EPA Ramps-Up VGP Inspections and Enforcement

Pratt's Energy Law Report

The authors explain the increased enforcement risks under the U.S. Environmental Protection Agency’s Vessel General Permit and what shipping and offshore companies can do to avoid getting caught up in costly proceedings.

We are just over 18 months into the Biden administration and environmental enforcement is on the rise. Although enforcement dropped dramatically under the Trump administration, the Biden administration has been clear about its intent to use environmental enforcement tools to “encourage and incentivize compliance by private sector entities,” quoting Assistant Attorney General Todd Kim, head of the Environment and Natural Resources Division of the U.S. Department of Justice (“DOJ”).

This focus has borne out in several ways, including what seems to be an increase in inspections and enforcement of the U.S. Environmental Protection Agency’s (“EPA”) Vessel General Permit (“VGP”) in several EPA regions around the country.

The risk of getting caught in EPA’s crosshairs for a VGP violation is real and should be front-of-mind for companies across the shipping and offshore sectors.

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“EPA Ramps-Up VGP Inspections and Enforcement,” by Jeanne M. Grasso and Kierstan L. Carlson was published in the June 2022 edition of Pratt’s Energy Law Report (Vol. 22, No. 6), an A.S. Pratt Publication, LexisNexis. Reprinted with permission.

This article was first published in the March 2022 edition of Mainbrace, Blank Rome’s quarterly maritime newsletter.