Tuesday, 23rd December 2008
This circular explains that the US District Court for the Northern District of California issued an order delaying the effective date of vacating the long- standing EPA regulations which excludes certain vessel discharges from the permitting requirements of the Clean Water Act until 6 February 2009. As such, the current exemption (40 C.F.R. § 122.3(a)) will remain in place until that date. The EPA advises that the effective date of the VGP still remains as 19 December 2008. However, the EPA will not actually require permit authorisation and owners will not need to comply with the terms of the finalised VGP requirements until 6 February 2009. Even though the compliance date is now 6 February 2009, industry will have an extra two weeks (until February 19, 2009) to implement discharge inspections, training and recordkeeping requirements.
