Assisting the maritime industry in regulatory compliance

Bryant’s Maritime Consulting

Incidental discharges

Commencing in February 2009, the US Evironmental Protection Agency (EPA) is requiring most commercial vessels to comply with permitting requirements for discharges incidental to the normal operation of the vessel. The Vessel General Permit (VGP) requirement was published by the EPA on February 5, 2009. Attached is a paper that I recently presented at the Green Ship Technology Conference in Hamburg, Germany explaining the implications of this new requirement. Each regulated vessel that is greater than or equal to 300 gross registered tons or has the capacity to hold or discharge more than eight (8) cubic meters (2,113 gallons) of ballast water must submit a Notice of Intent (NOI) so as to remain in compliance. For regulated vessels already in operation, the NOI must be submitted during the time period beginning June 19, but not later than September 19, 2009. Additional information regarding the VGP program is contained in the EPA Fact Sheet.





    logo11 Interviews on Jones Act issues re oil spill response

    I was interviewed by a reporter for NPR (previously known as National Public Radio) for their "All Things Considered" program. The interview addressed a number of issues regarding the Gulf of Mexico oil spill. The only portion of the interview that made it into print and on the air was my discussion of the impact (or non-impact) of the Jones Act on the response to the spill. My comments were taken slightly out of context, but are basically correct. I find it surprising how a few individuals throwing up an obscure statute as the reason that the oil has not been swept from the Gulf of Mexico has gotten so much coverage. (7/10/10).

    Prior to the NPR interview, I was interviewed by a reporter for Florida Public Radio regarding the impact of the Jones Act (and other cabotage laws) on the response to the ongoing Gulf of Mexico oil spill. A report of that interview, with a link to the actual broadcast thereof, is attached. The interview took over 20 minutes and the radio broadcast condensed that down to about two minutes, so numerous details relating to cabotage have been glossed over or omitted. (6/23/10).