ECM refers to our prior Client Alert 12-2013 with respect to the new VGP of 19 December 2013. As of 30 September the EPA website is now configured to allow submission of a Notice of Intent (NOI) under the new 2013 VGP. ECM is also prepared to accept applications for our 2013 VGP services.
Notice of Intent (NOI)
Our new Form 10-A is now ready and attached for those who wish to have ECM submit their NOI's for them. Form 10-A may also be downloaded from our website at www.ecmmaritime.com. The new VGP requires more data to be inputted for the new NOI, in addition to what was required on the current NOI which expires on 19 December 2013. Therefore our fee for the new NOI will be $200 per NOI. Since each vessel must have their own NOI submitted, we are afraid we will not be able to offer any discounts for multiple vessels. In order to avoid the backlog of NOI submissions as we draw nearer to that 19 December 2013 date, we would urge you to submit your completed 10-A forms to us as soon as possible, if you want ECM to proceed on your behalf.
Vessel General Permit Compliance Manual
ECM will be offering a ship-specific VGP Compliance Manualintended to be assembled in a binder and used for all VGP records on board. The package includes detailed instructions for compliance, NPDES activities log, weekly checklist, pre-arrival checklist, corrective action report form, US state regulations, training log and assembly instructions. All forms and logs will be writable so they may be retained electronically for those who wish to maintain their records in that format. Our fee for this service will be $500 per ship for new clients and $400 per ship for those clients who have previously used our NPDES services for the first VGP. For ease of convenience, a copy of Form 11-A is attached here.
Other VGP Services
ECM will continue to offer the following services:
- Annual Inspection services. Each vessel is required to conduct a detailed annual inspection (audit) ofthe VGP compliance program on board and retain an inspection report on board. ECM conducts inspections in all US ports and most large foreign ports. Our fees are $1300 for an Annual Inspection/Audit for clients who use ECM for all their VGP compliance needs, and $1500 for those that do not.
- Maintenance of NOI accounts including updates and submission of Notices of Termination (NOT's) ($200/vessel added to the annual retainer).
- Resolution of Port State Control deficiencies with respect to NPDES deficiencies and/or nonconformities(included in the maintenance fee).
- Annual Reports. At a later date ECM will also be offering submission services for the Annual Report.The first Annual Report will be due by the end of February 2015 for the 2014 calendar year. As of this Client Alert, the EPA has not yet provided their Annual Report electronic format (this report along with both NOIs and NOTs must all be submitted electronically under the new VGP). As and when we see the EPA's Annual Report format, we will be able to set a price for this service.
- Training seminars and on-board training during inspections ($400 per person for seminars, on-boardtraining included with the Annual inspection/audit fee).
For additional information or to request forms for services, please contact ECM at vgp@ecmmaritime.com.