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Old 14-03-2008, 13:38   #16
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DOD agenciers are required to comply with all Federal standards. The only difference is that DOA agencies are not subject to the same enforcement actions the rest of the regulated community is subject to.

No one gets rich off a program such as this and make no mistake - this problem has been created solely by the enviro group which brought the suit resulting in mandating compliance with a provision of the CWA no one wanted to do.

EPA has insufficient staff to implement even a state run oversight program and certainly states have insufficient resources to implement it. It's strictly paranoia to believe that any government entity would want to manage such a permit and inspection program. Actually the converse is true - no government environmental agency wants this or believes it is necessary.


As far as the perception any government entity can make money from such a program, to put it bluntly, that is just plain silly.
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Old 14-03-2008, 13:59   #17
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There are still some navy's still using TBT antifouling (NZ & Australia) & probably most of the others.
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Old 14-03-2008, 14:22   #18
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Originally Posted by S/V Illusion View Post
DOD agenciers are required to comply with all Federal standards. The only difference is that DOA agencies are not subject to the same enforcement actions the rest of the regulated community is subject to.

No one gets rich off a program such as this and make no mistake - this problem has been created solely by the enviro group which brought the suit resulting in mandating compliance with a provision of the CWA no one wanted to do.

EPA has insufficient staff to implement even a state run oversight program and certainly states have insufficient resources to implement it. It's strictly paranoia to believe that any government entity would want to manage such a permit and inspection program. Actually the converse is true - no government environmental agency wants this or believes it is necessary.


As far as the perception any government entity can make money from such a program, to put it bluntly, that is just plain silly.
That's kind of what I was thinking. The scale of the staff needed to inspect your boat for EPA compliance couldn't even be funded by the permit fee if it cost a couple hundred a year.

Seems unlikely to happen in its current (stated in this post) form.

It doesn't make fiscal sense.
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Old 14-03-2008, 14:30   #19
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The US government is now going to monitor 'deck runoff 'and 'engine cooling water'? Wow, I am truly impressed that your economy can afford the huge expenditure of public funds that will be required in order to enforce these new regulations. Further, I'm impressed that the average boater can afford the extra cost of inspection, licences or permits and presumably, installing or converting to completely closed cooling systems. And here I thought you were in the middle of an economic downturn and running a record deficit.

Maybe there is no sense in looking for other places as a home port for pleasure boating - things in the US, at least, certainly seem to be headed in the right direction.

Brad
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Old 14-03-2008, 14:34   #20
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The Feds could download the responsibility to the States.
Gord, you're right about that.

Back in 1971, the Feds delegated responsibility for creating a nationwide, comprehensive discharge permit system, and enforcement of that system, to the states. That was the National Pollutant Discharge Elimination (NPDES) permitting system that's still in effect today. All point-source discharges (industrial, commercial and municipal) were required to file for a permit.

Strangely enough, at that time, it was the Army Corps of Engineers that was the federal agency promulgating the regs, since they were responsible for "navigable waters" of the U.S. under a law passed in 1898, I think.

Nothing to stop them from doing it again in this case.
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Old 14-03-2008, 14:46   #21
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Gord, you're right about that.

Back in 1971, the Feds delegated responsibility for creating a nationwide, comprehensive discharge permit system, and enforcement of that system, to the states. That was the National Pollutant Discharge Elimination (NPDES) permitting system that's still in effect today. All point-source discharges (industrial, commercial and municipal) were required to file for a permit.

Strangely enough, at that time, it was the Army Corps of Engineers that was the federal agency promulgating the regs, since they were responsible for "navigable waters" of the U.S. under a law passed in 1898, I think.

Nothing to stop them from doing it again in this case.
And how many states created permit systems for discharge on pleasure craft in 1971? This doesn't apply to small boats.

Also, if the feds were after revenue from boaters, I'm sure they would just put back up the VHF licensing rule or something easy like that. Creating an army of inspectors (at great cost) is very unlikely to happen.
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Old 14-03-2008, 14:48   #22
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First I consider myself pretty environmentlly aware and this is plain silly. I wonder if those rabid enviromentalist relize their kayaks and canoes will need permits also for “deck runoff”? It would seem that ANYTHING on the water will need a permit. I guess we will need to block the scuppers and install a holding tank.
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Old 14-03-2008, 15:26   #23
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And how many states created permit systems for discharge on pleasure craft in 1971? This doesn't apply to small boats.

Also, if the feds were after revenue from boaters, I'm sure they would just put back up the VHF licensing rule or something easy like that. Creating an army of inspectors (at great cost) is very unlikely to happen.
SS,

My post was to give an example of the Feds dumping administrative and enforcement burdens on the States, following Gords comment to that effect. No the NPDES system did not apply to boats, nor even to farms at that point
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Old 14-03-2008, 16:07   #24
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The EPA Position Report is only 4 pages long, and answers many of the questions, and suppositions, posed here.
Goto:
http://www.nmma.org/lib/docs/nmma/gr...Permitting.pdf
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Old 14-03-2008, 16:19   #25
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I wrote my Rep today - thank you for the info. I hope this can get the same treatment that McCain/Kennedy got when they tried to railroad us on that one.

I hope their phones ring off the hook. I'll do what I can.

-T
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Old 14-03-2008, 16:22   #26
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US Senators Barbara Boxer and Bill Nelson have introduced legislation called the Clean Boating Act of 2008. The legislation, prompted by the National Marine Manufacturers' concerns over an EPA permitting scheme, was applauded by the association. If passed by Congress and signed by President Bush, the Clean Boating Act would permanently restore a longstanding regulation that excludes recreational boaters and anglers from discharge permitting requirements under the Clean Water Act.
"This issue has been a cloud hanging over our industry and, as promised, Senators Boxer and Nelson have worked to address it," said Scott Gudes, vice president of government relations for NMMA, in a statement. "We call on Congress to swiftly adopt this bill well in advance of the September 2008 permitting deadline."
In September 2006, a US District Court in California ordered that the EPA regulate ballast water discharges because of the danger of transporting invasive species. The judge told the EPA to have a permitting system in place within two years. The proposed legislation would restore a 35-year-old EPA exemption for non-polluting incidental discharges like weather deck run-off and engine coolant water.
"Unfortunately, the court's decision to overturn the entire exemption unintentionally tossed recreational boats into the same category as commercial ships," said Thom Dammrich, president of the NMMA, in the statement. "While minimizing the exchange of ballast water from one international port to another is very important in reducing the spread of aquatic invasive species, it is equally important not to sweep small recreational boats into the same regulatory scheme."
The NMMA is worried that millions of boaters may suddenly have to be permitted, and even the EPA has told IBI that they have never instituted a permitting scheme of this magnitude.
Gudes said that recreational boats are already "heavily regulated" under the Clean Water Act, the Clean Vessel Act, the Oil Pollution Act, and other federal and state laws.
"Without legislative relief soon, everyday boaters would be required by federal law to apply for the same expensive permits as ocean-going commercial vessels and land-based industrial facilities," Gudes said.
Gudes said that NMMA has been working with other organizations like BoatU.S. as well as a bipartisan group of Senators and Congressmen to push the legislation through. "Congress must now enact this legislation before the clock runs out on America's recreational boaters," Gudes said in the statement.

NMMA DOCUMENTS pertaining to the Clean Water Act of 2008
Ballast Water & Boat Permittinghttp://www.nmma.org/government/federal/

UNIFORM NATIONAL DISCHARGE STANDARDS FOR VESSELS OF
THE ARMED FORCES (864 pages)
http://www.nmma.org/lib/docs/nmma/gr/environmental
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Old 14-03-2008, 16:46   #27
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What is most bothersome about this is the title - the implication that the government is somehow wasting our tax dollars is flat misleading.

It was an enviro group which sued and one District Court judge who found for the plaintiff that created this mess. All the government has consistently done since our beloved Congress passed the CWA is write a regulatory exclusion exempting rec boaters from the provisions of the statute (as they rightly should have).

Best I can tell, the government was, is and appears to continue to be on our side on this issue. If anyone is wasting money, it's the enviro group who brought the suit.
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Old 14-03-2008, 16:53   #28
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...It was an enviro group which sued and one District Court judge who found for the plaintiff that created this mess. All the government has consistently done since our beloved Congress passed the CWA is write a regulatory exclusion exempting rec boaters from the provisions of the statute (as they rightly should have).
Best I can tell, the government was, is and appears to continue to be on our side on this issue...
Exactly. You must have read some of the documents. Thank you.
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Old 14-03-2008, 18:15   #29
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Actually I must admit to having not read the link - I administered the water and waste programs for EPA up until a few years ago and am too painfully aware of the details
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