MARAD Letter to EPA on Ballast Water Litigation

The U.S. Maritime Administration (MARAD) sent a Letter to the Environmental Protection Agency (EPA) expressing its concern over the pending litigation relating to ballast water discharges and the current exemption for such discharges from the requirements of the National Pollutant Discharge Elimination System (NPDES). MARAD is concerned about the long-term workability of applying the NPDES permitting regime to ballast water discharge. It is also concerned about the potentially crippling short-term impact that repeal of the normal operation exclusion could have pending any appeal of the court decision. (HK Law)