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Old 11-04-2011, 16:05   #1
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EPA Rulemaking Webinars

I apologize ahead of time to those members of CF who do not have a boat in US waters. Those of you who are members of BoatUS will already have seen the following, and I apologize for subjecting it to you again, but everyone's response to the EPA is important. Below the BoatUS advisory I have pasted my own response to the EPA. Sorry that this is so lengthy, but I think it is important that we boaters not stand around with our hands in our pockets while the EPA prepares to tell us that we can't wash our boats.

The U.S. Environment Protection Agency (EPA) is developing future clean boating requirements for all recreational boats in the next few months, and they need to hear from you. During April, they are hosting weekly "webinars" to solicit boater input (April 6 - 6 pm, April 14 - 8 pm, April 22 - 10 am, and April 25 - 12 pm; all eastern time). I'm writing to encourage you to participate in one of these online events.
For more information on the webinars and to register in advance (which is required): http://water.epa.gov/lawsregs/lawsguidance/cwa/vessel/CBA/participate.cfm
A specific list of proposed requirements is not yet available. We do know that sewage will not be discussed or covered - it's part of a different law. EPA is looking at several broad categories of vessel discharges:
  • Antifouling paints and zincs
  • Graywater (from showers and sinks)
  • Bilge water (with concern about oil and grease, which is already illegal to discharge)
  • Cleaning products/maintenance practices
  • Disposal of garbage and fishing waste
  • Transport of invasive species
We need you to help EPA know that any new mandatory "management practices" must be based in science, and should be reasonable, practical, and economical. You should share with EPA the clean boating practices that you already employ, or that can be easily adopted within your boating. For ideas:
http://www.boatus.com/foundation/cleanwater/

For additional information on this topic from BoatU.S. go to:
www.boatus.com/gov/cba/

You may also submit questions, comments or concerns directly to CleanBoatingAct-HQ@EPA.GOV before June 2, 2011.
For more info from EPA:
http://water.epa.gov/lawsregs/lawsguidance/cwa/vessel/CBA/about.cfm

It is crucial that EPA hear from a variety of boaters on this topic. We hope you can tune into one of these sessions so that EPA can gain your perspective.





To Whom It May Concern:

First, a bit of background: I have been a recreational boater for most the past 40 years. During that time I have seen many positive changes driven by regulatory change. By training and profession I am an economist so I am sympathetic to using regulation to correct market failures, including the problem of the commons. Unfortunately, scheduling prevents me from participating in any of the remaining three webinars. Let me share a few observations based on the scant information available at your web site About the Clean Boating Act | Clean Boating Act | US EPA.

Under the heading Discharge Pollutants and Management Practices you raise several areas of concern to which I would like to respond:

1. ... release of antifouling ... agents –-
a. The antifouling paint industry is an international business. Regulations vary around the world. In order to capture market share paint manufacturers conduct R&D in order to conform to the most stringent laws. To the best of my understanding the most stringent laws are now in Australia. What would be the incremental gain in US waters, measured in terms of released toxins, in moving from our current standard to, say, those now in force in Australia? What would be the incremental cost of moving more US boaters in this direction? What is the least cost method, short of outright prohibition of ablative paints, of moving more US boaters toward the Australian standard?
b. What are standard boatyard practices regarding management of removal and application of antifouling paints? The yards with which I am familiar on Chesapeake Bay all require drop clothes and vacuum eguipped sanders. In addition, some yards go as far as draping the boat when old paint is being removed. What would be the incremental cost to boaters of requiring that all boats be drop clothed and draped? What would be the reduction in toxic runoff? What would be the benefit to marine life?
c. What practices are followed by boat owners? Users of ablative paints are directed by manufacturers to NOT scrub the bottom while the boat is in the water. When boats are hauled for cleaning during the season the runoff is captured before it drains back into the marine environment.
d. In conclusion, perhaps the EPA should institute a marketing campaign, funded by paint manufacturers, to move more boaters toward the less toxic but effective bottom paints. Just like private industry, the EPA should have to sell its ideas.
2. ... release of ... corrosion control agents –-
a. How much zinc is being released into the water by recreational boaters use of sacrificial anodes? How far above levels that are not toxic to marine life is the current level? What alternatives to zinc anodes are available and at what cost? Without corrosion control agents, commonly understood to be zinc anodes, almost all underwater metal machinery on existing boats would soon meet an untimely end. This is a very high cost to pay for the very small amounts of zinc released by sacrificial anodes into the water by recreational boaters.
b. Is the best solution to the problem the recycling of used anodes? If they are not now being recycled, why not? The value of the anodes in recycling is a rough measure of society’s valuation of the harm caused by the anodes in the water.
3. ... transport of aquatic nuisance species –- This applies to both inadvertent and deliberate transportation of nuisance species. Unless I am mistaken, there is already ample regulation of this at the state level.
a. Are the state regulations not stringent enough?
b. Are state regulations not being enforced? If state regulations are not being enforced due to a shortage of manpower and other resources, will the USCG have the resources to be involved in this kind of enforcement?
4. ... bilgewater –- Under current regulations bilge water is exactly that, water. There is ample law that prohibits the discharge of petrochemical waste into America’s waterways. Again, unless I am mistaken, there is already a zero tolerance rule. In order to avoid running afoul of existing law most boaters have either basins beneath their engine or products like Oilsorb from 3M to keep petroleum products on board instead of going into the marine environment.
5. ... cleaning and maintenance related discharges – What is the specific problem that this is meant to address? What products are currently being used to clean boats? How often and how much? What levels of such products can be tolerated by aquatic life? What reductions and at what cost would it take to achieve a level that can be tolerated by aquatic life?
a. Current law already restricts the use of phosphates in detergents.
b. Detergent makers are already marketing eco-friendly detergents.
c. Again, like industry, the EPA has an obligation to sell their ideas to the marketplace.
6. ... fishing waste – What is the specific problem that this is meant to address?
a. If by fishing waste the EPA means the scales and entrails of caught and cleaned fish, then one can only ask what happens to a fish that has not been caught, but instead dies a natural death?
b. If the concern is material such as lost and/or abandoned synthetic fishing line then this seems like a litter problem that is better addressed at a local level.
7. ... graywater – Household gray water is the waste from the likes of showers, tubs and sinks. Recreational boats also have showers and sinks. One must ask, again, what problem has been identified that needs attenuation?
a. A distinguishing feature of recreational boats is that when they are docked or moored at their home location the user has access to the same facilities and waste water disposal systems available to a land-bound home owner. This begs several questions.
i. When owners are on-board their boats at their home location, do they use their boat’s shower and sink for bathing, or do they use the available shoreside facilities?
ii. When recreational boats are away from dockside their supply of fresh water is extremely limited. The limited supply of fresh water places a limit on the amount of gray water that can be discharged. Given the frequency of boat usage and the even less frequent use of the boat away from dockside and which requires use of fresh water, what is the magnitude of the quantity of gray water that is of concern?
b. Where on an existing boat will the gray water be stored until it can be removed. Keep in mind that boaters are already storing blackwater.
c. Perhaps the concern is with kitchen waste that goes down the drain. Again, the distinction between a boat and land-bound home is important. A shoreside house, more likely than not, has a garbage disposal so that food waste is ground up and enters the municipal waste water treatment stream. Recreational boats do not have the luxury of an In-sink-erator, since a garbage disposal requires electricity and water to run, both in short supply on a boat. Boaters are also unlikely to rinse food waste down the drain since the cost of a clogged drain on a boat is not just the cost of the plumber but also the hundreds of dollars necessary to haul the boat out of the water so that the drain can be dismantled. For this reason boaters have strainer in the drain so that solid matter can go into the solid waste stream for later disposal on shore.

Further general considerations include the following: In considering all of these issues one must ask how many boats are on the water and represent sources of environmental risk as enumerated on the EPA web site. Take gray water as an example. At present there are about 13 million registered boats. Of these 95% are less than 26 feet. On the basis of size of boat alone, the proposed regulatory review would affect only about 650,000 boats. Given the length of the U.S. coastline, this amounts to 52 boats per mile. For the sake of argument let’s suppose that the typical boat owner uses their boat every weekend for an average seven month boating season, or 28 days per year. With this average usage and average boat density one would expect to see 4 boats per day per mile of coastline. If on average each of those boats expels 10 gallons of gray water per day , a very large amount on a boat of less than 40 feet, the total discharge per day would be 40 gallons per mile of coastline. The statisticians among us might say that the phosphate carried in those 40 gallons is statistically different from zero. However, as I teach my students, there is a difference between statistical significance and numerical importance. Is the phosphate concentration in 40 gallons of gray water numerically important, even after accounting for the concentration of the boat population and the length of the boating season?
There is a comment on your web site that I find especially disturbing. To whit “
In addition, the discharges from vessels sometimes contain environmentally harmful concentrations of pollutants.” This comment implies that discharges that can harm should be reduced to zero.This remark/attitude flies in the face of a long history of economic research already implemented by the EPA. I teach my students that even when it comes to pollution, the rule should be based on incremental gain and incremental cost, no matter how hard it may be to measure them. The specific example I use is to ask them whether City Council should implement a ‘no litter’ rule in the City of Philadelphia. With a little thought they arrive at the conclusion that zero litter tolerance is not economically feasible.
Finally, on the EPA web site it is stated that the Coast Guard would be responsible for any enforcement evolving from EPA rule-making. This raises the question of compliance and enforcement? Does/will the Coast Guard have the resources to enforce the regulations implied by the EPA announced webinars? How much is the Coast Guard currently committing to enforcement of, say, existing black water discharge laws, or are violations uncovered as a result of other Coast Guard activities? Is current boat owner black water regulation compliance essentially voluntary in light of the low cost of compliance and the low probability of apprehension? If compliance with new regulations is costly and the probability of apprehension is low then there is ample evidence that compliance rates will be low.

As the EPA goes forward I hope to see some clarity of purpose and clear headed analysis of the issues.

Sincerely,

Andrew Buck
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Old 11-04-2011, 16:52   #2
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Re: EPA Rulemaking Webinars

I did attend the webinar in Annapolis last week (online) and I found the information regarding the mission and the intent sound and generally non-threatening for boaters; although, the amount of participation may have prevented direct feedback and comments even though many questions were addressed.
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Old 12-04-2011, 07:50   #3
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Re: EPA Rulemaking Webinars

KB,
thanks for the reminder. Plan to attend Thursday
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Old 17-04-2011, 23:24   #4
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Re: EPA Rulemaking Webinars

Quote:
Originally Posted by KestrelBuck View Post
I apologize ahead of time to those members of CF who do not have a boat in US waters. Those of you who are members of BoatUS will already have seen the following, and I apologize for subjecting it to you again, but everyone's response to the EPA is important. Below the BoatUS advisory I have pasted my own response to the EPA. Sorry that this is so lengthy, but I think it is important that we boaters not stand around with our hands in our pockets while the EPA prepares to tell us that we can't wash our boats.

The U.S. Environment Protection Agency (EPA) is developing future clean boating requirements for all recreational boats in the next few months, and they need to hear from you.....

To Whom It May Concern:

First, a bit of background: I have been a recreational boater for most the past 40 years. During that time I have seen many positive changes driven by regulatory change.....

As the EPA goes forward I hope to see some clarity of purpose and clear headed analysis of the issues.

Sincerely,

Andrew Buck
Hi every one so the EPA is makeing new rules what is new?
Do you need a Native Garden to eat all your wast on a boat and to send clean water back in to the Ocean?
Or maybe they can help you to flot Bio Islands around the Boats or Can I make a Garden for the EPA and then be kiced out of it and they get it for free?
Or may be the EPA wants to help the State with a madedate In the befor Brown that stated Indians have there own envierment and all lands are of the State and The Indian has his Envierment and to stay out of ares and payd people for Native plants.
EPA wants Indian plants to clean the lakes and streams with no Native involment but Goverment Indians that are trained to thank like them.
So lets go Green and be like a Indian of the USA. But no True Indian Envolment.
Thank you it was nice to talk about the Envierment of 500 Years.
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Old 18-04-2011, 01:38   #5
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Re: EPA Rulemaking Webinars

KestrelBuck,

Thanks for:
  1. Bringing this webinar to our attention. It is great that we can get involved in policy making now, rather than simply always having to bear the brunt of it!
  2. Giving us a very comprehensive run down of the issues. Even if I can't attend, your list is a very simple reminder of our practices which need addressing.
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