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Old 11-23-2016, 10:40 AM   #1
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City: Inside Passage Summer/Columbia River Winter
Country: USA
Vessel Name: Alaskan Sea-Duction
Vessel Model: 1988 M/Y Camargue YachtFisher
Join Date: Jul 2012
Posts: 3,041
More info NDZ Puget Sound


Background


The Washington State Department of Ecology has petitioned the U.S. Environmental Protection Agency to designate all of Puget Sound and its tributaries as a No Discharge Zone, even though no credible scientific evidence has been provided to justify this regulatory overkill. Raw sewage discharges are already illegal within three miles of the shoreline, and recreational and commercial boaters employ federally-approved Marine Sanitation Devices (MSDs) type I and type II to treat discharges in the areas they use, OR employ type III “holding tanks”. The effect of such NDZ is to eliminate TREATED discharge from type I and type II units.

You should know that that there is no evidence that connects discharges from these MSDs and the state of Puget Sound water quality problems. Second, there’s zero evidence that links the banning of Type 1 or Type 2 Marine Sanitation Devices to ANY improved water quality within the other No Discharge Zones around the country.

The U.S. EPA is focusing its review of the NDZ petition solely on whether “reasonable” pump-out capacity (both recreational and commercial) exists to make the Puget Sound-wide NDZ feasible. But because environmental organizations are making a full-throttle attempt to rally around this flawed NDZ petition, it is critical for the recreational boating community to state its overall concerns, too. We have been advised to create a record in opposition.

Please tell the EPA that recreational boaters value clean water – and would even support the idea of targeted No-Discharge Zones that are scientifically grounded. But, a full Puget Sound No Discharge Zone is not based in science, is not necessary, and focuses on the wrong problem. Ecology and the EPA should focus on failed septic systems along the shoreline, illegal spills and massive storm-event discharges from Puget Sound wastewater treatment plants and Victoria, B.C. that are much more damaging to water quality in Puget Sound. We should target efforts on water quality to where problems actually exist.

Finally, while we don’t agree at all with a Puget Sound-wide NDZ, if it goes forward, recreational boaters should be granted the same 5-year phase-in period that has been suggested for commercial vessels. Due process is undermined with a prohibition that goes into effect immediately, the day the NDZ is declared.


HOW to Post Your Message

This Action Alert requires you to type in – or cut’n’paste – your comments DIRECTLY into EPA’s “comments-collection” page here: https://www.regulations.gov/comment?D=EPA_FRDOC_0001-19949

EPA has only until December 7 to hear from you -- This exercise should take about four minutes. It’s worthwhile; it matters; and it’s important. Thanks.
If you know of specific areas not well-served by pump-out facilities, please lead with those comments. And here’s a template (below) for cut’n’paste, of what we see as the remaining salient points:
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Please reject a Puget Sound-wide No Discharge Zone petition by Washington’s Department of Ecology
  • The Department of Ecology’s plan to designate all of Puget Sound a No Discharge Zone is regulatory overkill, is not based on sound science, and should not go forward;
  • Independent water quality scientists have found that models used by Ecology dramatically overstated the volume and composition of vessel discharges into the Puget Sound;
  • We believe in Clean Water, and we could even support scientifically-based, targeted No Discharge Zones in shellfish and low-flushing areas;
  • Remember: Raw sewage discharges are already illegal within three miles of the shoreline, and many boaters treat sewage discharges now with Coast Guard-approved type I and type II Marine Sanitation Devices (MSDs), which will be outlawed by the proposed NDZ.
  • Please say NO to regulatory overkill – let’s ask Ecology to focus on the real problems causing water quality impairment. The biggest ones involve the billions of gallons of raw sewage dumped by Victoria, B.C. as well as (during storm events) by King County METRO and Seattle Public Utilities.
  • Overreaching regulation that imposes costs on boaters and provides no real benefit is the very definition of bad public policy. EPA should deny Ecology’s petition and request Ecology develop an NDZ solution that works for marine interests and the environment.
  • While we don’t agree with a sound-wide NDZ, if there’s going to be one, recreational boaters should have the same five-year phase-in as commercial vessels. It is a due process “foul” to instantaneously declare previously-legal solutions as illegal, without giving any time for phase-in or compliance.
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1988 M/Y Camargue Yacht Fisher
Alaskan Sea-Duction
MMSI: 338131469
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