The United States Environmental Protection Agency's (EPA) National Pollutant Discharge Elimination System (NPDES) vessel program regulates incidental discharges from the rmal operation of vessels operating in a capacity as a means of transportation. In 2008, EPA issued its first Vessel General Permit (VGP) (EPA, 2008a). When finalizing that permit, EPA estimated that approximately 70,000 vessels would be eligible for coverage under the VGP. Part 22.214.171.124 of the 2008 VGP requires owners or operators of vessels that are greater than or equal to 300 gross [registered] tons or have the capacity to hold or discharge more than 8 cubic meters (2,113 gallons) of ballast water to submit a complete and accurate Notice of Intent (NOI) in accordance with Part 10 of the VGP to obtain authorization to discharge. Owners and operators of existing vessels had until September 19, 2009 to submit an NOI to seek coverage under the VGP.1 Vessels less than 300 gross tons that do t have the capacity to hold or discharge more than 8 cubic meters (m3) of ballast water are authorized to discharge without having to submit an NOI.