The initial implementation of the United States Environmental Protection Agency’s (EPA) Vessel General Permit (VGP) is now theoretically astern of the marine industry, but unlike any other new regulatory effort, this one has numerous unintended consequences, many of which remain “submerged” and undetected by vessel owners, their customers, insurers, and indeed the EPA itself. Although the protection of the marine environment is essential, it would appear as if the evolving American approach to regulate ballast water discharges will not achieve this quickly.