On October 16, 2026, EPN submitted comments opposing EPA’s changes to the National Pollutant Discharge Elimination System definition of “discharge of a pollutant.” In the comments, EPN argues that EPA draws an arbitrary line—whether a vessel is connected to the seabed—that bears no relationship on the volume, toxicity, or environmental effect of what the vessel discharges. EPA’s proposed rule will remove permitting requirements for large seafood processors to the detriment of Tribal treaty fisheries, independent commercial crabbers, marine Endangered Species, and the coastal states that rely on EPA permits to protect the health of their waters. EPA’s proposal changes a nearly five-decades-old established congressional practice; fails to economically analyze the costs to be borne by fishers, Tribes, and coastal communities; and leaves the door open for dischargers outside of permitted seafood operators, which could include oil rigs and the support vessels that service offshore oil and gas operations that may qualify for the same exclusion.
EPN Submits Comments on Updated NPDES Definition of “Discharge of a Pollutant”
