREAT LAKES WATER TRANSPORTATION

This industry group comprises establishments primarily engaged in providing deep sea, coastal, 

and Great Lakes water transportation, as well as transportation via the St. Lawrence Seaway. 

Marine transportation establishments using the facilities of the St. Lawrence Seaway Authority 

Commission are considered to be using the Great Lakes Water Transportation System (U.S. 

Census Bureau, 2007a). Firms in this NAICS grouping are further classified based on their area 

of operation (deep sea or coastal/Great Lakes) and payload type (cargo or passengers). 

Deep Sea Freight Transportation

The businesses in this industry sector are primarily engaged in providing deep sea transportation 

of cargo to or from foreign ports. This sector encompasses oceangoing barges, oil tankers, and 

other large freight vessels (U.S. Census Bureau, 2007a). A large portion of U.S. foreign trade 

merchandise (1.4 billion metric tons) is transported via water, making this sector the cornerstone 

of U.S. international trade. 

Because of its close relationship to international trade, deep sea freight transportation has been 

increasing steadily over the past 20 years, driven by increasing imports to the United States from 

foreign ports. 

Over the last half-century, the United States’ merchant fleet has declined in number. Though the 

U.S. vessel fleet has shrunk, it has also become more efficient, with today’s merchant vessels 

carrying 40 percent more cargo and requiring fewer crew members (Transportation Institute, 

undated). 

Deep Sea Passenger Transportation

Establishments in this sector are primarily engaged in providing deep sea transportation of 

passengers to or from foreign ports (U.S. Census Bureau, 2007a). The most common type of deep 

sea passenger transportation is the cruise ship. 

This leisure-based industry sector is more vulnerable to economic fluctuations, since its revenues 

draw on discretionary consumer spending. The global economic crisis and recession greatly 

reduced consumers’ disposable income and thus their leisure spending (U.S. BEA, 2011a). It is 

likely that the scenic and sightseeing transportation sector was impacted by the recession. 
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Coastal and Great Lakes Freight Transportation

Firms transporting cargo in coastal waters; the Great Lakes System (including the St. Lawrence 

Seaway); or deep seas between ports of the United States, Puerto Rico, and U.S. island 

possessions or protectorates fall into this NAICS code classification (U.S. Census Bureau, 

2007a). 

The Jones Act of 1920 requires that all domestic waterborne trade (between two points in the 

United States) be conducted on vessels built in the United States, documented in the United 

States, and owned by U.S. citizens or companies (Transportation Institute, undated). Vessels 

operating in the Coastal and Great Lakes Freight Transportation sector are subject to this law. 

The majority of the vessels in this sector are barges, though the sector is also characterized by its 

use of other freight transport vessels, as well as tugboats (Transportation Institute, undated). In 

the Great Lakes, the transportation system comprises bulk cargo carriers, ocean going vessels and 

smaller cruise ships. 

Coastal domestic trade to and from Alaska, Hawaii, and U.S. Territories consists mainly of the 

shipment of petroleum and petroleum products, chemicals, and agricultural products. The primary 

products transported on the Great Lakes System are coal, limestone, and iron ore (Transportation 

Institute, undated; Quinn, 2002). A relatively large share of these vessels is expected to be greater 

than 79 feet in length and therefore subject to the VGP. 

Coastal and Great Lakes freight transportation accounts for nearly 30 percent of all U.S. domestic 

waterborne shipments by weight in 2009, or 857 million short tons. Coastal and Great Lakes

freight transport accounts for almost 90 percent of all self-propelled traffic, but only 13% of barge 

traffic by weight (USACE, 2009). Great Lakes freight transportation (domestic and foreign) was 

relatively constant from 1990 to 2005, ranging between 150 and 200 million short tons per year. 

Tonnage decreased below 150 million tons in 2007 and was significantly less in 2009, at about 

100 million tons (USACE, 2009). Generally, approximately two-thirds of Great Lakes tonnage is 

domestic freight and one-third is foreign (this pattern remained even after the decline in tonnage) 

(USACE, 2009). 

Coastal freight transportation experienced the same post-2005 decline with 1.4 billion tons 

shipped in 2009, down from 1.6 billion shipped in 2006. This reversed the growing trend 

observed between 1990 and 2005 when coastal freight transportation increased from around 

1.1 billion tons per year to more than 1.6 billion tons, as a result of increased foreign shipments 

(USACE, 2009). 

Coastal and Great Lakes Passenger Transportation

This industry sector contains establishments primarily engaged in providing water transportation 

of passengers in coastal waters, the Great Lakes System (including the St. Lawrence Seaway), or 

deep seas between ports of the United States, Puerto Rico, and United States island possessions 

and protectorates. This industry sector includes many coastal and Great Lakes ferries used to 

travel short distances between coastal ports, or from shores to nearby islands, as well as larger 

vessels used on the Alaska Marine Highway, which travels between ports on the southern coast of 

Alaska and northwestern Canada (Reference for Business, 2007c).
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INLAND WATER TRANSPORTATION

Businesses primarily engaged in providing inland water transportation of passengers and cargo on 

lakes, rivers, or intracoastal waterways (except on the Great Lakes System) are classified under 

this NAICS grouping, and are further classified between freight and passenger transportation 

(U.S. Census Bureau, 2007a). 

As required by the Jones Act, all vessels in this industry sector are domestic flagged and owned.

Inland Waterways Freight Transportation

The companies in this industry sector are primarily engaged in providing inland water 

transportation of cargo on lakes, rivers, or intracoastal waterways (except on the Great Lakes 

System) (U.S. Census Bureau, 2007a). This sector contains a large portion of the vessels in the 

United States, as it encompasses river barges, as well as the tug and towboats that propel them. 

The vast majority of boats in this sector are barges, which outnumber other inland freight vessels 

by about 10 to 1 (Transportation Institute, undated). 

The products carried by this industry sector include more than half of U.S. grain shipments, a 

quarter of chemical and petroleum exports, and a fifth of domestic coal shipments (Transportation 

Institute, undated). Barges account for 79 percent of domestic waterborne freight. 

Inland waterways freight transportation, similar to Great Lakes and coastal water transportation 

has experienced a decrease in cargo tonnage since 2006, although prior to this the total tonnage 

transported had remained constant over the past two decades (USACE, 2009). Nevertheless, 

inland waterways transport accounts for over 50 percent of all domestic waterborne freight 

shipments (USACE, 2009).

Inland Waterways Passenger Transportation

This industry sector provides inland water transportation of passengers on lakes, rivers, or 

intracoastal waterways (except on the Great Lakes System) (U.S. Census Bureau, 2007a). This 

sector includes water taxis and ferries (except coastal and Great Lakes ferries), usually traveling 

short distances between inland ports, such as in New York harbor or in San Francisco Bay.

The ferry industry has been rebounding from historic lows in the 1970s, and short-distance ferries 

in urban areas have become alternatives to crowded highways and urban transit systems. In 2000, 

the 677 ferries operating in the United States served 578 destinations along 352 routes, 

transporting 113 million passengers (these figures include coastal and Great Lakes ferries) 

(Reference for Business, 2007c). 

SCENIC AND SIGHTSEEING TRANSPORTATION, WATER

This industry group comprises establishments primarily engaged in providing scenic and 

sightseeing transportation on water. The services provided are usually local and involve same-day 

return to place of origin (U.S. Census Bureau, 2007a). 

This sector encompasses a wide variety of vessel types, from small “swamp buggies” used to tour 

the Florida Everglades to chartered dinner cruisers to larger whale-watching boats. The range of 

services offered has continued to expand over the past decade, with gambling boats becoming 

popular in Indiana and Iowa, and similar gaming “cruises-to-nowhere” becoming popular in 

Florida (Reference for Business, 2007d).
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This leisure-based industry sector is more vulnerable to economic fluctuations, since its revenues 

draw on discretionary consumer spending. The global economic crisis and recession greatly 

reduced consumers’ disposable income and thus their leisure spending (U.S. BEA, 2011a). It is 

likely that the scenic and sightseeing transportation sector was impacted by the recession. 

SUPPORT ACTIVITIES FOR WATER TRANSPORTATION

This NAICS grouping includes establishments classified in the following NAICS sectors: 48831, 

Port and Harbor Operations; 48832, Marine Cargo Handling; 48833, Navigational Services to 

Shipping and Salvage; and 48839, Other Support Activities for Water Transportation (U.S. 

Census Bureau, 2002). 

Businesses in these sectors are the link between a vessel’s load (cargo or passengers) and that 

load’s final destination. This sector provides the highest percentage of employment in the water 

transportation industry, as many of these services are labor-intensive.

Port and Harbor Operations

Businesses in this industry sector operate ports, harbors (including docking, pier and waterfront 

terminal facilities), or canals (U.S. Census Bureau, 2007a). Vessels in port and harbor operations 

may be involved in maintaining upkeep of harbor via dredging silt, clearing foreign debris, or 

assisting with construction projects (Reference for Business, 2007f). Vessels, such as tugboats, 

may also be responsible for assisting larger vessels in docking maneuvers in harbors and towing 

vessels. As of 2008, there were 5,425 towboats in the U.S. fleet (USACE, 2009). The private 

tugboat industry experienced a boon in late 1990s when the U.S. Navy began chartering tugs 

instead of replacing its fleet (Reference for Business, 2007g). The vessels in this industry sector 

are likely to be smaller, auxiliary vessels as opposed to the large container ships and barges that 

they serve.

Marine Cargo Handling

This industry comprises establishments primarily engaged in providing stevedoring and other 

marine cargo handling services (except warehousing) (U.S. Census Bureau, 2007). This sector 

contains only a small number of vessels, as most of its business is land-based. 

This particular industry sector, along with port and harbor operations, has been growing over the 

last decades as a result of the increase in foreign trade, mostly with Asian countries. Marine cargo 

handling and port and harbor operations on the Pacific Coast account for about half of all such 

operations in the United States (Reference for Business, 2007e).

Despite the increase in volume of shipments handled, employment in marine cargo handling, as 

well as in port and harbor operations, has been on the decline in recent years, due to increased 

automation of tasks and other technological advances that reduce the need for manual labor. The 

industry’s unions, the International Longshoremen’s Association and the International Longshore 

and Warehouse Union, are nevertheless still strong and maintain high membership rates 

(Reference for Business, 2007e). Nevertheless, the decline in volume of shipments due to the 

recession undoubtedly impacted employment in these indirect industries.
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Navigational Services to Shipping and Salvage

This NAICS classification includes two main types of businesses: navigational services to 

shipping and marine salvage (U.S. Census Bureau, 2002). 

Vessels in this industry do not typically carry passengers or cargo, but rather assist larger vessels 

in entering and leaving port, or in other operations. The salvage subsector of this industry sector 

includes maintenance vessels that prepare ships for salvage and scrap.

Other Support Activities for Water Transportation

Other auxiliary services of the water transportation industry are grouped into this category, which 

includes maintenance, repair and salvaging of vessels, inspections, security, and other operations. 

In recent years, many ship repair companies have been hesitant to work on vessels due to liability 

concerns, and underwriters have been cautious of paying claims that are the result of poor 

maintenance; these uncertainties have kept the industry from expanding (Reference for Business, 

2007f). Additionally, traditional salvage jobs decreased in the 2000s, potentially due to 

environmental concerns (Reference for Business, 2007f). However, after the terrorist attacks of 

2001, there was a growth in the marine and cargo security industry (Reference for Business, 

2007f). 

3.2.3 FISHING

The fishing industry includes commercial catching or taking of finfish, shellfish, or miscellaneous 

marine products from a natural habitat, such as the catching of bluefish, eels, salmon, tuna, clams, 

crabs, lobsters, mussels, oysters, shrimp, frogs, sea urchins, and turtles (U.S. Census Bureau, 

2007a).

Since the 1990s, finfish volume has been declining, due to severely depleted fisheries in the 

Atlantic and loss of breeding grounds to pollution, as well as to increasingly strict regulations 

aimed at preventing these problems (Reference for Business, 2007a, b). Demand has not been 

strong enough to prevent declines in the value of the catches. Shellfish volume has remained 

relatively constant, with the total value of the catch increasing slightly. Fish and seafood imports 

have increased over the same period, intensifying the competition in this industry (National 

Marine Fisheries Service, 2003).

In 2009, Alaska led the nation in both volume and value of fish caught. Louisiana and Virginia 

were second and third respectively in volume of fish caught, while Massachusetts and Maine 

were second and third in terms of value of fish landings (National Marine Fisheries Service, 

2011). 

While the overall fishing industry counts over 65,000 vessels, only an estimated 4 percent of the 

commercial fishing vessels operating domestically are greater than 79 feet in length, according to 

data from MISLE (see Section 2), and are therefore covered by the VGP. 

3.2.4 MINING

The mining industry comprises establishments that extract naturally occurring mineral solids, 

such as coal and ores; liquid minerals, such as crude petroleum; and gases, such as natural gas. 

Within the mining industry, the drilling oil and gas wells sector (NAICS 213111) operates vessels 
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covered by the VGP, including 131 MODUs. This sector comprises establishments primarily 

engaged in drilling oil and gas wells for others on a contract or fee basis (U.S. Census Bureau, 

2007a). According to data provided by the IADC, the 131 MODUs covered by the VGP include 

5 drillships, 24 semi-submersible units, 5 submersible units, 40 inland barge units, and 57 jackup 

units (IADC, 2007). Note that these MODUs represent only a very small fraction of the total 

number of establishments reported overall in the drilling oil and gas wells sector, as described in 

Section 3.3.2. 

In the remainder of this report, unless otherwise noted, the term mining industry refers more 

specifically to the drilling oil and gas wells sector within the industry rather than the mining 

industry as a whole. 

3.3 RECENT TRENDS

This section reviews the recent trends in the water transportation and fishing industries in terms 

of number of firms, numbers of vessels, and financial performance. It also highlights trends in the 

drilling oil and gas wells sector of the mining industry. 

The reference period is from 2002 through 2007, the years of the two most recent Economic 

Censuses, except for the number of vessels which is measured between 2007 and 2008. 

Overall, the water transportation and fishing industries saw a decline in the number of firms and 

total revenues. In contrast, the drilling oil and gas wells sector experienced relatively strong firm, 

revenue, and employment growth. The number of vessels was generally unchanged in the most 

recent years for which statistics are available and relative to the universe of vessels that was 

considered by EPA during the development of the 2008 VGP. 

Employment, establishment, and payroll data for the Fishing Industry for 2007 are from the 

County Business Patterns dataset because the fishing industry is not included in the Economic 

Census. In cases where Fishing Industry data were not available from the Census Bureau, they 

were obtained from the Small Business Administration. 

3.3.1 NUMBER OF VESSELS BY INDUSTRY SECTOR

Table 3-2 shows changes in the number of vessels between 2000 and 2008, according to the 

WTLUS database (USACE, 2009).16 Over this period, the WTLUS database recorded a loss of 

one percent in the total number of non fishing vessels, although some vessel types (e.g., towboats, 

tank barges) saw their counts increase slightly. 

 

16 These vessel totals only include vessels in the WTLUS database, and do not encompass those vessels listed only in 

MISLE as the MISLE database was only available for one year.
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Table 3-2. Number of Vessels in the WTLUS Database, 2000-2008. 

Vessel Type 2000 2005 2007 2008

% Change

(2007-08)

Self-Propelled

Dry Cargo and/or Passenger, Offshore Support 2,780 2,967 3,001 2,985 -1%

Vehicular Ferries and Railroad Cars 292 619 604 578 -4%

Tankers 135 100 80 76 -5%

Towboats 4,995 5,290 5,356 5,424 1%

Total – Self-Propelled 8,202 8,976 9,041 9,063 0%

Non-Self-Propelled

Barges, Dry Cargo 27,342 29,107 27,162 26,652 -2%

Barges, Tanker 3,985 4,011 4,467 4,560 2%

Railroad Car Floats 33 34 25 26 4%

Subtotal-non Self-Propelled 31,360 33,152 31,654 31,238 -1%

TOTAL-Vesselsa 39,641 41,354 40,695 40,301 -1%

Source: U.S. Army Corps of Engineers, 2009.

Note: Timeseries data on the number of fishing vessels could not be found.

3.3.2 NUMBER OF ESTABLISHMENTS BY INDUSTRY SECTOR

Table 3-3 summarizes the changes in numbers of establishments for each sector of the water 

transportation, fishing, and mining industries between 2002 and 2007. The water transportation 

industry experienced a decrease of 4.1 percent in the number of establishments over this period, 

although deep sea, coastal and great lakes water transportation experienced a much greater 

decline. Conversely, inland water transportation and scenic and sightseeing transportation both 

experienced a marginal increase in the number of establishments. The mining industry also 

experienced an increase in number of establishments. 

The largest increase in the number of establishments was in coastal and Great Lakes passenger 

transportation for which Census reports a 61 percent change in the number of establishments over 

the five-year period. Inland waterways freight transportation grew 9 percent in number of 

establishments, and port and harbor operations and navigational services to shipping and salvage 

both grew by 11 to 12 percent. The fishing industry and the drilling oil and gas wells sector 

experienced 10 and 8 percent increases in the number of establishments, respectively, between 

2002 and 2007.
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Table 3-3. Number of Establishments by Industry Sector, 2002 and 2007.

NAICS Description 2002 2007 % Change

Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water Transportation

Deep Sea Freight Transportation 456 360 -21.1%

Deep Sea Passenger Transportation 87 55 -36.8%

Coastal and Great Lakes Freight Transportation 677 527 -22.2%

Coastal and Great Lakes Passenger Transportation 114 184 61.4%

Subtotal-Deep Sea, Coastal, Great Lakes 1,334 1,126 -15.6%

Inland Water Transportation

Inland Waterways Freight Transportation 321 351 9.3%

Inland Waterways Passenger Transportation 269 244 -9.3%

Subtotal Inland 590 595 0.8%

Scenic and Sightseeing Transportation

Scenic and Sightseeing Transportation, Water 1,726 1,740 0.8%

Support Activities for Water Transportation

Port and Harbor Operations 233 262 12.4%

Marine Cargo Handling 567 495 -12.7%

Navigational Services to Shipping and Salvage 778 864 11.1%

Other Support Activities for Water Transportation 924 819 -11.4%

Subtotal-Support Activities 2,502 2,440 -2.5%

TOTAL-Water Transportation 6,152 5,901 -4.1%

Fishing Industry

Fishing 1,916 2,062a 7.6%

Mining Industry

Drilling oil & gas wells sector 1,926 2,109 9.5%

Source: U.S. Census Bureau, 2002a, 2002b, 2007a, 2007b; 

a Based on reporting requirements for the data source, the number of establishments only includes 

firms with full-time employees. 

3.3.3 ESTABLISHMENT AND EMPLOYMENT BIRTHS AND DEATHS

Table 3-4 summarizes average establishment birth and death rates for each industry sector for 

which these data were available. The reference period for these trends is 2002–2007. Birth and 

death rates in the water transportation and fishing industries average between about 5 and 

15 percent of their total numbers of establishments.17 

For deep sea, costal and great lakes water transportation and support activities for water 

transportation, deaths outnumber births. However, for inland water transportation and scenic and 

sightseeing transportation births outnumber deaths. The largest average net change occurred in 

scenic and sightseeing water transportation, with an average of 28 establishment births per year. 

 

17 For the mining industry, the fraction is based on births and deaths relative to the 9,935 establishments reported in 

the 2007 Economic Census for NAICS 213 – Support activities for mining. According to the 2007 Economic Census, the 

drilling oil and gas wells sector (NAICS 213111) represented about a fifth (2,109 establishments) of the establishments 

reported in the support activities for mining sector (NAICS 213) that year.
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The fishing industry averaged a net change of eight establishment births per year between 2002 

and 2007, while the support activities for mining sector averaged a net change of over 450 births 

per year between 2002 and 2007. 

Table 3-4. Establishment Births and Deaths, Five-Year Annual Average: 2002-2007.

Industry Sector Net Change Births Deaths

Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water 

Transportation

-9.8 133.8 143.6

Inland Water Transportation 9.6 90.0 80.4

Scenic and Sightseeing Transportation, Water 27.6 192.0 164.4

Support Activities for Water Transportation -5.6 182.0 187.6

Water Transportation Industry Average 6.7 184.7 178.0

Fishing Industry

Fishing 8.0 228.8 220.8

Mining Industry

Support Activities for Mininga 458.6 1,155.6 697.0

a Data were only available for NAICS 213 (Support Activities for Mining) and were not 

available at the 6-digit NAICS level. The 2002 Economic Census reports 9,104 

establishments in NAICS 213.

Source: U.S. SBA, 2007a

Table 3-5 summarizes the net change in employment (difference between births and deaths) for 

each industry sector for which these data are available. Specific information on job creation and 

elimination was not available for many industry sectors.

All the water transportation sectors had an average net gain of jobs over the five years. Support 

activities for water transportation averaged the largest change in employment per year, with an 

average of 2,111 jobs created per year. Scenic and sightseeing transportation also averaged more 

than 1,000 jobs created per year between 2002 and 2007. Inland water transportation and deep 

sea, coastal and Great Lakes water transportation averaged net job creation rates of 573 and 510 

employees per year, respectively.

The fishing industry averaged a decline of 149 jobs per year over the same period whereas the 

support activities for mining sector (NAICS 213) averaged an increase of nearly 33,115 jobs per 

year. According to the 2007 Economic Census, the drilling oil and gas wells sector (NAICS 

213111) accounts for a little under a third of the paid employees reported overall in the support 

activities for mining sector (NAICS 213) (106,859 paid employees as compared to 368,613 paid 

employees).
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Table 3-5. Net Change in Employment: Five-Year Annual Average, 2002-2007.

Industry Sector Net Change

Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water Transportation 509.8

Inland Water Transportation 573.2

Scenic and Sightseeing Transportation, Water 1,058.8

Support Activities for Water Transportation 2,111.6

Water Transportation Industry Average 983.9

Fishing Industry

Fishing -149.2

Mining Industry

Support Activities for Mininga 33,115.0

a Data were only available for NAICS 213 (Support Activities for Mining) and were not 

available at the 6-digit NAICS level. The 2002 Economic Census reports 9,104 

establishments in NAICS 213.

Source: U.S. SBA, 2007a

3.3.4 FINANCIAL PERFORMANCE 

Table 3-6 presents changes in revenue or receipts by industry, in constant dollars. Overall, the 

water transportation industry experienced robust growth of 22 percent over the period 2002–

2007, which is more robust than the overall U.S. economy’s growth of 15 percent during this 

period (U.S. BEA, 2011b). There was significant variability in the performance of the various 

industry sectors, with revenues increasing 106 percent in inland water transportation and 20 

percent in deep sea, coastal and Great Lakes water transportation sectors. Port and harbor 

operations saw a 27 percent decline in revenue, while navigational services to shipping and 

salvage had a 25 percent increase in revenue over the same period. Coastal and Great Lakes 

passenger transportation and inland waterways freight transportation saw huge growth, with 

revenues increasing over 100 percent. 

The drilling oil and gas wells sector experienced an increase of almost 115 percent over the same 

period. 

No revenue data were available for the fishing industry in 2007. Instead EPA found data on total 

value of commercial fish landings in 2007 and used these data as proxy for revenues. Other 

industry data—employment, payroll—are from the U.S. Small Business Administration and the 

Census’ County Business Patterns dataset because fishing is not included in the Economic 

Census. 
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Table 3-6: Revenues by Industry Sector, 2002 and 2007.

Industry Sector 2002

($ millions)a

2007

($ millions)

Percent 

Change

Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water Transportation $23,778 $28,513 19.9%

Inland Water Transportation $2,873 $5,934 106.5%

Scenic and Sightseeing Transportation, Water $1,111 $1,271 14.4%

Support Activities for Water Transportation $11,296 $12,128 7.4%

TOTAL-Water Transportation $39,058 $47,845 22.5%

Fishing Industry

Fishing b $3,646 $4,199 15.2%

Mining Industry

Drilling oil & gas wells sector $10,450 $22,512 115.4%

Source: U.S. Census Bureau, 2002b, 2007a; U.S. SBA, 2002b; NOAA, 2011a 

a 2002 Economic Census revenue data updated to $2007 by using Consumer Price Index (CPI) deflator (US BLS, 

2011). All data are in 2007 dollars. 

b No revenue data are available for the commercial fishing industry in the Economic Census 2007. The 2007 value of 

fish landing is used as a proxy of revenue for that industry. For consistency, revenues for 2002 are also based on the 

value of fish landing. 

3.4 INDUSTRY MARKET STRUCTURE

The water transportation and fishing industries, and the drilling oil and gas wells segment of the 

mining industry are comprised of a large number of small businesses, whether classified by 

employment size or by annual revenues. The vast majorities of firms in these industries employ 

fewer than 100 people and earn revenues of less than $1 million per year. 

This large concentration of small firms earning relatively low amounts of revenue may make the 

water transportation and fishing industries, and the drilling oil and gas wells segment of the 

mining industry more sensitive to changes in operating costs. 

3.4.1 FIRMS AND REVENUES

Table 3-7 details the number of firms and revenues by employment size in 2007. Firms not 

operating the entire year do not report employment data, and are classified under “NR” in the 

table. 

In the water transportation industry, 59 percent of firms employ fewer than 20 people, though 

these firms only account for 13 percent of the industry’s revenue. Large firms employing more 

than 500 people, on the other hand, account for only 2 percent of businesses in the industry, but 

earn a similar share (13 percent) of its revenue.

In the fishing industry, the vast majority of firms (98 percent) employ fewer than 20 people. Less 

than 0.1 percent of fishing firms employ over 500 people. The share of small firms may be even 

greater, however, since nonemployer statistics suggest that firms without employees outnumber 

those with at least one paid employee by a ratio of over 30 to 1 (about 65,000 compared to 2,000). 

The drilling oil and gas wells sector also contains a larger percentage of firms employing fewer 

than 20 people (72 percent), and these firms account for only a small share of total industry 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 28

revenue (11 percent). The large firms in this sector account for approximately 2 percent of total 

firms, but earn half of the sector’s revenue. 
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Table 3-7. Firms and Revenues by Employment Size, 2007.

Number of Firms Revenues ($1,000) 2

Number of Employees 1-19 20-99 100-499 500+ NR1 1-19 20-99 100-499 500+ NR

Water Transportation

Deep Sea, Coastal, Great Lakes Water Transportation

Deep Sea Freight Transportation 125 31 27 5 29 509,454 806,482 3,443,618 1,495,150 37,871

Deep Sea Passenger Transportation 30 3 5 3 7 29,514 - 918,024 11,363,598 1,114

Coastal and Great Lakes Freight Transportation 223 73 40 8 49 696,938 1,139,877 3,565,401 2,787,529 90,748

Coastal and Great Lakes Passenger Transportation 90 27 5 1 41 60,623 255,766 96,847 - 33,615

Inland Water Transportation

Inland Waterways Freight Transportation 175 55 29 5 52 185912 537,463 1,894,812 1,475,344 70,925

Inland Waterways Passenger Transportation 147 23 6 0 57 96,531 139,284 127,179 D 19,888

Scenic and Sightseeing Transportation, Water

Scenic and Sightseeing Transportation, Water 933 103 8 2 656 410,068 378,698 D D 217,917

Support Activities for Water Transportation

Port and Harbor Operations 150 38 8 1 23 235,284 236,246 288,638 D 16,305

Marine Cargo Handling 129 74 40 19 27 193,590 1,129,606 1,000,772 3,888,876 33,727

Navigational Services to Shipping and Salvage 523 91 24 2 104 541,853 917,516 431,609 D 59,809

Other Support Activities for Water Transportation 534 123 29 45 88 85,910 175,465 101,170 D 21,668

TOTAL-Water Transportation 3,059 641 221 91 1,133 3,045,677 5,716,403 11,868,070 3,045,677 603,587

Percentage of Industry 59% 12% 4% 2% 22% 13% 24% 49% 13% 2%

Fishing

Fishing4 2,002 37 11 3 -- -- -- -- -- --

Percentage of Industry 98% 2% 0.5% 0% -- -- -- -- -- --

Mining 

Drilling oil & gas wells sector5 1,084 178 44 34 164 554,065 957,281 995,244 2,543,388 36,798

Percentage of Sector 72% 12% 3% 2% 11% 11% 19% 20% 50% 1%

Source: U.S. Census Bureau, 2007; U.S. SBA, 2007b

Notes: 1. NR = Firms that do not report revenue or employment data because they do not operate the entire year. 2. Revenue data are not complete; some revenue data was not included in 

data set due to disclosure concerns. 3. D = data withheld to avoid disclosing data for individual companies. 4. Data only include firms with employees, which represent only a small subset of 

fishing industry establishments. 5. Revenue data for NAICS code 213111 taken from “total value of shipments and receipts for services” representing gross sales.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

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Table 3-8 details the number of firms according to annual revenue in each sector of the water 

transportation, fishing, and mining industries. In the water transportation industry, firms earning 

less than $1 million per year account for 60 percent of the industry’s firms, and firms earning 

between $1 and $5 million account for another 23 percent. A large majority (83 percent) of firms 

earn revenues less than $5 million.

Table 3-8. Number of Firms According to Revenue Size, 2007.

Number of Firms

Revenues (millions of dollars) <1a 1-5 5-25 25-100 100+

Water Transportation

Deep Sea, Coastal, Great Lakes Water Transp.

Deep Sea Freight Transportation 65 45 35 25 18

Deep Sea Passenger Transportation 23 5 3 3 7

Coastal and Great Lakes Freight Transportation 126 103 60 30 25

Coastal and Great Lakes Passenger Transportation 71 28 19 5 -

Subtotal-Deep Sea, Coastal, Great Lakes 285 181 117 63 50

Inland Water Transportation

Inland Waterways Freight Transportation 104 87 43 18 12

Inland Waterways Passenger Transportation 124 33 16 3 -

Subtotal Inland 228 120 59 21 12

Scenic and Sightseeing Transportation, Water

Scenic and Sightseeing Transportation, Water 834 178 31 3 0

Support Activities for Water Transportation

Port and Harbor Operations 86 81 22 6 2

Marine Cargo Handling 76 77 69 28 12

Navigational Services to Shipping and Salvage 403 142 67 23 5

Other Support Activities for Water Transportation 446 126 46 7 1

Subtotal-Support Activities 1,011 426 204 64 20

TOTAL-Water Transportation 2,358 905 411 151 82

Percentage of Industry 60% 23% 11% 4% 2%

Fishing

Fishing4 1,773 217 47 11 5

Percentage of Industry 86% 11% 2% 1% 0%

Mining Industry

Drilling oil & gas wells sector5 1,396 310 225 78 50

Percentage of Sector 68% 15% 11% 4% 2%

Source: U.S. Census Bureau 2007b

a The Economic Census breaks down this category further into firms with revenue less than $100,000; $100,000 to 

$249,999; $250,000 to $499,999; and $500,000 to $999,999. 

ND: No data available on distribution of establishments by revenue size

3.4.2 REVENUE BY VESSEL

Data on revenue by vessel are not generally published in national-level data sets. Some statistics 

are available from public sources, however, regarding per vessel revenue to commercial 

fishermen in different regions by type of catch or operational configuration. For example, data for 

California salmon and Dungeness crab fisheries suggest average revenue per vessel ranging from 

$23,142 for small vessels to $75,715 for medium and large vessels ($25,031 to $81,897 in 2010 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 31

dollars) (Hackett and Hansen, 2008). Permit data for Alaska fisheries show similarly wide 

variability in average revenue per active permit, with larger vessels (60 feet or greater in length) 

having higher revenue than smaller vessels. Average revenues for 2010 ranged from less than 

$2,000 for the lower quartile of permits holders for halibut fishing by hand troll, to nearly 

$2.5 million for the upper quartile of permits holders for king crab fishing (Alaska Commercial 

Fisheries Entry Commission, 2011). Within each type of Alaskan fishery (catch, type of 

equipment, or region), the ratios of revenues earned by the top quartile permit holders and those 

earned by the bottom quartile permit holders can be as high as twenty to one. Revenue to 

Northeast fishermen using vessels 75 feet and above averaged $790,779 per vessel in 2010 

(NOAA, 2011b). The commercial fishing vessels covered by the 2013 VGP are those greater than 

79 feet. 

Historical data of per vessel revenue for other industry sectors are available from trade 

publications and industry analysts. For example, Clarkson’s ClarkSea Index represents weighted 

average shipping rates across vessel types for oil tankers (VLCC, Suezmax, Aframax and clean 

product carriers), dry bulk carriers (Capesize, Panamax, Handymax and Handysize, gas carriers 

(VLGC) and fully cellular containerships. The index provides an indicator of earnings for 

principal commercial vessel types. The average index value in 2010 was $15,179 per day per 

voyage. Historical daily charter rates for the period of 1980-2000 ranged between $5,000 and 

$22,500 per day (Kite-Powell (2001), cited in USCG (2008),

18 Rates reported in 2006 were about 

twice these 20-year average values, ranging from $17,000 to $37,500 per day (USCG, 2008). 

3.4.3 SMALL BUSINESSES

The U.S. Small Business Administration (SBA) defines small businesses for the various sectors 

of these industries as follows (U.S. SBA, 2010): 

 Deep sea, coastal, and Great Lakes water transportation; inland water transportation – 

fewer than 500 employees

 Scenic and sightseeing transportation; navigational services to shipping and salvage; 

other support activities for water transportation – revenues less than $7 million 

 Port and harbor operations; marine cargo handling – revenues less than $25.5 million 

 Fishing – revenues less than $4 million 

 Drilling oil and gas wells sector – fewer than 500 employees.

Table 3-9 summarizes the number of small businesses in each sector of the water transportation, 

fishing, and mining industries. On the whole, all major industries consist of at least 85 percent 

small businesses. Inland waterways passenger transportation and coastal and Great Lakes 

passenger transportation have the highest percentage small businesses with 99 to 100 percent 

small businesses.

These percentages were calculated based on the number of firms operating the entire year, as 

employment figures are not available for firms operating only part of the year.

 

18 The dollar year is not specified. 
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Table 3-9: Small Businesses by Industry Sector.

Industry Sector Small Business 

Threshold

Firms 

Operated 

Entire Year

Small 

Businesses

Percent 

Small 

Business

Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water Transp.

Deep Sea Freight Transportation 500 Employees 188 183 97.3%

Deep Sea Passenger Transportation 500 Employees 41 38 92.7%

Coastal and Great Lakes Freight Transportation 500 Employees 344 336 97.7%

Coastal and Great Lakes Passenger Transportation 500 Employees 123 122 99.2%

Subtotal-Deep Sea, Coastal, and Great Lakes 696 679 97.6%

Inland Water Transportation

Inland Waterways Freight Transportation 500 Employees 264 259 98.1%

Inland Waterways Passenger Transportation 500 Employees 176 176 100.0%

Subtotal-Inland 440 435 98.9%

Scenic and Sightseeing Transportation, Water

Scenic and Sightseeing Transportation, Water $7 million 1,046 1,020 97.5%

Support Activities for Water Transportation

Port and Harbor Operations $25.5 million 197 189 95.9%

Marine Cargo Handling $25.5 million 262 222 84.7%

Navigational Services to Shipping and Salvage $7 million 640 560 87.5%

Other Support Activities for Water Transportation $7 million 626 581 92.8%

Subtotal-Support Activities 1,725 1,511 87.6%

TOTAL-Water Transportation 3,907 3,645 93.3%

Fishing Industry

Fishing a $4 million 1,916 1,843 96.2%

Mining Industry

Drilling oil & gas wells sector 500 Employees 2,109 1,893 89.8%

Source: U.S. Census Bureau, 2007

a Includes only employer firms. Nonemployer statistics suggest that the vast majority of firms in the fishing industry earn 

significantly less than $4 million annually.

3.4.4 EMPLOYMENT AND PAYROLL

Employment in the water transportation increased by seven percent while employment in the 

fishing industries declined by 14 percent over the period between 2002 and 2007 (Table 3-10).

However, payroll in both industries increased despite the decline in fishing employment numbers. 

In fact, almost all sectors within the water transportation industry saw an increase in payroll 

coastal including Great Lakes freight transportation which had a decrease in employment (Table 

3-11). Employment and payroll in the drilling oil and gas wells sector increased by 76 percent 

and 108 percent, respectively, over the same period. 

Note that these figures, and those discussed in the rest of this section, reflect the detailed data 

available from the most recent Economic Census. They do not capture the impact of the 

subsequent recession which likely reduced employment and payroll in these sectors, as in many 

other sectors of the U.S. economy. 
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TOTAL NUMBER OF EMPLOYEES BY INDUSTRY SECTOR

In 2007, the water transportation industry employed about 157,000 people. Over 40 percent of 

these people were employed by businesses providing support activities for water transportation. 

Another third worked in the deep sea, coastal, and Great Lakes water transportation sector, with 

the remaining 20 percent being split between inland water transportation and scenic and 

sightseeing transportation on water. The fishing industry employed about 5,600 people in 2007, 

while the drilling oil and gas wells employed over 106,000 people. 

Overall, the water transportation industry saw a 7.3 percent increase in its number of employees 

between 2002 and 2007. The drilling oil and gas wells sector saw a large (77 percent) increase in 

employment. The only industry to experience a decline was the fishing industry which had a 14.3 

percent decline in employment. Overall, the U.S. unemployment rate decreased from 6.0 percent 

to 5.0 percent between 2002 and 2007 (U.S. BLS, 2011).19

Deep, sea passenger transportation, coastal and Great Lakes passenger transportation, inland 

waterways freight transportation all experienced large increases in employment, growing by 

40 percent or more. These industries also experienced strong growth in revenue, in some cases 

increasing by over 100 percent from 2002 to 2007. Deep sea freight transportation and inland 

waterways passenger transportation, other support activities for water transportation and fishing 

industry had the largest decreases in employment, declining by about 14 percent. All these 

industries – except for fishing – also experienced declines in revenue, ranging anywhere from 6 to 

almost 10 percent. 

 

19 Note that these statistics represent changes between 2002 and 2007, the latest year for which detailed Economic 

Census data are available. The data pre-date the recession and therefore do not reflect the subsequent drop in overall 

employment across most sectors of the U.S. economy.
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Table 3-10. Employment by Industry Sector, 2002-2007.

NAICS Description

2002 

Number of 

Employees

2007

Number of 

Employees % Change

Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water Transportation

Deep Sea Freight Transportation 13,083 11,896 -13.8%

Deep Sea Passenger Transportation 11.491 18,210 58.5%

Coastal and Great Lakes Freight Transportation 24,333 22,989 -5.5%

Coastal and Great Lakes Passenger Transportation 2,382 3,303 38.7%

Subtotal-Deep Sea, Coastal, Great Lakes 52,009 56,389 8.4%

Inland Water Transportation

Inland Waterways Freight Transportation 10,040 16,775 67.1%

Inland Waterways Passenger Transportation 3,277 2,824 -13.8%

Subtotal Inland 13,317 19,599 47.2%

Scenic and Sightseeing Transportation

Scenic and Sightseeing Transportation, Water 11,557 12,692 9.8%

Support Activities for Water Transportation

Port and Harbor Operations 5,593 5,987 7.0%

Marine Cargo Handling 37,707 37,358 -0.9%

Navigational Services to Shipping and Salvage 13,157 13,538 2.9%

Other Support Activities for Water Transportation 13,112 11,513 -12.2%

Subtotal-Support Activities 69,569 68,396 -1.7%

TOTAL-Water Transportation 146,452 157,085 7.3%

Fishing Industry

Fishing 6,537 5,600 -14.3%

Mining Industry

Drilling oil & gas wells sector 60,450 106,859 76.8%

Source: U.S. Census Bureau, 2002a, 2002b, 2007a, 2007b

 

PAYROLL BY INDUSTRY SECTOR

The 7 percent increase in employment in the water transportation industry as a whole was 

accompanied by an 18 percent increase in payroll from 2002 to 2007 (Table 3-11). Large

increases were seen in deep sea passenger transportation and inland waterways freight

transportation which also had large gains in employment. Within the water transportation 

industry, only inland waterways passenger transportation and other support activities for water 

transportation had decreases in payroll. These sectors both had some of the largest decreases in 

employment as well.

The fishing industry’s payroll rose by about 4 percent, despite a relatively large 14 percent 

decrease in its employment base.

The payroll for drilling oil and gas sector increased substantially (over 100 percent), reflecting a 

76 percent increase in employment in that sector.
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Table 3-11. Payroll by Industry Sector, 2002-2007.

NAICS Description

2002 Annual 

Payroll 

($millions)a

2007 Annual 

Payroll 

($millions) % Change

Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water Transportation

Deep Sea Freight Transportation 847 847 0.0%

Deep Sea Passenger Transportation 513 838 63.4%

Coastal and Great Lakes Freight Transportation 1,370 1,667 21.7%

Coastal and Great Lakes Passenger Transportation 80 135 68.9%

Subtotal-Deep Sea, Coastal, Great Lakes 2,809 3,486 24.1%

Inland Water Transportation

Inland Waterways Freight Transportation 555 947 70.5%

Inland Waterways Passenger Transportation 130 112 -13.9%

Subtotal Inland 685 1,059 54.5%

Scenic and Sightseeing Transportation

Scenic and Sightseeing Transportation, Water 307 350 13.8%

Support Activities for Water Transportation

Port and Harbor Operations 281 289 3.1%

Marine Cargo Handling 1,674 1,741 4.0%

Navigational Services to Shipping and Salvage 665 796 19.6%

Other Support Activities for Water Transportation 566 513 -9.5%

Subtotal-Support Activities 3,186 3,338 4.8%

TOTAL-Water Transportation 6,987 8,233 17.8%

Fishing Industry

Fishing 291 302 3.8%

Mining Industry

Drilling oil & gas wells sector 2,871 5,984 108.4%

Source: U.S. Census Bureau, 2002a, 2002b, 2007; U.S. SBA, 2007b

a 2002 Economic Census revenue data updated to $2007 by using Consumer Price Index (CPI) deflator (US BLS, 

2011). All data in $2007.
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4 COST OF BEST MANAGEMENT PRACTICES

The first step in assessing costs of the revised VGP permitting requirements consists of 

determining the population of vessels that will be affected by the Permit. As detailed in Section

2.1: Domestic Vessel Population the total population of domestic vessels is 58,602, and the total 

population of foreign vessels is 12,429. Permit requirements for discharges incidental to the 

normal operation of a vessel will impact virtually every non-military, non-recreational vessel 79 

feet or greater used in a capacity of transportation and entering U.S. territorial waters. However, 

some vessels will implement only a subset of practices because certain discharges are not 

applicable to all vessel types. For example, practices associated with graywater discharges are not 

applicable to barges since this vessel class does not produce this type of discharge. Practices 

associated with aqueous film-forming foam (AFFF) discharges are only applicable to some utility 

vessels and to freight and tank ships since other vessel classes do not have a firefighting system.

Practices applicable to ballast water management systems are only applicable to the subset of 

vessels equipped with ballast water tanks. Further, this analysis is concerned exclusively with the 

incremental costs (positive or negative) associated with revisions to the 2008 VGP requirements. 

Revisions that have the potential to result in incremental costs consist of (1) changes in the 

universe of vessels covered by the VGP and (2) changes in the practices needing to be 

implemented by vessel owners to ensure compliance with the Permit. 

To estimate the effect of the revised Permit requirements, a baseline must be identified from 

which to measure this effect. The baseline takes into account previous conditions and determines 

how the industry would act in the future in the absence of revised Permit requirements. Given that 

this Permit is not entirely new but instead is revising an existing permit issued in 2008, the 

baseline for this analysis assumes that all vessels are in full compliance with the 2008 VGP 

requirements. Accordingly, the baseline for this analysis is full industry compliance with the 2008 

Permit as well as with existing federal and state regulations and with current industry practices or 

standards that exceed current regulations to the extent that they can be empirically observed. 

As noted above, one source of incremental cost relates to changes in the universe of vessels 

covered by the VGP. An important consideration concerns any expansion to the scope of the VGP 

to vessel categories. Vessels newly covered by the VGP would have to implement practices to 

address general categories of discharges, along with any vessel-specific requirement. As the 2013 

VGP covers all commercial fishing vessels 79 feet or greater in length (instead of only those 

commercial fishing vessels that have ballast water discharges, as was the case for the 2008 VGP), 

these vessels are newly subject to all applicable practices. Except for cases where the 

requirements have been revised as part of the 2013 VGP, the costs to owners of the commercial 

fishing vessels of implementing practices are estimated based on EPA’s analysis of the 2008 

VGP, but with unit costs restated in 2010 dollars. 

A second component of incremental cost relates to substantive changes in effluent limits and 

related requirements (applicable to all vessels or selected vessel types) or in the recordkeeping, 

monitoring, reporting, and other general requirements. EPA estimated the impact of the revised 

requirements per vessel based a review of the changes in vessel practices that may be needed to 

comply with the revised requirement, industry communications, and research of publicly 

available information. Additional cost inputs are also derived from conversations with 
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manufacturers and field experts. For each discharge category, EPA estimated the annual pervessel compliance costs based on the per-instance cost of performing each practice and the 

number of times per year the practice needs to be performed. Several discharge categories were 

not analyzed for incremental costs because (1) the industry is already implementing the practices 

specified in the 2013 VGP or (2) the expected cost of the relevant practice(s) is negligible.

Finally, the total annual cost per discharge category is estimated by multiplying the practice cost 

per vessel by the number of vessels expected to incur incremental costs due to the revised Permit 

requirements. 

The remainder of this section is organized as follows:

 Section 4.1 discusses the incremental costs of technology-based effluent limits and 

related requirements applicable to all vessels. These requirements are contained in 

Section 2.1 of the VGP.

 Section 4.2 discusses the incremental costs of practices related to effluent limits and 

requirements related to 27 discharge categories. These requirements are contained in 

Section 2.2 of the VGP.

 Section 4.3 discusses the incremental costs associated with practices applicable to 

specific vessel types. These requirements are contained in Section 5 of the VGP.

 Section 4.4 discusses the incremental costs associated with general inspection, 

monitoring, reporting, and recordkeeping requirements applicable across vessel types. 

These requirements are contained in Sections 1 and 4 of the VGP.

4.1 TECHNOLOGY-BASED EFFLUENT LIMITS AND RELATED REQUIREMENTS 

APPLICABLE TO ALL VESSELS

Part 2.1 of the VGP provides general effluent limits designed to apply to all covered vessels for 

all covered discharge types present on a particular vessel. The practices described in this section 

are broadly applicable and generally constitute common industry practices for all vessels. They 

relate to material storage, toxic and hazardous material, fuel spills and overflows, discharges of 

oil, compliance with other regulations applicable to vessel discharge, and training. With the 

exception of new general training requirements, the practices contained in the 2013 VGP are 

unchanged from the 2008 VGP. The new training requirements outlines the responsibilities of the 

vessel owner to ensure that their crew are adequately trained to implement the terms of the VGP 

and operate all pollution prevention equipment on board the vessel. The Permit does not require 

specific, formal training but instead provides flexibility to owners to integrate the necessary 

information within their existing training program and EPA expects that training on the 

applicable pollution prevention procedures is already being conducted by all vessels subject to the 

VGP. Accordingly, this requirement is not expected to represent an incremental burden on vessel 

owners. 
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4.2 EFFLUENT LIMITS AND RELATED REQUIREMENTS RELATED TO SPECIFIC 

DISCHARGE CATEGORIES 

The following analysis of practice costs (including per vessel cost and the population of vessels 

expected to incur additional costs) relies on information collected in support of the 2008 VGP 

(EPA, 2008) and additional information from manufacturers and field experts on the incremental 

costs of revised requirements. 

Several of the revised requirements involve a change in customary operating practices that 

potentially involve additional labor hours and equipment. For practices involving additional labor 

hours, EPA has used labor rates20 and hourly estimates developed as part of the 2008 VGP 

analyses, based on communication with industry representatives, outside research, and other data 

sources (see EPA, 2008). Cost estimates for additional capital and maintenance expenditures

necessary to comply with revised requirements were obtained from manufacturers of relevant 

equipment. As necessary, one-time costs are annualized using a 7 percent discount rate.

The population of vessels to which each practice applies was determined based on information 

collected in support of the 2008 VGP, EPA’s Report to Congress summarizing findings from 

analyses of discharges incidental to the operation of certain vessels (EPA, 2010b), information 

submitted to EPA in Notice of Intents (NOIs) received under the 2008 VGP, and other available 

information on common practices applied by different types of vessels. 

The following sections discuss the revised permit requirements, provides estimates of the number 

of vessels that may incur incremental costs, and summarizes the estimated costs of implementing 

the practices. The discussion follows the order of the VGP for the 27 discharge categories. For 

completeness, the discussion covers all 27 discharge categories, even those for which EPA does 

not expect incremental costs (e.g., applicable vessels are already implementing and/or the cost of 

the practice is negligible); discharge categories for which no incremental costs are expected are 

noted. 

 

20 Except where otherwise noted, the analysis uses a labor rate of $33.72 when estimating the costs of incremental 

labor hours. This rate is based on the average labor rate used in the 2008 VGP analysis, which reflects the average 

across industry sectors based on input from industry representatives (EPA, 2008). We escalated the labor rate from 

2007 to 2010 dollars using the Bureau of Labor Statistics Employment Cost Index (ECI) of 1.067.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

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4.2.1 DISCHARGES OF DECK WASHDOWN AND RUNOFF AND ABOVE WATER LINE 

HULL CLEANING

PERMIT REQUIREMENTS

The 2013 VGP requirements for discharge of deck washdown and runoff are fundamentally 

similar to the 2008 VGP requirements. The revised permit language clarifies that exposed decks 

must be broom cleaned (or comparable management measures) and all existing debris removed 

before deck washdown. 

AFFECTED VESSEL POPULATION

Based on the description of practices within this discharge category, deck washdown and runoff 

is potentially applicable to all 58,602 vessels. However, 56,276 of the vessels (all vessels with the 

exception of the newly covered commercial fishing vessels) are already covered by the 2008 VGP 

and are therefore assumed to be in compliance with the existing requirements. Therefore, only 

commercial fishing vessels will potentially incur incremental costs as a result of the requirement 

to implement these practices. 

The population potentially affected by practices applicable to the deck runoff discharge category 

is shown in Table 4-1. 

Table 4-1. Vessel Counts for Practice Applicable to Deck Runoff.

Vessel Class Total Vessel Count 

Commercial Fishing 2,326

Freight Barges 0

Freight Ships 0

Passenger Vessels 0

Tank Barges 0

Tank Ships 0

Utility Vessels 0

TOTAL 2,326

COST ESTIMATES 

Input from industry representatives on the 2008 VGP requirements suggested that deck cleanup is 

commonly performed prior to deck washdowns. Also, based on the survey responses, commercial 

fishing vessels are assumed to already practice deck cleanup as part of standard sanitary practices 

(e.g., after moving fish to the fish hold).21 

 

21 In the 2008 VGP analysis, EPA assumed that performing cleanup before a deck washdown takes significantly more 

time as compared to performing cleanup prior to departing from port. Cleanup prior to a deck washdown would 

entail moving all pieces of machinery and cargo so as to clean the entire deck. However, cleanup prior to departing 

from port would only require clearing loose items from the deck. Survey responses indicated a wide range of cleanup 

time necessary prior to conducting a deck washdown: from 1 to 6 hours. EPA estimated that it would take 30 minutes 

to perform cleanup prior to departing from port. (see EPA, 2008)
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

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Industry input provided on the 2008 VGP also indicated that it is common for all vessels to have 

drip pans installed for every piece of machinery on deck. The VGP requires that drip pans be 

onboard the vessel, if feasible, to collect any oily water from machinery and prevent spills. If 

vessels have drip pans, it is common practice for vessels to perform regular drip pan cleaning 

and/or draining. However, to capture potential costs to older vessels where such pans are not 

already provided, EPA performed a sensitivity analysis to examine the potential cost to older 

commercial fishing vessels that may have to install drip pans and for those that may need to 

perform cleaning and/or draining.

To evaluate whether the use of phosphate-free cleaners have the potential to impose incremental 

costs on vessel owners, EPA gathered information on the cost difference between “green” and 

conventional cleaning products; in particular the cost of phosphate-free and safer/clean products 

that carry third-party certification, compared to the cost of conventional cleaning products 

without such third-party certification. EPA found that there was no systematic cost difference 

between soaps certified by third parties as more “environmentally friendly” and conventional 

products; in fact, the certified “green products” were often less expensive. Based on a review of 

retail prices for 32 unique boat soaps , EPA found that the average per-unit cost of certified 

cleaners ($20.27/gallon) was slightly less than the average per-unit cost of non-certified, 

conventional cleaners ($20.98/gallon) (prices taken from West Marine, Jamestown Distributors, 

Amazon.com and Greenboatstuff.com). Based on these findings, EPA assumes that the VGP 

requirement to use non-toxic, phosphate-free cleaners does not result in an incremental cost. 

SENSITIVITY ANALYSIS

The cost input values are shown in Table 4-2, and the estimates/assumptions derived for each 

practice are described below.

Table 4-2. Per-Vessel Costs for Practices Associated with Deck Runoff

Practice Labor Hours Unit Cost Cost Description

Performing deck cleanup prior to 

departing from port

0.5 $16.86a Per Instance

Draining and/or wiping and cleaning 

the drip pans or coamings

1.5 $50.58a Per Instance

Drip pan waste disposal N/A $441.98 Per Instance

Installing drip pans or coamings for 

every piece of machinery on deck

N/A $178.09 Annualized cost of a Onetime Installation

a Unit cost is estimated by multiplying the labor hours by the average hourly labor rate of $33.72. 

b Includes cost of $442 per instance to dispose of drip pan waste.

Deck Cleanup

 Average Labor Hours: EPA has taken the median of 3.5 hours to estimate the time it 

would take to perform deck cleanup prior to conducting a deck washdown. However, the 

time requirement to perform cleanup prior to departing from port is assumed to be 

significantly less: around 30 minutes. 

 Average Labor Rate: An average labor rate of $33.72 was used. Note that this is greater 

than the average wage for workers in the commercial fishing industry (based on BLS data 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 41

for from BLS Occupational and Employment Statistics for code 45-3011 “Fishers and 

Related Fishing Workers”) and may therefore overstate the cost of this practice.

 Annual Number of Instances: The number of times that a commercial fishing vessel 

departs from port is assumed to range from 3 to 6 times per month or more, with an 

assumed average of 4.5 times per month or 54 times per year. This is based on an average 

length of fishing trips of 5 to 8 days and is consistent with data from Northeast fisheries 

that show average trip durations of 7.9 days for groundfish trips and 4.7 days for nongroundfish trips (NOAA, 2011b). 

 Baseline: Based on industry input during the development of the 2008 VGP, EPA 

assumes that deck cleanup is currently conducted prior to departing from port by all 

commercial fishing vessels. 

Drip Pan Cleaning

 Average Labor Hours: Industry input on the 2008 VGP provided an estimate of 1 to 2 

hours required per instance of cleaning, or 1.5 hours on average. 

 Average Labor Rate: A labor rate of $33.72 was assumed. 

 Additional Cost: EPA assumes an average cost of $442 per drip pan waste disposal, 

consistent with the cost estimate developed in support of the 2008 VGP (in 2008 dollars, 

the average costs are $400 with a range of $200 to $1,200 per instance). 

 Annual Number of Instances: The number of times that a vessel cleans and/or drains its 

drip pans ranges from 1 to 4 times per month. Given the fact that commercial fishing 

vessels often only operate part of the year, EPA estimated an average of once per month

or 12 times per year.

 Baseline: For the low end estimate, EPA assumes that drip pan cleaning is currently 

practiced 100 percent of the time (or does not apply). For the high end estimate, EPA 

assumes that cleaning is currently practiced 99 percent of the time (or does not apply). 

Installation of Drip Pans/Coamings

 One-time Installation Cost: The 2008 VGP analysis assumed an average one-time cost 

per installation estimate for all machinery on deck of $ $2,000 in 2008 dollars ($2,210 in 

2010 dollars). Annualized over 30 years at a 7 percent discount rate, the cost is $178.09. 

 Baseline: For the low end estimate, EPA assumes that 100 percent of commercial fishing 

vessels already have drip pans/coamings installed (or does not apply). For the high end, 

EPA assumes that 99 percent of vessels already have drip pans/coamings installed or the 

requirement does not apply. EPA is assuming that older vessels may need to install drip 

pans. Thus, the remaining 1 percent of vessels may incur this incremental cost.

The cost per commercial fishing vessel for each practice and the total cost associated with all 

commercial fishing vessels are presented in Table 4-3. As presented in the table, the total annual 

incremental costs estimated across the population of commercial fishing vessels newly subject to 

the permit requirements ranges from $0 to $160,593. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 42

Table 4-3. Deck Runoff Sensitivity Analysis.

Practice and Vessel Class Vessel Count

% Vessels 

Assumed to Incur 

Incremental Cost

Annual Cost 

per Vessela,b

Total Annual 

Cost

Low End Estimate

Deck Cleanup 2,326 0% $0.00 $0

Drip Pan Cleaning 2,326 0% $0.00 $0

Installation of Drip Pans/Coamings 2,326 0% $0.00 $0

Low End Total $0

High End Estimate

Deck Cleanup 2,326 0% $0.00 $0

Drip Pan Cleaning 2,326 1% $59.11 $137,484

Installation of Drip Pans/Coamings 2,326 1% $178.09 $4,142

High End TOTAL $141,627

a Drip pan cleaning is assumed to occur 99% or 100% of the time (high and low end estimates, respectively).

b Cost for the installation of drip pans/coamings is annualized at a 7 percent discount rate over 30 years.

4.2.2 DISCHARGES OF BILGE WATER

The VGP reinforces several of the requirements of the Act to Prevent Pollution from Ships 

(APPS), the U.S. implementation of the 1973/78 International Convention for the Prevention of 

Marine Pollution from Ships (MARPOL), regarding discharges of oily bilge water. Additionally, 

the VGP prohibits the discharge of bilge water by vessels weighing more than 400 tons within 

1 nm of shore except during emergencies. These Permit requirements complement current 

requirements found in the USCG regulations governing Oily Mixture (Bilge Slops) Discharges on 

Oceangoing Ships Over 400 Tons, implemented under the authority of APPS and last amended in 

1999. These regulations require the use of oily-water separators on discharges of bilge water by 

vessels larger than 400 tons (33 CFR 155). 

VGP requirements consistent with APPS do not impose any additional costs on subject operators. 

EPA is considering authorizing the discharge of bilge water by vessels weighing more than 400 

tons within 1 nm of shore if the discharge meets specified requirements. The requirements would 

include the following three conditions: The discharge must have an oil content at or below 5 ppm; 

the vessel must be equipped with an oily-water bilge alarm that is capable of detecting to 5 ppm; 

and the vessel’s oil discharge monitoring system must meet the monitoring conditions found in 

Part 2.2.2.1.1 of the permit. EPA is seeking comments on this option; it is not currently included 

in the proposed 2013 VGP. 

Accordingly, the cost of this option is not included in the cost of the proposed 2013 VGP. 

EPA nonetheless estimated the potential cost, were EPA to finalize the 2013 VGP to authorize the 

discharge of treated bilgewater meeting specified criteria, of the practice. These costs are 

discussed below.

DESCRIPTION OF PERMIT OPTION

The 2013 VGP bilge water permit requirements build upon the 2008 VGP requirements by 

retaining general practices related to the minimization of bilge water discharges. In addition, 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 43

however, EPA is seeking comments on an option to authorize the discharge of treated bilge water

by certain vessels greater than 400 tons provided that vessels utilize an oil discharge monitoring 

system and an overboard discharge control unit and alarm, and also perform maintenance, 

monitoring, and sampling according to a specified schedule. Thus, if EPA were to finalize the 

option, the revised permit requirements would stipulate that existing vessels greater than 400 

gross tons for which holding the bilge water is not technically feasible and all new vessels 

(constructed on or after December 19, 2013) greater than 400 gross tons may discharge bilge 

water in waters subject to this permit if they meet specified conditions on which EPA is seeking 

comments. 

Potential Permit Text (Excerpt): 

Vessels subject to this Part may discharge treated bilgewater only if their discharge meets the 

following conditions: 

 The oil content of that discharge must be at or below 5 ppm. 

 The vessel must be equipped with an oily-water bilge alarm that is capable of detecting to 

5 ppm. This alarm must prevent the discharge of any bilgewater with an oil content of 

greater than 5 ppm 

The vessel’s oil discharge monitoring system must meet the monitoring conditions found in Part 

2.2.2.1.1 of this permit. 

Bilgewater Monitoring 

All vessels to which Part 2.2.2.1 applies (see above) must be equipped with an oil discharge 

monitoring system that monitors the discharge of oily bilge water into waters subject to this 

permit. These vessels must also be equipped with an overboard discharge control unit that 

automatically initiates the sequence to stop the overboard discharge of the effluent in alarm 

conditions and prevents the discharge throughout the period the alarm condition prevails. The 

overboard discharge control unit must be designed to receive automatic signals of oil content of 

the effluent, measured as ppm, from the oil content meter. 

Each oil content meter and each control section of an oil discharge monitoring system must be 

subjected to a functional test that includes the operations listed in 33 CFR § 157.12f and is 

conducted as outlined in 46 CFR § subpart 162.050 on a suitable test bench prior to delivery. The 

detailed program for a functional test of such equipment must be developed by the manufacturer, 

taking into account the features and functions of the specific design of equipment and the types of 

oils that will be monitored. A completed workshop certificate, including the delivery functional 

test protocol, must be received with each unit delivered. A copy of the certificate must be carried 

aboard the vessel at all times. 

Routine maintenance of the monitoring system and troubleshooting procedures must be clearly 

defined in the oil discharge monitoring system’s Operating and Maintenance Manual kept 

onboard the vessel. All maintenance activities related to the bilge water monitoring system and 

overboard discharge control unit must be recorded and the information must remain on board for 

inspection purposes. In addition, vessel staff training must include familiarization with the 

operation and maintenance of the bilgewater overboard discharge control and oil discharge 

monitoring equipment. 

Initial Analytical Monitoring
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 44

To demonstrate the effectiveness of the oil discharge monitoring system, the vessel 

owner/operator must take at least five (5) samples from the vessel on different days over a 90-day 

period that are representative of the treated effluent to be discharged. A vessel which has an oil 

discharge monitoring system that has been type approved by any flag administration to a 5 ppm 

standard and has an alarm which prevents the discharge of any bilgewater with an oil content of 

greater than 5 ppm may instead immediately commence maintenance monitoring. 

Initial monitoring must be done within the first 120 days of permit coverage (or before), within 90 

days of oil discharge monitoring system installation onboard the vessel, or before the vessel 

discharges into waters subject to this permit, whichever is later. Samples will be analyzed for oil 

by Method ISO 9377-2 (2000) Water Quality–Determination of hydrocarbon oil index–Part 2: 

Method Using Solvent Extraction and Gas Chromatography (incorporation by reference, see 46 

CFR § 162.050–4) or EPA Method 1664. If the measured samples meet the 5 ppm standard 

specified in Part 2.2.2.1, then the vessel owner/operator has demonstrated the effectiveness of 

their oil discharge monitoring system for controlling their bilgewater discharge. Records of the 

sampling and testing results must be retained onboard for a period of 3 years in the vessel’s 

recordkeeping documentation. Records of monitoring information shall include: 

 The date, exact place, and time of sampling or measurements; 

 The individual(s) who performed the sampling or measurements; 

 The date(s) analyses were performed;

 The individual(s) and laboratory(ies) who performed the analyses; 

 The analytical techniques or methods used; and 

 The results of such analyses.

Maintenance Analytical Monitoring 

Annually, vessels to which Part 2.2.2.1 applies must collect a sample of the bilgewater effluent 

for analysis of oil by Method ISO 9377-2 (2000) Water Quality–Determination of hydrocarbon 

oil index–Part 2: Method Using Solvent Extraction and Gas Chromatography (incorporation by 

reference, see 46 CFR § 162.050–4) or EPA Method 1664 to demonstrate treatment equipment 

maintenance and compliance with this permit. At the time of sample collection, the reading on the 

oil content meter will be recorded so the oil concentration measured by the laboratory can be 

compared to the oil content meter. If there is a difference between the laboratory result and the 

oil content meter that is greater than 100 percent, then the vessel must recalibrate the oil content 

meter. Alternatively, vessels can annually detach the oil content meter and send the meter to the 

manufacturer for service and calibration. Following manufacturer service and calibration, the 

meter must be reattached to the bilgewater effluent monitoring location. While the oil content 

meter is being serviced by the manufacturer, the vessel cannot discharge bilgewater effluent 

under the conditions in Part 2.2.2.1. 

In addition, an annual test of the oil discharge monitoring system alarm functions and the 

electronic-valve switching function must also be performed onboard the vessel to verify they will 

activate when the oil concentration measured by the oil content meter is greater than 5 ppm. 

Records of the sampling and testing results must be retained onboard for a period of 3 years in 

the vessel’s recordkeeping documentation. Records of monitoring information shall include:
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 45

 The date, exact place, and time of sampling or measurements, and any meter 

recalibration;

 The individual(s) who performed the sampling or measurements, and any meter 

recalibration;

 The date(s) analyses and any meter recalibration were performed;

 The individual(s) who performed the analyses and any meter recalibration;

 The techniques or methods used for sample analyses and any meter recalibration; and 

 The results of such analyses and any meter recalibration.

Monitoring Reporting 

The vessel owner/operator must submit data showing that the bilgewater standards are achieved 

by their oil discharge monitoring system to EPA’s e-reporting system, unless they meet one of the 

exceptions to electronic reporting found in Part 1.14 of this permit. Monitoring data must be 

submitted at least once per calendar year no later than February 28 of the year after the data are 

collected. Data may be submitted as part of the vessel’s annual report. 

Current regulation of oily bilge water discharges from vessels is based on Annex I of the 

International Convention for the Prevention of Pollution From Ships, 1973 as modified by the 

Protocol of 1978 (MARPOL 73/78). Under MARPOL, all ships over 400 gross tons are required 

to have equipment installed onboard that limits the discharge of oil into the oceans to 15 ppm 

when a ship is en route. All vessels over 400 GT are also required to have an oil content monitor 

(OCM), including a bilge alarm, integrated into the piping system to detect whether the treated 

bilge water that is being discharged from the bilge separator meets the discharge requirements. 

Some countries have bilge discharge requirements that are stricter than the international 15 ppm 

standard. For example, the Canadian Regulations for the Prevention of Pollution from Ships and 

for Dangerous Chemicals requires 5 ppm bilge alarms for Canadian-flagged vessels which 

discharge treated bilge water in the Great Lakes.

Bilge separators, oil content meters and bilge alarms are certified by the Coast Guard to meet 46 

CFR 162 (MARPOL Annex I implementing regulations). Type approval is based on testing of 

manufacturer-supplied oil pollution control equipment by an independent laboratory, in 

accordance with test conditions prescribed by the Coast Guard (33 CFR 155 and 157 and 46 CFR 

162). In conformance with IMO resolution MEPC.108(49), the measurement of oil (petroleum 

products or hydrocarbon, HC) in bilge separator effluent must be analyzed using ISO method 

9377-2:200022 or equivalent. 

If finalized by EPA in the 2013 VGP, the 5 ppm bilge water discharge standard could result in 

incremental costs to existing vessels greater than 400 gross tons that currently discharge treated 

bilge water outside 1 nm from shore, and to new vessels greater than 400 gross tons that will 

 

22 This analytical method is “Water quality -- Determination of hydrocarbon oil index -- Part 2: Method using solvent 

extraction and gas chromatography”.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 46

discharge treated bilge water rather than holding it. Vessels would not be required to modify their 

current practices if they hold their bilge water. Table 4-4 summarizes the changes in requirements 

applicable to different categories of vessels and their potential cost implications. Note that all 

vessels would continue to have the option to hold their bilge water, if they have the requisite 

storage capacity.

Table 4-4. Summary of the Potential Implications of Revised Bilge Water Discharge 

Requirements under Consideration

Vessel / 2008 VGP Conditions 2013 VGP Potential Cost implications a

Within 1 nm

Existing vessels

• Hold • Hold • None

• Discharge treated bilge water only if 

not technologically feasible to hold

• Discharge treated bilge water

if not technologically feasible 

to hold, or

• None

• Treat to 5 ppm, monitor using 

oil content monitor, and 

conduct annual monitoring

• Treatment system retrofit (unless 

vessel has existing system capable 

of reaching 5 ppm) and monitoring

New vessels

• Hold • Hold • None

• Discharge treated bilge water

(treated to 15 ppm) only if not 

technologically feasible to hold

• Discharge bilge water treated 

to 5ppm

• Incremental cost of more advanced 

treatment system and monitoring

Within 1-3 nm

Existing vessels

• Hold • Hold • None

• ≥ 6 knots: Treat to 15 ppm and 

monitor using oil content monitor

• < 6 knots: Discharge bilge water

(treated to 15 ppm) only if threatens 

safety and stability

• ≥ 6 knots: Treat to 15 ppm and 

monitor using oil content 

monitor

• < 6 knots: Discharge bilge 

water (treated to 15 ppm) only 

if threatens safety and stability

• Regardless of speed: Treat to 5 

ppm, monitor using oil content 

monitor, and conduct annual 

monitoring

• None

• None

• Treatment system retrofit (unless 

vessel has existing system capable 

of reaching 5 ppm) and monitoring

New vessels

• Hold • Hold • None

• ≥ 6 knots: Treat to 15 ppm and 

monitor using oil content monitor

• Treat to 5 ppm, monitor using 

oil content monitor, and 

conduct annual monitoring

• Incremental cost of more advanced 

treatment system capable of 

• < 6 knots: Discharge bilge water meeting 5 ppm limit and monitoring

(treated to 15 ppm) only if threatens 

safety and stability

a Not all potential cost implications are attributable to this Permit. Owners of existing vessels are not required to retrofit 

their vessel to discharge within 1 nm but may instead continue to hold their bilge water. 

VESSEL POPULATION POTENTIALLY AFFECTED BY OPTION

For the purpose of estimating the number of vessels that may elect to implement bilge water

treatment (if the option were to be finalized as part of the 2013 VGP), EPA used information 

contained in the NOI for existing vessel and assumptions on the number of new vessels greater 

than 400 gross tons that may become operational during the period of the permit. Estimates were 

developed separately for existing and new vessels. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 47

Existing Vessels

The MISLE database indicates that a total of 47,556 vessels weigh more than 400 gross tons. 

Data from NOIs submitted to EPA as of August 2010 show that about 4 percent of vessels larger 

than 300 gross tons use an onboard bilge water treatment system (the fraction of vessels vary 

among the vessel classes with a majority of oil and gas tankers and medium and large cruise ships 

reporting the use of an onboard treatment system for their oily water or bilge water discharges).23 

These vessels are currently expected to hold their bilge water while within 1 nm from shore, but 

could potentially have the capability to discharge treated bilge water provided that they comply 

with the specified effluent limits and monitoring, maintenance, and reporting requirements of the 

2013 VGP. EPA assumes that existing vessels are unlikely to change their practice (i.e., they will 

continue to hold bilge water) unless they already meet the revised limits and associated 

requirements and/or find economically beneficial to do so (i.e., treatment and monitoring costs 

are lower than those of holding the bilge water). Vessels that currently have onboard treatment 

systems may either decide to treat their bilge water to meet the discharge limits of 5 ppm, or may 

continue to hold the bilge water. 

There is evidence that at least some vessels and installed bilge separators are capable of meeting 

the 5 ppm limit proposed in the 2013 VGP. The Canadian Regulations for the Prevention of 

Pollution from Ships and for Dangerous Chemicals requires 5 ppm bilge alarms on inland 

waters24 (Great Lakes), and the Canadian Arctic Waters Pollution Prevention Act requires zero 

discharge in Arctic waters (all Canadian waters north of 60°). As of February 2011, Lloyd’s 

Register Clean Shipping Index Verification provides certification of bilge water treatment 

systems meeting a 5 ppm discharge standard. This is a verification service to shipowners and 

operators wishing to demonstrate their success in reducing the environmental impact of their 

activities beyond the requirements of classification or statutory rules and regulations. 

Additionally, Det Norske Veritas (DNV) of Norway requires bilge separators to be equipped with 

a 5 ppm bilge alarm to fulfill the DNV Guidance for Clean Design (DNV, 2005). 

All vessels over 400 GT are required to have an oil content monitor (OCM), including a bilge 

alarm, integrated into the piping system to detect whether the treated bilge water that is being 

discharged from the bilge separator meets the discharge requirements. Standards for approval of 

OCMs are defined under 46 CFR 162.050 or MARPOL 73/78 Annex I. Under MARPOL, the 

limit for discharge into the oceans is 15 ppm when a ship is en route (IMO MEPC107(49)). Any 

bilge water found to contain oil or oil residues with an oil content greater than the 15 ppm limit 

 

23 The NOI data are self-reported and may under represent the number of vessels that have a bilge water treatment 

system onboard.

24 Part 2, Subdivision 4 (Oil and Oily Mixture Discharges ) of the Regulations for the Prevention of Pollution from Ships 

and for Dangerous Chemicals states the following under Authorized Discharge — Section I Waters:

The discharge of an oily mixture from machinery spaces is authorized from any ship in Section I waters if 

... 

(c) the discharge is processed through oil filtering equipment that

(i) produces an undiluted effluent that has an oil content of no more than 15 ppm, and

(ii) triggers an alarm and a discharge-stopping device as soon as the oil content in the effluent exceeds

(A) 5 ppm, where discharged in inland waters of Canada, or

(B) 15 ppm, where discharged in fishing zone 1, 2 or 3 or in those internal waters of Canada that do not include inland 

waters of Canada; (end of citation)
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 48

must be retained onboard or discharged to a designated reception facility or treated with the bilge 

water separator until the oil concentration falls below its allowable discharge concentration. 

When the oil content in the effluent is detected to exceed these limits, an alarm and discharge 

stopping device (typically a valve that diverts the noncompliant effluent back to the bilge 

separator to be reprocessed) is activated.

New Vessels

A total of 47,148 vessels greater than 400 gross tons are estimated to be covered by the VGP. As 

summarized in Section 3.3: Recent Trends, the number of vessels in the domestic fleet has been 

relatively flat in recent years, or has even seen declines in certain types of vessels. For the 

purpose of this analysis, EPA assumes that the future vessel population will remain relatively 

unchanged over the permit period. Using an assumed life of 30 years, approximately 1/30th of the 

vessel fleet may be replaced in any given year, or 1,572 vessels per year. Based on NOI data for 

the 2008 VGP, EPA further assumes that 4 percent of the new vessels constructed on or after 

December 19, 2013 will opt to treat their bilge water to the required effluent limits, with the 

fraction of vessels ranging by vessel types from less than 1 percent for barges to over 70 percent 

for tank ships, consistent with characteristics of existing vessels. 

The population of existing and vessels potentially affected by practices applicable to bilge water

discharge category is shown in Table 4-5. The table includes the estimated number of new vessels 

coming into service each year. As these new vessels enter service, they may potentially incur 

higher costs as a result of the revised VGP requirements, if EPA finalizes the option in the 2013 

VGP. The number of vessels that may potentially incur higher costs as a result of the revised 

VGP is assumed to grow at a constant rate over the period of analysis. 

Table 4-5. Vessel Counts for Practices Applicable to Option to Authorize Discharge of Treated 

Bilge Water (to 5 ppm). 

Vessel Class Percentage of 

Vessels with 

Onboard Bilge 

Water

Treatmenta

Total Existing 

Vessels with 

Onboard Bilge 

Water Treatment

New Vessels with 

Onboard Bilge 

Water Treatment 

(per Year)b

New Vessels with 

Onboard Bilge 

Water Treatment 

(at Year 5)

Commercial Fishing 27% 111 4 19 

Freight Barges 0% 31 1 5 

Freight Ships 71% 470 16 78 

Passenger Vessels 40% 109 4 18 

Tank Barges 1% 63 2 10 

Tank Ships 71% 199 7 33 

Utility Vessels 29% 728 24 121 

TOTAL 1,711 57 285

a Based on NOI data on onboard treatment systems and waste streams generated aboard vessels.

b The U.S. Coast Guard estimates that there are approximately 86 new oceangoing vessels built per year (70 FR 

67066).
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 49

COST ESTIMATES FOR OPTION

In the case of existing vessels that currently treat their bilge water, the cost of complying with the 

bilge water requirements includes costs for oil discharge monitoring system, overboard discharge 

control system, monitoring, sampling, maintenance, and reporting.25 Since EPA assumes that 

existing vessels will continue to use current practices (treat or hold, depending on the vessel), 

these costs are not incremental costs of complying with the revised VGP.

For new vessels, incremental costs for the option include any higher costs associated with 

installing and operating a treatment system capable of meeting the 5 ppm effluent limit, as 

compared to the cost of a system capable of treating the effluent to 15 ppm, along with the costs 

of the oil discharge monitoring system, overboard discharge control system, monitoring, 

sampling, maintenance, and reporting. 

Other requirements pertaining to personnel training and equipment maintenance are the same for 

high performance systems as for systems only capable of treating effluent to 15 ppm and 

therefore do not represent incremental costs attributable to the VGP. 

Treatment Systems and Oil Content Monitors

Cost estimates for bilge water treatment systems and oil content monitors (OCMs) were obtained 

from equipment manufacturers. Information obtained by EPA for treatment systems capable of 

meeting the 5 ppm limit suggests that the cost of these systems vary widely (from $11 to $234 per 

1,000 gallons treated), depending upon the flow rate, volume of bilge water treated, and the cost 

of residual disposal. Labor also seems to be an important cost differential for some of the higher 

flow systems. 

Capital costs were based on the purchase price of bilge separator treatment systems sized to treat 

a bilge water flow rate of 1 m3

/hr (6,300 gal/day), considered to be an average bilge water flow 

rate for a ship (Ghidossi et al., 2009). Other sources indicate that average bilge water flow rates 

for ocean-going vessels are considerably lower, on the order of 1 m3

/day, and that only the largest 

vessels would generate as much as 1 m3

/hr. The amount of bilge water that accumulates onboard 

can vary, and depends on a number of factors including the size of the ship, engine room design, 

preventative maintenance, and the age of the components. Although there could be a proportional 

relationship between ship tonnage and bilge water produced, many variables exist that can easily 

cause a smaller vessel to produce more bilge wastes than a larger vessel (EPA, 2008). To address 

this variability, EPA estimated treatment costs for each system using different assumptions about 

how often the system was operated (i.e., batch mode or continuous operation). 

Operation and maintenance costs were based on systems operating at two different flow rates, 

1 m3

/day and 1 m3/hr, as described above. Costs were estimated for the following categories of 

 

25 Representatives from equipment manufacturers suggested that treatment systems can be retrofitted onto existing 

vessels. They described the process as straightforward and requiring only minimal input from engineers. However, 

they also noted that the retrofit can be time-intensive. The process involves a site survey and usually requires the 

vessel owner to contract an electrician, pipe-fitter, and welder. More experts may be required depending on the 

vessel, and often coordinating their efforts can be difficult. The American Bureau of Shipping (ABS) must approve the 

final installation. One representative suggested that the process can take anywhere from 1.5 to 3 weeks, though 

another noted that, with efficient coordination of labor, the process can take as little as two days.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 50

expenses: chemicals, filter and sorbent media, maintenance and replacement parts, labor for 

operation and maintenance (O&M), and disposal of recovered oil and sludge. It was assumed that 

all bilge water treatment systems would require 0.5 to 2 hours per day of crew labor, because 

EPA could not resolve conflicting claims regarding which systems required more or less labor to 

operate and maintain. Cost of labor was assumed to range between $32 and $50 per hour, based 

on Bureau of Labor Statistics data and other cost estimates. Recurring costs of supplies, 

chemicals, replacement media and parts were provided by the vendor. These costs were estimated 

based upon experience with treating a “representative” bilge water (i.e., 200 ppm free oil, 

100 ppm emulsified oil, 300 ppm suspended solids). In reality, the treatability of bilge water

varies considerably between vessels and over time, and so these costs will also vary.26 Due to a 

lack of reliable information, however, EPA was unable to consider this variability in these cost 

estimates. Energy costs to operate the bilge separators were not included, because energy 

(electricity and heat) is not considered expensive on many vessels (Ghidossi et al., 2009). The 

cost of disposing of residual oil and sludge retained in the vessel’s holding tank was based upon 

contract hauling by a certified waste hauler, and drum disposal of solid oily residuals (i.e., spent 

filters and sorbent media) was assumed. EPA did not consider the alternative of incinerating 

residual oil and sludge aboard ship, although this disposal method is used on some vessels. All 

costs were expressed in 2010 dollars, with purchase costs of foreign equipment based on currency 

exchange rates in effect in August 2010. Capital costs were amortized over 20 years using a 

discount rate of 7 percent. Tables in Appendix A compare the cost of the various systems 

reviewed by EPA for the two system flow rates. These systems commonly include OCMs and 

alarm and automated shut-off designed to prevent the discharge of bilge water exceeding the set 

limit. Because the amount of bilge water generated varies across vessels depending on the size, 

age, and service conditions, among other factors, it is difficult to develop average estimates for 

any given vessel type. 

Fluorescent detection OCMs have a reported capital cost of $12,500, which manufacturers 

indicated may be higher than that of conventional OCMs although no precise estimates of the 

conventional systems could be obtained. Some of the manufacturer representatives EPA 

consulted believe that the fluorescent detection monitor is not necessary to accurately measure 

effluent with oil content below 15 ppm and down to near 0 ppm, even though some 

manufacturers point to testing by the U.S. Navy and by other major commercial ship operators 

that suggests that a fluorescent detection OCM measures effluent below 15 ppm with greater 

accuracy than a more commonly used conventional light scattering OCM.

27 Since OCMs are 

 

26 A. Chan, personal communication, September 22, 2010; L. Mazzarone, personal communication, September 1, 

2010. 

27 Communication with representatives from GMG Systems and Ecologix suggested that OCMs that do not use 

fluorescent detection can detect below 15 ppm. This is different from findings reported in by NAG Marine 

(http://www.td107.com/compare_oil_content_monitor.php) which claim that fluorescent detection monitors are 

generally more accurate. This is attributed to differences in how the two types of systems detect the presence of oil. 

As the name suggests, light scatter OCMs estimate the oil content based on the amount of light that gets scattered in 

a sample stream, and often cannot discriminate between oil and other particles. Fluorescent detection OCMs detect 

only oil molecules based on the unique wavelength signatures when the molecules are irradiated with UV light. EPA 

expressed an interest in the difference in cost between the two types of OCMs in cases where fluorescent detection 

would be necessary to ensure discharges below 5 ppm oil content.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 51

included within the costs of the bilge water treatment systems obtained from equipment 

manufacturers, EPA expects that the included monitor is capable of accurately detecting the 

specified concentration limits. 

It should be noted that despite its cost, treatment is less expensive than the cost of onshore oily 

waste disposal by certified waste haulers in the US, estimated to cost from $300 to $2,000 per 

1,000 gallons (New Logic Research, 2010; Lou Mazzarone, personal communication, September 

1, 2010). Therefore, even where vessels have the capacity to hold their bilge water, they may find 

onboard treatment to be more cost effective. EPA did not account for potential cost savings in 

estimating the impact of the revised bilge water requirements. 

Further, the costs presented above are the actual costs of the specified systems. Limited 

information on the costs of systems capable of meeting a 15 ppm limit, but not 5 ppm suggests 

that these systems may not be significantly more expensive. For example, in estimating the cost 

of implementing bilge water treatment to the 15 ppm limit, the U.S. Coast Guard cited annual 

costs for these systems ranging between $9,000 and $19,000 (in 2009 dollars). This is generally 

comparable to the annualized costs obtained by EPA for systems capable of reaching limits of 

5 ppm, particularly smaller systems sized to treat effluent rates up to 1 m3

/day that have costs 

ranging between $6,312 and $22,550. 

Testing

The Permit specifications under consideration call for initial monitoring consisting of five 

sampling events over a 60-day period, followed by maintenance monitoring conducted once a 

year. The cost associated with these sampling events was estimated by assuming sample 

preparation and administrative activities associated with the collection and processing of the 

sample ranging between 2 and 3 hours for each sampling event that is part of the initial 

monitoring. Laboratory costs and incidentals such as shipping were assumed to be $300 per 

sampling event.

28 

The cost of follow up maintenance monitoring was assumed to be similar but to require an 

additional 0.5 hour of labor to conduct the testing of the oil monitoring system alarm functions 

and switching functions. The assignment of additional time for these tests is likely to 

overestimate the incremental burden since testing of control equipment is part of regular 

maintenance practices for vessel owners. Recalibration of the oil content meter, if necessary, is 

expected to be part of the baseline maintenance of the vessel and this practice is therefore 

assumed to impose no incremental cost. For instance, interviews with representatives of OCM 

manufacturing companies indicate that they generally recommend having the monitors calibrated 

every two years. Good operating practice and compliance with IMO policy requires vessel 

owners to follow the maintenance requirements stipulated by equipment manufacturer, at 

minimum. But companies often have a corporate policy of calibrating the monitors annually. The 

costs of re-calibration were estimated at $250 to $500 per monitor. As this calibration is expected 

 

28 We contacted laboratories to get quotes for conducting testing using method ISO 9377-2(2000) Water QualityDetermination of hydrocarbon oil—Part 2: Method using solvent extraction and gas chromatography. While we were 

able to obtain information on reactant costs (about $100/analysis), these costs do not include the technician rates or 

overhead. For the purpose of this analysis, we assumed that each analysis costs $250.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 52

to be conducted in the baseline, no incremental cost is attributed to the revised VGP 

requirements.

Reporting

Under the option under consideration, vessel owners must submit data on their compliance with 

bilge water treatment standards as part of their annual reporting to EPA. The incremental burden 

of adding this information to the existing annual report is assumed to be negligible. 

SENSITIVITY ANALYSIS

EPA estimated the potential incremental costs to vessel owners using the cost input values 

presented above and the following assumptions. 

Bilge water Treatment Costs

 Bilge water Flow Rate: EPA assumed that larger vessels (freight ships and tanker ships) 

have flow rates ranging between 8 and 16 m3

/day for the low and high end estimates, 

respectively, while other vessels have flow rates ranging between 0.25 and 0.75 m3

/day, 

respectively. Costs for the larger vessels are based on systems capable of treating 

1 m3

/hour while those for smaller vessels are based on systems capable of treating 

1 m3

/hour. 

 Incremental Costs: The cost estimates presented above are the total costs of systems 

capable of meeting effluent concentrations of 5 ppm. There is insufficient information to 

assess the share of this cost that is incremental to the cost of systems capable only of 

meeting limits of 15 ppm. For the purpose of this analysis, EPA conservatively assumed 

that the higher performing systems are up to twice as expensive than the less performing 

systems (i.e., the incremental cost represents between 0 and 50 percent of the bilge water

treatment system cost).29 The 50 percent incremental cost estimate is likely to be a 

conservative assumption since some of the systems readily achieve 15 ppm and require 

only a polishing step to meet the 5 ppm limit.

 Baseline: EPA assumed that the fraction of new vessels that will install bilge water

treatment systems capable of meeting effluent concentrations of 5 ppm is similar to the 

fraction of vessels that currently have onboard bilge water treatment, based on the 2008 

VGP NOIs. The fraction ranges from 0 percent for barges, to over 70 percent for tank 

ships. EPA assumes that all of these vessels would potentially incur incremental costs for 

installing systems capable of meeting the 5 ppm limit. This assumption may overestimate 

the number of vessels incurring incremental costs due to the revised requirement since 

several companies are already meeting the lower limit voluntarily.30

 

29 For example, in the case of a 5 ppm system that costs $20,000 and is twice as expensive as a less effective system 

capable of meeting a 15 ppm limit, the incremental cost is $10,000, or 50 percent.

30 In addition to the programs mentioned earlier in this section, other companies describe their policy to discharge 

only bilge water with an oil content of 5 ppm of less in public documents. For example, Royal Caribbean has adopted 

as its corporate policy the discharge of “treated bilge water beyond 12 nm, less than 5 ppm oil to water and at speed 

of 6 knots or greater.” (Waste Stream Operational Controls, Royal Caribbean, undated) 
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November 30, 2011 53

Testing Costs

 Implementation rate: All vessels assumed to use a bilge water treatment system will have 

to conduct 5 rounds of initial monitoring within the first 60 days of permit coverage 

followed by an annual maintenance monitoring round. 

 Baseline: Vessel owners are assumed to comply with manufacturers’ recommendation 

concerning calibration of oil content monitors. No incremental cost is therefore assumed 

for re-calibration, when needed. 

The estimated cost per vessel for each practice and the total cost associated with all vessels are

summarized in Table 4-3. As discussed in the introduction to this section, practices resulting in 

incremental costs to vessel owners are under consideration only and are not currently included in 

the proposed 2013 VGP. Consequently, these costs are not counted in the total cost for the 

proposed 2013 VGP but are being provided here for information only.
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Table 4-6. Bilge Water Treatment Sensitivity Analysis.

Vessel Class

Number of New 

Vessels with Bilge 

water Treatment

Annual Cost per 

Vessela Total Annual Cost

Low End Estimate

Bilge water Treatment

Commercial Fishing 11 $0 $0

Freight Barges 3 $0 $0 

Freight Ships 47 $0 $0 

Passenger Vessels 11 $0 $0 

Tank Barges 6 $0 $0 

Tank Ships 20 $0 $0 

Utility Vessels 73 $0 $0

Bilge water Treatment TOTAL 171 $0

Testing a

Commercial Fishing 11 $832.39 $9,156

Freight Barges 3 $832.39 $2,497

Freight Ships 47 $832.39 $39,122

Passenger Vessels 11 $832.39 $9,156

Tank Barges 6 $832.39 $4,994

Tank Ships 20 $832.39 $16,648

Utility Vessels 73 $832.39 $60,764

Testing TOTAL 171 $142,338

Low End Total $142,338

High End Estimate

Bilge water Treatment

Commercial Fishing 11 $8,461 $92,607 

Freight Barges 3 $8,461 $25,205 

Freight Ships 47 $91,023 $4,153,806 

Passenger Vessels 11 $8,461 $90,368 

Tank Barges 6 $8,461 $50,410 

Tank Ships 20 $91,023 $1,795,178 

Utility Vessels 73 $8,461 $610,049 

Bilge water Treatment TOTAL 171 $6,817,623

Testing a

Commercial Fishing 11 $907.23 $9,980

Freight Barges 3 $907.23 $2,722

Freight Ships 47 $907.23 $42,640

Passenger Vessels 11 $907.23 $9,980

Tank Barges 6 $907.23 $5,443

Tank Ships 20 $907.23 $18,145

Utility Vessels 73 $907.23 $66,228

Testing TOTAL 171 $155,137

High End Total $6,972,760

a Initial and maintenance monitoring is assumed to apply to all vessels that will install a bilge water treatment system. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

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4.2.3 DISCHARGES OF BALLAST WATER 

The 2013 VGP complements USCG requirements under the Nonindigenous Aquatic Nuisance 

Prevention and Control Act of 1990 (NANPCA), as reauthorized and amended by the National 

Invasive Species Act of 1996 (NISA), regarding the impacts of discharges from ballast water 

treatment systems (BWTS). 

The 2013 VGP specifies performance standards for BWTS, along with associated monitoring, 

sampling, testing, and recordkeeping. The requirements are applicable to all vessels that operate 

in U.S. waters and are equipped with ballast water tanks, unless they are in innocent passage, with 

the exception of crude oil tankers engaged in coastwise trade, vessels of the armed forces31, and 

vessels that operate exclusively in one Captain of the Port Zone.

The BWTS performance standards are the same as the “Phase One” standards proposed by USCG 

in 2009 under 33 CFR part 151 and 46 CFR part 162 (74 FR 44632), which EPA expects to be 

finalized and promulgated by the time the 2013 VGP comes into effect. 

Technologies to meet these limits have been shown to be available: several studies and 

publications discuss current treatment technologies, their efficacy and performance, and their 

availability for shipboard installation (see EPA SAB, 2011; ABS, 2010; Albert et al., 2010; 

CSLC, 2010; GLBWC, 2010; WDNR 2010). For a description of how EPA developed these 

limits for the 2013 iteration of the VGP, please see the proposed permit fact sheet (EPA, 2011b). 

The VGP-specific monitoring and recordkeeping include sampling and analytical testing of the 

BWTS effluent twice per year and reporting of the results of these tests in an annual report to 

EPA. While the additional monitoring and testing requirements will impose additional costs on 

most subject vessel operators, the requirements consistent with BWTS under USCG regulations 

will not. 

PERMIT REQUIREMENTS

The 2013 VGP ballast water requirements build upon the 2008 VGP requirements and USCG 

regulations expected to be in place by the time the 2013 VGP takes effect. The 2013 VGP 

identifies four ballast management methods available to vessels: (1) on-board treatment, (2) 

onshore treatment; (3) use of public water supply; and (4) no discharge in regulated waters. It also 

provides for specific requirements for vessels that treat their ballast water and enter the Great 

Lakes. 

Permit Text (Excerpt): 

2.2.3.5.1 Ballast Water Management Measures

In addition to the other requirements of this permit, owner/operators of vessels with the capacity 

to carry greater than or equal to 8 cubic meters of ballast water may use one of the four 

following ballast water management methods to meet the numeric discharge limits in Part 

2.2.3.5: 

 

31 Vessels of the armed forces are subject to the Uniform National Discharge Standards for Vessels of the Armed 

Forces (33 U.S.C. 1322(n))
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2.2.3.5.1.1 Ballast Water Management using a Ballast Water Treatment System 

Vessel owner/operators utilizing a ballast water treatment system (BWTS) must use a system 

which has been shown to be effective by testing in accordance with the EPA-ETV protocol for the 

verification of ballast water treatment technology conducted by an independent third party 

laboratory, test facility or test organization. Once the effluent limits in Part 2.2.3.5 become 

applicable to a vessel (see part 2.2.3.5.2 for applicability timeframes for specified categories of 

vessels), owners/operators of vessels utilizing a ballast water treatment system to meet the 

requirements of Part 2.2.3.5 of this permit must meet those limits as an instantaneous maximum.

Additionally, following installation of a BWTS, the master, owner, operator, agent, or person in 

charge of the vessel must maintain the BWTS in accordance with all manufacturer specifications. 

Furthermore, all treatment must be conducted in accordance with the BWTS manufacturer’s 

instructions. The BWTS must be used prior to any discharge of ballast water to waters of the U.S. 

2.2.3.5.1.1.1 Monitoring From Vessels Using Ballast Water Treatment Systems

The monitoring requirements in Part 2.2.3.5.1.1 apply to ballast water discharges from vessels 

employing ballast water treatment systems that are required to achieve the effluent limitations of 

Part 2.2.3.5. The monitoring is divided into three components. The first, in Part 2.2.3.5.1.1.2, is 

required of all vessels and generally requires monitoring equipment performance to assure the 

system is fully functional. Vessels conducting this monitoring also must adequately calibrate 

their equipment as required in Part 2.2.3.5.1.1.3. The second component, in Part 2.2.3.5.1.1.4 

requires monitoring from all ballast water systems for selected biological indicators. The third 

component, in part 2.2.3.5.1.1.5 requires monitoring of the ballast water discharge itself for 

biocides and residuals to assure compliance with the effluent limitations established in part 

2.2.3.5 of the permit, as applicable. 

2.2.3.5.1.1.2 Ballast Water System Functionality Monitoring

Ballast water treatment systems use physical and/or chemical processes, or a combination 

thereof, to achieve reductions in living organisms. The use of physical/chemical indicators of 

treatment performance verifies that the ballast water treatment system is operating according to 

the manufacturers’ operating specifications. To assess the BWTS functionality, monitoring 

indicators of the BWTS functionality is required at least once per month for specific parameters 

that are applicable to your system. The required parameters to be monitored, with appropriate 

monitoring approaches are contained in Appendix J. For example, if your system uses a filter 

and chlorine dioxide, you must meet the requirements for systems using both filters and chlorine 

dioxide. If your system uses cavitation, UV, and hypochlorite generation, you must monitor 

conditions for all three treatment units. EPA expects that most ballast water treatment systems 

will make use of at least two physical and/or chemical processes. 

Most ballast water treatment systems have control and self diagnostic equipment such as sensors 

that continuously measure treatment parameters to verify performance. The metrics to be 

monitored are based on common approaches used in ballast water treatment systems. As new 

approaches become commonly available, EPA will develop new monitoring parameters as 

appropriate. 

2.2.3.5.1.1.3 Ballast Water monitoring equipment calibration 
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November 30, 2011 57

At a minimum, all applicable sensors and other equipment must be calibrated annually. 

Additionally, all applicable sensors and other control equipment must be calibrated no less 

frequently than recommended by the sensor or other equipment manufacturer, or by the ballast 

water treatment system manufacturer or when warranted based on device drift from a standard 

or calibrated setting. EPA expects many sensor types (e.g., pH probes, TRO sensors, turbidity 

sensors) will need to be calibrated on a more frequent basis. Calibration of the sensors and 

equipment can be conducted on-board the vessel or they can be removed and shipped to the 

manufacturer or other vendor for calibration. During the period when the sensors are not 

installed (or otherwise inoperable thus significantly compromising the performance of the ballast 

water treatment system), the vessel must not discharge ballast water.

2.2.3.5.1.1.4 Effluent Biological Organism Monitoring 

Once a ballast water treatment system is required to be installed onboard a vessel (see part 

2.2.3.5.2 for applicability and timeframe for installation of such vessels), any ballast water 

discharges from such vessels will be subject to the effluent limitations in Part 2.2.3.5 of this 

permit. To ascertain compliance with the effluent limitation in that section, EPA is establishing 

the following biological indicator compliance monitoring. These samples can be taken by 

collecting a small volume sample from the ballast water discharge (consistent with the sampling 

guidance found in EPA’s Generic Protocol for the Verification of Ballast Water Treatment 

Technology) and analyzing the sample for concentrations of certain biological indicator 

parameters. Analysis of concentrations of indicator organisms must include monitoring for the 

parameters in Table 2 below utilizing the methods in that table, or other EPA Part 136 methods 

as applicable. 

[Table 2: Indicator Organism Monitoring Parameters] 

Biological indicator compliance monitoring sampling of ballast water effluent must be conducted 

2 times per year for vessels with type approved devices for which high quality type approval data 

are available, and 4 times per year for non-type approved devices or type approved devices for 

which high quality data are not available. Each sample must be tested independently and the 

individual results must be reported and not averaged. Monitoring must be conducted at least 14 

days apart from different discharge events. 

Type approved devices for which high quality type approval data are available means either: 

a) any ballast water treatment system type approved by the United States federal 

government; or 

b) any ballast water treatment system: 

i. type approved by a foreign administration; 

ii. for which efficacy testing was conducted by an independent 3rd party testing 

organization, either in accordance with the ETV protocol or in a manner consistent with the ETV 

protocol with respect to QA/QC procedures, the use of validated methods including appropriate 

volumes of representative samples, and full description and documentation of test procedures, 

results and analyses; and 

iii. all active substance data (e.g., the full data package submitted to the flag administration 

for type approval) have all been made available to the US EPA. 
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2.2.3.5.1.1.5 Requirements and Effluent Limitations for BWTS that use Active Substances 

(e.g., biocides) 

2.2.3.5.1.1.5.1 Authorization of Residual Biocides Associated with Ballast Water Treatment 

Systems

Many ballast water treatment systems produce or use biocides as an agent to reduce living 

organisms present in the ballast water tank. In order to be eligible for coverage under this 

permit, any ballast water treatment system must not use any biocide that is a “pesticide” within 

the meaning of the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C § 136 et seq.) 

unless that biocide has been registered for use in ballast water treatment under such Act. The 

requirement in the preceding sentence does not apply if such biocide is generated solely by the 

use of a “device” on board the same vessel as the ballast water to be treated by the biocide, as 

the term “device” is defined in the Federal Insecticide, Fungicide, and Rodenticide Act. In 

addition, if the ballast water treatment system uses or generates biocides and you will discharge 

ballast water treated with biocides into waters subject to this permit, you must meet one of the 

following conditions to be eligible for permit coverage. 

The discharge of biocides or residuals may not exceed the following instantaneous maximum 

limits expressed as micrograms per liter (μg/l). 

[Table 3. Maximum Ballast Water Effluent Limits for Residual Biocides]

Any other biocides or derivatives may not exceed acute water quality criteria listed in EPA’s 

1986 Quality Criteria for Water [the Gold Book], and any subsequent revision, at the point of 

ballast water discharge. The Gold Book can be found at: 

www.epa.gov/waterscience/criteria/library/goldbook.pdf. Tables summarizing the subsequent 

revisions can be found at: http://www.epa.gov/waterscience/criteria/wqctable/index.html. 

Discharges of biocide residuals or derivatives must also meet monitoring requirements under 

Part 2.2.3.5.1.1.1, and reporting and recordkeeping requirements in Part 2.2.3.5.1.1.6. 

If the biocide used or produced by your system and its derivatives is not listed in the previous 

table or found in EPA’s Gold Book, you must notify EPA at least 120 days in advance of its use 

and provide any associated aquatic toxicity data for that biocide or its derivatives of which you 

are aware. EPA may impose additional limitations on a treatment system-specific basis, or 

require you to obtain coverage under an individual permit, if necessary. EPA may inform the 

vessel owner/operator of specific requirements. You may also seek coverage under an individual 

NPDES permit pursuant to Part 1.8.2 of this permit. You may not discharge the biocide at issue 

until you receive a response from EPA to your notification. 

2.2.3.5.1.1.5.2 Residual Biocide and Derivative Monitoring

For vessels subject to Part 2.2.3.5.1.1.1, you must conduct monitoring of the vessel ballast water 

discharge for any residual biocides or derivatives used in the treatment process, in part to 

demonstrate compliance with the conditions in Part 2.2.3.5.1.1.5.1. For instance, if chlorine is 

the biocide used in the ballast water treatment, you must test for residual chlorine in the vessel 

ballast water discharge to see if it complies with the standards in Part 2.2.3.5.1.1.5.1. 

In order to demonstrate that residual biocides or derivatives are in compliance with this permit, 

that substantial quantities of harmful byproducts are not produced, and provide EPA with needed 
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November 30, 2011 59

information about system functionality, the vessel operator initially must take samples according 

to the following: 

[Table 4: Monitoring Schedule for Residual Biocides or Derivatives of the Residual Biocide] 

Type approved devices for which high quality type approval data are available means either: 

a) any ballast water treatment system type approved by the United States federal 

government; or 

b) any ballast water treatment system: i) type approved by a foreign administration; ii) 

for which efficacy testing was conducted by an independent 3rd party testing 

organization, either in accordance with the ETV protocol or in a manner consistent with 

the ETV protocol with respect to QA/QC procedures, the use of validated methods 

including appropriate volumes of representative samples, and full description and 

documentation of test procedures, results and analyses; and iii) all active substance 

data (e.g., the full data package submitted to the flag administration for type approval) 

have all been made available to the US EPA. 

Each sample must be tested independently and the individual results must be reported and not 

averaged. Samples must be tested as soon as possible after sampling, and may not be held longer 

than recommended for each tested constituent as given in 40 CFR Part 136. Sampling and testing 

shall be conducted using a sufficiently sensitive method according to 40 CFR Part 136 or may 

use an alternate method if allowed in Table 5 below. 

[Table 5. Residual Biocides and Biocide Derivative Monitoring Requirements]

2.2.3.5.1.1.6 Ballast Water Treatment System Recordkeeping and Reporting 

Records of sampling and testing results required under Part 2.2.3.5.1.1 must be retained onboard 

for a period of three years in the vessel’s recordkeeping documentation. Vessels must also submit 

the testing results to EPA using EPA’s e-reporting system as part of the vessel’s annual report 

(unless you are eligible to submit a hard copy of the annual report). 

Records of monitoring information shall include: 

 The ballast water treatment system used, its type approval certificate, and records of 

whether the system is a vessel with type approved devices for which all type approval 

data have been made available; 

 The individual(s) who performed the sampling, measurements, and/or inspections; 

 The date(s) analyses and/or inspections were performed;

 Any sensor or other control equipment calibration and functional tests conducted during 

the inspection as applicable;

 The techniques or methods used for any sensor or other control equipment calibration 

and functional tests as applicable;

 The date and time of all monitoring results (monitoring in Parts 2.2.3.5.1.1.2, 

2.2.3.5.1.1.4, and 2.2.3.5.1.1.5, as applicable); 

 The analytical techniques or methods used as applicable, and 

 The results of such analyses.
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You must submit your monitoring data as part of your annual report. For systems already in use 

as of the effective date of this permit, initial sampling data must be submitted with the first annual 

report. For systems which are not already in use as of the effective date of this permit, initial 

sampling data must be submitted on the annual report following the calendar year of the system’s 

first use. Data must be submitted on the Ballast Water Treatment System Report form attached to 

the annual report available in Appendix H of this permit or submitted to EPA’s e-reporting 

system available at www.epa.gov/npdes/vessels/eNOI. 

[2.2.3.5.1.2 Onshore Treatment of Ballast Water] 

[2.2.3.5.1.3 Use of Public Water Supply Water] 

[2.2.3.5.1.4 No Discharge of Ballast Water] 

[2.2.3.5.2 Schedule for when Ballast Water Treatment Becomes BAT (and Therefore 

Required)] 

[2.2.3.5.3 Vessels Not Required to Meet Part 2.2.3.5 Treatment Standards] 

[2.2.3.6 2.2.3.6 Interim requirements for vessels not meeting the ballast water 

management measures in Part 2.2.3.5] 

2.2.3.7 Vessels Entering the Great Lakes

In addition to complying with the requirements of this permit, all vessels that are equipped to 

carry ballast water and enter the Great Lakes must comply with 33 CFR Part 151, Subpart C 

titled: “Ballast Water Management for Control of Nonindigenous Species in the Great Lakes and 

Hudson River.” Vessels that operate outside the EEZ and more than 200 nm from any shore and 

then enter the Great Lakes via the Saint Lawrence Seaway System must also comply with 33 CFR 

Part 401.30. Vessels that are unable, due to weather, equipment failure, or other extraordinary 

condition, to effect a BWE before entering the EEZ prior to entering the Great Lakes, must 

employ another method of ballast water management listed in 33 CFR 151.1510 or otherwise 

comply with the provision of 33 CFR 151.1514. 

Additionally, vessels utilizing a ballast water treatment system (see Part 2.2.3.5.1.1 of the permit) 

must also conduct ballast water exchange or saltwater flushing (as applicable) in addition to 

treating their ballast water if they meet the following requirements:

 The vessel operates outside the EEZ and more than 200 nm from any shore and then 

enters the Great Lakes via the Saint Lawrence Seaway System, and 

 The vessel has taken on ballast water that has a salinity of less than 18 ppt from a 

coastal, estuarine, or freshwater ecosystem within the previous month.

If a vessel affected by these requirements has not taken on ballast water with a salinity of less 

than 18 ppt in the previous month, the master of the vessel must certify to this effect in their 

ballast water recordkeeping requirements before entering the Great Lakes. 

Among the options available to owners of ballast tank-equipped vessels in the 2013 VGP, the 

provisions related to on-board treatment of ballast water are substantively different from 

requirements that were contained in the 2008 VGP. This analysis therefore focuses most 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 61

specifically on these provisions. As outlined in the 2013 VGP, onboard treatment requirements 

consist of three main components. First the VGP sets performance criteria for BWTS in terms of 

allowable limits on living organisms that may be discharged with ballast water. Second, the VGP 

contains limits on the amount of residual biocides or their derivatives that may be discharged into 

waters subject to the permit. Third, the VGP outlines required monitoring, sampling, testing, and 

reporting activities aimed at ensuring that the BWTS performs as specified and that the ballast 

water discharged meets the standards. The VGP also specifies additional requirements for vessels 

that treat their ballast water and enter the Great Lakes.

The BWTS performance criteria contained in the 2013 VGP are generally similar to the IMO and 

USCG standards. According to the compliance schedule announced by USCG in its proposed rule 

(74 FR 44632), all newly built vessels constructed on or after January 1, 2012 will have to 

comply with the discharge standards summarized in Table 4-7 upon their delivery, while vessels 

constructed before January 1, 2012 will have to comply with the discharge standards as early as 

their first drydocking after January 1, 2014 or January 1, 2016, depending on their ballast water 

capacity.32 This compliance schedule is roughly the same as that specified by the IMO Ballast 

Water Management Convention, which is set to enter into force 12 months after ratification by 30 

States, representing 35 per cent of world merchant shipping tonnage. As of July 31, 2011, 28 

States had ratified the Convention, representing 25.43% of world’s merchant shipping tonnage. 

EPA therefore expects that the IMO convention will enter into force and/or the US Coast Guard 

rulemaking will be finalized by the time this permit becomes effective on December 19, 2013. 

Note that some jurisdictions have different standards. For example, the State of California 

promulgated performance standards for ballast water discharges in that State’s water that are 

structured differently than the IMO D-2 or USCG Phase One standard as they are based on a “no 

detectable living organism” standard for the larger size class. The other size classes contained in 

the California standards are similar (but not identical) to the “Phase Two” proposed by USCG in 

2009, but set a final implementation date of January 1, 2020 by which date vessels must have 

zero detectable living organisms in their ballast water discharge. California also provides explicit 

guidelines for sampling points and methods. The States of Michigan, Minnesota, and Wisconsin 

also have state-specific ballast water discharge standards. Other states, such as New York, 

Illinois, Indiana and Ohio have previously required ballast water treatment as part of their VGP 

401 certification requirements. 

Given these existing USCG, IMO, and State requirements which are generally equivalent to, or 

even more stringent than the 2013 VGP, EPA does not expect the performance standards 

stipulated in the 2013 VGP to impose an incremental cost to vessel owners, as vessels will

already be required to comply with IMO, USCG, and state standards. 

 

32 Existing vessels with ballast water capacity between 1,500 and 5,000 m3 must comply starting January 1, 2014 

while existing vessels with ballast water capacity less than 1500 m3 or greater than 5,000 m3 must comply starting 

January 1, 2016.
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Table 4-7. USCG Phase One and IMO D-2 Ballast Water Discharge Standards.

Organism Size Class Discharge Standard

>50 μm <10/m3

> 10 μm and ≤ 50 μm <10/ml

≤ 10 μm N/A

E. coli <250 cfu/100 ml

Intestinal enterococci <100 cfu/100 ml

Toxicogenic Vibrio cholerae (human cholera) <1 cfu/100 ml

cfu = colony forming unit

In addition to these discharge standards, the 2013 VGP also stipulates monitoring, sampling, 

testing, and reporting activities that vessel owners must complete.

The purpose of these activities is two-fold: First, to monitor the operation of the BWTS to ensure 

that it functions as expected and as designed by the manufacturer, and second, to characterize the 

discharge at the discharge point into waters subject to the permit. Specific requirements include:

 Functionality monitoring: Physical/chemical indicators of treatment performance verify 

that the ballast water treatment system is operating according to the manufacturers’ 

requirements. Most ballast water treatment systems have control and self-diagnostic 

equipment that continuously measure treatment parameters to verify performance. 

Sensors commonly incorporated into the most frequently installed systems include flow 

meters, pH sensors, dissolved oxygen sensors, OPR and amperometric (TRO) sensors, 

and on-line chlorine analyzers. Other ballast water treatment systems are provided with 

testing meters or kits, such as portable chlorine and dissolved ozone monitors, to verify 

adequate levels of treatment chemicals are being maintained within the ballast tanks. 

Vessel operators monitor and record this data and make adjustments, maintenance, or 

repairs to the ballast water treatment system to ensure the equipment is functioning 

properly. 

 Monitoring equipment calibration: This requirement is meant to ensure that all 

applicable sensors and other control equipment are calibrated, when warranted, based on 

device drift and as recommended by sensor and equipment manufacturers, or by ballast 

water treatment system manufacturers.

 Effluent biological organism monitoring: This requirement is intended to verify that the 

treatment system is operating properly by collecting a small volume sample and 

analyzing the sample for concentrations of certain indicator parameters.

 Residual biocide and derivative monitoring: While ballast water treatment technologies 

reduce the probability of invasion, such treatment may introduce other water quality 

impacts, such as toxicity. For example, the addition or in-process generation of 

disinfecting chemicals may result in an effluent with some residual toxicity. Therefore, 

for vessels having ballast water treatment systems that either add or generate biocides for 

treatment (e.g., chlorine, chlorine dioxide, ozone, etc.) the VGP 2013 requires that 

owners conduct monitoring of the vessel ballast water discharge for any residual biocides 

to demonstrate compliance with specified action levels. 
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November 30, 2011 63

AFFECTED VESSEL POPULATION

The total population of vessels potentially affected by practices applicable to the ballast water 

discharge category was described in Section 2.5 of this report. Table 4-7 summarizes estimates of 

the total number of domestic vessels potentially subject to ballast water standards, based on 

figures from the USCG (USCG, 2008). Not all vessels, however, will use onboard treatment to 

comply with discharge requirements. Estimates developed by King et al. (2010) suggest that less 

than half of the vessels with ballast water discharge are likely to install onboard BWTS. The 

fraction varies across vessel types. Other vessels are more likely to use an alternative compliance 

method such as not discharging ballast water while in regulated waters, using onshore facilities, 

or using freshwater as ballast. 

Further, only a subset of the BWTS installed use biocides as disinfection methods and would 

have the potential to discharge residual biocides and therefore be subject to the related 2013 VGP 

requirements. According to Lloyd’s Register (2011), about half of the 200 BWTS installed as of 

June 2011 use chemical disinfection methods that have the potential to discharge residual 

biocides.33 

Table 4-8. Vessel Counts for Practices Applicable to Ballast Water Treatment.

Vessel Class Vessels with Ballast 

Water Tanksa

Vessels Assumed to use 

Onboard BWTSb

BWTS with Potential to 

Discharge Residual 

Biocidesc

Commercial Fishing 819 334 167 

Freight Barges - - - 

Freight Ships 1,711 404 202 

Passenger Vessels 185 185 93 

Tank Barges - - - 

Tank Ships 63 63 31 

Utility Vessels 101 101 50 

TOTAL 2,878 1,086 543 

a Based on USCG estimates. 

b Based on estimates by King et al. (2010). 

c Half of the BWTS installed are assumed to use chemical disinfection methods.

Finally, vessels that use a BWTS and enter the Great Lakes are subject to additional flushing 

requirements if: (1) they operate outside the EEZ and more than 200 nm from any shore and then 

enter the Great Lakes via the Saint Lawrence Seaway System, and (2) they have taken on ballast 

water that has a salinity of less than 18 ppt from a coastal, estuarine, or freshwater ecosystem 

within the previous month. 

EPA could not find data on the exact number of vessels that meet the two criteria above. Data on 

ballast water discharges in the Great Lakes and Saint-Lawrence Seaway System (GLSLSS) by 

transoceanic ships in 2002 suggests that there were 46 vessel visits that year from ships with 

 

33 These methods include ozonation, chlorination, electrolysis/electrochlorination, or most other chemical/biological 

treatment.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 64

ballast on board, each discharging 10,000 m3, and an additional 531 visits from unballasted 

vessels (Cangelosi and Mays, 2006), for a total of 566,200 m3 discharged. More recent NBIC data 

for 2009 show 188 vessels discharging a total of 1,050,920 m3 of ballast water in states bordering 

the Great Lakes. This is equivalent to about a quarter of non-commercial fishing vessels assumed 

to use onboard BWTS. For the purpose of this analysis, EPA distributed the vessels assumed to 

enter the Great Lakes according to the previously estimated number of vessels assumed to use 

onboard BWTS, as shown in Table 4-9. 

Table 4-9. Vessel Counts for Practices Applicable to Ballast Water Treatment for Vessels 

Entering the Great Lakes.

Vessel Class Vessels with Ballast 

Water Tanksa

Vessels Assumed to use 

Onboard BWTSb

Vessels Assumed to 

Enter the Great Lakesc

Commercial Fishing 819 334 - 

Freight Barges - - - 

Freight Ships 1,711 404 101

Passenger Vessels 185 185 46

Tank Barges - - - 

Tank Ships 63 63 16

Utility Vessels 101 101 25

TOTAL 2,878 1,086 188

a Based on USCG estimates.

b Based on estimates by King et al. (2010).

c 25% of the BWTS installed are assumed to be on vessels that enter the Great Lakes.

COST ESTIMATES 

There are three main categories of costs for complying with the ballast water treatment 

requirements: 1) costs associated with the purchase, installation, and operation of the treatment 

system; 2) costs associated with BWTS functionality monitoring and equipment calibration; and 

3) costs associated with discharge monitoring. 

For vessels that enter the Great Lakes, potential additional costs are associated with the 

requirement to conduct ballast water exchange. 

These costs are discussed below.

Capital and O&M Costs

The USCG estimated the costs of installing and operating a BWTS compliant with its Phase One 

performance standards (USCG, 2008). Capital costs range from less than $300,000 to more than 

$2.5 million depending on the vessel characteristics (type and size) and the type of treatment 

system installed.

34 Annual operation and maintenance costs (for electricity, chemicals, crew 

labor, periodic maintenance, parts, training, and other logistics) are estimated to be comparatively 

 

34 Cost estimates ranged between $258,000 for chemical treatment in offshore supply vessel, to more than 

$2.5 million to retrofit Very Large Crude Carriers (VLCCs) with ozone generating systems. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 65

low; they amount to approximately 1/200 of the annualized capital costs, or $$1,708 per vessel

per year, on average. USCG estimated the total annualized costs to owners of the 4,758 U.S. 

flagged vessels that would need to install BWTS to comply with Phase One regulations at $167.5 

million (2007 dollars).

35 These cost estimates may be higher than actual costs given the broader

availability of treatment systems since the estimates were developed. Since the VGP performance 

standards are the same as those expected to be in effect under the USCG regulations, vessels are 

assumed to already have to comply with these requirements in the baseline and the cost of 

installing BWTS is not an incremental cost attributable to the 2013 VGP. 

Functionality Monitoring and Calibration

The second potential cost component relates to monitoring the BWTS to ensure that it is 

functioning properly, and as necessary, calibrating sensors and probes. For example, this practice 

may involve monitoring filters, chemical injection, and dosage equipment, tracking energy usage 

of the UV system, and inspecting any other necessary components of the system to ensure that 

they are working as designed and specified by the manufacturer. Since all ballast water treatment 

systems are expected to come equipped with the necessary sensors and monitoring equipment, 

capital costs are expected to be minimal. In the unlikely event that sensors and monitoring 

equipment need to be installed, their costs would need to be accounted for when estimating VGP 

compliance costs. For example, upfront capital costs for installing additional monitoring 

equipment for a filtration and chlorine dioxide system are approximately $10,000, or about $920 

per year (annualized using a discount rate of 7 percent and life of 20 years).36 

EPA estimates that each inspection or monitoring event may require about 1.15 hour to complete 

(1 hour to conduct an inspection and 9 minutes to record findings) and that these events are 

conducted monthly. EPA further assumes that re-calibration may be needed annually, with each 

calibration event requiring 8 hours of staff time and 15 minutes in recordkeeping time. The total 

annual burden of these two activities amounts to about 22 hours per year. Since compliance with 

the IMO, USCG or other applicable discharge standards already implies that the vessel owner 

monitors the BWTS and recalibrates sensors and probes as needed, costs specifically attributed to 

the 2013 VGP are limited to any additional recordkeeping that is specific to the VGP.37 For the 

purpose of this analysis, EPA estimated the additional VGP-specific recordkeeping burden at 

2 hours per year (9 minutes each month for ongoing inspections, plus 15 minutes for documenting 

annual calibration). Based on an average labor rate of $33.72 per hour, costs for this requirement 

average about $67 per vessel per year.

 

35 Present value costs discounted at 7 percent. 

36 This is based on the purchase of a turbidity meter ($2,350) and chlorine dioxide sensor ($984) and installed costs 

equal to three times the equipment cost. The total installed capital cost is estimated at $9,732 (3 x $2,350 + 3 x 984).

37 California regulations (Public Resources Code Section 71205(g)) require that the vessel owner maintain a ballast 

water treatment performance log on board the vessel. At a minimum, this treatment performance log must include: 

The dates, times, and locations of the starting and stopping of the system for the purpose of treating ballast water; 

Dates, time and descriptions of any system malfunctions, including problem resolution; Dates, times and locations of 

both scheduled and unscheduled maintenance of the system; All relevant measures of system performance recorded 

during system operation (for example - UV transmittance, residual chemical concentration). 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 66

Discharge Monitoring for Biological Indicators and Residual Biocides

The third potential cost component relates to the testing of ballast water effluent from the BWTS 

for the presence of bacterial indicators and residual biocides, if applicable. While some vessel 

owners may already test their effluent to ensure the proper performance of the BWTS, this testing 

is not generally required to comply with the IMO or USCG discharge standards and EPA 

therefore assumes that all vessels equipped with a BWTS would need to conduct additional 

sampling and testing to comply with the 2013 VGP.38 

The 2013 VGP stipulates two types of discharge monitoring: biological indicators and residual 

biocides (if applicable for the type of BWTS). In both instances, the VGP specifies the 

parameters to be analyzed and the frequency of monitoring, depending on the type of treatment 

system installed. 

The required biological indicator compliance testing of ballast water effluent must be conducted 

2 times per year for vessels with type approved devices for which all type approval data are 

available, and 4 times per year for non-type approved devices or type approved devices for which 

data are not available. 

The 2013 VGP requires discharge testing for the presence of residual biocides, if applicable, 

several times during the initial 90 days of permit coverage, followed by maintenance monitoring 

thereafter. The number of sampling events needed during the first 90 days (3 to 5 events) and the 

frequency of subsequent monitoring events (2 or 4 events per year) is dependent on the type of 

system, as summarized in Table 4-10 below. 

Table 4-10. Discharge Sampling and Testing Requirements.

Type of Monitoring Type approved devices for 

which all type approval data 

are available

Type approved devices for 

which data are not available

Biological Indicators 2 times per year 4 times per year

Residual Biocides

Initial Monitoringa 3 times during first 90 days 5 times during first 90 days

Maintenance Monitoring 2 times per year 4 times per year

a The initial monitoring is conducted only once during the period of the Permit. 

Each sampling event involves collecting ballast water effluent samples and either analyzing these 

samples on-board the vessel or sending the samples to an onshore laboratory for analysis. The 

cost of each event consists of labor hours for vessel staff and laboratory costs (including sample 

shipping and handling).39 

 

38 The State of California encourages owners to conduct regular performance testing to ensure that the treatment 

system is working properly, but system performance verification is not specifically required under Public Resources 

Code Section 71205(g). 

39 While vessel owners may decide to do some analyses onboard the vessel, the use of outside laboratories is used as 

an upper bound on compliance costs.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 67

EPA estimated that each sampling event will require 2 hours to complete and 0.5 hour to record. 

Additional sampling for biocide, in the case of vessels equipped with systems that have the 

potential to discharge residual biocide, is estimated to require 1 hour to complete, and 0.5 hour to 

record. Table 4-11 presents assumed incremental burden and cost estimates for discharge 

sampling and analytical testing of ballast water discharges. 

Table 4-11. Annual per vessel cost of ballast water requirements. 

Practice Incremental 

Burden 

(hours)

Lab and 

Incidental 

Costs

Frequency 

(#/year)

Annual 

Costa e

Capital and O&M costs Not applicable (no incremental cost)

BWTS monitoringb 0.15 None 12 $60.70

BWTS calibrationc 0.25 None 1 $8.43

If Using Type approved devices for which all type approval data are available

Biological sampling and testing d 2.50 $150 2 $468.61

Initial biocide sampling and testing e 1.50 $150 3 $97.84 

Maintenance biocide sampling and testingf 1.50 $150 2 $401.17

If Using Type approved devices for which data are not available

Biological sampling and testing d 2.50 $150 4 $937.22

Initial biocide sampling and testing e 1.50 $150 5 $195.68

Maintenance biocide sampling and testing f 1.50 $150 4 $802.33

a Annual cost calculated as burden hours times the average labor rate of $33.72/hour plus lab and incidental costs times 

the frequency. 

b Burden associated with the additional recordkeeping that may be needed under the VGP.

c Burden associated with the additional recordkeeping that may be needed under the VGP.

d Testing for E. coli, enterococci, and total live bacteria.

e Annual cost of the initial biocide sampling and testing represents one-time costs of initial testing annualized over 5 

years (at 7% discount rate) of the VGP and assumes that the initial round of biocide sampling and testing replaces one 

periodic monitoring event.

f Based on testing for trihalomethanes or bromoform.

Note that EPA generally assumed that vessels will test for the presence of residual biocides and 

their corresponding derivatives and analytes listed in Table 5 of the 2013 VGP, namely: 

alkylamines, chlorine or chlorine dioxide, methadione, ozone, peracetic acid. In instances where 

the biocide used or produced by the BWTS and its derivatives is not one listed in the 2013 VGP, 

the vessel owner will have to conduct whole effluent toxicity (WET) testing. The requirements 

for such testing are similar to requirements that were contained in the 2008 VGP, and relatively 

few vessels are expected to conduct WET testing. Therefore, EPA assumed that this provision 

does not represent an incremental cost. 

Additional Operating Costs for Vessels Entering the Great Lakes

Certain vessels that use an onboard BWTS and enter the Great Lakes must conduct ballast water 

exchange or saltwater flushing (as applicable) in addition to treating their ballast water. This 

requirement has the potential to increase operating costs for these vessels by increasing the 

volume of water exchanged and treated. To estimate the incremental costs, EPA relied on 

estimates of the operating cost for ballast water treatment and exchange developed by the U.S. 

Coast Guard (USCG, 2008), summarized in Table 4-12. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 68

Table 4-12. Ballast Water Treatment and Exchange Costs.

Practice Unit Cost ($/m3)

c

Treatmenta $0.259

Exchangeb $0.035

a Based on costs in Table 3.6 of USCG (2008). Represents the average cost across different treatment systems 

(chlorine generate, chemical apply, filter and radiate, deoxygenate, and ozone generate) for Handy bulk carriers, 

escalated to 2010 dollars using CCI. 

b Based on costs in Table B-3 of USCG (2008). Represents the average cost of systems capable of treating 750 m3

/hour

and 2,000 m3

/hour, escalated to 2010 dollars using CCI. 

c Cost originally stated in 2007 dollars were escalated to 2010 dollars using CCI (adjustment factor = 1.1049). 

Reporting

Vessel owners must submit data on their compliance with ballast water treatment standards as 

part of their annual reporting to EPA. The incremental burden of compiling the information 

collected during each inspection or sampling event for use in the existing annual report is 

assumed to be negligible relative to the estimated burden of each event and of the annual report. 

SENSITIVITY ANALYSIS

EPA estimated the potential incremental costs to vessel owners using the cost input values 

presented above and the following assumptions. 

Ballast Water Treatment Costs

Given existing requirements assumed in the baseline, EPA assumed that no additional vessel will 

install a BWTS to comply specifically with the VGP discharge standards. Therefore, no 

incremental capital and operation costs are attributable to the 2013 VGP. 

Performance Monitoring Costs

 Vessel population: EPA estimated the population of vessels potentially subject to the 

discharge standard based on figures presented in USCG (2008). Only a fraction of these 

vessels, however, may ultimately install a BTWS to comply with the discharge 

requirements. Based on estimates presented in King et al. (2010), EPA assumed that 

about 40 percent of vessels will install a BTWS in the low end estimate, and 60 percent in 

the high end estimate. This subset of vessel is assumed to conduct performance 

monitoring. 

 Baseline and Incremental Costs: BWTS already include the necessary instruments to 

monitor performance. Further, vessel owners are assumed to already comply with 

manufacturers’ recommendation concerning the monitoring and calibration of monitors 

and probes as part of their existing operations. Incremental costs are assumed to consist 

of recordkeeping requirements specific to the 2013 VGP and are the same in the low and 

high end estimates (Table 4-11). 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 69

Effluent Sampling and Testing Costs

 Vessel population: The types of tests needing to be performed for each vessel depends on 

the type of system used to disinfect the effluent. All vessels that use a BWTS will have to 

conduct sampling and testing for biological parameters (E. coli, enterococci, etc.). Only 

some systems have the potential to discharge residual biocide, however, and would have 

to test for the presence of biocides in the effluent. Systems that have the potential to 

discharge residual biocides are those that disinfect using chemical inactivation (using 

chlorine or other biocide such as menadione). Systems that use physical disinfection (UV, 

deoxygenation, cavitation, heat) do not have the potential to discharge residual biocides 

and vessels equipped with these systems would not incur the related testing cost. Based 

on information available from Lloyd’s Register, about half of the BWTS installed on 

vessels will use some form of chemical disinfection with the potential to discharge 

residual biocide. EPA therefore assumes that 100 percent of vessels using a BWTS will 

conduct sampling and testing for biological indicators, whereas between 50 percent (low 

end) and 75 percent (high end) of the vessels with BWTS incur incremental costs for 

biocide sampling and testing. 

 Sampling frequency: The frequency of biocide testing depends on the type of BTWS 

installed, and in particular, whether the device is type-approved in the U.S. (or data have 

been made available to EPA). In general, EPA assumes that BTWS manufacturers will 

willingly share their data to gain approval in the U.S. as they have market incentives to 

do so. Nevertheless, EPA conservatively assumed that some vessels may use BTWS that 

have not been type approved in the U.S. For the low end estimate, EPA assumes that 

1percent of vessels use BWTS that are not type-approved in the U.S. and would be 

subject to the more frequent testing requirements. This fraction is assumed to be 5 

percent in the high end estimate. 

 Baseline: None of the vessels subject to the sampling and testing requirement are 

assumed to conduct sampling and testing in the baseline. Therefore, the costs of 

conducting biological sampling and testing (and biocide sampling and testing, if

applicable) are assumed to be incremental costs attributable to the 2013 VGP. 

 Unit Costs: Assumed unit costs are the same in the low end and high end estimates 

(Table 4-11). Costs per vessel depend on the type of BWTS used. As described above, 

EPA assumes that 1 percent and 5 percent of vessels may use type approved devices for 

which data are not available in the low and high end estimates, respectively. The costs 

per vessel are then calculated as the weighted average annual frequency of monitoring 

events multiplied by the cost of each monitoring event. For example, for biological 

monitoring, this cost is $473.30 per vessel per year for the low end estimate (0.99 x 2 + 

(1-0.99) x 4) x $234.31)

Vessels Entering the Great Lakes

 Vessel population: EPA estimated the population of vessels potentially subject to the 

Great Lakes-specific requirements based on NBIC data on the number of unique vessels 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 70

(188 vessels) that discharged ballast water in states adjoining the Great Lakes in 2009 

(NBIC, 2011).40 Only a fraction of these discharges, however, are applicable discharges, 

i.e., took place within the Great Lakes, would meet the VGP applicability criteria (i.e., 

vessel operates outside the EEZ and more than 200 nm from shore and has taken on 

ballast with a salinity of less than 18 ppt), and involved vessels that use an onboard 

BWTS. The data is not sufficiently detailed to estimate the exact number of vessels and 

associated discharges subject to the Great Lakes-specific VGP requirement. For the 

purpose of this analysis, EPA assumed that half the discharged volume reported in states 

adjoining the Great Lakes would be subject to the Great Lakes-specific exchange 

requirements. 

 Volume Exchanged and Treated: Based on NBIC data for 2009, vessels discharged a total 

of 1,050,779 m3 of ballast water that year, or an average of 5,590 m3 per discharging 

vessel per year. Some vessels use a flow-through exchange method involving the 

pumping of three times the ballast tank capacity while other vessels simply empty and 

refill their tank. The volume exchanged affects operational costs by increasing pumping 

and treatment costs. In the absence of information on the volume of water exchanged 

using each of these two methods, EPA assumed that 0 to 50 percent of vessels conduct

flow through exchange for the low and high end estimates, respectively. This assumption 

is combined with the assumption regarding the fraction of vessel visits involving 

applicable discharges discussed in the previous paragraph (50 percent) to estimate the 

volume exchanged and treated. Thus, for the low end estimate, EPA assumed that 

525,460 m3

 of ballast water of water must be exchanged and treated (0.5 × 1,050,920 m3). 

For the high end estimate, EPA assumed that 262,730 m3

 are exchanged using the emptyrefill method (half of the volume calculated above), and 788,190 m3

 are exchanged using 

the flow-through method (three times the remaining volume). 

 Baseline: EPA assumed that all exchanges and treatment costs are attributable to this 

requirement. 

The estimated cost per vessel for each practice and the total cost associated with all vessels are

summarized in Table 4-13. 

 

40 Another 751 vessels reported no discharge.
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 71

Table 4-13. Ballast Water Treatment Sensitivity Analysis.

Vessel Class Number of Vessels

Annual Cost per 

Vessel Total Annual Cost

Low End Estimate

BWTS Monitoring

Commercial Fishing 327 $69.13 $22,633 

Freight Barges - - -

Freight Ships 685 $69.13 $47,321 

Passenger Vessels 74 $69.13 $5,122 

Tank Barges - - - 

Tank Ships 25 $69.13 $1,733 

Utility Vessels 40 $69.13 $2,780 

Monitoring TOTAL 1,151 $79,589 

Sampling and Testing (biological)

Commercial Fishing 327 $473.30 $154,964

Freight Barges - - $- 

Freight Ships 685 $473.30 $324,004

Passenger Vessels 74 $473.30 $35,068

Tank Barges - - $- 

Tank Ships 25 $473.30 $11,868

Utility Vessels 40 $473.30 $19,032

Biological Sampling TOTAL 1,151 $544,935

Sampling and Testing (biocides)

Commercial Fishing 164 $802.32 $82,508

Freight Barges - - $- 

Freight Ships 342 $802.32 $172,510

Passenger Vessels 37 $802.32 $18,671

Tank Barges - - $- 

Tank Ships 13 $802.32 $6,319

Utility Vessels 20 $802.32 $10,133

Biocides Sampling TOTAL 576 $290,141

Great Lakes-Specific Requirements

Commercial Fishing - - $- 

Freight Barges - - $- 

Freight Ships 101 $819.47 $82,766 

Passenger Vessels 46 $819.47 $37,948 

Tank Barges - - $- 

Tank Ships 16 $819.47 $12,842 

Utility Vessels 25 $819.47 $20,594 

Biocides Sampling TOTAL 188 $154,151 

Low End Total $1,068,820
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 72

Vessel Class Number of Vessels

Annual Cost per 

Vessel Total Annual Cost

High End Estimate

BWTS Monitoring

Commercial Fishing 491 $69.13 $33,951 

Freight Barges - - $- 

Freight Ships 1,027 $69.13 $70,987 

Passenger Vessels 111 $69.13 $7,683 

Tank Barges - - $- 

Tank Ships 38 $69.13 $2,600 

Utility Vessels 60 $69.13 $4,170 

Monitoring TOTAL 1,727 $119,391 

Sampling and Testing (biological) a

Commercial Fishing 491 $937.20 $241,651 

Freight Barges - - $- 

Freight Ships 1,027 $937.20 $505,253 

Passenger Vessels 111 $937.20 $54,685 

Tank Barges - - $- 

Tank Ships 38 $937.20 $18,507 

Utility Vessels 60 $937.20 $29,678 

Biological Sampling TOTAL 1,727 $849,774 

Sampling and Testing (biocides) a

Commercial Fishing 368 $802.32 $277,508 

Freight Barges - - $- 

Freight Ships 770 $802.32 $580,224 

Passenger Vessels 83 $802.32 $62,799 

Tank Barges - - $- 

Tank Ships 28 $802.32 $21,253 

Utility Vessels 45 $802.32 $34,082 

Biocides Sampling TOTAL 1,295 $975,866 

Great Lakes-Specific Requirements

Commercial Fishing - - $- 

Freight Barges - - $- 

Freight Ships 101 $1,638.93 $165,532

Passenger Vessels 46 $1,638.93 $75,895

Tank Barges - - $- 

Tank Ships 16 $1,638.93 $25,685

Utility Vessels 25 $1,638.93 $41,189

Biocides Sampling TOTAL 188 $308,301

High End Total $2,253,333

Total may not add up due to rounding.

4.2.4 ANTI-FOULING HULL COATINGS

PERMIT REQUIREMENTS

The 2013 VGP clarifies the 2008 VGP requirements regarding the use of TBT, whether or not 

used as a biocide, as well as the use of other non-TBT organotin compounds used as catalysts. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 73

AFFECTED VESSEL POPULATION

Since the Global Anti-fouling System Treaty came into effect on September 22, 2008 and the 

2008 VGP prohibited the use of TBT on all vessels, few vessels are expected to still use TBT on 

their hulls. 

Permit Text: 

2.2.4 Anti-Fouling Hull Coatings/ Hull Coating Leachate 

 All anti-fouling hull coatings subject to registration under FIFRA (see 40 CFR § 152.15) 

must be registered, sold or distributed, applied, maintained, and removed in a manner 

consistent with applicable requirements on the coatings’ FIFRA label. 

 For anti-fouling hull coatings not subject to FIFRA registration (i.e., not produced for 

sale and distribution in the United States), hull coatings must not contain any biocides or 

toxic materials banned for use in the United States (including those on EPA’s List of 

Banned or Severely Restricted Pesticides). This requirement applies to all vessels, 

including those registered and painted outside the United States. 

At the time of initial application or scheduled reapplication of anti-fouling coatings, you must 

give consideration, as appropriate for vessel class and vessel operations, to the use of hull 

coatings with the lowest effective biocide release rates, rapidly biodegradable components (once 

separated from the hull surface), or non-biocidal alternatives, such as silicone coatings.

Some ports and harbors are impaired by copper, a biocide used commonly in anti-foulant paints. 

These waters include Shelter Island Yacht Basin in San Diego, California, and waters in and 

around the ports of Los Angeles/Long Beach. A complete list of such waters may be found at 

www.epa.gov/npdes/vessels. When vessels spend considerable time in these waters (defined as 

spending more than 30 days per year), or use these waters as their home port (i.e., house boats, 

ferries or rescue vessels), vessel owners/operators shall consider using anti-fouling coatings that 

rely on a rapidly biodegradable biocide or another alternative rather than copper-based 

coatings. If after consideration of alternative biocides, vessel operators continue to use copperbased antifoulant paints, they must document in their recordkeeping documentation how this 

decision was reached.

The discharge of Tributyltin (TBT) from any source (whether used as a biocide or not) or any 

other organotin compound used as a biocide is prohibited by this permit. Therefore, vessel 

owners/operators covered by this permit have a zero discharge standard for TBT (whether or not 

used as a biocide) or any other organotin compound used as a biocide. You may not use an 

antifoulant coating containing TBT or any other organotin compound used as a biocide. If the 

vessel has previously been covered with a hull coating containing TBT (whether or not used as a 

biocide) or any other organotin compound used as a biocide, vessels must be effectively 

overcoated so that no TBT or other organotin leaches from the vessel hull or the TBT or other 

organotin coating must have been removed from the vessel’s hull. 

When used as a catalyst, an organotin compound other than TBT (e.g., dibutyltin) is not to be 

present above 2500 mg total tin per kilogram of dry paint. Furthermore, the coating shall not be 

designed to slough or otherwise peel from the vessel hull. Incidental amounts of coating 

discharged by abrasion during cleaning or after contact with other hard surfaces (e.g., moorings) 

are not prohibited. 
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COST ESTIMATES 

No requirements within this discharge category for TBT require cost analysis because these 

requirements already apply in the baseline. EPA assumes that the requirements for other antifouling paints have negligible cost implications. Finally, while vessel owners that decide, after 

consideration of alternative biocides, to continue to use copper based antifoulant paints will have 

to document the basis of their decision, these documentation requirements are anticipated to 

represent a minimal additional burden for these vessel owners relative to the annual paperwork 

burden discussed in Section 4.4. 

4.2.5 AQUEOUS FILM-FORMING FOAM

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that potentially incur incremental costs for these requirements are commercial fishing 

vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with 

applicable requirements. However, EPA has determined that commercial fishing vessels typically 

do not have firefighting systems that require regular AFFF discharge. This discharge category is 

assumed to have zero incremental cost. 

4.2.6 BOILER/ECONOMIZER BLOWDOWN

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that potentially incur incremental costs for these requirements are commercial fishing 

vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with 

applicable requirements. However, EPA has determined that practices applicable to 

boiler/economizer blowdown discharges have negligible costs and/or the industry is assumed to 

currently practice the Permit requirements. This discharge category is assumed to have zero 

incremental cost.

4.2.7 CATHODIC PROTECTION

PERMIT REQUIREMENTS

The 2013 VGP retains the requirements present in the 2008 VGP but adds specific practices to 

prevent the growth of fouling organisms at the sacrificial anode location, when feasible. 

Permit Text [Emphasis added to highlight additional requirement of the 2013 VGP]:

Cathodic protection must be maintained to prevent the corrosion of the ship’s hull. The discharge 

of zinc, magnesium, and aluminum are expected from properly functioning cathodic protection 

sacrificial electrodes. However, vessel operators must minimize the flaking of large, corroded 

portions of these anodes. Sacrificial anodes must not be used more than necessary to adequately 

prevent corrosion of the vessel’s hull, sea chest, rudder, and other exposed areas of the vessel. 

Vessel operators must appropriately clean and/or replace these anodes during periods of 

maintenance (such as drydocking), so that release of these metals to waters is minimized. 

Furthermore, when feasible, sacrificial anodes should be flush-fitted to the hull, or vessel 

operators must fill the space between the anode and hull backing to remove the potential for 

hotspots for fouling organisms. 
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Vessel operators should note that magnesium is less toxic than aluminum and aluminum is less 

toxic than zinc. If vessel operators use sacrificial electrodes, they must select electrode devices 

with metals that are less toxic to the extent technologically feasible and economically practicable 

and achievable. If a vessel selects aluminum, they must document in their recordkeeping 

documentation why they made this selection, and why use of magnesium is not appropriate. 

Likewise, if a vessel selects zinc, they must document why they did not select magnesium or 

aluminum.

EPA recommends the use of Impressed Current Cathodic Protection (ICCP) in place of or to 

reduce the use of sacrificial electrodes when technologically feasible (e.g., adequate power 

sources, appropriate for vessel hull size and design), safe, and adequate to protect against 

corrosion, particularly for new vessels. If vessel operators use ICCP, they must maintain 

dielectric shields to prevent flaking. 

AFFECTED VESSEL POPULATION

Based on the description of practices within this discharge category, all vessels with steel hulls 

within each of the vessel classes are potentially subject to the cathodic protection practices. Data 

from MISLE and WTLUS indicates that approximately 93 percent of vessels overall have steel 

hulls, although the fraction of steel hulled vessels varies by vessel type from 51 percent of 

passenger vessels to over 95 percent of freight barges and tank barges. Commercial fishing 

vessels, 79 percent of which are steel hulled, are newly covered by the VGP and therefore 

potentially incur incremental costs for this discharge category, while other types of vessels only 

potentially incur incremental costs from the additional requirements pertaining to fouling 

organisms. The population potentially affected by practices applicable to the cathodic protection 

discharge category is shown in Table 4-14.

Table 4-14. Vessel Counts for Cathodic Protection Practices. 

Vessel Class Vessel Counta

Commercial Fishing 1,967 

Freight Barges 38,834 

Freight Ships 730 

Passenger Vessels 1,018 

Tank Barges 6,941 

Tank Ships 276 

Utility Vessels 5,235 

TOTAL 55,002

a Includes steel hulled vessels only.

COST ESTIMATES 

Consistent with information obtained while developing the 2008 VGP, EPA assumes that there 

are no incremental costs to vessels for implementing cathodic protection on applicable vessels 

since steel hulled vessels generally have either an ICCP or a sacrificial electrodes system of 

cathodic protection (EPA, 2008). EPA expects that this is also the case for steel hulled 

commercial fishing vessels newly covered by the 2013 VGP. 
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Practices aimed at preventing potential hotspots for fouling organisms (anodes to be flush-fitted 

to the hull or a backing to be inserted in the space between the anode and the hull) are assumed to 

already be implemented and therefore do not represent incremental costs on vessel owners.

A sensitivity analysis was performed to estimate potential costs of cathodic protection installation 

for vessels that will opt to purchase an ICCP system in accordance with the Permit 

recommendations. In the sensitivity analysis EPA has estimated a potential low and high 

incremental cost associated with cathodic protection installation. These low and high estimates 

are based upon the percentage of vessels that may need to install an updated system.

Practices associated with maintenance and replacement of the cathodic protection system will not 

incur incremental costs, and no sensitivity analysis is performed since these practices are 

regularly performed when deemed necessary. 

Finally, documentation of the anode selection is anticipated to represent a minimal additional 

burden for the subset of vessel owners that use aluminum or zinc, relative to the annual 

paperwork burden discussed in Section 4.4. 

SENSITIVITY ANALYSIS

Costs of installing either an ICCP or a sacrificial electrodes system of cathodic protection were 

estimated based upon communication with a cathodic protection manufacturing company (see 

EPA, 2008). The cost input values of cathodic protection system installation are shown in Table 

4-15 (escalated to 2010 dollars), and the estimates/assumptions derived for each practice are 

described below. 

Table 4-15. Cathodic Protection Installation Cost Estimates (2010$). 

Vessel Class Low End 

Installation Cost

High End 

Installation Cost

Average Installation 

Cost

Commercial Fishing $16,574 $19,889 $18,232 

 Installation Costs: Cost estimates were obtained from a representative from a cathodic 

protection manufacturing company. The figures are dependent upon the area of steel on 

the hull as well as other minor components. Commercial fishing vessels are assumed to 

have costs similar to those of freight ships. The cost estimates shown in Table 4-15 were 

originally provided in 2008 dollars and escalated to 2010 dollars using the consumer cost 

index from the Bureau of Labor Statistics.

 Baseline: For the low end estimate, EPA assumes that no commercial fishing vessel will 

install an ICCP system due to the Permit recommendations. For the high end estimate, the 

fraction is assumed to be 5 percent.

 Equipment Life: The ICCP system is expected to last for the lifetime of the vessel. Thus, 

the total incremental cost of the device is annualized at a 7 percent discount rate over 

30 years to estimate the annual cost per vessel presented in Table 4-16.

The cost per vessel and the total cost associated with all vessels are presented in Table 4-16. At 

the low end, there is no incremental cost. At the high end, if 5 percent install an ICCP system, the 

potential incremental cost is approximately $144,500. 
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Table 4-16. Cathodic Protection Sensitivity Analysis, Purchase of a Cathodic Protection System.

Vessel Class

Vessel 

Counta

% Vessels 

Needing to 

Purchase 

System

Annual Cost per 

Vesselb

Total 

Annual Cost

Low End Estimate

Commercial Fishing 1,967 0% $1,469.22 $0

Low End TOTAL 1,967 $0

High End Estimate

Commercial Fishing 1,967 5% $1,469.22 $144,496 

High End TOTAL 1,967 $144,496

a Applies to steel hulled vessels only.

b Annualized at a 7% discount rate over 30 years.

4.2.8 CHAIN LOCKER EFFLUENT

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that practices applicable to chain locker effluent discharges are 

found in only a subset of vessel classes. The practices in this category are applicable to freight 

ships, tank ships, and various utility vessels; they do not apply to the other vessel classes because 

their anchors are rarely or never deployed or other equipment is used (e.g., anchor cable). Since 

the 2013 VGP requirements are unchanged from current practices and since chain locker effluent 

discharges are not applicable to newly covered commercial fishing vessels, no vessel is assumed 

to incur incremental cost as a result of the 2013 permit. 

Furthermore, EPA’s analysis of the 2008 VGP had found that most practices in the chain locker 

effluent discharge category were already implemented by the industry even before the VGP was 

promulgated (EPA, 2008). For vessel types to which the discharge category applies, EPA had 

performed a sensitivity analysis only for the potential incremental costs associated with washing 

down the anchor chain as it is being hauled out of the water. In the sensitivity analysis EPA 

estimated a potential low and high incremental cost associated with washing down the anchor 

chain ranging from 0 to $4.74 per vessel per year (in 2008$). 
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4.2.9 CONTROLLABLE PITCH PROPELLER AND THRUSTER HYDRAULIC FLUID AND 

OTHER OIL SEA INTERFACES INCLUDING LUBRICATION DISCHARGES FROM 

PADDLE WHEEL PROPULSION, STERN TUBES, THRUSTER BEARINGS, 

STABILIZERS, RUDDER BEARINGS, AZIMUTH THRUSTERS, PROPULSION POD 

LUBRICATION, AND WIRE ROPE AND MECAHNICAL EQUIPMENT SUBJECT TO 

IMMERSION

PERMIT REQUIREMENTS

The Permit requirements to minimize the discharge of oil are generally unchanged. The 2013 

VGP, however, introduces requirements for new build vessels (those constructed after December 

19, 2013) to use environmentally acceptable lubricants (EALs) in all oil-to-sea interfaces.41 An 

existing vessel (one constructed before December 19, 2013) must use EALs in their oil-to-sea 

interfaces unless it is technically infeasible. If an existing vessel finds it is technically infeasible 

to use an environmentally acceptable lubricant for their vessel, the owner/operator must explain 

why they cannot do so in their recordkeeping documentation, and must note the use of a nonenvironmentally acceptable lubricant in the vessel’s Annual Report. 

Permit Text [Emphasis added to highlight new requirements of the 2013 VGP.]:

2.2.9 Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil-to-Sea 

Interfaces Including Lubrication Discharges from Paddle Wheel Propulsion, Stern Tubes, 

Thruster Bearings, Stabilizers, Rudder Bearings, Azimuth Thrusters, Propulsion Pod Lubrication, 

and Wire Rope and Mechanical Equipment Subject to Immersion 

The protective seals on controllable pitch propellers, azimuth thrusters, propulsion pods, rudder 

bearings, or any other oil-to-sea interfaces must be maintained in good operating order to 

minimize the leaking of hydraulic oil or other oils. The vessel owner/operator must not discharge 

oil in quantities that may be harmful as defined in 40 CFR Part 110 from any oil-to-sea interface. 

If possible, maintenance activities on controllable pitch propellers, thrusters, and other oil-to-sea 

interfaces should be conducted when a vessel is in drydock. 

Minimize maintenance activities on stern tube seals when a vessel is outside of drydock. If 

maintenance or emergency repair must occur on stern tubes or other oil-to-sea interfaces which 

have a potential to release oil in quantities that may be harmful as defined in 40 CFR Part 110, 

appropriate spill response equipment (e.g., oil booms) must be used to contain any oil leakage. 

Operators of the vessel must have ready access to spill response resources to clean up any oil 

spills.

After applying lubrication to wire rope and mechanical equipment subject to immersion, wire 

ropes, and other equipment must be thoroughly wiped down to remove excess lubricant. 

All vessels constructed on or after December 19, 2013 must use an environmentally acceptable 

lubricant in all oil-to-sea interfaces. “Environmentally acceptable lubricants” means 

 

41 Part 7 of the permit defines environmentally acceptable lubricants to denote a lubricant that is biodegradable, 

exhibits low toxicity to aquatic organisms and has a low potential for bioaccumulation.
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lubricants that are “biodegradable” and “non-toxic” and are not “bioaccumulative” as defined 

in Appendix A of this permit. 

For all vessels built before December 19, 2013, unless technically infeasible, owners/operators 

must use an environmentally acceptable lubricant in all oil to sea interfaces. If a vessel is 

unable to use an environmentally acceptable lubricant, you must document in your 

recordkeeping documentation consistent with Part 4.2 why you are unable to do so, and must 

report the use of a non-environmentally acceptable lubricant to EPA in your Annual Report. 

Use of an environmentally acceptable lubricant does not authorize the discharge of any 

lubricant in a quantity that may be harmful as defined in 40 CFR Part 110. 

AFFECTED VESSEL POPULATION

As for other discharge categories, commercial fishing vessels which are newly covered under the 

2013 VGP may incur incremental costs of all practices contained under this category, while other 

vessel types are already complying with the 2008 VGP and only incur incremental costs, if any, 

associated with the revised requirements to use environmentally acceptable lubricants. 

Based on the description of practices within this discharge category, all vessels have the potential 

to discharge oil due to oil-to-sea interface and a subset of vessel classes, including commercial 

fishing vessels, freight ships, tank ships, and various utility vessels have the potential to discharge

controllable pitch propeller hydraulic fluid. No other vessel classes are expected to operate 

controllable pitch propellers. 

In establishing the different requirements for new build vessels versus existing vessels, EPA 

considered the processes employed and potential changes which might be necessary by some 

existing vessels to use EALs. Many existing vessels can use EALs which are compatible with 

their existing equipment. However, the requirement is specified as to be only required where 

technically feasible. This recognizes the possibility that while it is technically feasible for many 

existing vessels to use EALs, it might not be technically feasible for these vessels to use EALs 

with all existing equipment. In contrast, new build vessels can select equipment during design and 

construction which is compatible with EALs. Furthermore, they can design additional onboard 

storage area for EALs if they choose to use traditional mineral based oil for engine lubrication 

(thereby needing two types of oils on-hand). 

The population potentially affected by practices applicable to this discharge category is shown in 

Table 4-17.
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Table 4-17. Vessel Counts for General Oil-to-Sea Interface and Controllable Pitch Propeller 

Hydraulic Fluid Practices. 

Vessel Class Vessel Count

(oil to sea interface)

Vessel Count

(controllable pitch 

propeller)

Commercial Fishing 2,326 2,326 

Freight Barges 39,760 - 

Freight Ships 812 812 

Passenger Vessels 1,970 - 

Tank Barges 7,144 - 

Tank Ships 332 332 

Utility Vessels 6,258 6,258 

TOTAL 58,602 9,728

COST ESTIMATES 

Based upon the industry input to the 2008 VGP, maintenance of the controllable pitch propeller is 

already performed when in drydock and, when applicable, oil booms and oil absorbent pads are 

purchased and are in use. Therefore, requirements present in the 2008 VGP are assumed to 

impose no incremental costs on commercial fishing vessels newly covered by the 2013 VGP. 

The use of environmentally preferred lubricants may impose incremental costs on all covered 

vessels to the degree that these products are more (or less) expensive than the conventional 

products. 

For environmentally acceptable lubricants, EPA obtained cost data from retailers of marine 

lubricants. Pricing data suggest a wide variability in the cost of different types of lubricants, 

depending on their use and formulation. On average, EPA found that EALs are 38 percent more 

expensive than conventional (e.g., mineral-based lubricants) although this difference is not 

always present and some EALs appear to be priced similarly as synthetic lubricants. These 

findings appear to be consistent with input from industry representatives EPA interviewed who 

indicated that EALs from vegetable sources are 10 percent to 50 percent more expensive than 

conventional lubricants but also noted that synthetic-based lubricants tend to be significantly 

more expensive than mineral-based lubricants (twice to four times more expensive).42 

Publicly available information on the price of EALs tends to be for retail purchases of relatively 

small quantities of lubricants by recreational boaters. These prices are likely to be significantly 

higher than the price paid by the owner of a larger vessel such as those covered by the VGP. EPA 

contacted several manufacturers and distributors of EALs to get information on large quantity 

pricing, but representatives contacted were generally unable to provide average prices or price

differences between the products, noting that this type of information is proprietary. One industry 

representative offered an illustrative example of the price difference between EALs and 

 

42 Anecdotal estimates on cost differences between EALs and conventional lubricants varied widely. Industry 

representatives generally noted that EALs are more expensive than mineral-based lubricants with one industry 

representative offering an approximate ratio at 3 to 1.
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conventional lubricants with the unit price for a standard lubricant ($7.80/gallon) being half that 

of the equivalent biodegradable, vegetable-based product ($15.40/gallon).43 

Information on average consumption of lubricants by different types of vessels was similarly 

difficult to obtain from published sources or directly from vessel owners with industry 

representative noting that the quantities vary widely across vessels.

In one published study, Etkin (2010) estimated the volume of oil leaks from vessels based on 

prior studies and five years of data of in-port lubricant replacement rates from a lubricant 

supplier. Sources of operational discharges discussed in the study include deck machinery and inwater (submerged) machinery such as stern tube bearings, thruster gearboxes, and horizontal 

stabilizers. The data show leak rates that vary by vessel type, condition, age, and maintenance. 

The average daily stern tube lubricant consumption rate across vessel types is reported as 2.6 

liters per day, but ranges from less than 1 liter per day to 20 liters per day. The highest average 

rate is associated with barge carriers while several utility vessels (e.g., patrol vessel, dredger) and 

fishing vessels had rates in the lower end of the range. In addition to stern tube leakage, Etkin 

(2010) also provides estimates of lubricant leakage from deck machinery and in-water submerged 

machinery. Consumption of oil used as lubricant in-water submerged applications is estimated to 

range between 1 and 29 liters per port visit, depending on the type of vessel. Values derived from 

Etkin (2010) are within the range of annual consumption estimates EPA was gathered anecdotally 

from industry representative for different types of vessels. 

For the sensitivity analysis presented below, EPA used the illustrative average oil consumption 

rates due to leakage and illustrative incremental costs to estimate potential incremental costs to

vessel owners for replacing conventional lubricants with EALs in all oil-to-sea interfaces. 

SENSITIVITY ANALYSIS

Consumption estimates are based on values presented in Etkin (2010) as summarized in Table 

4-18. These estimates represent consumption of lubricants due to leakage. To the degree that they 

do not account for replacement of oil remaining in the various systems, these values may 

underestimate total lubricant consumption. 

 

43 The products are considered to offer similar performance and characteristics. Note that EALs may offer 

performance advantages over mineral-based oils: information obtained from another manufacturing company 

representative suggests that EALs may provide measurable performance advantages, including an extended life (50 to 

100 percent increase is reported) when compared to conventional mineral-based oils.
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Table 4-18: Lubricant Consumption Rates by Vessel Class. 

Vessel Class

Consumption 

rate for stern 

tube bearing 

(liters/day)

Consumption 

rate for all 

other 

submerged 

equipment 

(liters/day)

Total 

(liters/day)

Total 

(gallons/day)

Total 

(gallons/year)a

Commercial Fishing 2.0 3.0 5.0 1.3 121 

Freight Barges - 1.0 1.0 0.3 24 

Freight Ships 7.0 7.0 14.0 3.7 337 

Passenger Vessels 2.0 3.3 5.3 1.4 128 

Tank Barges - 1.0 1.0 0.3 24 

Tank Ships 5.0 1.5 6.5 1.7 157 

Utility Vessels 1.5 6.0 7.5 2.0 181 

Source: Etkin (2010). Consumption rates are attributed to each vessel class based on the average rates for 

corresponding types of vessel presented in Etkin (2010). 

a Assumes that consumption while in port covers days when vessels are traveling between ports. Vessels are assumed 

to spend 3 days in travel for each day in port.

The sensitivity analysis also uses the following assumptions.

 Lubricant Costs: A wide range of lubricants are used in marine applications with very 

diverse prices and quantities used. EPA was not able to obtain specific data on the 

relative consumption rates of different categories of lubricants by vessels covered by the 

VGP. As an upper bound estimate of the potential incremental cost, EPA assumed a price 

difference of 120 percent, based on the illustrative example provided by one industry 

representative ($15.40 per gallon vs. $7.80 per gallon). For the lower bound estimate, 

EPA assumed a 50 percent difference in price, based on EPA’s review of retail prices for 

different types of lubricants marketed for marine application, which found an average 

price difference of 38 percent. The same baseline price of $7.80 per gallon was assumed 

for both the low and high bound estimates, based on the illustrative example discussed 

earlier in this section. The incremental cost incurred by a vessel owner is therefore 

assumed to range between $4 and $8 per gallon. 

 Baseline: As low end estimate, EPA assumed that 5 percent of existing and 15 percent of 

new vessels use EALs (or alternatively, EALs represent 2.5 percent and 5 percent of 

lubricant uses) in the baseline. As high end estimate, EPA assumed that only 2.5 percent 

of existing vessels and 5 percent of new vessels use EALs.

 Implementation Rate: As low end estimate, EPA assumed that all new vessels and

50 percent of existing vessels would replace their existing lubricants with EALs while for 

the high end estimate, EPA assumed that all new vessels and 75 percent of existing 

vessels would do so.

The cost per vessel for each practice and the total cost associated with all vessels are provided in 

Table 4-19. The annual incremental costs for all vessels range from approximately $6.0 million to 

$18.3 million.
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Table 4-19. Environmentally Acceptable Lubricants Sensitivity Analysis. 

Vessel Class Vessel Counta

% Vessels 

where 

Practice is 

Applicableb

Annual Cost 

per Vessel

Total Annual 

Cost

Low End Estimate (Average Incremental Cost $4/gallon)

Use EAL

Commercial Fishing 2,315 49% $482 $534,654 

Freight Barges 39,757 48% $96 $1,821,140 

Freight Ships 765 50% $1,350 $544,316 

Passenger Vessels 1,959 48% $514 $483,069 

Tank Barges 7,138 48% $96 $327,422 

Tank Ships 312 50% $627 $103,580 

Utility Vessels 6,185 48% $723 $2,169,474 

Low End TOTAL 58,431 $5,983,656

High End Estimate (Average Incremental Cost $8/gallon)

Use EAL

Commercial Fishing 2,315 73% $964 $1,642,369 

Freight Barges 39,757 73% $193 $5,606,986 

Freight Ships 765 74% $2,700 $1,630,424 

Passenger Vessels 1,959 73% $1,028 $1,483,289 

Tank Barges 7,138 73% $193 $1,007,702 

Tank Ships 312 74% $1,254 $309,930 

Utility Vessels 6,185 73% $1,446 $6,641,840 

High End TOTAL 58,431 $18,322,539

a Existing and new vessels, assuming that vessels are replaced at the rate of 1/30th of the population each year.

b Fraction represents the combination of assumptions on the fraction of new and existing vessels that implement the 

practice in the baseline and those anticipated to use EALs under the 2013 VGP.

4.2.10 DISTILLATION AND REVERSE OSMOSIS BRINE

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that practices applicable to discharges of distillation and reverse 

osmosis brine have negligible costs and/or the industry is assumed to currently practice the Permit 

requirements. This discharge category is assumed to have zero incremental cost.

4.2.11 ELEVATOR PIT EFFLUENT

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that these vessels typically do not have elevator pit effluent. They 

do not incur an incremental cost as a result of their VGP coverage and this discharge category 

therefore is assumed to have zero incremental cost.
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4.2.12 FIREMAIN SYSTEMS

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that firemain systems are uncommon on commercial fishing 

vessels and these vessels therefore do not incur an incremental cost as a result of their VGP 

coverage. This discharge category is assumed to have zero incremental cost.

4.2.13 FRESHWATER LAYUP

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that freshwater layup discharges are uncommon to commercial 

fishing vessels and these vessels therefore do not incur an incremental cost as a result of their 

VGP coverage. This discharge category is assumed to have zero incremental cost.

4.2.14 GAS TURBINE WASH WATER

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that gas turbine wash water discharges are generally not present 

on commercial fishing vessels and these vessels therefore do not incur an incremental cost as a 

result of their VGP coverage. This discharge category is assumed to have zero incremental cost.

4.2.15 GRAYWATER

Graywater is defined in the Vessel General Permit as the discharge derived from “galley, bath and 

shower water, as well as wastewater from lavatory sinks, laundry, and water fountains” (EPA, 

2010a). The 2008 VGP contains a number of special provisions applying to discharges of 

graywater from cruise ships, specifying treatment standards for graywater discharges in port or 

within 1 nm of shore, and requiring that releases between 1 and 3 nm of shore occur only when 

traveling at a speed of at least 6 knots. These requirements were established based on the U.S. 

Coast Guard Limitations on Discharge of Treated Sewage or Graywater in Alaska, promulgated 

in 2001 (33 CFR 159). Even before the 2008 VGP was finalized, several other states had existing 

requirements for graywater discharges. For example, Maine adopted Alaska’s discharge 

requirements for vessels with passenger capacities of at least 250 under the 2003 Act to Protect 

Maine’s Coastal Waters and the California Clean Coast Act, enacted in 2004, prohibits cruise 

ships from discharging any graywater into California’s territorial waters. Additionally, several 

states, including Washington, Hawaii, and Florida, had voluntary memoranda of understanding 
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November 30, 2011 85

with the cruise ship industry that discourage the discharge of untreated graywater in port or 

within 4 nm of shore.44 

Also relevant to graywater discharges are two other federal regulations. First, under Section 

312(a) of the CWA, graywater discharges from commercial vessels in the Great Lakes region are 

currently treated as sewage and thus are excluded from the scope of the VGP. Second, the 

National Marine Sanctuaries Act authorizes the National Oceanic and Atmospheric 

Administration (NOAA) to designate National Marine Sanctuaries wherein certain discharges, 

including graywater, may be restricted to protect sensitive ecosystems. 

PERMIT REQUIREMENTS

The 2013 VGP generally maintains graywater requirements contained in the 2008 VGP but 

additionally requires that any vessel constructed on or after December 19, 2013 which provide 

overnight accommodation to at least 10 crew and any vessel operating on the Great Lakes that is 

not a “commercial vessel” comply with additional requirements. If they discharge graywater, 

these vessels must conduct monitoring. Effluent limits for non “commercial vessels” (as defined 

in CWA Section 312(a)(10)) operating on the Great Lakes are specified as no more than 

200 cfu/100 ml fecal coliform and no more than 150 mg/l of suspended solids 

Part 2.2.15.2 of the 2013 VGP states that samples must be taken for BOD, fecal coliform, 

suspended solids, pH, and total residual chlorine, and that sampling must be conducted in 

accordance with the 40 CFR Part 136 methods. Samples taken from non-commercial vessels 

operating on the Great Lakes must meet the standards specified in Part 2.2.15.1 of the permit, 

which pertain to fecal coliform and suspended solids. Records of monitoring information must 

include the date, exact place, and time of sampling/measurements, the individual(s) who 

performed the sampling/measurements, the date(s) the analyses were performed, the individual(s) 

who performed the analyses, the analytical techniques/methods used, and the results of such 

analyses.

All records of the sampling and testing results must be retained onboard in the vessel’s 

recordkeeping documentation for 3 years. 

Permit Text [emphasis added to highlight principal revisions and new requirements of the 2013 

VGP]:

2.2.15 Graywater 

All vessels must minimize the discharge of graywater while in port. For those vessels that cannot 

store graywater, the owner or operator and their crews must minimize the production of 

graywater in port. Examples of ways to minimize production of graywater include delaying 

laundry, scullery activities, and restricting length of showers while in port, and using high 

efficiency faucets and showerheads. All vessels that have the capacity to store graywater shall 

 
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not discharge it in waters listed in Appendix G. For vessels that cannot store graywater, vessel 

operators must minimize the production of graywater while in waters listed in Appendix G. 

For vessels greater than 400 gross tons that regularly travel more than 1 nm from shore that 

have the capacity to store graywater for a sufficient period, graywater must be discharged 

greater than 1 nm from shore while the vessel is underway, unless the vessel meets the treatment 

standards and other requirements contained under Parts 5.1.1 and 5.1.2 or 5.2.1 and 5.2.2 of this 

permit. Additional specific requirements for graywater apply to cruise ships (Parts 5.1 and 5.2) 

and large ferries (Part 5.3).

Vessels that do not travel more than 1 nm from shore shall minimize the discharge of graywater 

and, provided the vessel has available graywater storage capacity, must dispose of graywater 

onshore if appropriate facilities are available and such disposal is economically practicable and 

achievable unless the vessel meets the treatment standards and other requirements contained 

under Parts 5.1.1 and 5.1.2 or 5.2.1 and 5.2.2 of this permit. You must also minimize the 

discharge of graywater when the vessel is not underway. 

If graywater will be discharged in waters subject to this permit, the introduction of kitchen oils to 

the graywater system must be minimized. When cleaning dishes, you must remove as much food 

and oil residue as practicable before rinsing dishes. Excess oils used in cooking, including 

animal fats and vegetable oils, shall not be added to the graywater system. Under no 

circumstances may oil from the galley and scullery be discharged in quantities that may be 

harmful as defined in 40 CFR Part 110. 

Vessel owners/operators must use phosphate-free and non-toxic soaps and detergents, as defined 

in Appendix A of this permit, for any purpose if graywater will be discharged into waters subject 

to this permit. Soaps and detergents must be free from toxic or bioaccumulative compounds and 

not lead to extreme shifts in receiving water pH. For purposes of this part, extreme shifts means 

causing pH to fall below 6.0 or rise above 9.0 as a direct result of the discharge.

If your vessel is underway in a nutrient-impaired water, or a water that is impaired as a result of 

nutrient enrichment (such as waters listed as impaired for phosphorus, nitrogen, or for hypoxia 

or anoxia [low dissolved oxygen concentrations]), you must follow these additional 

requirements:

 When the vessel has adequate graywater storage capacity, the vessel owner/operator 

shall not discharge graywater into nutrient-impaired waters subject to this permit (e.g., 

the Chesapeake Bay). A complete list of such waters can be found at 

www.epa.gov/npdes/vessels. 

 Where the vessel does not have adequate storage capacity to eliminate such discharges, 

graywater production and discharge must be minimized in such waters. Any such 

discharge must be conducted while the vessel is underway in areas with significant 

circulation and depth to the extent feasible. Graywater stored while in such waters can 

later be disposed of onshore or discharged in accordance with the other requirements of 

this permit. 

2.2.15.1 Additional Graywater Requirements for Certain VGP Vessels Operating in the 

Great Lakes 
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Any vessel operating on the Great Lakes that is not a “commercial vessel” as defined in CWA 

section 312(a)(10) must meet one of the following requirements for graywater management:

(i) The vessel must hold all graywater for onshore discharge to an appropriate shoreside 

facility; or 

(ii) The graywater discharge must not exceed 200 fecal coliforms per 100 milliliters and 

contain no more than 150 milligrams per liter of suspended solids.

Vessels subject to this part must conduct monitoring required under Part 2.2.15.2 to 

demonstrate treatment equipment maintenance and compliance with the limits of this part. 

Records of the sampling and testing results must be retained onboard for a period of 3 years in 

the vessel’s recordkeeping documentation consistent with Part 4.2 of this permit.

2.2.15.2 Graywater Monitoring 

The following monitoring requirements are applicable to vessels which discharge graywater 

into waters subject to this permit and meet one of the following conditions:

 The vessel is a new build vessel constructed on or after December 19, 2013, has a 

maximum crew capacity greater or equal to 10, and provides overnight 

accommodations to those crew; or 

 The vessel is subject to Part 2.2.15.1 of this permit. 

Vessel owners/operators must conduct and analyze two samples per year, at least 14 days apart, 

and report the results of those samples as part of their Annual Report. Samples must be taken 

for Biochemical Oxygen Demand (BOD), fecal coliform, suspended solids, pH, and total 

residual chlorine. Sampling and testing shall be conducted according to 40 CFR Part 136. If 

the vessel is subject to Part 2.2.15.1, measured samples must meet the standards specified in 

that part.

Records of monitoring information shall include:

 The date, exact place, and time of sampling or measurements;

 The individual(s) who performed the sampling or measurements;

 The date(s) analyses were performed;

 The individual(s) who performed the analyses; 

 The analytical techniques or methods used; and

 The results of such analyses.

Vessels subject to this part must note whether the graywater effluent is treated or untreated, 

and also note whether the effluent is graywater alone or if it is mixed with another effluent type 

(e.g., graywater mixed with sewage). Records of the sampling and testing results must be 

retained onboard for a period of 3 years in the vessel’s recordkeeping documentation 

consistent with Part 4.2. 

Vessels which do not enter waters subject to this permit for the calendar year need not conduct 

monitoring for that year, but must clearly indicate on their Annual Report that they did not 

enter waters subject to this permit during that year. 
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AFFECTED VESSEL POPULATION

Practices related to graywater discharges are potentially applicable to every vessel class except 

for freight barges and tank barges (as those vessels do not produce graywater). All applicable 

vessels with the exception of commercial fishing vessels are assumed to currently implement the 

2008 VGP requirements; unchanged 2013 VGP requirements potentially represent an incremental 

cost for owners of commercial fishing vessels. 

Additional graywater monitoring requirements apply to certain vessels. NOIs received by EPA to 

date show that 1 percent of vessels overall use onboard treatment for their graywater, with the 

largest share of vessels using graywater treatment being large and medium cruise ships, followed 

by large ferries. The revised requirements are not expected to change current practices, as vessels 

that currently hold their graywater are expected to continue doing so. Characteristics of vessels 

that had submitted an NOI as of August 2010 suggest that 10 percent of existing passenger 

vessels use graywater treatment. Smaller fractions of tank ships and freight ships (2 percent) and 

commercial fishing vessels and utility vessels (1 percent) have graywater treatment onboard. In 

the aggregate, an estimated 11,698 vessels are assumed to implement onboard graywater 

treatment in the baseline. 

In addition, the 2013 VGP requires certain new build vessels that discharge graywater to comply 

with monitoring requirements. New build vessels subject to the monitoring requirements are 

those constructed on or after December 19, 2013, with maximum crew capacity greater or equal 

to 10, and overnight accommodations for those crew. Except for barges which provide no crew 

accommodation, and utility vessels where EPA assumed that about a quarter meet the criteria, all 

new vessels are assumed to potentially be subject to the graywater monitoring requirements. The 

number of new vessels in each class was estimated at 1/30th of the vessel population, based on an 

assumed vessel life of 30 years. 

New requirements for non “commercial vessels” (as defined in CWA Section 312(a)(10)) that 

travel in the Great Lakes are applicable to any vessel that is not “used in the business of 

transporting property for compensation or hire, or in transporting property in the business of the 

owner, lessee, or operator of the vessel.” (33 U.S.C. 1322 (a)(10)). EPA has included the 

requirement so that there is no ambiguity that any non-recreational, non-military vessel greater 

than 79 feet is expected to treat or hold their graywater when operating on the Great Lakes. 

Numerous vessels are considered “commercial vessels” under Section 312(a)(10) of the Clean 

Water Act and currently either hold their graywater for onshore disposal at a sewage treatment 

plant or treat that graywater using an existing Marine Sanitation Device. Hence, holding capacity 

is present on some vessels or treatment devices are available and used for managing graywater 

from vessels operating on the Great Lakes and EPA believes most, if not all, VGP eligible vessels 

operating on the Great Lakes should already be meeting these conditions. 

The population potentially affected by revisions to requirements applicable to the graywater 

discharge category is shown in Table 4-20.
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Table 4-20. Vessel Counts for Graywater Practices. 

Vessel Class Number of 

Existing 

Vessels

Fraction of 

Existing 

vessels a

Total Existing 

Vessel Count

Total New 

Vessel Count 

(low 

estimate)b

Total New 

Vessel Count 

(high 

estimate)c

Commercial Fishing 2,326 1% 33 98 195 

Freight Barges 39,760 0% - - - 

Freight Ships 812 2% 13 51 68 

Passenger Vessels 1,970 10% 205 149 165 

Tank Barges 7,144 0% - - - 

Tank Ships 332 2% 5 21 28 

Utility Vessels 6,258 1% 63 52 131 

TOTAL 58,602 319 370 586 

a Fractions are based on characteristics of vessels that submitted an NOI.

b Average number of new vessels subject to the requirements is estimated based on replacement of 1/30th of the 

vessel population each year during over the 5-year permit. 75% of commercial fishing, freight ships, tank ships, and 

passenger vessels are assumed to potentially discharge graywater, while 10% of utility vessels are assumed to 

provide overnight accommodation for at least 10 crews. 

c Average number of new vessels subject to the requirements is estimated based on replacement of 1/30th of the 

vessel population each year during over the 5-year permit. All commercial fishing, freight ships, tank ships, and 

passenger vessels are assumed to potentially discharge graywater, while a quarter of utility vessels are assumed to 

provide overnight accommodation for at least 10 crews.

d The number of passenger vessels is adjusted to account for the 113 passenger vessels (cruise ships) previously 

estimated to comply with the treatment requirements in the 2008 VGP analysis (see EPA, 2008)

COST ESTIMATES 

Additional monitoring requirements for vessels that discharge treated graywater have the 

potential to impose incremental compliance cost on the owners of these vessels. Monitoring 

requirements are similar to those contained in the 2008 VGP for medium and large cruise ships, 

except for their lower annual frequency. Costs for implementing the monitoring requirements are

estimated at $201 per monitoring event, which covers analytical testing ($137 for all four 

parameters), sampling, administration, and reporting (one labor hour at an assumed average 

hourly rate of $33.72), and incidental expenses such as shipping ($30). 

SENSITIVITY ANALYSIS

The sensitivity analysis uses the following assumptions.

 Monitoring Costs: Per event costs are assumed to be $201, inclusive of all labor and 

material. 

 Baseline: EPA assumed that all cruise ships for which the requirement applies currently 

comply with the vessel type specific requirements in the 2008 VGP and therefore will not 

incur incremental costs as a result of the revised graywater requirements for all vessel 

types. The fraction of vessels that may treat rather than hold their graywater is assumed 

based on vessel characteristics from NOIs received by EPA as of August 2010. 

 Implementation Rate: EPA assumed that 100 percent of applicable vessels will need to 

conduct the additional monitoring. 
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The cost per vessel for each practice and the total cost associated with all vessels are provided in 

Table 4-19. The annual incremental costs range from approximately $231,000 to $318,000. 

Table 4-21. Graywater Monitoring Sensitivity Analysis.

Vessel Class

Existing 

Vessel Counta

New Vessel 

Count

Annual Cost 

per Vessel

Total Annual 

Cost

Low End Estimate

Monitor Graywater

Commercial Fishing 33 98 $402 $52,414 

Freight Barges - - $402 $0 

Freight Ships 13 51 $402 $25,554 

Passenger Vessels 92 149 $402 $96,594 

Tank Barges - - $402 $0 

Tank Ships 5 21 $402 $10,292 

Utility Vessels 63 52 $402 $46,289 

Low End TOTAL 206 370 $231,144 

High End Estimate

Monitor Graywater

Commercial Fishing 33 195 $402 $91,574

Freight Barges - - $402 $0

Freight Ships 13 68 $402 $32,332

Passenger Vessels 92 165 $402 $103,221

Tank Barges - - $402 $0

Tank Ships 5 28 $402 $13,053

Utility Vessels 63 131 $402 $77,768

High End TOTAL 206 586 $317,948

a For passenger vessels, the number of vessels that have incremental cost is further adjusted by removing the large and 

medium cruise ships assumed to already be implementing monitoring requirements under the 2008 VGP. 

4.2.16 MOTOR GASOLINE AND COMPENSATING DISCHARGE

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that practices applicable to motor gasoline and compensating 

discharges have negligible costs and/or the industry is assumed to currently practice the Permit 

requirements (e.g., in compliance with the oil discharge prohibition in 40 CFR part 110). This 

discharge category is assumed to have zero incremental cost.

4.2.17 NON-OILY MACHINERY WASTEWATER

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that practices applicable to non-oily machinery wastewater 

discharges have negligible costs and/or the industry is assumed to currently practice the Permit 
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requirements (e.g., in compliance with the oil discharge prohibition in 40 CFR part 110). This 

discharge category is assumed to have zero incremental cost.

4.2.18 REFRIGERATION AND AIR CONDENSATE DISCHARGE

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that practices applicable to refrigeration and air condensate 

discharges have negligible costs and/or the industry is assumed to currently practice the Permit 

requirements (e.g., in compliance with the oil discharge prohibition in 40 CFR part 110). This 

discharge category is assumed to have zero incremental cost.

4.2.19 SEAWATER COOLING OVERBOARD DISCHARGE (INCLUDING NON-CONTACT

ENGINE COOLING WATER, HYDRAULIC SYSTEM COOLING WATER, 

REFRIGERATION COOLING WATER)

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that practices applicable to seawater cooling overboard discharges 

have negligible costs and/or the industry is assumed to currently practice the Permit requirements 

(e.g., in compliance with the oil discharge prohibition in 40 CFR part 110). This discharge 

category is assumed to have zero incremental cost.

4.2.20 SEAWATER PIPING BIOFOULING PREVENTION

The 2013 VGP requirements for this discharge category are fundamentally similar to the 2008 

VGP requirements. Therefore, the only vessels that are potentially impacted by this section are 

commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to 

comply with applicable requirements. However, EPA has determined that practices applicable to 

seawater piping biofouling prevention discharges have negligible costs and/or the industry is 

assumed to currently practice the Permit requirements (e.g., in compliance with the oil discharge 

prohibition in 40 CFR part 110). This discharge category is assumed to have zero incremental 

cost.

4.2.21 SMALL BOAT ENGINE WET EXHAUST

The Permit updates the 2008 VGP to require that vessels with two-stroke engines use 

environmentally acceptable lubricants. 

Permit Text [Emphasis highlights new requirements of the 2013 VGP]:

2.2.21 Boat Engine Wet Exhaust 

Vessel engines generating wet exhaust must be maintained in good operating order, well tuned, 

and function according to manufacturer specifications to decrease pollutant contributions to wet 
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exhaust. Vessel owner/operators should use low sulfur or alternative fuels for their vessels to 

reduce the concentration of pollutants in discharges from boat engine wet exhaust. 

EPA encourages vessel operators to consider four stroke engines instead of two stroke engines 

for vessels generating wet exhaust that are covered under this permit. Use of a four stroke engine 

may minimize the discharge of pollutants to waters subject to this permit. Where vessels utilize 

two stroke engines, environmentally acceptable lubricants (as defined in Appendix A of this 

permit) must be used unless technologically infeasible. If technologically infeasible, the vessel 

owner/operator must document in their recordkeeping documentation why they are not using 

environmentally acceptable lubricants. 

AFFECTED VESSEL POPULATION

No information is available from the combined MISLE/WTLUS database to determine the 

number of vessels that currently use two-stroke engines. Newly covered commercial fishing 

vessels are potentially impacted by the requirements pertaining to small boat engine wet exhaust; 

certain existing vessels that use two strokes engines may be affected by the additional 

requirements to use environmentally acceptable lubricants. However, as discussed in the next 

section, neither the baseline nor the revised requirements are expected to represent incremental 

costs for these vessels. EPA therefore did not determine the size of the relevant vessel population. 

COST ESTIMATES 

General practices relating to equipment maintenance and low sulfur fuels are assumed to already 

be implemented by vessel owners, including those in the fishing industry. EPA reviewed prices 

for different types of engine lubricants including EALs and mineral-based products and found no 

systematic difference in the unit cost of these products that would suggest that using EALs would 

result in additional costs for vessel owners; in fact some EAL products were less expensive than 

petroleum-based lubricants.45 Accordingly, EPA estimates that revisions of requirements for this 

discharge category have no incremental cost.

4.2.22 SONAR DOME DISCHARGE

The 2013 VGP requirements are fundamentally identical to the 2008 VGP requirements. 

Therefore, the only vessels that are potentially impacted by this section are commercial fishing 

vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with 

applicable requirements. However, EPA has determined that practices applicable to sonar dome 

discharges have negligible costs and/or the industry is assumed to currently practice the Permit 

requirements. This discharge category is assumed to have zero incremental cost.

 

45 The average cost per gallon for environmentally acceptable two-stroke engine oil was approximately $23 as 

compared to average cost of $32 for non-EAL products.
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4.2.23 UNDERWATER SHIP HUSBANDRY DISCHARGES

PERMIT REQUIREMENTS

The 2013 VGP retains the requirements of the 2008VGP with minor clarifications on practices to 

minimize the impacts of ship husbandry. 

Permit Text [Emphasis highlights new requirements of the 2013 VGP]:

2.2.23 Underwater Ship Husbandry Discharges 

Vessel owners/operators must minimize the transport of attached living organisms when traveling 

into U.S. waters from outside the U.S. economic zone or between Captain of the Port (COTP) 

zones.

Whenever possible, rigorous hull-cleaning activities should take place in drydock, or at a landbased facility where the removal of fouling organisms or spent antifouling coatings paint can be 

contained. If water-pressure-based systems are used to clean the hull and remove old paint, you 

must use facilities which treat the washwater prior to discharging to waters subject to this permit 

in order to remove the antifouling compound(s) and fouling growth from the washwater. If 

mechanical means (scraping, etc.) are used to clean the hull and remove old paint, the 

materials removed from the hull during that process must be collected and disposed of properly 

(e.g., onshore). These materials must not be allowed to contaminate nearby waters. 

Vessel owners/operators who remove fouling organisms from hulls while the vessel is waterborne 

must employ methods that minimize the discharge of fouling organisms and antifouling hull 

coatings. These shall include: 

 Use of appropriate cleaning brush or sponge rigidity to minimize removal of antifouling 

coatings and biocide releases into the water column; 

 Limiting use of hard brushes and surfaces to the removal of hard growth; and 

 When available and feasible, use of vacuum or other control technologies to minimize the 

release or dispersion of antifouling hull coatings and fouling organisms into the water 

column. 

Vessel owners/operators must minimize the release of copper-based antifoulant paints during 

vessel cleaning operations. Cleaning of hull surfaces coated with copper-based antifoulant paint 

must not result in any visible cloud or plume of paint in the water; if a visible cloud or plume of 

paint develops, shift to a softer brush or less abrasive cleaning technique. A plume or cloud of 

paint can be noted by the presence of discoloration or other visible indication that is 

distinguishable from hull growth or sediment removal. Production of a plume or cloud of 

sediment or hull growth is normal in some cases during vessel hull cleaning, but this plume or 

cloud must be substantially paint free (e.g., paint should not be clearly identifiable in the plume 

or cloud). When feasible, attempts must be made to minimize the release of fouling organisms 

and antifouling systems (including copper-based coatings) into surrounding waters. 

Vessels that use copper-based anti-fouling paint must not clean the hull in copper-impaired 

waters within the first 365 days after paint application unless there is a significant visible 

indication of hull fouling. EPA maintains a list of copper-impaired waters on its webpage at 
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www.epa.gov/npdes/vessels. If you clean before 365 days in copper-impaired waters, you must 

document in your recordkeeping documentation why this early cleaning was necessary

AFFECTED VESSEL POPULATION

The discharge category is potentially applicable to all vessels covered by the VGP. All vessels 

except commercial fishing vessels are already complying with existing requirements under the 

2008 VGP and would only incur incremental costs, if any, from revised requirements. The newly 

covered commercial fishing vessels have the potential to incur incremental costs if the practices 

required by the Permit differ from current industry practices. 

The population potentially affected by practices applicable to discharges in the underwater ship 

husbandry category is shown in Table 4-22.

Table 4-22. Vessel Counts for Underwater Ship Husbandry Practices. 

Vessel Class Vessel Count

Commercial Fishing 2,326 

Freight Barges 39,760 

Freight Ships 812 

Passenger Vessels 1,970 

Tank Barges 7,144 

Tank Ships 332 

Utility Vessels 6,258 

TOTAL 58,602

COST ESTIMATES 

Since practices associated with underwater ship husbandry are generally contracted to diving 

companies, information gathered from diving companies is most useful. In estimating the impacts 

of the 2008 VGP, EPA found that the requirements contained in the 2008 VGP were consistent 

with existing standard practices and therefore the requirements did not represent incremental 

costs for vessel owners. Revisions to the requirements in the 2013 VGP similarly highlight 

practices that EPA believes are already common, such as minimizing contamination from paint 

scrapings, fouling organisms or antifouling systems. 

Because the circumstances are anticipated to be infrequent, documentation of cleanings 

conducted in copper-impaired waters within 365 days of paint application likely represents only a 

minimal additional burden for the subset of vessel owners affected, relative to the annual 

paperwork burden discussed in Section 4.4. 

Accordingly, revisions to requirements under this discharge category are not expected to impose 

incremental costs on vessel owners.

4.2.24 WELLDECK DISCHARGES

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 
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However, EPA has determined that practices applicable to welldeck discharges have negligible 

costs and/or the industry is assumed to currently practice the Permit requirements. This discharge 

category is assumed to have zero incremental cost.

4.2.25 GRAYWATER MIXED WITH SEWAGE FROM VESSELS

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only 

vessels that are potentially impacted by this section are commercial fishing vessels as all other 

vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. 

However, EPA has determined that practices applicable to discharges of graywater mixed with 

sewage have negligible costs and/or the industry is assumed to currently practice the Permit 

requirements. This discharge category is assumed to have zero incremental cost.

4.2.26 EXHAUST GAS SCRUBBER WASHWATER DISCHARGE

In the 2013 VGP, is proposing several monitoring requirements for those vessels which use 

exhaust gas scrubber systems. These requirements are similar to those contained in the 

International Maritime Organization (IMO) guidelines for exhaust gas cleaning systems in 

resolution Marine Environmental Protection Committee (MEPC) 184(579). In addition to 

continuous monitoring of the washwater, vessel owners must analyze the effluent for several 

pollutants on a quarterly basis. The results of the monitoring must be submitted to EPA annually. 

Additionally, the VGP contains other requirements to assure that exhaust gas scrubber discharges 

are consistent with existing US law. 

PERMIT REQUIREMENTS

Permit Text:

2.2.26 Exhaust Gas Scrubber Washwater Discharge 

Exhaust gas scrubber washwater discharge must not contain oil, including oily mixtures, in 

quantities that may be harmful as determined in accordance with 40 CFR Part 110. Sludge or 

residues generated in treating exhaust gas scrubber washwater discharge must not be discharged 

in waters subject to this permit and must be delivered ashore to adequate reception facilities. 

In addition, owner/operators of vessels with exhaust gas cleaning systems that result in 

washwater discharges must meet the numeric effluent limits found in Part 2.2.26.1 and the 

monitoring requirements found in Part 2.2.26.2 this permit. These limits are consistent with the 

IMO guidelines set forth in section 10 for Exhaust Gas Cleaning (EGC) Systems (resolution 

MEPC.184(59)). Among other things, these guidelines recommend the establishment of limits for 

concentrations of pollutants in the effluent. 

[2.2.26.1 Exhaust Gas Scrubber Treatment Standards] 

2.2.26.2 Exhaust Gas Scrubber Analytical Monitoring Requirements 

2.2.26.2.1 Continuous Monitoring

The data recording system must comply with the guidelines in sections 7 and 8 of MEPC.184(59) 

and must continuously record pH, PAH, and turbidity. 
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When the EGC system is operated in waters subject to this permit, the washwater monitoring and 

recording must be continuous. The values monitored and recorded must include pH, PAH, 

turbidity, and temperature.

The pH electrode and pH meter must have a resolution of 0.1 pH units and temperature 

compensation. The electrode must comply with the requirements defined in BS 2586 or of 

equivalent or better performance and the meter should meet or exceed BS EN ISO 60746-2:2003. 

The PAH monitoring equipment must be capable of monitoring PAH in water in a range of at 

least twice the discharge concentration limit given in the table above. A demonstration must be 

made that the equipment operates correctly and does not deviate more than 5 percent in 

washwater with turbidity within the working range of the application. For those applications 

discharging at lower flow rates and higher PAH concentrations, ultraviolet light monitoring 

technology or equivalent should be used due to its reliable operating range. 

The turbidity monitoring equipment must meet requirements defined in ISO 7027:1999 or USEPA 

180.1. 

All continuous monitoring equipment must be calibrated as recommended by probe 

manufacturers or Exhaust Gas scrubber manufacturers. At a minimum, all probes must be 

calibrated at least annually. EPA expects many probe types (e.g., turbidity probes) will need to be 

calibrated on a more frequent basis. 

2.2.26.2.2 Quarterly Analytical Monitoring. 

In addition to the continuous monitoring found in Part 2.2.26.2.1 of this permit, vessel 

owner/operators must collect and analyze one sample per quarter for each of the constituents 

analyzed in Part 2.2.26.2.3 to demonstrate treatment equipment maintenance, probe accuracy, 

and compliance with this permit. Records of the sampling and testing results must be retained 

onboard for a period of 3 years in the vessel’s recordkeeping documentation consistent with Part 

4.2. 

2.2.26.2.3 Analytes for Quarterly Analytical Monitoring

Vessels conducting monitoring as required by Part 2.2.26.2.2 must monitor for the following 

parameters, choosing either sufficiently sensitive EPA Part 136 methods or other methods if 

specifically allowed:

 Dissolved and Particulate Metals, including Aluminum, Antimony, Arsenic, Cadmium, 

Chromium, Copper, Lead, Manganese, Nickel, Selenium, Thallium, and Zinc (recommend 

using EPA Methods 200.8 or 200.9); 

 PAHs including Acenaphthylene, Acenaphthene, Anthracene Benz[a]anthracene, 

Benzo[ghi]perylene, Benzo[a]pyrene, Benzo[b]fluoranthene +, benzo[k]fluoranthene, 

Chrysene, Dibenz[a,h]anthracene, Fluoranthene, Fluorene, Indeno[1,2,3,c,d]pyrene, 

Naphthalene, Phenanthrene, and Pyrene (recommend using EPA Methods 550.1, 610, 

625, 8100, 8270c, 8310); 

 Nitrates (recommend using EPA Method 353.2); 

 pH (using Standard Methods (SM) 4500-H B); 

 Turbidity (using SM 2130 B); 
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 Temperature (using SM 2550); and 

 Dissolved Oxygen (using SM 4500-O G).

2.2.26.2.4 Monitoring Reporting 

Vessel owners/operators must submit all monitoring data to EPA’s e-reporting system, unless 

exempted from electronic reporting consistent with Part 1.14 of this permit. Monitoring data must 

be submitted at least once per calendar year no later than February 28 of the following year on 

the vessel annual report. Data must be submitted on or attached to a DMR available in Appendix 

I of this permit or submitted to EPA’s e-reporting system available at www.epa.gov/vessels/eNOI. 

Data may be submitted as part of the vessel’s annual report. 

AFFECTED VESSEL POPULATION

Vessels potentially affected by this requirement are those equipped with a marine diesel engine 

that use wet scrubbers or hybrid scrubbers to reduce air pollution from their gas exhaust46 to 

comply International, Federal, or regional requirements, and that discharge the washwater into 

waters subject to the permit.

At present, only a handful of vessels use exhaust gas cleaning systems (EGCS). With tighter air 

pollution regulations coming into effect and the growing availability of EGCS, however, a greater 

number of vessels may use EGCS in the future to reduce their SOX emissions. No estimate could 

be found on the projected number of vessels that will install EGCS in coming years, and of those, 

the number of wet or hybrid systems that may discharge washwater. For the purpose of this 

analysis, EPA assumed that the number of vessels will be relatively small in the first year of the 

permit (i.e., 0.5 percent of freight or tank ships) but will increase to up to 10 percent of these 

vessels by the end of the permit period.47

COST ESTIMATES 

In the 2013 VGP, EPA is establishing numeric BAT limits which are consistent with the 

international guidelines established by the IMO. Though marine gas exhaust systems are in the 

early stages of development, EPA has found that all marine manufacturers are designing systems 

with these IMO guidelines in mind and that testing of these systems onboard vessels. 

Furthermore, these systems are generally based on technologies that have been used in land based 

applications, and these technologies generally transfer well to ship-based applications. Because 

the limits set in the VGP are fundamentally similar to an existing international standard, treatment 

manufacturers are currently designing their equipment to meet this standard. By reinforcing 

existing limits, EPA is imposing no additional burden.48 

 

46 Other approaches to reducing air emissions include fuel conversion or switching to low-sulfur fuel.

47 A guide developed by Ship Operations Cooperative Program (SOCP) suggests that vessels burning more than about 

4,000 metric tons of fuel oil annually within emissions controls area may see cost advantages to using a EGCS instead 

of switching to low-sulfur fuel, depending on the cost difference between high and low-sulfur fuels and vessel-specific 

characteristics (space constraints, stability, areas of operation, etc.) (SOCP, 2011).

48 Additionally, vessel owner/operators may realize cost savings when using lower grade fuel (which requires use of a 

scrubber) compared to the higher grade, lower sulfur content fuels.
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While the numeric effluent limits are not expected to impose any incremental costs on vessel 

owners, EPA’s requirement that vessel owners conduct analytical sampling quarterly and report 

the results of their continuous and quarterly monitoring as part of the annual report are specific to 

the 2013 VGP and may represent an incremental costs. 

Vessel owners are assumed to conduct continuous monitoring in accordance with IMO 

requirements. This includes reviewing equipment readings and calibrating probes as specified by 

the equipment manufacturer. No incremental cost is therefore calculated for the conduct of these 

activities. However, EPA assumes that vessel owners may incur up to 2 hours in additional 

recordkeeping burden in compiling the information as part of their annual report for each 

applicable vessel.

Costs for implementing the quarterly monitoring requirements are estimated at $437 per 

monitoring event. This cost includes analytical testing ($303), sampling, administration, and 

reporting (2.5 labor hours at an assumed average hourly rate of $33.72), and incidental expenses 

such as shipping ($50). 

SENSITIVITY ANALYSIS

The sensitivity analysis uses the following assumptions.

 Monitoring Costs: Per event costs are assumed to be $437, inclusive of all labor and 

material. Four monitoring events are conducted each year. 

 Baseline: EPA assumed that none of the vessels equipped with EGCS would otherwise 

conduct the quarterly analytical sampling and testing (but would be conducting 

continuous monitoring). In the low end estimate, EPA assumed that up to 5 percent of 

freight and tank ships use an EGCS by the end of the permit period (0% in year 1; 0.5% 

in year 2, 1% in year 3; 2% in year 4, and 5% in year 5). For the high end estimate, EPA 

assumed that up to 10 percent of freight and tank ships use an EGCS by the end of the 

permit period (0.5% in year 1; 1% in year 2, 2% in year 3; 5% in year 4, and 10% in year 

5). 

 Implementation Rate: EPA assumed that 100 percent of applicable vessels will need to 

conduct the additional monitoring and recordkeeping, each year. 

The cost per vessel for each practice and the total cost associated with all vessels are provided in 

Table 4-19. The annualized incremental costs range from approximately $34,000 to $75,500. 
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Table 4-23. Exhaust Gas Scrubber Washwater Discharge Monitoring Sensitivity Analysis.

Vessel Class Vessel Counta

Annual Cost per 

Vesselb

Total Annualized

Costc

Low End Estimate

Monitor Graywater

Commercial Fishing - $0 $0

Freight Barges - $0 $0 

Freight Ships 41 $1,817 $24,418

Passenger Vessels - $0 $0

Tank Barges - $0 $0 

Tank Ships 17 $1,817 $9,990

Utility Vessels - $0 $0

Low End TOTAL 57 $34,408

High End Estimate

Monitor Graywater

Commercial Fishing - $0 $0

Freight Barges - $0 $0 

Freight Ships 81 $1,817 $53,570

Passenger Vessels - $0 $0

Tank Barges - $0 $0 

Tank Ships 33 $1,817 $21,918

Utility Vessels - $0 $0

High End TOTAL 114 $75,488

Total may not add up due to rounding.

a Represents the number of vessels that are assumed to use a EGCS by the last year of the VGP. Not all vessels incur 

the annual cost for each of the 5 years of the permit.

b Annual monitoring costs for a vessel that uses a wet or hybrid EGCS, including sampling, analytical tests, and 

incidentals.

c Costs are annualized over the 5-year permit period, accounting for the distribution of costs over time. They are 

calculated by annualizing (at 7 percent discount rate) the present value of estimated compliance costs for each year 

based on the number of domestic vessels assumed to use a wet or hybrid EGCS. 

4.2.27 FISH HOLD EFFLUENT

PERMIT REQUIREMENTS

The 2013 VGP adds requirements for discharges of fish hold effluent as follows: 

Permit Text:

You must minimize the discharge of fish hold water and/or ice while in port. All reasonable steps 

must be taken to prevent the discharge of excess fish hold water and ice while the vessel is 

stationary at the pier. If fish waste is contained in the fish hold effluent, the fish hold effluent may 

not be discharged while in port, unless a physical separation method is used (e.g., filters or 

removal of residuals).

 The discharge of fish hold effluent (including dirty ice) is prohibited if you are unloading 

your catch at a land-based seafood processing facility or pier. If a shore-based discharge 
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facility is otherwise available to receive your effluent, then discharge of fish hold effluent 

(including dirty ice) is prohibited if the facility meets the following:

– Its use is economically achievable, and

– The facility has a valid NPDES permit, or 

– That facility discharges to an NPDES-permitted sewage treatment facility. 

 The discharge of unused bait overboard is prohibited, unless you caught that bait in the 

same water body or watershed. Unused bait purchased from a bait shop or dealer may 

not be discharged overboard. 

AFFECTED VESSEL POPULATION

Based on the description of practices within this discharge category, only commercial fishing 

vessels have the potential to produce this discharge since no other vessels are expected to have 

fish holds. The population potentially affected by practices applicable to discharges in the fish 

hold effluent category is shown in Table 4-24. Note that the vessel count presented in the table 

may overestimate the number of vessels to which the practice would apply since not all fishing 

vessels have fish holds. 

Table 4-24. Vessel Counts for Fish Hold Effluent Practices

Vessel Class Vessel Count

Commercial Fishing 2,326

Fishing Vessels 0

Freight Barges 0

Freight Ships 0

Passenger Vessels 0

Tank Barges 0

Tank Ships 0

Utility Vessels 0

TOTAL 2,326

COST ESTIMATES 

The 2013 VGP requires that vessel operators use a physical separation method to remove excess 

fish waste and residuals from the water prior to discharging fish hold effluent. Based upon EPA 

research, this practice is consistent with existing vessel practice: for example, most vessels have 

coarse filters to keep solid fish waste from being discharged with liquid effluent. Codex 

Alimentarius provides a recommended International Code of Practice for Fresh Fish, including 

technological guidelines for the handling and processing of fresh fish intended for human 

consumption (FAO, 1976). The Codex specifies that vessels should use coarse filters for their fish 

hold effluent. When present, these coarse filters should help ensure that no excess fish debris is 

discharged, consistent with the VGP requirements.

EPA has also prohibited the discharge of fish hold effluent pierside where shore based facilities 

are available: where they are available, vessels must utilize these facilities. . 
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According to a review of available information, at least two dockside facilities currently offer the 

option to discharge fish hold effluent to a shore-based facility instead of discharging to 

surrounding waters. These two facilities are in San Francisco, CA and Sitka, AK. 

EPA assumes that there are no costs associated with not discarding any unused bait overboard, 

given that the vessel owners or operators can readily wait and discard the bait at an appropriate 

shore-based facility.

Therefore, none of the requirements described in this section are expected to represent an 

incremental cost to owners of commercial fishing vessels. 

4.3 COSTS OF VESSEL-SPECIFIC REQUIREMENTS

Part 5 of the VGP stipulates additional requirements applicable to selected vessel classes. The 

cost implications of these requirements are discussed below, focusing on requirements revised in 

the 2013 VGP. Similar to the discussion of costs applicable across vessel types, the discussion 

follows the order of the sections in the VGP. For completeness, all sections are included, with 

notes on whether the VGP revisions are expected to represent incremental costs on vessel owners.

4.3.1 LARGE AND MEDIUM CRUISE SHIPS

PERMIT REQUIREMENTS

The 2013 VGP generally maintains the requirements specific to cruise ships contained in the 

2008 VGP but makes minor clarifications (e.g., prohibition of discharges of toxic materials) and a 

few substantive changes to the requirements. 

Revisions having the potential to impose incremental costs include those related to graywater 

discharges (i.e., treatment and monitoring), for which requirements applicable to large and 

medium cruise ships are more stringent than those applicable to other vessel types. The 2013 

VGP requires large cruise ships to either hold their untreated graywater or treat it to meet the 

effluent limitations prior to discharging when within 3 nm from shore. The 2013 VGP thus 

extends the zone within which untreated graywater can never be discharged from 1nm to 3 nm. 

Cruise ship owners must also monitor for additional parameters not previously included in the 

2008 VGP: e. coli, total phosphorus, ammonia, nitrate/nitrite, and total kjeldahl nitrogen (TKN). 

Other changes merely clarify the graywater requirements and are not expected to impose 

incremental costs on vessel owners. These include:

 Clarifications that requirements for initial monitoring of the graywater treatment system 

may be met through monitoring conducted under the 2008 VGP. This clarification 

removes potential duplicate monitoring. 

 Clarifications that the schedule for submitting the annual monitoring report follows a 

calendar year schedule. This clarification does not affect the scope or frequency of 

reporting. 

 Clarifications that the annual monitoring report is part of the NPDES annual reporting 

requirement. This separates the reporting requirement from reporting of the information 

to the COTP for cruise ships operating in Alaska waters.
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Relevant excerpts of the permit text are included below.

Permit Text: 

Discharge Standards: 

Pierside Limits – While pierside, appropriate onshore reception facilities for graywater must be 

used unless the vessel treats graywater with a device to meet the standards in Part 5.1.1.1.2. If 

such facilities are not reasonably available and you do not have the capacity to treat graywater

to meet the standards in Part 5.1.1.1.2, you must hold the graywater until the vessel is underway 

and not in waters subject to this permit. Appropriate reception facilities are those authorized for 

use by the port authority or local municipality and that treat the discharge in accordance with its 

NPDES permit. 

Operational Limits: You must meet the following restrictions: 

• While operating within 3 nm from shore, discharges of graywater are prohibited 

unless they meet the effluent standards in Part 5.1.1.1.2. 

[Limits Applicable to Operation in Nutrient Impaired Waters (unchanged from 2008 VGP)] 

[Graywater Treatment Standard (unchanged from 2008 VGP)] 

Monitoring Requirements [Part 5.1.2]

Untreated Graywater [Part 5.1.2.1] 

The discharge of untreated graywater by large cruise ships is not authorized in waters subject 

to this permit. Any discharge of untreated graywater within waters subject to this permit must 

be reported to EPA as an incidence of noncompliance on the vessel’s Annual Report. 

Treated Graywater [Part 5.1.2.2] 

Prior to entering waters of the United States, vessel operators must demonstrate that they have 

an effective treatment system that complies with the standards in Part 5.1.1.1.2 if they will 

discharge graywater within 3 nm of shore. 

Initial Monitoring [Part 5.1.2.2.1] 

In order to demonstrate the effectiveness of the treatment system, the vessel operator must take at 

least five (5) samples from the vessel on different days over a 30-day period that are 

representative of the treated effluent to be discharged. A vessel owner/operator that submitted 

data to EPA for a vessel’s discharge from an AWTS under the 2008 VGP requirements or 

submitted such data to the U.S. Coast Guard to meet the requirements of Section 1411(b) of 

Title XIV, Pub. L. 106-554 (Dec. 31, 2000, 114 Stat. 2763) [Certain Alaska Cruise Ship 

Operations] (codified at 33 USC 1901 note) does not need to conduct initial monitoring, and 

may instead immediately commence maintenance monitoring consistent with Part 5.1.2.2.2 of 

this permit.

Initial monitoring must be done within the first 90 days of permit coverage, within 90 days of 

AWTS installation onboard the vessel, or before vessels discharge into waters subject to this 

permit, whichever is later. Samples must be taken for BOD, fecal coliform, suspended solids, pH, 

and total residual chlorine. Furthermore, samples must be taken for E. coli, total phosphorus 

(TP), ammonia, nitrate/nitrite, and Total Kjeldahl Nitrogen (TKN). Sampling and testing shall 

be conducted according to 40 CFR Part 136. If the measured samples meet the standards 
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specified in Part 5.1.1.1.2, then the owner/operator has demonstrated the effectiveness of their 

treatment system for controlling their graywater discharge. Records of the sampling and testing 

results must be retained onboard for a period of 3 years in the vessel’s recordkeeping 

documentation. 

Records of monitoring information shall include: 

 The date, exact place, and time of sampling or measurements; 

 The individual(s) who performed the sampling or measurements; 

 The date(s) analyses were performed;

 The individual(s) who performed the analyses; 

 The analytical techniques or methods used; and 

 The results of such analyses. 

Analytical results for total residual chlorine below the method detection limit shall be deemed 

compliant with the effluent limits, provided the permittee uses a testing method with a detection 

limit no higher than 10.0 μg/L under ideal conditions. EPA recommends Method SM4500-CL G 

(DPD Colorimetric Method) for these purposes as it is able to reach 10 μg/L under ideal 

conditions and so meets these requirements. SM4500-Cl G is typically the method that Alaska 

Department of Environmental Conservation (ADEC)/U.S. Coast Guard uses for compliance 

monitoring. 

Testing and reporting for total residual chlorine is not required if chlorine is not used as 

disinfectant in the wastewater treatment works process and no water is drained to the graywater 

system from water with onboard chlorine additions (e.g., swimming pools, spas). 

If a permittee has already received certification for continuous discharges from an AWTS by the 

U.S. Coast Guard to meet the requirements of Title XIV, Pub. L. 106-554 (Dec. 31, 2000, 114 

Stat. 2763) [Certain Alaska Cruise Ship Operations] (codified at 33 USC 1901 note), the vessel 

need not conduct initial monitoring and may commence conducting maintenance monitoring. 

Maintenance Reporting [Part 5.1.2.2.2] 

After demonstrating the effectiveness of their system, vessel owners/operators must collect and 

analyze one sample per quarter for each of the constituents listed in Part 5.1.2.2.1 to demonstrate 

treatment equipment maintenance and compliance with this permit. Furthermore, samples must 

be taken for E. coli, total phosphorus (TP), ammonia, nitrate/nitrite, and Total Kjeldahl Nitrogen 

(TKN). Records of the sampling and testing results must be retained onboard for a period of 3 

years in the vessel’s recordkeeping documentation. 

Monitoring Reporting [Part 5.1.2.2.3] 

The owner/operator must submit data showing that the graywater standards are achieved by their 

treatment system to EPA’s e-reporting system or to EPA, ATTN: VGP Cruise Ship Monitoring 

Results, 1200 Pennsylvania Ave., MC 4203M, Washington, DC 20460. Initial sampling data must 

be submitted at least 7 days before entering waters subject to this permit, within 90 days of 

obtaining permit coverage, or within 90 days of AWTS installation onboard the vessel, whichever 

is later. Maintenance monitoring data must be submitted at least once per calendar year no later 

than February 28 of the following year (e.g., 2014 data must be submitted by February 28, 
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2015). Data must be submitted on DMRs available in Appendix I of this permit or submitted to 

EPA’s e-reporting system available at www.epa.gov/vessels/eNOI. Data may be submitted as 

part of the vessel’s annual report.

AFFECTED VESSEL POPULATION

The population estimate shown in Table 4-25 was provided by Cruise Lines International 

Association (CLIA) in support to EPA’s analysis of the 2008 VGP. Large sized cruise ships are in 

the 500+ passenger/crew capacity classification, and medium sized cruise ships are in the 100 to 

499 passenger/crew capacity classification.49 

Table 4-25. Cruise Ship Counts.

Vessel Classa Alaskan Certified Cruise 

Ships

Non-Alaskan Certified 

Cruise Ships

Total Count

Large Cruise Ships 30 113 143

Medium Cruise Shipsc 0 32 32

TOTAL 30 145 b 175

a Cruise ships fall within the passenger vessels category.

b This count is based upon CLIA populations. There may be an additional 5% that are non-CLIA members.

c The estimated number of medium cruise ships was determined based upon a 250-499 passenger/crew capacity 

classification rather than the 100-499 range. However, based on preliminary data provided by CLIA, there are very few 

cruise ships within the 100-249 passenger/crew capacity classification. EPA therefore expects that the estimate is only 

slightly below the actual universe of medium cruise ships.

COST ESTIMATES 

The majority of the practices associated with cruise ship graywater management are already 

practiced by the cruise ship industry. Changes to pierside and operational limits for large cruise 

ships would require vessels to treat their graywater to the specified standards, or hold graywater 

while pierside for later discharge beyond 3 nm from shore. Cruise ships already have the capacity 

to hold graywater for extended periods of time or are operating the necessary treatment systems 

to generate effluent that meets the limits specified in the 2013 VGP. Large cruise ships have the 

capacity to hold graywater for a minimum of 1 to 2 days, as evidenced by their ability to hold all 

wastewaters while sailing in areas such as Glacier Bay in Southeast Alaska, where discharges are 

generally prohibited under their concession contracts with the National Park Service. According 

to responses to EPA’s 2004 cruise ship survey of large cruise ships operating in Alaskan waters, 

graywater holding capacity ranged from 5 to 90 hours, with an average holding capacity of 56 

hours. 

Medium cruise ships will incur no incremental cost associated with this practice since the Permit 

standards are already practiced. Medium cruise ships that are able to voyage more than 1 nm are 

 

49 The estimated number of medium cruise ships in Table 4-25 was determined based upon a 250-499 

passenger/crew capacity classification rather than the 100-499 range. However, based on data provided by CLIA, 

there are very few cruise ships within the 100-249 passenger/crew capacity classification. EPA therefore expects that 

the estimate is only slightly below the actual universe of medium cruise ships. 
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already complying with graywater treatment standards. These ships have the option to discharge 

graywater in nutrient impaired waters while sailing at a speed of at least 6 knots. Since this is 

already an industry standard, according to the economic analysis of the 2008 VGP (EPA, 2008), 

there is no incremental cost associated with this Permit requirement. 

Requirements pertaining to operation in nutrient impaired waters, sculleries and galleys, 

hazardous waste, untreated graywater documentation, and monitoring have not changed 

substantively and therefore no incremental cost is associated with the 2013 VGP revisions.

Requirements to include additional parameters as part of initial and maintenance monitoring are 

not expected to add a significant cost to vessel owners beyond the cost previously estimated as 

part of the 2008 VGP analysis (EPA, 2008). This is because previously estimated costs for

conducting the monitoring ($1000 per event, in 2008 dollars) already represent a very 

conservative estimate of the cost of collecting samples, performing the laboratory analyses, 

administering and keeping records, and covering all other incidentals associated with a 

monitoring event. The new parameters are not expected to add costs that would not already fit 

within this conservative estimate.

4.3.2 LARGE FERRIES

The 2013 VGP generally retains vessel-specific requirements applicable to large ferries. One 

exception is the removal of requirements applicable to the discharge of coal ash from coal fired 

propulsion systems. Under the 2013 VGP, the discharge of coal ash slurry from coal fired 

propulsion systems from ferries is no longer authorized under the permit. This is consistent with 

EPA’s suspension of the authorization for these discharges in December 2012. Either coal ash 

discharges must cease into waters subject to this permit or they must be authorized under an 

individual NPDES permit. The change in permit language is made to be consistent with the 

existing requirements and this revision therefore is not expected to impose incremental costs on 

large ferries. 

4.3.3 UNMANNED BARGES (SUCH AS HOPPER BARGES, CHEMICAL BARGES, TANK 

BARGES, FUEL BARGES, CRANE BARGES, DRY BULK CARGO BARGES)

The 2013 VGP retains the vessel-specific requirements applicable to barges contained in the 2008 

VGP with limited revisions to clarify the applicability of the requirements to unmanned barges 

and to barges used to transport petroleum and oil products. As these barges were originally 

included in the analysis of the 2008 VGP, the revisions are not expected to result in incremental 

costs. Other revisions include clarification on practices to prevent discharges of oily or toxic 

materials; the practices described in the revisions are already implemented by vessels and/or 

represent a negligible incremental cost on vessels that have the relevant equipment (scuppers). 

Permit Text:

5.4.1 Additional Effluent Limits 

Barges must minimize the contact of below deck condensation with oily or toxic materials and 

any materials containing hydrocarbon. Whenever barges are pumping water from below deck, 

the discharge shall not contain oil in quantities that may be harmful as defined in 40 CFR Part 

110. If a visible sheen, as defined in Appendix A of this permit, is noted, vessel operators must 
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initiate corrective action in accordance with Part 3 and meet recordkeeping requirements in Part 

4.2 of this permit. 

All tank barges must have spill rails and must mechanically plug their scuppers before any cargo 

operations if required by vessel class society and/or 33 CFR Parts 155 and/or 156. Additionally, 

scuppers, when available, must be mechanically plugged during fueling of ancillary equipment 

(e.g., generators and compressors) located on the deck of the barge. If scuppers are 

unavailable, other types of secondary containment should be employed. If any spills result 

during loading or unloading of cargo, or other ancillary equipment fueling operations, vessel 

owners/operators must completely clean up spills or residue before scuppers are unplugged. 

Vessel owners/operators must clean out cargo residues (i.e., broom clean) such that any 

remaining residue is minimized before washing the cargo compartment or tank and discharging 

washwater overboard. 

Vessel owners/operators must clean out cargo residues (i.e., broom clean) such that any 

remaining residue is minimized before washing the cargo compartment or tank and discharging 

washwater overboard. 

5.4.2 Supplemental Inspection Requirements

After every instance of pumping water from areas below decks, or immediately following washing 

down the decks, you must conduct a visual sheen test. The visual sheen test is used to detect free 

oil by observing the surface of the receiving water for the presence of an oily sheen. The operator 

should focus the inspection on the area surrounding the vessel where discharges from below deck 

or deck washings are discharges into the receiving water. A visible sheen is defined in Appendix 

A of this permit. If a visible sheen is observed, you must initiate corrective actions required in 

Part 3 of this permit and meet recordkeeping and notification (reporting) requirements in Part 

4.2 of this permit. 

4.3.4 OIL TANKERS, PETROLEUM TANKERS OR BULK CHEMICAL CARRIERS

The 2013 VGP retains the vessel-specific requirements applicable to oil tankers, petroleum 

tankers, or bulk chemical carriers contained in the 2008 VGP with limited revisions to clarify the 

applicability of the requirements to bulk chemical carriers. As these vessels were originally 

included in the analysis of the 2008 VGP, the revisions are not expected to result in incremental 

costs. 

4.3.5 RESEARCH VESSELS

The 2013 VGP vessel-specific requirements applicable to research vessels are identical to those 

contained in the 2008 VGP. No incremental cost is therefore anticipated. 

4.3.6 EMERGENCY VESSELS (FIRE BOATS, POLICE BOATS)

The 2013 VGP vessel-specific requirements applicable to emergency vessels are identical to 

those contained in the 2008 VGP. No incremental cost is therefore anticipated. 
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4.4 GENERAL INSPECTION AND PERMIT PAPERWORK BURDEN

The permit paperwork burden is comprised of five potential cost inputs: 

 Recordkeeping

 Routine inspections 

 Annual report

 Notice of Intent filing

 Annual reporting requirement 

Some of the practices necessary to comply with these requirements are already implemented by 

vessel owners in accordance with business practices and to comply with the 2008 VGP 

requirements. However, commercial fishing vessels may incur incremental burden as a result of 

their coverage under the VGP. Additionally, for previously covered vessels, revisions to certain 

Permit requirements may require additional time for these tasks. 

The 2013 VGP makes several modifications to the general inspection and paperwork 

requirements. The revisions generally aim to clarify the requirements or reduce the burden on 

covered vessels by streamlining the process of submitting information to EPA, following 

comments EPA received from regulated entities. The principal revisions to permit requirements 

include: 

 The addition of the Permit Authorization and Record of Inspection (PARI) Form to be 

completed for vessels for which an NOI is not required. The short form (1 page) must be 

maintained onboard the vessel and used to document the conduct of annual inspections. 

 For routine visual inspections, the 2013 VGP clarifies the frequency of inspections as 

once per week or per voyage and conducted on a schedule that coincides with other 

routine inspections, if feasible. The text changes do not modify the frequency of 

inspections required under the 2008 VGP. Other changes include removing the 

requirement to sample discharge streams otherwise not readily visually inspected on a 

quarterly basis. 

 Changes to the requirements for vessels that are unmanned for an extended period of time 

(13 days or greater). The requirements specify the scope of the inspections and the 

frequency, both of which are meant to be less extensive than the regular routine visual 

inspection. This change may result in cost savings for owners of affected vessels.

 For recordkeeping, the revisions clarify that vessel owners may keep either paper or 

electronic records, provided that the format can be read in a similar manner as a paper 

record, is dependable, and is accessible during an inspection. This change improves the 

efficiency of recordkeeping.

 For annual reports, the revisions clarify the timing of the report according to calendar 

year with preference for electronic reporting. In the case of unmanned, unpowered 

barges, the revisions allow owners to submit a single annual report for all their barges, 

provided that certain conditions are met (no analytical monitoring data are included, there 

were no instances of noncompliance, etc.). This change may result in cost savings for 

owners of unmanned, unpowered barges. 
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The implications of the revised permit requirements for currently covered vessels and of 

extending the scope of the permit to commercial fishing vessels are discussed below. Note that 

changes in the inspection and reporting burden associated with specific discharge categories (e.g., 

ballast water treatment systems, bilge water treatment systems) are discussed within each 

discharge-specific section of this report. For example, incremental burden due to BWTS 

monitoring, sampling, testing, and recordkeeping requirements is discussed in Section 4.2.3. 

4.4.1 REVISED PAPERWORK REQUIREMENTS

In analyzing the impacts of the 2008 VGP, EPA had developed high end estimates that assumed 

the time required for vessels for recordkeeping, routine inspections, drydock inspections, and 

annual inspections. The estimates varied from no additional time to additional time that varied 

according to the size of the vessels. This was based on the assumption that certain vessel classes 

are more likely to have a higher number of applicable discharge categories, and thus, a potentially 

higher number of practices to perform and report upon. EPA divided vessel classes according to 

two categories (“Large” and “Small”), where the categories reflect not only the average size of a 

vessel, but also its relative complexity. In determining inspection and recordkeeping burden, 

“large” vessels were assumed to have greater time requirement than “small” vessels. Table 4-26

presents the crosswalk of vessel classes to the two categories. 

Table 4-26. Vessel Class Breakdown.

“Large” Vessels ”Small” Vessels

Cruise Ships

Commercial Fishing 

Freight Barges

Freight Ships Passenger Vessels

Tank Ships Utility Vessels

Tank Barges

Most of the revisions to the general inspection and paperwork requirements are not expected to 

result in significant incremental costs to vessel owners as they generally either clarify the 

requirements or recognize existing practices. For example, revisions to the routine inspection 

requirements do not change the expected frequency of such inspections, nor its scope; NOIs and 

annual reports are already being submitted electronically by the large majority of vessel owners.

The addition of the PARI Form is assumed to represents minimal burden for vessels as the very 

short form (1 page) consists of information that is readily available to the owner and is used to 

document activities (annual inspections) that are already occurring under the baseline. 

Based on feedback from the industry on the 2008 VGP which indicated that EPA may have 

underestimated the paperwork burden associated with complying with the 2008 VGP, however, 

EPA is increasing the estimated burden assumed to be involved in submitting an NOI (if 

applicable), maintaining the relevant records (including the PARI Form, if applicable), and 

preparing the annual report under the 2013 VGP, all else being equal. Table 4-27 presents the 

inspection and recordkeeping burden assumptions for the 2013 VGP, by vessel category. 
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Table 4-27. Incremental Burden Assumptions for General Inspection and Paperwork 

Requirements.

Requirement Burden Hours for Small 

Vessels

Burden Hours for Large 

Vessels

Frequency

NOI 1.0 1.0 Once every 5 years

Routine inspectionsa 1.5 2.5 Annually

Recordkeeping 0.5 1.0 Annually

Drydock inspection 2.0 4.0 Once every 5 years

Annual reportb 1.5 3.0 Annually

Source: EPA, 2008, unless otherwise noted. The assumed burden for routine inspection and annual report has been 

revised to reflect comments received from industry representatives that estimates presented in EPA, 2008 were too low.

a The burden for routine inspections has been revised from 1.0 and 2.0 hours.

b The burden for preparation of the annual report has been revised from 0.5 and 2.0 hours.

Two revisions to the VGP requirements have the potential to reduce compliance costs for certain 

vessel owners in non-negligible ways: the submittal of combined annual reports for barges and 

the reduced frequency of routine inspections for vessels that are unmanned for an extended period 

of time. The effects of these two changes are discussed below.

To estimate the effect of reducing the number of annual reports needing to be submitted for 

barges, EPA used data on the average number of barges operated by the same owner (see Section 

3.3). According to MISLE data, barge operators have, on average, 13 barges. Some operators, 

however, have significantly more barges under their name (up to a maximum of nearly 4,000) and 

37 companies have more than 100 barges each. Savings associated with a single annual submittal 

for all barges may therefore be significant. Table 4-28 presents savings calculated across all barge 

based on MISLE data, assuming that companies with more than three barges will submit a single 

annual report to EPA and that submitting a combined report takes about a quarter of the time 

necessary to prepare a single report. 

Table 4-28. Incremental Burden (Reduction) for Combined Barge Annual Reports.

Scenario Number of Individual Annual 

Reports Submitted Total Annual Report Costsd

Individual Reports (Baseline)a 45,582 $2,305,697

Combined Single Report Submitted b 19,320 $1,396,142

Changec (26,262) ($909,554)

a Assumes that one report per barge is submitted to EPA. 

b Companies with more than 3 barges are assumed to submit a single combined report for all of their barges. 

c Negative value represents a reduction (saving) relative to baseline requirements.

d. Costs are estimated assuming 1.5 hour per baseline individual report (see above for burden assumption based on 

EPA, 2008). For combined report, each barge included in the report after the first one is assumed to require 1/4 of the 

burden of an individual report. Costs associated with the burden hours are calculated using a labor rate of $33.72/hour. 

Estimating the effects of the revised requirements for unmanned vessels is complicated by the 

lack of data on the number of vessels that are unmanned for extended periods of time. Reductions 

in the burden may be significant particularly in cases where the VGP requirements are the sole 

reason for conducting an inspection. Under the 2008 VGP, a vessel owner may be conducting a 
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weekly inspection of the vessel with VGP-related recordkeeping representing only a small 

component of the inspection. Conducting routine inspections on a bi-weekly basis only while the 

vessel is unmanned for an extended period of time, for example during a six month period, 

reduces the annual burden associated with VGP compliance by 25 percent (for this particular 

example). The reduction in burden may be even larger, however, than suggested by the VGP 

burden alone, since the VGP burden is expressed as incremental burden beyond existing 

inspections and an owner may not need to perform a weekly inspection during this period other 

than to comply with the 2008 VGP routine inspection requirement. 

4.4.2 PAPERWORK REQUIREMENT BURDEN FOR NEWLY COVERED COMMERCIAL 

FISHING VESSELS

As shown previously in Table 4-26, commercial fishing vessels are assumed to have costs that are 

similar to those of other “small” vessels such as passenger vessels (except cruise ships), utility 

vessels, and barges. 

Based on the burden assumptions presented in the previous section, the commercial fishing 

vessels newly covered under the 2013 VGP are estimated to incur incremental costs from general 

inspection and paperwork requirements of about $361,000 for the high end estimate. Details of 

this estimate are shown in Table 4-29. For the low end estimate, the vessels are assumed to 

already implement all general inspection and recordkeeping practices as part of their existing 

business practices, except for the Permit-specific NOI submission and annual report and the total 

cost is estimated at $137,296. 

Table 4-29. Incremental Burden Assumptions for General Inspection and Paperwork 

Requirements for Commercial Fishing Vessels. 

Requirement Number of Vessels a Cost per Vessel b Total Costs

NOI 321 $8.22 $2,640

Routine inspections c 2,184 $50.58 $110,475

Recordkeeping c 2,184 $16.86 $36,825 

Drydock inspection c 2,184 $16.86 $35,925

Annual report 2,184 $50.58 $110,475

Total (Low End Estimate) $113,115

Total (High End Estimate) $296,339

a The count excludes 142 commercial fishing vessels that submitted an NOI as of August 2010. The burden for these 

vessels is already included in the baseline for this rule. 

b The costs are calculated assuming a labor rate of $33.72.

c Cost is excluded from low end estimate

4.5 ANALYSIS OF TOTAL NATIONAL COSTS 

The estimated total compliance costs for each of the practices that have the potential to represent 

an incremental cost to vessel owners are provided in Table 4-30. The estimated VGP compliance 

costs vary between the low and high end estimates because of the different assumptions made 

regarding the vessel populations and the number of instances for which incremental costs will be 
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incurred. As shown in the table, the largest share of incremental costs is associated with practices 

related to the oil-to-sea interface discharge category, followed by those in the ballast water and 

graywater discharge categories. Various changes to streamline the paperwork requirements for 

certain types of vessels are expected to result in an aggregate reduction in inspection and 

recordkeeping burden and associated costs. 
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Table 4-30. Total Annual Compliance Costs, by Practice Category and Vessel Class

Vessel Class

Total Annual Costs (2010$)

Deck 

Washdown Bilge Watera

Ballast 

Water

Cathodic 

Protection

Oil to Sea 

Interfaces Graywater

Exhaust Gas 

Scrubber 

Washwater

General 

Inspection 

and 

Paperwork

Low End Estimate

Commercial Fishing $0 $0a $260,106 $0 $534,654 $52,414 $0 $113,115

Freight Barges $0 $0a $0 $0 $1,821,140 $0 $0 -$771,017

Freight Ships $0 $0

a $626,605 $0 $544,316 $25,554 $24,418 $0

Passenger Vessels $0 $0

a $96,809 $0 $483,069 $96,594 $0 $0

Tank Barges $0 $0a $0 $0 $327,422 $0 $0 -$138,537

Tank Ships $0 $0

a $32,762 $0 $103,580 $10,292 $9,990 $0

Utility Vessels $0 $0

a $52,539 $0 $2,169,474 $46,289 $0 $0

Low End Total $0 $0a $1,068,820 $0 $5,983,656 $231,144 $34,408 -$796,440

High End Estimate

Commercial Fishing $141,627 $0

a $626,994 $144,496 $1,642,369 $91,574 $0 $296,339

Freight Barges $0 $0a $0 $0 $5,606,986 $0 $0 -$771,017

Freight Ships $0 $0a $1,476,474 $0 $1,630,424 $32,332 $53,570 $0

Passenger Vessels $0 $0

a $217,782 $0 $1,483,289 $103,221 $0 $0

Tank Barges $0 $0a $0 $0 $1,007,702 $0 $0 -$138,537

Tank Ships $0 $0

a $73,702 $0 $309,930 $13,053 $21,918 $0

Utility Vessels $0 $0a $118,192 $0 $6,641,840 $77,768 $0 $0

High End Total $141,627 $0a $2,513,144 $144,496 $18,322,539 $317,948 $75,488 -$613,215

a EPA is considering optional bilge water practices. Since the practices are not included in the proposed 2013 Permit, however, potential incremental costs to 

vessel owners are not included in the cost of the proposed Permit.
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Table 4-31 summarizes the total estimated costs to each vessel class across the discharge 

categories. As shown in the table, total annual costs range between $6.5 million and 

$20.9 million, depending on the set of assumptions used. 

Table 4-31. Total Annual Compliance Costs for All Practices, by Vessel Type, Including 

Paperwork Costs.

Vessel Type Total Cost (2010$)a

Low End Estimate

Commercial Fishing $960,288

Freight Barges $1,050,123

Freight Ships $1,220,893

Passenger Vessels $676,472

Tank Barges $188,885

Tank Ships $156,625

Utility Vessels $2,268,302

Low End Total $6,521,588

High End Estimate

Commercial Fishing $2,943,399

Freight Barges $4,835,969

Freight Ships $3,192,800

Passenger Vessels $1,804,293

Tank Barges $869,164

Tank Ships $418,603

Utility Vessels $6,837,800

High End Total $20,902,027

a Only includes U.S. flagged vessels.

4.6 UNCERTAINTIES AND LIMITATIONS 

There is significant uncertainty in several assumptions that affect the costs discussed in this 

section, including:

 The number of vessels expected to implement practices to comply with new requirements 

is uncertain. In addition to uncertainty regarding the number of vessels operating in U.S. 

waters (see Section 2.6), there is also uncertainty regarding practices currently 

implemented by active vessels. For practices that are included in (or were considered for) 

the 2008 VGP for at least some vessels, EPA used information obtained from industry 

representatives during the development of the 2008 VGP. The information reflected 

conditions before promulgation of the VGP and therefore may differ from baseline 

practices currently being implemented. EPA also relied on information compiled from 

NOIs received through August 2010. The NOI information is self-reported and not 

always reported across all vessels. Nonetheless, it likely provides the most relevant 

indicator of practices implemented by the subset of NOI vessels for the analysis baseline.

To account for uncertainty in the number of vessels that implement practices, EPA used 

ranges wherever possible to indicate the sensitivity of the results to varying assumptions.
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 Cost information was obtained from industry during the development of the 2008 VGP. 

EPA complemented this information with additional research of public data and personal 

communications with industry experts. For example, the costs of bilge water treatment 

systems were developed by reviewing manufacturer specification, published literature, 

and through interviews with industry representatives. Costs for laboratory tests, soaps and 

cleaners, and other practice components were obtained using similar methods. Because 

EPA made a limited number of contacts, the relevant estimates are likely to be subject to 

uncertainty regarding their applicability to different vessels considering the diversity of 

vessel characteristics and operations. Wherever possible, EPA used ranges to reflect the 

diversity in costs.

 For certain practices – most notably the use of environmentally acceptable lubricants – 

EPA was unable to obtain detailed information on either product costs or quantities likely 

to be purchased for different types of vessels, despite numerous attempts to obtain the 

information from various industry representatives including from lubricant 

manufacturers, vessel owners, or ship maintenance companies. Industry representatives 

we contacted could not provide the requested cost information either because they 

considered the data confidential business information, because they did not feel that their

data were sufficiently representative, or because they felt that any estimate they may be 

able to develop would not appropriately capture variability across vessels or locations. 

The anecdotal information EPA was able to obtain regarding EAL prices or volumes

were not sufficiently detailed to be used in the analysis. For the purpose of this 

preliminary analysis, EPA relied on pricing information obtained from retail vendors and 

on an illustrative example provided by one industry representative. The assumed prices 

for conventional and EALs may be higher or lower than prices actually paid by vessel 

owners for different products and vessel types. EPA estimated quantities of lubricants for 

different vessel classes based on leakage rates reported for different types of vessels in 

Edkin (2010). The amount of lubricant purchased by vessel owners would have to be at 

least enough to make up for leaks and leakage rates may therefore represent a lower 

bound for the amount of lubricant purchased. Anecdotal information EPA compiled from 

industry representatives suggests, however, that these volumes are generally within the 

range of annual consumption of lubricants used in oil-to-sea interfaces for different 

classes of vessels. 

 There is uncertainty about the number of vessels to which some practices apply, either 

because of a lack of detailed information about individual vessels or because of evolving 

technologies that may change the character of vessel discharges. Requirements applicable 

to discharges from exhaust gas cleaning systems (EGCS) apply to a subset of vessels that 

use such systems (see Section 4.2.26). A present, only a handful of vessels use EGCS and 

projections on the number of domestic vessels that may be equipped with EGCS in the 

future are highly speculative. To reflect the uncertainty, EPA used ranging assumptions 

on the number of vessels to which the different requirements may apply. 

Given these important areas of uncertainty, the cost estimates discussed throughout this report

should be interpreted as illustrative of the range of incremental costs that may result from 

complying with the revised VGP requirements, and not as a precise account of costs that a vessel 

owner may incur for any specific vessel.
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5 ANALYSIS OF IMPACTS ON FIRM REVENUES AND FINANCIAL 

PERFORMANCE

The previous chapters assessed total compliance costs to vessels of revisions to the VGO 

requirements. As summarized in Section 3, most of these vessels are associated with firms in the 

fishing and water transportation industries. Section 4 presents the ranges of incremental costs that 

may be incurred by each vessel covered by the VGP, depending on the assumed unit costs of each 

required practice, which may vary by vessel type, size, and operating characteristics. 

To determine the economic impacts of revisions to the VGP, EPA examined the incremental 

compliance costs relative to the financial conditions of “typical” businesses associated with the 

affected vessels. Since over 95 percent of the firms in the water transportation and fishing 

industries and in the drilling oil and gas wells sector are small (see Section 3.4.3), it is unlikely 

that a significant number of large firms would incur material impacts. Large firms are also more 

likely to operate larger or a greater number of vessels. Because the relative impact of VGP 

compliance and the number of affected entities are expected to be much greater for small 

entities, 50 the firm-level analysis focuses on assessing impacts on small businesses,.

5.1 METHODOLOGY

The analysis involves combining the estimated incremental operating costs attributed to 

compliance with the 2013 VGP with information about baseline financial conditions of model 

firms in each industry to examine the potential financial impacts on firms. Cost-to-revenue ratios 

are used as metrics for potential financial stress, where financial stress may reveal itself as a lack 

of profitability, cash deficiencies, or even bankruptcy. Firms expected to experience financial 

stress may need to change their business operations, including potentially downsizing or closing 

operations. 

The key steps of the analysis involve: (1) assigning each vessel in the vessel database to a NAICS 

code, (2) estimating the number of vessels per firm in each industry, (3) estimating the 

distribution of compliance costs per vessel and per firm, and (4) comparing the costs to the firm 

revenues. These steps are described below.

5.1.1 ASSIGN EACH VESSEL TO A NAICS CODE

The framework for the model firms reflects the range of firm types across the major industry 

groups. Financial data for each major industry groups are available in the Economic Census while 

SBA provides firm data by revenue bracket. Since the Economic Census does not have the same 

vessel categories as compared to other data sources (notably the MISLE/WTLUS database, which 

 

50 Small entities are defined as one of the following: A small business according to SBA size standards; a small 

governmental jurisdiction that is a government of a city, county, town, school district, or special district with a 

population of less than 50,000; or a small organization that is a not-for-profit enterprise that is independently owned 

and operated and is not dominant in its field.
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contains more complete numbers of all potentially regulated vessels and firms), each of the 

vessels and firms from the vessel database was assigned to a NAICS code to correspond to the 

Economic Census industry categories. The number of firms likely to incur costs as a result of the 

Permit was identified using the MISLE data based on the number of uniquely named managing 

owners for vessels expected to be covered by the VGP. The number of firms likely to incur costs 

as a result of the Permit was identified using the MISLE and WTLUS databases. Firms identified 

in the vessel databases were assigned a NAICS code in order to determine the number of firms 

subject to permit requirements for each NAICS code. Industry classification information for 

individual firms listed in the vessel databases was obtained primarily from ReferenceUSA’s 

Business Database (ReferenceUSA, 2006), Dun & Bradstreet’s Million Dollar Database (Dun & 

Bradstreet, 2006) and manta.com, supplemented by company Web sites and industry 

publications. Both ReferenceUSA and Dun & Bradstreet link subsidiaries and branch offices to 

company headquarters, allowing for an identification of domestic parent entities. Dun & 

Bradstreet’s Million Dollar Database classifies businesses based on eight-digit Standard Industrial 

Classification (SIC) codes. Since both the Census and SBA base their data on NAICS codes, EPA 

matched the first four digits of the SIC codes provided in Dun & Bradstreet to corresponding sixdigit NAICS codes using the U.S. Census Bureau’s bridge between 1987 SIC and 2002 NAICS 

codes (U.S. Census Bureau, 2002b). 2007 NAICS codes for the affected industries are unchanged 

from their 2002 definitions. The Dun & Bradstreet company names were matched to the vessel 

owner/operator names in the MISLE/WTLUS database to provide a NAICS code classification 

for most vessels in the vessel database. Vessels that could not be matched to a NAICS code based 

on their owner/operator were allocated to the NAICS sectors using the relative distribution of 

vessels across the sectors, by vessel type.

Once the number of firms with vessel permits was estimated for each NAICS code, EPA 

distributed these firms across revenue size categories proportionally to the distribution of firms by 

revenue size category indicated in Economic Census data. This estimated distribution of firms by 

revenue size category is assumed to be more accurate than estimates that could be derived solely 

from the Economic Census, since the Economic Census includes firms that are not expected to be 

affected by the rule. These totals were used to determine the number and percentage of firms 

experiencing economic impacts.

5.1.2 ESTIMATE THE NUMBER OF VESSELS PER FIRM

To establish the baseline and post-cost financials for each model firm, the per-vessel practice

costs developed in Section 4 are applied to the firm level. To determine the total incremental costs 

that a firm could incur, EPA first estimated the average number of vessels owned and operated by 

firms in each NAICS sector using information from the combined MISLE/WTLUS database. 

As shown in Table 5-1, the average number of vessels varies across the NAICS sectors from 

about one vessel per owner in the fishing industry, to nearly four vessels per owner in the support 

activities for water transportation sector. 
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Table 5-1: Number of Vessels by Firm in Each Industry Sector.

Number of Vessels Listed Under the 

Same Managing Owner

NAICS Description Minimum Maximum Average

Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water Transportation 1 32 1.8

Inland Water Transportation 1 72 2.0

Scenic and Sightseeing Transportation, Water 1 24 1.3

Support Activities for Water Transportation 1 74 3.7

Fishing Industry

Fishinga 1 96 1.1

Mining Industry

Drilling oil & gas wells sector 1 34 3.1

Source: EPA analysis of MISLE data (USCG, 2009).

For each NAICS code, EPA determined the number of vessels that were listed with a firm name 

as well as the number of firms corresponding to these vessels. Based upon the total number of 

firms and vessels within the subset in each NAICS code, the average number of vessels per firm 

was determined for each NAICS code. However, since this value is expected to vary among the 

different firm sizes, this average value was adjusted for each revenue size category so that the 

average number of vessels in each revenue size range is proportional to the midpoint of revenue 

in a revenue size category and the total number of vessels obtained when multiplying the number 

of firms by the number of vessel is equal to the total vessel population. 

EPA expects that some firms, particularly those in the smallest revenue category (annual revenue 

less than $100,000), may not operate vessels subject to the 2013 VGP. For example, they may use 

vessels less than 79 feet that are instead covered by the sVGP. This is consistent with reported 

revenue per vessel discussed in Section 3.4.2, which indicate revenue for the larger vessels that 

are often greater than the average revenue of firms in the smallest revenue category 

(approximately $50,000). For example, revenue of commercial fishing firms using medium and 

large vessels ranged between $82,000 and nearly $2.5 million, with average revenue to Northeast 

fishermen using vessels 75 feet and averaging $790,779 per vessel in 2010 (NOAA, 2011b). 

Historical data of per vessel revenue for other industry sectors suggest earnings in the $10,000 to 

$40,000 per day (USCG, 2008). While these represent averages for certain types of vessels and 

operations and variability is expected, the figures nonetheless suggest that larger vessels such as 

those covered by the VGP are perhaps less likely to be operated by firms in the lowest revenue 

category. Accordingly, EPA allowed the average number of vessels for firms in the lowest 

revenue category to be less than one (0.5 vessels per firm), reflecting the fact that not all of the 

smallest of firms operate vessels subject to the 2013 VGP and/or the vessels they operate tend to 

be at the lower end of the size range and have lower compliance costs (e.g., less likely to use 

onboard ballast water treatment, consume less lubricants, require less complex inspections). 

5.1.3 ESTIMATE THE DISTRIBUTION OF COSTS PER VESSEL

For each vessel type and discharge category, EPA has already estimated in Section 4: (1) the total 

number of vessels, (2) the probability of a vessel incurring incremental costs, and (3) the 
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incremental cost of each practice. By assuming that the probability of incurring an incremental 

cost for a given practice is independent of incurring costs for any of the other practices, EPA can 

estimate the probabilities of incurring costs for all possible combinations of practices. 

In the analysis, the low end cost estimate includes up to five possible practices, and the high end 

cost estimate includes up to six possible practices. Treating each practice cost as an independent, 

binary “on/off” cost event, this means that there are theoretically 25 and 26

 possible combinations 

of cost events for the low end and high end cost estimate, respectively. Each combination cost 

event is defined on the basis of whether or not each of the specific practices is “on” or “off” (and 

the resulting costs) together with the probability of each practice being “on” or “off.” Each 

practice is assigned a probability of occurrence for each vessel class by dividing the number of 

vessels estimated to incur a given practice cost by the total number of vessels, and therefore this 

is the probability for the individual practice to be “on.” Conversely, the probability of the 

individual practice being “off,” is equal to one minus the probability of the practice occurrence. 

The overall probability of occurrence for a given practice combination is the product of these 

individual probabilities. As a result, most of the cost combinations are not meaningful for the 

impact analysis because one or more of the practice “on/off” instances in the combination event 

have a zero probability of occurrence, and thus the overall probability of that particular event, 

which is calculated as the product of the individual “on” or “off” practice probabilities, is zero. 

The high occurrence of zero probability combination practice events results from the presence of 

practice costs that are always assumed to be incurred, or have one hundred percent probability of 

occurrence. The maximum number of observed practice combinations for a vessel type is 

therefore smaller than the theoretical 64 possibilities (64 = 26

). 

For each of the possible practice combinations, EPA multiplied the total number of vessels by 

vessel class by the calculated probability of the combination practice event to estimate the 

number of vessels incurring costs for a given combination of practices. Finally, EPA calculated 

the per-vessel cost by vessel class associated with each combination of practices by summing the 

costs of the individual practices where costs are incurred. This calculation provided the 

distribution of per-vessel costs. The distribution shows a high probability of occurrence for very 

low cost combination practice events. The probability of occurrence declines rapidly as the cost 

of the combination practice events increases. The higher cost combination practice events—

which require a combination of all or nearly all of the individual practices—have a very low 

probability of occurrence. 

EPA estimated the distribution of per-firm costs from the distribution of per-vessel costs using the 

following approach. For firms in industries with more than one vessel class, EPA estimated vessel 

costs corresponding to the minimum, maximum and each 10 percentile increment in between 

these extremes – thereby yielding 6 possible vessel costs, which are assumed to be equally likely. 

For firms in industries with two vessel types, EPA evaluated the firm costs for 62 possible 

combinations of costs. For firms in industries with N vessel types, EPA evaluated the firm costs 

for 6N possible combinations of costs – 6 possible costs for each vessel class. For each industry, 

EPA calculated an average per-vessel cost from the vessel class-specific costs for all 6N possible 

combinations based on the relative number of vessels in each class. This average cost per vessel 

was then multiplied by the number of vessels per firm in each industry for a given revenue size 

category. Thus, for industries with more than one vessel class, EPA estimated a distribution of 

costs per firm with 6N equally likely possibilities, where N is the number of vessel classes 

observed for the industry. There were three sectors with only one vessel class, three sectors with 
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six vessel classes, and one sector each with two, three, four, and five and seven vessel classes. 

Figure 5-1 illustrates the calculation of firm cost impact for one possible combination of vessel 

costs and one revenue size bracket in a sector with two vessel classes.
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Figure 5-1: Illustrative calculation potential firm cost for one sector with two vessel types. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 121

5.1.4 COMPARE FIRM-LEVEL COSTS TO FIRM-LEVEL REVENUES

Data from the Economic Census as well as from the SBA’s Statistics of U.S. Businesses were 

used to determine the firm-level financial data for the transportation and mining industries. These 

sources provided the distribution of firms across several revenue brackets as well as the average 

revenue value in each revenue bracket. For firms associated with commercial fishing vessels, we 

combined Census information with statistics from NOAA and other sources on revenue per vessel 

(see Section 3.4) to characterize the distribution of revenue among firms of different sizes.

To evaluate the potential impact of the revised VGP on small entities, EPA used a cost-to-revenue 

test to evaluate the potential severity of economic impact on vessels and facilities owned by small 

entities. The test calculates annualized pre-tax compliance cost as a percentage of total revenues 

and uses a threshold of 1 and 3 percent to identify facilities that would be significantly impacted 

as a result of this Permit. 

The cost values equivalent to the 1 and 3 percent thresholds were estimated from the average 

revenue in each revenue bracket, or the midpoint of the revenue bracket when average revenue 

was not reported. EPA estimated the percentage of firms that would be significantly impacted as a 

result of the VGP revisions as the percentage of firm for which the estimated firm-level costs 

(number of vessels times the per vessel compliance costs) exceeded the 1 percent or 3 percent 

revenue thresholds.

5.2 SMALL ENTITY ANALYSIS

As described, EPA prepared an analysis that examines the impacts of this Permit on small 

entities. A small entity may be:

 A small business according to SBA size standards; 

 A small governmental jurisdiction that is a government of a city, county, town, school 

district, or special district with a population of less than 50,000; or 

 A small organization that is a not-for-profit enterprise that is independently owned and 

operated and is not dominant in its field.

The SBA defines small businesses based on NAICS codes and size standards expressed by the 

number of employees or annual receipts (13 CFR §121.20). For the water transportation, fishing, 

and drilling oil and gas wells sectors, SBA’s business size standards are based on annual revenues 

as well as employee size. The thresholds are as follows:

 Deep sea, coastal, and Great Lakes water transportation; inland water transportation – 

fewer than 500 employees

 Scenic and sightseeing transportation; navigational services to shipping and salvage; 

other support activities for water transportation – revenues less than $7 million 

 Port and harbor operations; marine cargo handling – revenues less than $25.5 million 

 Fishing – revenues less than $4 million 

 Drilling oil and gas wells sector – fewer than 500 employees (U.S. SBA, 2010). 
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If the revenues or employment were smaller than the corresponding thresholds, EPA classified 

the entities as small. Section 3.4.3 presents the number of small businesses in each sector of the 

water transportation and fishing industries, and of the drilling oil and gas wells sector within the 

mining industry. On the whole, the affected industries consist of more than 90 percent small 

businesses. Based on data from the U.S. Census Bureau and the SBA, of the 4,603 firms in the 

water transportation industries, 4,365 (95 percent) are small. In the fishing industry, 1,973 

(96 percent) of the 2,053 firms are small. In the drilling oil and gas wells sector, 2,073 

(98 percent) of the 2,109 firms are small.

After calculating the distribution of per-firm costs, the number and percentage of firms where 

costs exceed 1 percent and 3 percent of revenue was estimated (by NAICS sector and revenue 

bracket).

The costs used in this economic analysis are annualized costs, which reflect the annual equivalent 

value of first-year (one-time) costs and recurring costs. The resulting 2010 annualized costs for 

implementing practices to address relevant discharges range from $0 to about $6,700 per vessel, 

with the upper value for a freight ship assumed to incur the maximum of each applicable practice 

cost. Maximum compliance costs vary depending on the vessel type. For example, the maximum 

annual cost for a barge assumed to incur the maximum of each and every applicable practice is 

less than $500, with most of this cost associated with oil-to-sea interface practices. Across all 

vessel categories, relatively few vessels incur the maximum compliance costs and average annual 

costs are significantly lower: between $26 and $3,933, depending on the vessel type. 

After calculating the distribution of per-firm costs, the number of firms where costs exceed 

1 percent and 3 percent of revenue was estimated (by NAICS sector and revenue bracket). The 

costs used in the economic analysis are annualized costs, which reflect the annual equivalent 

value of first-year (one-time) costs and recurring costs. 

Table 5-2 summarizes the average firm-level revenue, number of firms, and cost thresholds 

across industry sectors for the 1 percent and 3 percent cost-to-revenue tests. The cost thresholds 

indicate the compliance costs that would correspond to 1 percent and 3 percent of revenue, and 

yield a significant impact based on the cost-to-revenue test. Because the impact of VGP 

compliance is likely to be most significant for firms at the lower end of the firm size spectrum, 

the table focuses on firms in the smallest revenue category in each industry. This category 

includes firms earning less than $100,000 each year. 

As shown in the table, compliance cost thresholds range between $330 and $2,040 per year for 

the 1 percent and 3 percent levels, respectively, depending on the industry.

.
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Table 5-2. Estimated 1% and 3% Revenue Thresholds by NAICS Code for Firms in Smallest Revenue Category. 

NAICS Industry Average 

Revenue of 

Firms in 

Category a

Number of 

Firms in 

Revenue 

Category

Compliance Cost 

at 1% Revenue 

Threshold

Compliance Cost at 

3% Revenue 

Threshold

Water Transportation b

483111 Deep sea freight transportation $33,143 7 $331 $994 

483112 Deep sea passenger transportation $49,417 12 $494 $1,483 

483113 Coastal/Great Lakes freight transportation $56,765 17 $568 $1,703 

483114 Coastal/Great Lakes passenger transportation $53,154 13 $532 $1,595 

483211 Inland waterways freight transportation and towing 

transportation

$33,000 16 $330 $1,056 

483212 Inland waterways passenger transportation and other water 

transportation

c $50,000 34 $500 $990

487210 Scenic and sightseeing transportation, water $48,283 247 $483 $1,448 

488310 Port and harbor operations $60,636 11 $606 $1,819 

488320 Marine cargo handling $68,000 11 $680 $2,040 

488330 Navigational services to shipping and salvage $55,661 56 $557 $1,670 

488390 Other support activities for water transportation $59,742 120 $597 $1,792 

Fishing d

1141 Commercial fishing $53,079 505 $531 $1,592

Mining d

213111 Drilling oil and gas wells $48,316 237 $483 $1,449

213112 Support activities for oil and gas operations $46,890 826 $469 $1,407

a Category includes all firms with receipts less than $100,000.

b Source: U.S. Census: Transportation and Warehousing: Subject Series - Establishment & Firm Size: Summary Statistics by Revenue Size of Firms for the United States: 2007

c No average revenue per firm is available. The value reflects the mid-point of the revenue size category.

d Source: SBA: U.S. All Industry Data by Receipt Size: 2007.
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Table 5-3 presents the distribution of the entities’ cost-to-revenue ratios. As summarized in Table 

5-3, the model results suggest that the total number of entities in the fishing industry that are 

expected to exceed the one percent cost-to-revenue threshold ranges between 0 and 189 for the 

low end and high end cost assumptions, respectively.

51 If we assume that all these entities are 

small, this number represents about 10 percent of small firms. The total number of entities in the 

water transportation industry that are expected to exceed the one percent cost-to-revenue 

threshold ranges from 52 to 171 under the low and high end cost assumptions, respectively, 

representing up to 6 percent of small firms, if we assume that all affected entities are small 

firms.

52 Overall, up to 7 percent of firms have costs estimated to exceed the one percent cost-torevenue threshold and less than 1 percent of firms are estimated to exceed the three percent costto-revenue threshold, based on high end cost estimates.53 

The critical cost thresholds range depending on revenue range and NAICS code. For example, a 

firm in the commercial fishing industry within the revenue range of $0-$100,000 (with average 

revenue for firms within the bracket of $53,079) would have a one percent critical cost threshold 

of $531. On the other hand, a firm within the marine cargo handling industry within the revenue 

range of $100 million or more (with average revenue of over $235 million) would have a 

one percent critical cost threshold of nearly $2.4 million. The majority of firms in the water 

transportation, fishing industry, and the drilling oil and gas wells sector have revenue ranging 

between $100,000 and $499,999. As shown in Table 5-3, the percentage of firms expected to 

exceed the 1 percent threshold under both the low and high end cost assumptions ranges from 0 to 

21 percent depending on the NAICS code. In examining the percentage of entities affected, the 

most impacted entities fall within the navigational service and inland waterways transportation 

sectors. These two sectors both have over 15 percent of entities that exceed the 1 percent 

threshold under the high end cost assumptions, but both have fewer than 100 entities (and less 

than 10 percent) estimated to exceed the 3 percent threshold. Under the low end cost assumption, 

less than 10 entities exceed the 3 percent threshold in the two sectors combined. 

As discussed later in Section 5.3, there is uncertainty in the estimated impacts of the revised VGP 

requirements on small entities, due to the way costs are allocated to vessels and to firms. In the 

absence of more detailed information on the characteristics of vessels and their respective owning 

firms, the analysis is meant to illustrate the potential magnitude of impacts to firms of different 

sizes. Considering per vessel revenue described earlier in this section and in Section 3.4.2, EPA 

believes that the analysis may overestimate impacts on the smaller firms by overstating their 

compliance costs. 

 

51 The distributional analysis model is likely overstates impacts to firms in this sector due methodology limitations 

discussed later in this Section and in Section 5.3, notably EPA’s conservative assumptions regarding the distribution of 

vessels to firms across size categories and relatively uniform characteristics of vessels assigned to firms with very 

different annual revenue.

52 Idem.

53 Idem.
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Table 5-3. Results of the Small Entity Impact Analysis. 

NAICS Code NAICS Description

1 Percent of greater Between 1 and 3 

Percent 3 Percent or greater

# 

Firms

% All 

Firms

% 

Small 

Firms

# 

Firms

% All 

Firms

% 

Small 

Firms

# 

Firms

% All 

Firms

% 

Small 

Firms

Low End Cost Estimate

11411 Finfishing, shellfishing, and other commercial fishing 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

483111/483113 Deep sea/coastal and Great Lakes freight 2 0.4% 0.4% 2 0.4% 0.4% 0 0.0% 0.0%

483112/483114 Deep sea/coastal and Great Lakes passenger 5 2.8% 2.9% 5 2.8% 2.9% 0 0.0% 0.0%

483211 Inland waterways freight transportation and towing transportation 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

483212 Inland waterways passenger transportation and other water transportation 6 3.5% 3.5% 6 3.5% 3.5% 0 0.0% 0.0%

487210 Scenic and sightseeing transportation, water 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

488310 Port and harbor operations 3 1.3% 1.5% 3 1.3% 1.5% 0 0.0% 0.0%

488320 Marine cargo handling 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

488330 Navigational services to shipping and salvage 37 5.7% 6.7% 37 5.7% 6.7% 0 0.0% 0.0%

488390 Other support activities for water transportation 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

TOTAL 52 0.9% 1.0% 52 0.9% 1.0% 0 0.0% 0.0%

High End Cost Estimate

11411 Finfishing, shellfishing, and other commercial fishing 189 9.2% 10.2% 189 9.2% 10.2% 0 0.0% 0.0%

483111/483113 Deep sea/coastal and Great Lakes freight 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

483112/483114 Deep sea/coastal and Great Lakes passenger 17 10.6% 10.9% 15 9.2% 9.4% 2 1.4% 1.4%

483211 Inland waterways freight transportation and towing transportation 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

483212 Inland waterways passenger transportation and other water transportation 37 21.0% 21.0% 34 19.2% 19.2% 3 1.8% 1.8%

487210 Scenic and sightseeing transportation, water 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

488310 Port and harbor operations 27 13.5% 15.4% 26 13.0% 14.9% 1 0.5% 0.6%

488320 Marine cargo handling 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

488330 Navigational services to shipping and salvage 90 14.1% 16.6% 85 13.3% 15.6% 5 0.8% 0.9%

488390 Other support activities for water transportation 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

TOTAL 360 6.0% 6.6% 348 5.8% 6.4% 11 0.2% 0.2%

Figures do not necessarily add to totals due to rounding.
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5.3 UNCERTAINTIES AND LIMITATIONS

In addition to uncertainty previously discussed in Section 4.6 relating to the compliance cost 

estimates for the various discharge categories, the distributional analysis discussed in this section

involves additional uncertainties related to how these costs are allocated to firms in each industry 

sector. 

For example, there is uncertainty surrounding the assignment of vessels to firms of different sizes. 

The VGP applies to non-recreational and non-military vessels 79 feet or more in length only. 

Vessel and firm-level data are not sufficiently detailed, however, to assign vessels of different 

sizes to firms in different revenue categories. Yes, the results of the distributional analysis are 

sensitive to this assumption. For the purpose of this analysis, EPA assumed that firms in the 

smallest revenue category potentially own and operate vessels covered by the VGP, and, further, 

that these firms are as likely as larger firms to own and operate any of the vessels covered by the 

VGP, regardless of its size or complexity. Instead, firms in the smallest revenue category possibly 

own and operate smaller vessels not covered by the VGP but instead covered separately under the 

sVGP. These firms would incur no incremental costs due to the revised VGP requirements. Even 

in cases where small firms own vessels covered by the VGP, these vessels may be smaller and 

less complex than the vessels owned by larger firms. As was discussed in Section 3.4.2, per vessel 

revenue generally increases with vessel size, suggesting that firms with lower revenue generally 

operate smaller vessels. Because of this distribution and because compliance costs tend to 

increase with vessel size and complexity, the analysis may overstate impacts on small firms. EPA 

adjusted the distribution to account for this to some degree by allowing firms in the smallest of 

the revenue categories (firms with annual revenue less than $100,000) to be assigned costs for 

less than one VGP vessel. 

In conducting the distributional analysis, EPA did not include cost savings associated with 

streamlining of the inspection, recordkeeping, and paperwork requirements. This is due to the 

difficulty of assigning these cost savings to any specific vessel since the savings will depend on 

the number of vessels owned by any given firm. As discussed in Section 4.4, however, these cost 

savings could be significant for firms with multiple freight or tank barges or with unmanned 

vessels. 

For each revenue bracket, EPA assumed that firm revenues were equal to the average revenue in 

the bracket (or the midpoint when the average was not available). There is uncertainty associated 

with this simplifying assumption, because calculating an average firm cost results in less variation 

compared to an alternative approach that simulates a distribution of firm revenues within revenue 

size ranges. 

There is uncertainty surrounding EPA’s assumption that the average number of vessels per firm is 

proportional to the midpoint of the revenue bracket. These assumptions may result in 

underestimation or overestimation of the number of vessels per firm, and the underestimation or 

overestimation may vary by revenue size category. In general, EPA believes that it is reasonable 

to assume that the smaller firms are likely to own or operate fewer vessels, or may own or operate 

a vessel that is smaller than the VGP size threshold of 79 feet. 

There is uncertainty surrounding the choice of using only 11 possible costs for each vessel class

(minimum, maximum, and by 10 percentile increments) and more accurate estimates could be 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

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obtained by using a greater number of cost possibilities. However, since industries can have up to 

seven vessel types, the number of sampled vessel costs is limited by computational feasibility - 

with up to 6 possible vessel-class costs and 7 vessel types there are 67 possible firm costs. 

After simulating a sample of vessel class costs, EPA calculated an average cost per vessel across 

all vessel classes within each industry sector. For example, NAICS 483212 include both 

passenger vessels and utility vessels, and on average, firms in the lowest revenue bracket have 

one vessel. Since 98 percent of the firms’ vessels are passenger vessels, the firm cost is estimated 

as the weighted average of vessel costs (0.98 * [Passenger Vessel Cost] + 0.02 * [Utility Vessel 

Cost]). There is uncertainty associated with this simplifying assumption, because calculating a 

weighted average vessel cost results in less cost variation compared to an alternative approach 

that simulates a distribution of vessel classes for firms.

Finally, there is uncertainty associated with the simplifying modeling assumption that practices 

are cost events with independent probabilities of being assigned to any one vessel. Instead, EPA 

expects that larger vessels are more likely to incur costs for more of the applicable practices, i.e., 

a vessel that is large enough to use a BWTS to comply with the ballast water requirements could 

also be more likely to employ bilgewater treatment. 
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6 BENEFITS ANALYSIS

EPA expects that reductions in vessel discharges resulting from revisions to the VGP will benefit 

society in two broad categories: (1) reduced risk of invasive species introduction and (2) 

enhanced environmental quality from reduced pollutant discharges. Section 6.1: Ballast Water 

and Invasive Species Impacts provides a qualitative assessment of the ecological and economic 

impacts of invasive species introductions and the benefits of reducing the occurrence of invasive 

species. Section 6.2: Benefits of Reduced Pollutant Discharges from Vessels discusses pollutants 

of concern (POCs) found in vessel discharges, their environmental effects, and the benefits likely 

to be achieved by the revised VGP requirements.

6.1 BALLAST WATER AND INVASIVE SPECIES IMPACTS

6.1.1 INTRODUCTION AND BACKGROUND

Introductions of non-indigenous species have occurred in the United States for centuries, with 

more than 50,000 total non-native species thought to be successfully established with reproducing 

populations in U.S. territory (Pimentel et al., 2005). Scientists and governments have long 

recognized the economic and ecological damages associated with land-based invaders, but 

attention has only turned toward aquatic non-indigenous species (ANS) since the 1980s, when the 

extent of the zebra mussel invasions in the Great Lakes region first became a serious problem 

(Ruiz and Reid, 2007). ANS invasions have caused tremendous economic and ecological 

damages to critical coastal and inland waters throughout the United States.

ANS may be introduced through a variety of vectors, including intentional introductions, escape 

from a confined environment, or ballast water and sediment from ballast tanks. One of the major 

known vectors for ANS introduction is through the ballast water tanks of commercial vessels. 

Ballast water is taken on in or near port to provide stability to ships that are not fully loaded. 

Often, aquatic invertebrates, plants, or microorganisms, as well as suspended sediments that may 

contain invasive species, are unintentionally taken in along with the ballast water. 

Studies conducted by NOAA’s Great Lakes Environmental Research Laboratory (GLERL) found 

that a majority of ships and a near-majority of tanks surveyed contained non-indigenous strains of 

pathogens known to cause human health impacts (Johengen et al., 2005; Reid et al., 2007). The 

Johengen et al. (2005) study also found that viable populations of non-native dinoflagellate and 

invertebrate species were present in a large majority of tanks sampled. Glassner-Shwayder (1999) 

refers to ships with ballast water as “biological islands” because they carry such a wide variety of 

organisms in their ballasts. According to some studies, as many as 4,000 species can be found in a 

typical ship’s untreated ballast water at one time.

When this ballast water is discharged in another port, or when sediments in the ballast tank are 

mixed with new ballast water, these species can be introduced into an exotic environment, and 

may become established under some conditions (Ruiz and Reid, 2007). Several of the most 

harmful invasive species currently known to exist in the United States, including the zebra 

mussel, the green crab, and the Asian clam, are all thought to have been introduced via ballast 
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water. Researchers hypothesize that as international trade, and therefore shipping traffic, 

increases, so does the threat of more ANS introductions (Glassner-Shwayder, 1999). 

The U.S. Coast Guard’s 2004 Rulemaking for Mandatory Ballast Water Management (codified in 

33 CFR 151) mandated open ocean ballast water exchange for ships traveling outside the 200-

nautical mile exclusive economic zone (EEZ) of the United States. While promulgation of the 

USCG regulation is reducing the probability of new introductions, it covers neither vessels 

traveling within the U.S. EEZ nor vessels with empty ballast tanks, both of which are potential 

sources of ANS introductions. The ballast water provisions of EPA’s 2008 VGP aimed to address 

these gaps where possible, further reducing the possibility of ANS introductions. Specifically, the 

2008 VGP required ballast water exchanges at least 50 nm from shore for vessels engaged in 

Pacific nearshore voyages, which were previously exempted from mandatory exchange 

procedures. It also required saltwater flushing for vessels declaring no ballast on board (NoBOB) 

or for vessels with some proportion of their ballast tanks empty. Several states have promulgated 

regulations that complement or strengthen national ballast water management requirements

specified in the 2008 VGP. 

While useful in reducing the presence of potentially invasive organisms in ballast water, ballast 

water exchange and saltwater flushing have variable effectiveness and may not always be feasible 

due to vessel safety concerns (EPA SAB, 2011). On August 28, 2009, the U.S. Coast Guard 

proposed new ballast water management standards to revise rules at 33 CFR 151 (74 FR 44632). 

These standards were proposed to be implemented in phases, with “Phase One” standards 

specifying limits on the discharge of living organisms that are similar to IMO’s Regulation D-2.54

Since the Phase One standards are expected to be in effect by the time vessels must obtain 

coverage under the 2013 VGP, EPA incorporated the USCG Phase One/IMO D-2 requirements in 

its new Permit. The 2013 VGP also includes monitoring, sampling, testing, and reporting 

requirements to verify the efficacy of ballast water treatment systems used onboard vessels.

Stricter limits on ballast water discharges and the confirmatory monitoring and testing will 

contribute to reducing the risk of ANS invasions and their consequences.

6.1.2 ANS IMPACTS

ANS invasions are a persistent problem in U.S. coastal and inland waters. ANS invade U.S. 

waters through a number of dispersal mechanisms including releases from fisheries; research and 

education facilities; restoration efforts; public aquaria and the aquarium pet industry; and by 

being attached to or within ships, drydocks, amphibious planes, floating marine debris, drilling 

platforms, navigation buoys and marine floats, canals, and recreational equipment (Carlton et al., 

2003). Each vector has been associated with introductions of highly damaging species in the past, 

although this analysis will focus primarily on the ballast vector described in the previous section. 

 

54 If practicability review shows that it is feasible, this Phase One standard would be followed by a “Phase Two” 

standard that set concentration limits at 1,000 times more stringent than Phase One standards for viable organisms 

greater than 10 microns and for bacteria and viruses.
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Though no reliable and comprehensive estimates of total ANS introductions nationwide exist, 

case studies of several major bodies of water across the country, as summarized in Table 6-1,

provide a sense of the extent of the problem. 

Table 6-1: Estimates of Invasive Species in Several Major Water Systems.

Region Estimated Rate of Invasiona Estimated Total Invasions to 

Dateb

Great Lakes Once every 28 weeksc 162

Mississippi River System Unknown 100

San Francisco Bay Once every 24 weeksd 212

Lower Columbia River Basin Once every 5 monthse 81

Gulf of Mexico Unknown 579

a Ruiz and Reid (2007) suggest that these figures may not reliably represent the true rate of introduction, as they are 

based on discovery data, which may not always track with the underlying rate of introduction. 

b All figures in this column are taken from USCG (2004b).

c NOAA (2007).

d Cohen and Carlton (1995).

e Sytsma et al. (2004).

The total costs associated with ANS in the United States are staggering. A recent study suggests 

that expenditures on control alone for ANS in the United States total approximately $9 billion 

annually (Pimentel et al., 2005). A broad range of damages are associated with any introduction 

of a given type of species, summarized in Table 6-2. Although some species cause no economic 

damage, others may cause hundreds of millions of dollars in damages. The majority of these 

damages may be broken down into six broad categories of impacts, which are described in the 

subsequent subsections.

Table 6-2: Estimates of Invasive Species Damages by Type of Species.

Type of Species Range of Potential Damages per Invasion per Year 

(Million 2010$)

Fish 0 – 161a

Mollusks 0 – 6,415b

Non-Mollusk Invertebrates 0 – 23.8c

Plants 0 – 36.9d

Pathogens 0 – 0.764e

a Based on Ruffe (Leigh, 1998), adjusted to 2007$ using CPI.

b Based on Zebra Mussel (Pimentel et al., 1999), adjusted to 2007$ using CPI.

c Based on European Green Crab (EPA, 2008a).

d Based on hydrilla (OTA, 1993), adjusted to 2007$ using CPI.

e Based on an outbreak of epidemic cholera (Lovell and Drake, 2007), adjusted to 2007$ using 

CPI.

COMMERCIAL AND RECREATIONAL FISHERIES

As noted above, the introduction of ANS can cause the imbalance of native ecosystems. ANS 

pose an especially serious risk to commercial and recreational fisheries, which like other aquatic 
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resources could be devastated by ANS (IDNR, 2003). Several examples of ANS impacts on 

fisheries are provided below (reported dollars are for the publication year). 

 Sea Lamprey: The sea lamprey, which is native to the Atlantic Ocean, was not initially 

introduced to the Great Lakes by ballast water, but has been introduced elsewhere 

through contaminated ballast water (Toledo, 2001). Upon its initial introduction, the sea 

lamprey caused a massive collapse of the trout fisheries in the Great Lakes. If sea 

lamprey control measures were eliminated, the resulting lost value to fisheries would be 

approximately $500 million annually, according to one estimate (OTA, 1993). Control 

measures that have been introduced to counteract the impacts of sea lampreys cost more 

than $12 million annually (ANSTF, 2007). 

 European Green Crab: The most likely mode of the initial European green crab 

introduction on the East Coast of North America was ship fouling (Cohen et al., 1995). 

Other possible pathways of introduction include ballast water and solid ballast. Grosholz 

(2006) and Cohen (1997) believe that incidental transport with commercial fishery 

products is the most likely vector for the initial introduction of C. maenas to the West 

Coast. The annual estimated economic damages from European green crab predation to 

commercial and recreational shellfisheries and eelgrass restoration efforts range from 

$18.6 to $22.6 million per year in the United States (EPA, 2008a). 

 Round Goby: The round goby, native to Eurasia and likely introduced via ballast water, 

is thought to have adverse impacts on fisheries, due to its lack of value as a sport or 

commercial catch and its aggressive tendencies toward baited lines. Fishermen report that 

they are sometimes able to catch only gobies when fishing for the more desirable walleye 

(Marsden and Jude, 1995). No attempts to quantify the value of these impacts have been 

made to date. 

 Zebra Mussel: An invasion of zebra mussels, which are native to the Caspian Sea and 

were introduced to U.S. waters in ballast water, has led to a halt in the $3 billion dollar 

Mississippi River shellfishing industry (Randall, 2001). 

 Pathogens: Pathogens transported in ballast water can also have significant adverse 

impacts on fisheries. Infectious salmon anemia (ISA) has been a persistent problem in 

U.S. Atlantic fisheries’ stocks since 2001. The original source and vector of this pathogen 

is unknown. Though there has been no attempt to quantify damages to the U.S. economy 

specifically from ISA, it is estimated that the annual cost in 1999 was $11 million in 

Norway, $14 million in Canada and $32 million in Scotland (Cipriano and Miller, 2002). 

Another recent fish pathogen of concern has been viral hemorrhagic septicemia (VHS). 

VHS has been known to exist in the coastal regions since the late 1980s, but only recently 

migrated into the Great Lakes through an unknown vector (USDA, 2006). An 

unpublished study found that VHS has impacted 6 of 23 fish species caught 

commercially in the Great Lakes, including two that account for 76 percent of the entire 

$13.5 million dollar harvest (Lovell and Drake, 2007). In 1991, an exotic strain of Vibrio 

cholerae (epidemic cholera) was identified in oysters in Mobile Bay on the Gulf Coast. 

The estimated economic losses due to the closure of oyster harvesting in Mobile Bay for 

five months in 1991 as a response to concerns about epidemic cholera contamination 

were $726,000 (2007$) (Lovell and Drake, 2007). 
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Two non-native pathogens, MSX (Haplosporidium nelsoni) and Dermo (Perkinsus 

marinus) have caused substantial damages to native oyster populations in several U.S. 

coastal regions. Though the original vector of introduction is unknown for both 

pathogens, ballast water is considered to be one potential source of MSX, and Dermo is 

known to transmit relatively easily between infected and uninfected oysters (McKnight, 

2007; Ewart and Ford, 1993). 

OTHER WATER-BASED RECREATION AND TOURISM

ANS have also had adverse impacts on recreation and tourism nationwide by damaging water 

quality and flow. Two invasive plants, hydrilla and water lettuce, have caused significant 

damages in U.S. waters. Both clog the water’s surface, blocking boating and swimming, 

impeding water flow, and disrupting plant and animal communities. Florida spends an estimated 

$1 million or more annually to control water lettuce, and the rest of the Eastern U.S. states spend 

approximately $100,000 annually (Van Driesche et al., 2002). Studies of two lakes in Florida 

affected by hydrilla found that degradation caused by the hydrilla cost the state $11 million in lost 

recreation expenditures (Pimentel et al., 1999).55

Invasive mollusks such as zebra mussels can also adversely affect a number of recreational 

activities, including boating and swimming. Zebra mussels often cover shorelines with sharpedged shells and rotting mussel flesh, which can diminish interest in visiting infested beaches. 

Biofouling can also be a deterrent to recreational boaters who would rather avoid zebra mussel 

fouling and the resulting necessity of extensive vessel cleaning (USACE, 2002). A study by 

Vilaplana and Hushak (1994) estimated that incremental annual costs to boat owners in the Great 

Lakes related to the mussel included $94 for protective anti-fouling paints, $171 for additional 

maintenance, and $207 for insurance.

BIODIVERSITY AND ECOSYSTEMS

Introductions of ANS can drastically alter virtually every characteristic of an aquatic ecosystem. 

ANS can affect the “composition, density, and interactions of native species” that can then cause 

“significant changes to the ecosystem, such as alterations to the food webs, nutrient dynamics and 

biodiversity” (IDNR, 2003). Ecosystems provide a variety of services, including water quality 

maintenance, detoxification and decomposition of waste, climate stabilization, mitigation of 

natural disaster impacts, and a source of income. Several significant instances of adverse 

ecosystem impact include:

 Zebra Mussel: Zebra mussels have had some of the most dramatic impacts observed to 

date on ecosystems, particularly in the Great Lakes region. The mussels achieved 

densities as high as 700,000 per square meter, which led to a much greater filtration rate 

of particulate matter, resulting in much lower turbidity (Griffiths et al., 1991; MacIsaac et 

al., 1995). This in turn led to much greater filtration of light through the water column, 

 

55 This cost may have an adverse impact locally, but because the money is still available to be spent elsewhere, this 

adverse impact does not represent a true net welfare loss.
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which affected plant viability and substantially increased competition for food for 

indigenous mollusks. 

 Round Goby: The round goby was first introduced into the Great Lakes region via ballast 

water. The goby preys on benthic fauna competing with species native to the Great Lakes 

and takes over prime spawning sites of native species, which is changing the balance of 

the ecosystem. Introduction of the round goby adversely affected a number of native 

species, including mottled sculpin, logperch, and darters. Due in part to the threat posed 

by the Round Goby and the Asian Carp, the U.S. Army Corps of Engineers and U.S. EPA 

have spent $1.2 million to erect a dispersal barrier to prevent its further spread down the 

Chicago Sanitary and Ship Canal to the Mississippi River (Glassner-Shwayder, 1999). 

 European Ruffe: The European ruffe preys on native fish and competes with them for 

habitat. It was introduced into the Great Lakes via ballast water and poses a serious threat 

to species like the walleye, yellow perch, and whitefish (Leigh, 1998). Populations of 

spawning European ruffe in the St. Louis River went from 200,000 in 1989 to 1.8 million 

in 1991. At the same time, populations of yellow perch, troutperch, emerald shiners, and 

spottail shiners decreased by 75 percent (RTF, 1992). The expected reduction in value of 

sport and commercial fisheries in the Great Lakes region due to the ruffe invasion is $119 

million (ANSTF, 2007).

 Snowflake Coral: Carijoa riisei, or snowflake coral, an invasive coral species, is 

threatening the ecosystem stability of the ecologically sensitive Northwestern Hawaiian 

Islands Coral Reef Ecosystem Reserve (NOAA, 2004a; Toonen, 2005). It is also a threat 

to the native black coral, which a local industry valued at $30 million harvests and uses to 

make jewelry. 

THREATENED AND ENDANGERED SPECIES

Invasions have had especially adverse impacts on threatened and endangered species by 

predation, alteration of habitat, or further competition for limited resources. It is estimated that 

non-indigenous species are a contributing factor to the endangered status of 70 percent of listed 

fish species, and more than half of combined endangered and threatened listings (OTA, 1993). 

They are also estimated to have contributed to 68 percent of fish extinctions in the last 100 years 

(Larson and Sytsma, 2006). 

DAMAGE TO INFRASTRUCTURE

Industrial facilities, such as those that purify water, generate electricity, and manufacture goods, 

depend on water intake structures to perform their services. These structures can often be 

adversely affected by ANS. 

So far, zebra mussels have been the most damaging ANS introduced into U.S. fresh waters, 

causing particularly severe problems with water intake structures (USACE, 2002). Zebra mussels 

attach to surfaces of water intake structures, navigation dams, pumping stations, and gears, often 

making them inoperable, which inconveniences the public and costs industry significant financial 

losses and damages (USACE, 2002). 

Hushak (1996) reports on the results of 398 surveys of Great Lakes users with lake water intake 

structures from 1989 to 1994 for private and public utilities, municipal water facilities, and 
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industrial users. Extrapolating the results of this survey to all facilities in the Great Lakes yielded 

total monitoring and control costs of $120 million from 1989 to 1994 with an average cost of $30 

million annually (Park and Hushak, 1998). Another study done in 1995 of the economic impact of 

zebra mussels (O’Neill, 1997) found that the total costs of zebra mussels control and monitoring 

were $69 million, with a mean cost of $205,570 per facility. The study results also showed that 

total annual expenses rose from $234,140 in 1989 to $17,751,000 in 1995 as the range of mussels 

increased (O’Neill, 1997). 

Another invasive bivalve species, the Asian clam, is estimated to have caused fouling damage 

that cost the nuclear industry about $1 billion per year in the early 1980s (OTA, 1993). Two other 

invasive bivalves, the brown mussel and the green mussel, have also caused fouling damages in 

the Gulf Coast region and Tampa Bay, respectively, where each has become established, although 

the total economic value of the damages is not known (Benson et al., 2002; GSMFC, 2003). 

Finally, invasive plant species such as hydrilla and water hyacinth can disrupt water flow in 

irrigation canals and in utility cooling reservoirs. Annual expenditures on aquatic weed control in 

the United States, much of which is spent on ANS weeds specifically, are estimated at $110 

million (Pimentel et al., 2005).

HUMAN HEALTH IMPACTS

Though the exact nature of the link between human health impacts and ANS invasions through 

ballast water is poorly understood, studies have established that pathogenic invasive species can 

be transported in ballast water (Ruiz and Reid, 2007). Moreover, in the case of epidemic cholera, 

a serious human pathogen, the presence of non-native strains was previously confirmed in U.S. 

waters (CDC, 1993). The potential human health impacts associated with ballast water transport 

are an object of increasing concern. Some pathogenic bacteria identified in ballast water known to 

be associated with adverse human health impacts include E. coli, enterococci, Vibrio cholerae, 

Clostridium perfingens, Salmonella spp. Cryptosporidium spp., and Giardia spp., as well as a 

variety of viruses (Knight et al., 1999; Reynolds et al., 1999; Zo et al., 1999). 

In July 1991, a strain of Vibrio cholerae was identified in oysters in Mobile Bay on the Gulf 

Coast that was indistinguishable from a Latin American strain not endemic to the United States. 

An investigation indicated that the pathogen was most probably introduced from the discharge of 

contaminated ballast water (CDC, 1993). Because oysters are often eaten raw, this is a potential 

human health threat. Of the 61 cases of cholera in the United States between 1995 and 2000, 14 

were caused by the consumption of undercooked seafood (Steinberg, 2001). Though it is unclear 

whether any of these cases were caused by exotic strains of Vibrio cholerae, this evidence clearly 

indicates that the potential exists for the transport of harmful non-native pathogens in ballast 

water. 

As mentioned in the introduction to this section, a study by NOAA also showed the potential for 

pathogens to be transported in ballast water tanks, even when they are not filled. The study found 

that virus-like particle concentrations in sampled ballast tanks ranged from 107 to 109

 per ml in 

residual unpumpable ballast water and from 107

 to 1011 per ml in sediment porewater. Bacteria 

concentrations under the same conditions were 105 to 109

 per ml and 104 to 108 per ml, 

respectively (Johengen et al., 2005). As in the 2008 VGP, and as an interim requirement in the 

2013 VGP (to be phased out as treatment is required), saltwater flushing in vessels with empty 
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ballast tanks will assist in reducing these risks by removing sediments may reduce the potential 

for pathogen contamination. 

Ballast water is also a vector for the microorganisms associated with the “red tide” or harmful 

algal bloom phenomenon. This phenomenon occurs when certain species of algae release toxins 

into an aquatic environment, which adversely impacts aquatic life and can also impact human 

health if fish contaminated with the toxin are consumed (WHOI, 2007). Although current USCG 

mandatory BMPs for all vessels with ballast tanks, codified in 33 CFR 151, require vessels not to 

take up ballast water in areas known to be contaminated with such organisms, the new Permit’s 

requirements governing ballast exchange may further reduce the spread and impact of these 

organisms. 

6.1.3 EFFICACY OF VGP BALLAST WATER MANAGEMENT PRACTICES

The incorporation of ballast water discharge standards in the 2013 VGP is expected to provide 

benefits through a reduction in the concentration of living organisms, leading to lower numbers of 

these organisms being introduced per discharge. Additional monitoring, sampling, testing, and 

reporting requirements will help further this benefit by verifying that BWTS perform according to 

their design specifications and meet the discharge limits. This overall strategy should reduce the 

number of new invasions because the likelihood of establishment increases with the number of 

organisms introduced per discharge or inoculation (Ruiz et al. 2000a, Minton et al. 2005). 

6.1.4 BENEFITS OF REDUCING ANS INTRODUCTIONS

The evidence presented in Section 6.1.2: ANS Impacts demonstrates that introductions of ANS 

through ballast water are associated with significant detrimental impacts throughout the United 

States. The ballast water provisions of EPA’s final Vessel General Permit, to the degree that they 

fill a gap in the existing ballast water management practices, can therefore be expected to 

generate benefits by reducing the risk of such damages in the future. Benefits would include the 

prevention of damages to fisheries, tourism, and recreation, of damages to infrastructure, and of 

adverse human health impacts, as well as prevention of further stresses on native biodiversity and 

ecosystems. 

The issue of ANS invasions and their impacts presents unique challenges for the estimation of the 

benefits associated with this Permit. Although ballast water is one of the major pathways of 

invasive species introduction, estimating changes in risk of introduction of invasive species from 

the Permit requirements is not feasible due to the lack of data on rates of invasive species 

introduction associated with ballast water releases. Moreover, because the type of species 

introduced in the future is unknown and the range of potential economic impacts associated with 

each species type is very large, estimating the monetary value of benefits from preventing future 

invasions with a reasonable degree of certainty would not be possible.

COMMERCIAL AND RECREATIONAL FISHERIES

A reduction in the number of ANS introductions due to the final ballast management 

requirements and other Permit requirements may prevent significant future damages to 

commercial and recreational fisheries that play a critical role in the U.S. economy. In 2009, 

7.9 billion pounds of fish and shellfish were landed by U.S. commercial fishermen at U.S. ports, 
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and were valued at $3.9 billion (NMFS, 2010). An additional 29.9 million anglers aged 16 and 

older spent an average of 17 days fishing in 2006, spending more than $40 billion dollars on trips, 

equipment, licenses, and other costs (USDOI, 2007). Leigh (1998) estimated the annual reduction 

in value of yellow perch, walleye, and whitefish fisheries due to ruffe invasion under moderate 

scenario assumptions to be $119 million (in 1998 dollars; $159 million (2010$) inflated using the 

Consumer Price Index (CPI)). 

OTHER WATER-BASED RECREATION AND TOURISM

Another source of potential benefits from the reduction of ANS introductions under the Permit 

will be the prevention of damages to valuable recreation and tourism sites. A report by NOAA 

(2004b) estimated the annual revenue associated with coastal tourism in the United States to be 

$54 billion, and found that beaches are the most popular tourist destinations in the United States. 

One invasive plant species alone, hydrilla, is associated with $14.5 million annually in control 

costs, and reduces lake recreation on two Florida lakes alone by $11 million in years when 

hydrilla covers the lakes (Pimentel et al., 1999). Since data are limited on the impacts of invasive 

species on recreation and tourism in ecosystems for which estimated rates of invasion exist, it is

not possible to calculate the level of expected benefits for other water-based recreation and 

tourism. However, EPA projects that there will be some incremental benefits.

BIODIVERSITY AND ECOSYSTEMS

Additional significant benefits from the Permit will accrue to biodiversity and ecosystems. As 

detailed in Section 6.1.2: ANS Impacts, ANS are associated with substantial adverse impacts on 

the composition of ecosystems and the biodiversity therein. The quantification of biodiversity 

benefits will not be attempted in this analysis due to the great deal of uncertainty surrounding the 

impact of a single ANS introduction on a given ecosystem relative to other factors, as well as the 

difficulty of predicting the rate of ANS introduction. However, potential benefits in the form of 

preservation of habitat and species are likely. 

THREATENED AND ENDANGERED SPECIES

The Permit requirements for ballast water management, by reducing the impacts of invasive 

species introductions on threatened and endangered species, will have benefits in terms of 

prevention of reduction in species population and species extinction. Total federal spending 

nationwide on programs related to the Endangered Species Act for 2004, the most recent year for 

which data are available, was more than $1.2 billion, and state spending was more than $200 

million (USFWS, 2005).

As mentioned above, ANS are considered likely contributors to the threatened or endangered 

status of 70 percent of listed fish species (Larson and Sytsma, 2006). Combined federal and state 

expenditures per listed species of fish in 2004 ranged from $25,000 to $1.09 million (USFWS, 

2005). It is not possible to calculate a range of benefits to threatened and endangered species 

associated with EPA’s Permit requirements, due to the lack of research linking specific invasions 

with quantifiable impacts on particular species. However, it is likely that some proportion of 

potential future expenditures on endangered and threatened fish, as well as expenditures on other 

aquatic endangered species, would be averted by reduced ANS introductions under the Permit 

requirements. 
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DAMAGE TO INFRASTRUCTURE

Another benefit of the Permit requirements for ballast management will result from averting 

damages to infrastructure by invasive species of plants and mollusks. Fouling by species such as 

the Asian clam, zebra mussel, and hydrilla has caused substantial economic damage to a variety 

of municipal and industrial entities in the past. Most of this damage takes the form of clogging 

water intake structures and disrupting the flow of water. One study estimated fouling damage to 

water intake infrastructure by zebra mussels for the year 2000 to be $5 billion (Khalanski (1997), 

and cited in Pimentel et al. (1999); $6.1 billion in 2007$ using CPI). 

HUMAN HEALTH 

Estimating expected human health benefits of EPA’s Permit is not feasible due to very limited 

data on the rates of non-endemic pathogen invasions and the human health effects of these 

pathogens. Nevertheless, the Permit provisions are likely to reduce the probability of introduction 

of harmful exotic pathogens and thus are expected to benefit human health. 

SUMMARY OF BENEFITS

The ballast water discharge standard and management practices established in the 2013 VGP are 

designed to directly address the likelihood of future ANS invasions. The categories of potential 

damages from such ANS invasions have been discussed above, and studies referenced as to the 

potential magnitude of these damages for each. To the degree that these damage estimates 

provide an indicator of the likely payback that can be anticipated from reducing ANS invasions, 

EPA believes the benefits of this Permit can be expected to be very significant. However, the 

complexity of analyzing the probability of ANS introduction and spread, the wide range and 

varied nature of impacts ANS invasions can cause, and the great breadth of the scope of this 

Permit prohibit EPA from developing a quantified estimate of these benefits.

6.2 BENEFITS OF REDUCED POLLUTANT DISCHARGES FROM VESSELS

6.2.1 INTRODUCTION AND BACKGROUND

The Clean Water Act and its associated regulations have greatly improved the quality of the 

nation’s waters over the past 40 years. Nevertheless, large portions of the United States’ fresh and 

saline waters remain degraded by elevated concentrations of harmful pollutants. As summarized 

by EPA, 50 percent of assessed rivers and streams; 66 percent of assessed lakes, ponds, and 

reservoirs; 64 percent of assessed bays and estuaries; and 38 percent of coastal shorelines were 

classified as impaired for at least one of their designated uses (EPA, 2011).56 Impairments of 

designated uses – the protection and propagation of fish, shellfish, and wildlife and the harvesting 

of aquatic life, among others – are associated with a variety of economic and ecological damages. 

 

56 States are responsible for assessing impairment of water bodies. States assessed 26 percent of rivers and streams; 

42 percent of lakes, ponds, and reservoirs; 21 percent of bays and estuaries; and 4 percent of coastal shorelines in the 

reporting cycle summarized in this report (generally ranging from 2002 and 2010, depending on the state, with data 

for most states reflecting assessments completed as of 2008). 
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The causes of impairment vary by waterbody, but commonly include pathogens, oxygen 

enrichment/oxygen depletion, nutrients, metals, turbidity, oil and grease, and nuisance exotic 

species. 57

As detailed in EPA’s 2010 study, several of these causes have associated pollutants that have be 

found in discharges incidental to the normal operation of vessels. For example, EPA found 

significant concentration of nutrients in deck runoff, graywater, bilge water, and fish hold tanks.

The 2013 VGP contain several new provisions aimed at reducing pollutant loadings incidental to 

vessel operation, either by minimizing the introduction of pollutants in the vessel effluents (e.g., 

use of environmental preferred cleaners or lubricants), employing treatment technologies to 

decrease pollutant loadings in the discharges, and by requiring regular inspection and monitoring 

to identify and address potential problems. In the section below, we describe the types of 

pollutants that may be found in vessel discharges and discuss how the 2013 VGP revisions may 

help reduce loadings of these pollutants to waters of the U.S. and therefore generate potential 

benefits for aquatic ecosystems. These benefits will be likely to occur mostly in waterways 

receiving the greatest amount of vessel traffic. 

The Permit covers many discharges and contains special provisions for numerous vessel types. 

Because of the breadth of coverage and provisions in the Permit, the following discussion does 

not address all of these provisions individually, but focuses on the more important changes in 

Permit requirements for certain types of vessel discharges. 

6.2.2 POLLUTANTS COMMONLY FOUND IN VESSEL DISCHARGES

The numerous individual harmful constituents of vessel discharges may be grouped into six broad 

categories: nutrients, pathogens, oil and grease, metals, other pollutants with toxic effects, and 

other non-toxic pollutants. Many of the 27 types of discharges covered by EPA’s Permit are 

associated with one of these six types of pollution. Table 6-3 summarizes pollutant types 

potentially reduced by Permit requirements.58

Table 6-3. Pollutants Found in Vessel Dischargesa

. 

Type of Discharge

Nutrients Pathogens Oil & 

Grease Metals Other 

Toxics

Other 

NonToxics

Deck Runoff X X X X X

Bilge water X X X X

Anti-fouling Hull Coating X X

AFFF X

Boiler Blowdown X X

Cathodic Protection X

Chain Locker Effluent X X

 

57 The risk of introduction of ANS is discussed in the next section.

58 The effect of ballast water provisions on risk of introduction of ANS is discussed in the preceding section.
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Type of Discharge

Nutrients Pathogens Oil & 

Grease Metals Other 

Toxics

Other 

NonToxics

Controllable Pitch Propeller 

Hydraulic Fluid

X X

Elevator Pit Effluent X X X

Firemain Systems X X X X

Freshwater Layup X

Gas Turbine Wash Water X X

Graywater X X X X X X

Motor Gasoline and 

Compensating Discharge X X

Non-Oily Machinery Wastewater X X X

Refrigeration and Air Condensate 

Discharge

X X

Rudder Bearing Lubrication 

Discharge

X

Seawater Cooling Overboard 

Discharge

X X

Seawater Piping Biofouling 

Prevention X

Small Boat Engine Wet Exhaust X X

Sonar Dome Discharge X X

Underwater Ship Husbandry X

Welldeck Discharges X X X X X X

Fish hold effluent X X X X X X

Source: Battelle (2007)

a. Other Permit requirements that could not be firmly linked to one of these six categories of pollutants are excluded 

from the table

Several types of discharges address by revisions to the VGP have particularly significant 

pollutant constituents and therefore also may be associated with substantial incremental benefits. 

They are described in more detail below. 

GRAYWATER

Untreated graywater contains multiple constituents of concern, including pathogenic bacteria, 

toxic and carcinogenic organic and inorganic compounds, nutrients, and metals (EPA, 2007a; 

EPA, 2010b). Table 6-4 summarizes the rates of discharge for major pollutants found in 

graywater in an EPA survey of cruise ships. The same survey found that total graywater discharge 

volumes ranged from 36 to 119 gallons/day/person, with a mean value of 67 gallons/day/person. 

Table 6-4. Types of Pollutants Found in Graywater Discharges

Type of Discharge

Average Concentrations of 

Pollutantsa EPA NRWQC Standardb

Ammonia – Nitrogen 2130-2210 μg N/L 2140-15,600 μg N/L CMC,

321-2960 μg N/L CCC

Nitrate 0.009-0.0872 mg/L ------

Total Kjeldahl Nitrogen 11.1-26.2 mg/L ------

Total Phosphorus 3.34-10.1 mg/L ------
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Type of Discharge

Average Concentrations of 

Pollutantsa EPA NRWQC Standardb

Fecal Coliform 2,950,000 MPN/100 mL 43 MPN/100 mL

Enterococci 8920 MPN/100 mL 35 MPN/100 mL

Hexane Extractable Materialc 78-149 mg/L ------

Arsenic 1.22-2.25 μg/L 0.14 μg/L

Copperd 483-510 μg/L total, 195 μg/L 

dissolved 74 μg/L CMC, 8.2 μg/L CCC

Nickel 29.7-48.7 μg/L total, 18.2 μg/L 

dissolved

4.8 μg/L CMC, 3.1 μg/L 

CCC

Thallium 0.93 μg/L total, 0.403 μg/L dissolved 0.47 μg/L (in shellfish)

Zinc 790-2540 μg/L total, 1610 μg/L 

dissolved 90 μg/L CMC, 81 μg/L CCC

Bis(2-ethylhexyl) phthalate 22.4-71.9 μg/L 2.2 μg/L

Tetrachloroethylene 10.7-11.4 μg/L 3.3 μg/L

Phenol 1.16-52.5 μg/L ------

Total Residual Chlorinee 372 μg/L 13 μg/L CMC, 7.5 μg/L CCC

Chlorides 125 mg/L ------

Source: EPA (2007a)

Note: Because of the quantity of metals and toxics detected, only pollutants exceeding EPA’s national 

recommended water quality criteria (NRWQC) or pollutants discussed elsewhere in this analysis are listed here.

a Ranges presented in this table represent differences in reported concentrations between data from the Alaska 

Cruise Ship Initiative of the Alaska Department of Environmental Conservation (ACSI/ADEC), and EPA’s own data, 

both presented in EPA (2007a). 

b EPA has not set NRWQC for all pollutants of interest. CCC is an abbreviation for Criterion Continuous 

Concentration, a long-term measure of pollutant loading. CMC is Criterion Maximum Concentration, a short-term 

measure.

c Hexane extractable material is considered an indicator of level of oil and grease contamination.

d ACSI/ADEC did not conduct separate sampling for dissolved metals, so a range is not listed for dissolved metals. 

e EPA did not sample total residual chlorine; ACSI/ADEC did not sample chloride.

Prior to the promulgation of the 2008 VGP, discharges of graywater had been largely unregulated 

at the federal level in the territorial waters of the United States, with two exceptions: the Great 

Lakes, where graywater discharges must be treated similarly to sewage discharges under the 

Clean Water Act; and the territorial waters of Alaska, where graywater discharges by cruise ships 

within the territorial waters are subject to discharge standards. Maine, Washington, Hawaii, and 

Florida also have state-level programs to reduce the impacts of graywater discharges from cruise 

ships. 

Under the revised VGP, vessels that discharge treated graywater within 1 nm of shore will have 

to comply with new monitoring requirements to help ensure the proper functioning of their 

treatment system. Releasing large volumes of untreated graywater in nearshore environments, 

estuarine environments, or in waters with limited circulation is more likely to cause negative 

environmental impacts. This is because these environments are likely to have higher vessel traffic 

and, therefore, greater graywater generation and discharge, are more likely to be stressed by other 

anthropogenic forces, and are likely to have less ability for dilution and assimilative capacity. The 

revised VGP clarifies that the graywater requirements also apply to vessels operating on the Great 

Lakes that are not commercial vessels, as defined in CWA section 312(a)(10), which will help 

protect the ecosystem of the Great Lakes.
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BILGE WATER

Bilge water is water from a variety of sources, including wastewater and leakage, which drains 

into a compartment in a vessel’s inner hull. While its composition and physical-chemical 

characteristics can vary widely, both over time and between different vessels, bilge water

typically contains various hydrocarbons and fuels, grease, antifreeze, hydraulic fluids, cleaning 

and degreasing solvents, detergents, metals (arsenic, copper, cadmium, chromium, lead, mercury, 

selenium and zinc), catalytic fines, soot, and other solid particles (sludge) (EPA, 2008). 

Among the constituents of bilge water, oils and greases are a primary concern. Oil is present in 

free form, dispersed, or emulsified. Oil/hydrocarbon concentrations in vessel bilges commonly 

fall in the 100 to 400 ppm range (US Navy 1999-2000). Ghidossi et al., (2009) reported a 

somewhat higher 500 ppm oil concentration in the bilge water of a ferry. Water accumulating in a 

vessel’s bilge spaces is periodically pumped to a holding tank to maintain vessel stability and 

prevent hazardous conditions resulting from its accumulation. The bilge water can then be 

managed either by retaining it onboard and later discharging it to a reception facility on shore, or 

treating it onboard with a bilge separator to meet applicable standards and regulations. Existing 

regulations are based on Annex I of the MARPOL 73/78 and require all vessels weighing more 

than 400 tons to have equipment that limit the discharge of oil into the oceans to 15 ppm when 

the vessel is en route. However, this practice does not eliminate all oil and grease from 

discharges, but merely reduces it to a level below 15 ppm. 

EPA’s VGP revisions address this gap by retaining existing requirements governing untreated 

bilge water but reducing the oil and grease concentration limit for discharges of treated bilge 

water to 5 ppm. Though these requirements will not eliminate all discharges of harmful pollutants 

via bilge water, they will reduce the loads in areas with heavy vessel traffic that are in nearshore 

environments. Several of the more advanced treatment systems that can reduce effluent 

concentrations to below 5 ppm also reduce concentrations of other pollutants. For example 

biological treatment systems degrade oils while also removing other organic pollutants such as 

glycols, solvents, detergents, nitrogen, and phosphate. Use of these systems may therefore be 

beneficial beyond their ability to reduce oil pollution into receiving waters. 

ENVIRONMENTALLY-ACCEPTABLE LUBRICANTS 

The 2013 VGP mandates the use of environmentally-acceptable lubricants (EALs) in oil-to-sea 

interface applications for existing vessels (subject to technical feasibility) and for all new build 

vessels. While use of EALs has been increasing in the last decade, revisions to the VGP will 

further increase the use of these products, and result in decreased environmental impact from the 

operational discharges of oil. Because the majority of a lubricant is composed of the base oil, the 

base oil used in an EAL must be biodegradable. The three most common categories of 

biodegradable base oils are: 1) vegetable oils, 2) synthetic esters, and 3) polyalkylene glycols. 

Traditional mineral oils have a small biodegradation rate, a high potential for bioaccumulation 

and a measurable toxicity towards marine organisms. In contrast, the base oils derived from 

oleochemicals (vegetable oils and synthetic esters) degrade faster and have a smaller residual, do 

not bioaccumulate appreciably and have a lower toxicity to marine organisms. Polyalkylene 

glycol-based lubricants are also generally biodegradable and do not bioaccumulate; however, 

some PAGs are more toxic due to their solubility. Lower environmental impacts will occur when 

a greater proportion of base oils are manufactured from non-mineral based oils. 
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6.2.3 POLLUTANT IMPACTS

Vessel discharges contain a wide variety of pollutants with the potential to cause ecological and 

economic harm to aquatic species and their habitat. The relationship between types of pollutants 

and associated discharges was summarized in Table 6-3, above. 

OIL AND GREASE 

Oil and grease are a component of vessel discharges with potentially harmful impacts to humans 

and to aquatic life. Oil in vessel discharges is required to be discharged in concentrations that 

may not be harmful, consistent with existing regulation under 40 CFR part 110. The Group of 

Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), a United 

Nations body, found that voluntary vessel discharges account for less than 1 percent of vessel oil 

discharges into the marine environment (GESAMP, 2007). However, vessel discharges may still 

contain enough oil to do ecological damage, even if they meet existing concentration 

requirements and account for a small percentage of total oil discharges worldwide. Oils are highly 

toxic and carcinogenic, and may inhibit reproduction and cause organ damage or even mortality 

(AMSA, 2003). Additionally, oil can taint organisms that are consumed by humans, which is a 

potential source of adverse health impacts. 

The 2013 VGP strengthens requirements applicable to several oil discharge categories to 

minimize and reduce discharges of oil and grease from several sources, including during bilge 

water and oil-to-sea interfaces. For bilge water, for example, the permit sets strict requirements 

for the monitoring of any treatment system present onboard a vessel. The 2013 VGP also 

mandates the use of environmentally acceptable to reduce loading of harmful compounds into the 

aquatic environment. 

NUTRIENTS

Nutrient pollution, including nitrogen and phosphorus, is a component of vessel discharges and a 

major source of water quality degradation throughout the United States (USGS, 1999). Though 

traditionally associated with agricultural runoff from fertilizer, sewage treatment facilities, and 

urban stormwater, a variety of other sources do exist, including graywater and bilge water

discharges from ships. Revisions to the VGP requirements applicable to these types of discharges 

are expected to reduce loadings of nutrients to receiving waters.

Nutrient pollution is associated with a variety of negative environmental impacts, the most 

notable of which is eutrophication, which can lead to reduced levels of dissolved oxygen due to 

increased demand (sometimes to the extremes of hypoxia), reduced levels of light penetration and 

turbidity, and changes in the composition of aquatic flora and fauna (National Research Council, 

2000). It also helps to fuel harmful algal blooms that can have devastating impacts on both 

aquatic life and human health, if affected organisms are consumed (WHOI, 2007). The impacts of 

these water quality reductions on recreation and fishing can be significant, particularly in 

estuaries. For example, a 1989 study found that a hypothetical 20 percent reduction in nitrogen 

and phosphorus loading in the Chesapeake Bay would result in an increase in recreation worth 

$34.6 million (in 1984 dollars) from increased public beach usage (National Research Council, 

2000). Nutrient pollution has also contributed to the decline of the Chesapeake crab fishery, due 

to its role in degrading underwater vegetation, which serves as an important habitat for post-larval 

crabs (Maryland DLS, 2005). 
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PATHOGENS

Pathogens are another important constituent of discharges from vessels, particularly in graywater. 

EPA’s study of graywater discharges from cruise ships found that levels of pathogen indicator 

bacteria exceeded enterococci standards for marine water bathing and fecal coliform standards for 

harvesting shellfish 66 percent and over 80 percent of the time, respectively (EPA, 2007a). 

Specific pathogens of concern found in graywater include Salmonella, E. coli, enteroviruses, 

hepatitis, and pathogenic protists (National Research Council, 1993). Elevated levels of these 

pathogens have increasingly resulted in beach closures in recent years, which in turn have 

reduced the recreational value of impacted beaches (NRDC, 2005). 

Though it is difficult to determine the precise contribution of vessel discharges to infections by 

these organisms, epidemiologists have attempted to quantify the proportion of total infections that 

are waterborne. For example, waterborne infection may account for as many as 60 percent of 

Giardia infections and 75 percent of pathogenic E. coli infections (National Research Council, 

1993). Graywater discharges are a significant source of pathogenic microorganisms within the 

regulated waters, and reducing them, for example through strengthening VGP graywater 

treatment requirements, will likely provide non-negligible human health benefits. 

METALS

Metals are a diverse group of pollutants, many of which are toxic to aquatic life and humans. 

Vessel discharges can contain a variety of metal constituents. For example, EPA’s study of cruise 

ship graywater found a total of 13 different metals in at least 10 percent of samples, with copper, 

nickel, and zinc detected in 100 percent of samples (EPA, 2007a). Bilge water also contains these 

constituents and likely others (Battelle, 2007). 

While some metals, including copper, nickel, and zinc, are known to be essential to organism 

function, many others, including thallium and arsenic, are non-essential or are known to have 

only adverse impacts. Even essential metals can do serious damage to organism function in 

sufficiently elevated concentrations. Adverse impacts can include impaired organ function; 

impaired reproduction and birth defects; and, at extreme concentrations, acute mortality. 

Additionally, through a process known as bioaccumulation, metals may not be fully eliminated 

removed from blood and tissues by natural processes, and may accumulate in predator organisms 

further up the food chain (EPA, 2007b). This process can result in adverse health impacts for 

humans, who may consume contaminated fish and mollusks. 

However, the impacts of metals on any given ecosystem are difficult to predict, due to the 

relatively complicated circumstances by which they are available to organisms. Bioavailability of 

metals, and therefore impacts, varies by species of organism, as well as by climate and chemistry 

of a water body (John and Leventhal, 1996). Moreover, background levels of metals can vary 

substantially by location (EPA, 2007b). 

OTHER POLLUTANTS WITH TOXIC EFFECTS

The term “other pollutants with toxic effects,” as it applies to constituents of vessel discharges, 

encompasses a variety of chemical compounds known to have a broad array of adverse impacts 

on aquatic species and human health. For example, EPA’s study of cruise ship graywater found a 

total of 16 different volatile and semi-volatile organic compounds in at least 10 percent of 

samples, for which the most significant rates and levels of detection were phthalates, phenol, and 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 144

tetrachloroethylene. Other notable pollutants with toxic effects detected included free residual 

chlorine and chlorides.

These compounds can cause a variety of adverse impacts on ecosystems, including fisheries, as 

well as on human health. Phthalates are known to interfere with reproductive health and liver and 

kidney function in both animals and humans (Sekizawa et al., 2003; DiGangi et al., 2002). 

Chlorine, though toxic to humans at high concentrations, is of much greater concern to aquatic 

species, which can experience respiratory problems, hemorrhaging, and acute mortality even at 

relatively low concentrations (EPA, 2007a). 

OTHER NON-TOXIC POLLUTANTS

The category “other non-toxic pollutants” includes all non-conventional pollutants except fecal 

coliform (discussed in pathogens) as applied to vessel discharges also consists of multiple 

pollutants with disparate impacts. The most important types are pH pollution and thermal 

pollution, which can be found in several of the discharges that will be reduced a as a result of 

VGP revisions, including graywater and bilge water. 

Some vessel discharges are more acidic or basic than the receiving waters, which can have a 

localized effect on pH (ADEC, 2007). Though no research has been done linking vessel pollution 

specifically to pH impacts on aquatic ecosystems, extensive literature on the impacts of pH 

changes in the contexts of aquaculture and acid rain does exist. For nearly all fish populations, pH 

more acidic than 5 or more basic than 10 will cause rapid mortality, and many individual species 

are sensitive to more moderate changes in pH (EPA, 2007e; Wurts and Durborrow, 1992). 

Some vessel discharges may also be warmer or colder than the ambient temperature of the 

receiving water, which can affect temperature locally (Battelle, 2007). Thermal impacts of vessel 

discharges are generally much smaller than those from better-known sources such as dams, power 

plant cooling water, and runoff, due to scale. However, even small temperature changes can 

impact some sensitive organisms’ growth, reproduction, and even survival, which implies that 

some vessel discharges may have adverse impacts on aquatic ecosystems, and also fisheries 

(Abbaspour et al., 2005; Cairns, 1972; Govorushko, 2007). 

6.2.4 BENEFITS OF REDUCING POLLUTANT DISCHARGES

Many of the nation’s busiest ports are considered to be impaired by a variety of pollutants found 

in vessel discharges, as is summarized in Table 6-5. The Permit is expected to reduce discharges 

of nutrients, metals, oil, grease, toxics, and other pollutants in waters with high levels of vessel 

traffic. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 145

Table 6-5. Impairment Status of the Top 20 Ports by Annual Vessel Calls.

Port Impairments by Pollutants Found in Vessel Discharges

Houston, TX Bacteria, Nutrientsa

New York City, NY Nitrogen, Oxygen Demand,b Cadmium, Mercury

Port Everglades, FL Fecal Coliform, Dissolved Oxygen, Nutrients

Miami, FL None listed

Los Angeles/Long Beach, CA Polycyclic Aromatic Hydrocarbons (PAHs),c Zinc, Copper, 

Chromium, Lead, Mercury, Cadmium, Nickel

San Juan, PR Ammonia, Fecal Coliform, Dissolved Oxygen

Savannah, GA Mercury, Dissolved Oxygen

St. Thomas, Virgin Islands Dissolved Oxygen, Fecal Coliform, Oil and Grease, pH

Seattle, WA PAHs, Fecal Coliform, pH

New Orleans, LA Fecal Coliform

Charleston, SC None listed

Baltimore, MD Zinc, Chromium

Elizabeth River, VA Phosphorus, Fecal Coliform

Oakland, CA Mercury, Selenium

Bayou Lafourche, LA Dissolved Oxygen, Nutrients, Total and Fecal Coliform

Galveston, TX Bacteria

Tacoma, WA Bis(2-ethylhexyl) phthalate, PAHs

Jacksonville, FL Coliform, Nutrients, Turbidity

South Louisiana, LA Fecal Coliform

Source: Battelle (2007)

a Two of the listed pollutants are found in the areas surrounding the shipping route through the Bay of Galveston to 

Houston, rather than in the Port of Houston itself. 

b Oxygen demand is associated with eutrophication (see the subsection on Nutrient pollution).

c PAHs are a subset of volatile and semi-volatile organic compounds and are associated with petroleum products

The evidence presented in the pollutant impacts section demonstrates that vessel discharges are 

associated with significant detrimental impacts throughout the United States. Stronger controls on 

specific discharges contained in 2013 VGP, as well as general housekeeping requirements of the 

Permit, can be expected to generate benefits through reducing the risk of damages in the future 

and making water quality improvements in already-impaired waters. Monetized benefits will 

include the prevention of fishery closures and of adverse human health impacts, as well as 

increased opportunities for recreation. Non-monetized benefits will include prevention of further 

stresses on biodiversity and ecosystems. Though the magnitude of benefits is not calculable, 

Table 6-6 presents a summary of potential benefits resulting from 2013 VGP revisions. 
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 146

Table 6-6. Benefits of Reducing Pollutants Found in Vessel Discharges.

Type of Benefit

ANS Nutrients Pathogens Oil & 

Grease Metals Other 

Toxics

Other 

NonToxics

Human Health X X X X X X

Biodiversity X X X X X X

Ecosystem 

Function

X X X X X X 

Improved Fishery 

Conditions

X X X X X X 

Increased 

Recreational 

Opportunities

X X X

X 

Source: Battelle (2007) 

a. Other Permit requirements that could not be firmly linked to one of these six categories of pollutants are excluded from 

the table
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 147

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November 30, 2011 157

APPENDIX A – BILGE WATER TREATMENT SYSTEM COST ESTIMATES
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 158

Table A-1. Bilge water Treatment System Cost Estimates - Low Flow (1 m3/day)

Bilge water

Treatment System System A System B System D System Eb System F System G System Hf System I System J

Purchase cost $13,350 $2,024/yra $21,270 $95,000 $38,400 $100,380 $16,300g $5,000j $10,000j

Replacement media 

& parts $2,090/yr

(see 

footnote a) $1,780/yr $143/yrc $1,550/yrd $1,095/yre

(see 

footnote h)

(see 

footnote h) $1,814/yrk

Labor $5,840-

9,125/yr $7,990/yr

$5,840-

9,125/yr

$5,840-

9,125/yr

$5,840-

9,125/yr

$5,840-

9,125/yr

$5,840-

9,125/yr

$5,840-

9,125/yr

$5,840-

9,125/yr

Residual Disposall

$127-253/yr $31-63/yr

$4,820-

9,640/yr $23-46/yr $127-253/yr $130-260/yr

(see 

footnote i)

(see 

footnote i)

(see 

footnote i)

Total annual cost $9,320-

12,730/yr

$10,050-

10,080/yr

$14,440-

22,550/yr

$14,970-

18,280/yr

$11,140-

14,550/yr

$16,540-

19,960/yr

$7,379-

10,664/yr

$6,312-

9,597/yr

$8,598-

11,883/yr

Cost per 1,000 

gallons treated $97-132 $104-105 $150-234 $155-190 $116-151 $172-207 $77-111 $66-100 $89-123

Note: Total annual costs were amortized over 20 years using a 7% discount rate. 

a Cost of operating equipment includes capital outlay, consumables (nutrient and pH chemicals, starter/booster microbial cultures, and chemical analysis supplies), spare parts, electrical usage, labor, disposal quantities 

and cost. 

b This system does not use chemicals or absorption filters to clean the water from oil and particles, only Gravitational-force, then uses a filter to polish to below 5ppm. The cost of the separator is the same for the 

2.5 m3/hr and 5 m3/hr systems. The cost of the filter is $925 and is replaced, at most, every 100 days.

c Replacement media and parts costs include replacement of O-ring seals and gaskets every 83 days of operation, and replacement of bearings every 333 days. The operating cost of this system is only the service 

required for the centrifugal separator -- every 2,000 running hours an Intermediate Service is made and every 8,000 a Major Service is made.

d Maintenance only includes replacing the filters. Replacement costs have three components: 1. Coalescer Element filter, replaced annually on new ships (bi-annually on older ships); 2. Advance Granular Media filter, 

usually replaced annually; 3. Gasket set, also replaced annually.

e Operating costs includes replacement parts, chemicals, and media. Filter media and Granular Activated Carbon (GAC) are steam regenerated and require annual replacement, at most.

f This system comes equipped with a fluorescent detection OCM.

g This system treats 2.4 m3/day, which is the lowest flow rate treated by this manufacturer's OWS systems.

h No replacement media and parts costs were provided. 

i Abt Associates was unable to estimate the residual disposal cost.

j This system treats 10.9 m3/day, which is the lowest flow rate treated by manufacturer's OWS systems.

k Includes replacement cost and labor of Stage II filter every 14 months. Filter costs $2,000 and requires two hours of labor to replace.

l Abt Associates was unable to verify estimates of the residual disposal cost reported in GLEC (2011).
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 159

Table A-2 Bilge water Treatment System Cost Estimates - High Flow (1 m3/hr)

Bilge Water 

Treatment System System A System B System D System Eb System F System G System Hf System I System J

Purchase cost $13,350 $7,025/yra $21,270 $95,000 $38,400 $100,380 $19,500 $14,000i $22,000i

Replacement media 

& parts $27,190/yr

(see 

footnote a) $2,200/yr $3,420/yrc $6,166/yrd $26,280/yre

(see 

footnote g)

(see 

footnote g) $1,814/yrj

Labor $23,360-

36,500/yr $49,400/yr

$23,360-

36,500/yr

$23,360-

36,500/yr

$23,360-

36,500/yr

$23,360-

36,500/yr

$23,360-

36,500/yr

$23,360-

36,500/yr

$23,360-

36,500/yr

Residual Disposall $1,640-

3,270/yr $750-1,500/yr

$115,630-

231,260/yr $550-1,100/yr

$1,140-

2,270/yr $860-1,710/yr

(see 

footnote h)

(see 

footnote h)

(see 

footnote h)

Total annual cost $53,450-

68,220/yr

$57,190-

57,940/yr

$143,200-

271,970/yr

$36,300-

49,980/yr

$34,290-

48,5600/yr

$59,970-

73,970/yr

$25,201-

38,341/yr

$24,682-

37,822/yr

$27,251-

40,391/yr

Cost per 1,000 

gallons treated $23-30 $25 $62-118 $16-22 $15-21 $26-32 $11-17 $11-16 $12-17

Note: Total annual costs were amortized over 20 years using a 7% discount rate.

a Cost of operating equipment includes capital outlay, consumables (nutrient and pH chemicals, starter/booster microbial cultures, and chemical analysis supplies), spare parts, electrical usage, labor, disposal quantities 

and cost. 

b This system does not use chemicals or absorption filters to clean the water from oil and particles, only Gravitational-force, then uses a filter to polish to below 5ppm. The cost is the same for the the 2.5 m3

/hr and 5 

m3

/hr systems.

c Replacement media and parts costs include replacement of O-ring seals and gaskets every 83 days of operation, and replacement of bearings every 333 days. The operating cost of this system is only the service 

required for the centrifugal separator -- every 2,000 running hours an Intermediate Service is made and every 8,000 a Major Service is made.

d Maintenance only includes replacing the filters. Replacement costs have three components: 1. Coalescer Element filter, replaced annually on new ships (bi-annually on older ships); 2. Advance Granular Media filter, 

usually replaced annually; 3. Gasket set, also replaced annually.

e Operating costs includes replacement parts, chemicals, and media. Filter media and Granular Activated Carbon (GAC) are steam regenerated and require annual replacement, at most.

f This system comes equipped with a fluorescent detection OCM.

g No replacement media and parts costs were provided. 

h Unable to verify the residual disposal cost.

i This system treats 5.68 m3

/hr, which is the flow rate closest to 1m3/hr that this company's OWS systems treat.

j Includes replacement cost and labor of Stage II filter every 14 months. Filter costs $2,000 and requires two hours of labor to replace.

l Abt Associates was unable to verify estimates of the residual disposal cost reported in GLEC (2011).
Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 160