Anti Fouling Paint Manufacturers Taking Aim At California Hull Cleaners

[fstbttms]

Originally Posted by s/v 'Faith'

Foggy illustrates the problem well. There are reasonable steps that can be taken to improve water quality, and then there are the reactionist measures taken by governments.

I hardly think requiring boatyards to be responsible for their wastewater discharges qualifies as "reactionist."

[Dsanduril]

Originally Posted by fstbttms

I hardly think requiring boatyards to be responsible for their wastewater discharges qualifies as "reactionist."

And therein lies the rub Fast. You could easily revise that sentence to read "I hardly think requiring divers to be responsible for their scraping/scrubbing discharges qualifies as "reactionist."

Bottom cleaning may cause 5% of the copper distribution from bottom paint or it may cause 50%, even you agree that it causes some copper discharge to the marine environment. And if it causes some discharge then by your own arguments maybe we should be regulating it. Should it be highest on the legislative priority list? Probably not, but you pays your money and you buys your politicians.

[fstbttms]

Originally Posted by Dsanduril

And therein lies the rub Fast. You could easily revise that sentence to read "I hardly think requiring divers to be responsible for their scraping/scrubbing discharges qualifies as "reactionist."

Bottom cleaning may cause 5% of the copper distribution from bottom paint or it may cause 50%, even you agree that it causes some copper discharge to the marine environment. And if it causes some discharge then by your own arguments maybe we should be regulating it. Should it be highest on the legislative priority list? Probably not, but you pays your money and you buys your politicians.

As a member of the California Professional Divers Association, I am certified in the use of a set of in-water hull cleaning best management practices, as required by the California EPA Non Point Source Pollution Control Program's Management Measure 4.2e. Hopefully your diver is as well. It would be nice, however, if the state actually enforced its own rules. Then maybe hull cleaners wouldn't be under the gun as much as we are.

[Deepdraft]

Fstbttms,

Thanks for the bottom paint recommendations and proposed in-water maintenance. I thought you'd enjoy the picture below. We hauled the boat for a survey and saw this:

[fstbttms]

Originally Posted by Deepdraft

Fstbttms,

Thanks for the bottom paint recommendations and proposed in-water maintenance. I thought you'd enjoy the picture below. We hauled the boat for a survey and saw this:

Attachment 58537

I've got many pictures like that:

[Dsanduril]

I'm only too familiar with your claim to use BMPs (where are they published by the way -for critical review and comment by the public? or do I have to pay the CPDA for a class in order to actually review the BMPs?). BMPs are every industry's method of attempting to avoid regulation. The "best" usually ends up being "this is the best we can do without it costing too much", where "costing too much" is decided by the industry. Just as you claim the paint lobby is the fox guarding the henhouse, so is a diver's organization developing BMPs. Are you claiming that using your BMPs results in zero discharge? Or only that it is the "best you can do"? Unless zero discharge then there is a case for external regulation.

Every industry and organization that develops BMPs claims that us poor saps that are members of the public couldn't possibly understand the difficulties and nuances of the profession in question, so we had best leave all of these decisions to the professionals.

[jeremiason]

I say that California is right! Ban copper, ban diesel, tax those rich mom & pops businesses and don't forget the geneticlly altered foods.


Then after all the tax paying citizens & businesses leave the State because of over regulation, the remaining liberals can declare bankrupcy and start over with group hug!

[Kenomac]

Originally Posted by foggysail

I'll share what happened last year where I docked. The local shipyard was fined by the EPA $175K for allowing boat wash runoff to enter the bay.

Frankly, I really can't see any difference between what the shipyard did by discharging boat wash runoff into the bay.... and what divers do when they scrape off the same growth and paint layers as they dive and "clean" the underside of a boat. Basically, the local EPA authorities penalized the "Rich businessman" who owns the boatyard for doing what the bottom scrubber divers do everyday.

To the marine environment... there's no difference.

It would make so much more sense to simply use a bottom paint product that can be left alone to do it's job, which is to repel marine growth; then just simply hose off any residual growth once a year during the annual haul out.... But we can't do that without being fined by the EPA. Total absurd nonsense.

[fstbttms]

Originally Posted by Dsanduril

I'm only too familiar with your claim to use BMPs (where are they published by the way -for critical review and comment by the public? or do I have to pay the CPDA for a class in order to actually review the BMPs?). BMPs are every industry's method of attempting to avoid regulation. The "best" usually ends up being "this is the best we can do without it costing too much", where "costing too much" is decided by the industry. Just as you claim the paint lobby is the fox guarding the henhouse, so is a diver's organization developing BMPs. Are you claiming that using your BMPs results in zero discharge? Or only that it is the "best you can do"? Unless zero discharge then there is a case for external regulation.

Every industry and organization that develops BMPs claims that us poor saps that are members of the public couldn't possibly understand the difficulties and nuances of the profession in question, so we had best leave all of these decisions to the professionals.

Try to follow along- The CPDA or the hull cleaning industry at large did not produce them unbidden in order to befuddle the "poor saps." The are a requirement of the Cal EPA, which states that they must be written by an industry professional association. On top of that, studies show that they work. Do they completely eliminate copper discharge? No. That would be a practical impossibility. But to argue that they are some kind of scam and to disparage their use by hull cleaners is fairly ridiculous.

They can be found at prodivers.org

[foolishsailor]

Hmmm, as a boat owner who lived in SF for 7 years and a native of California who lived there for decades, I don't understand all the fuss about the idea of in the water hull cleaning?

If you own a boat and keep it in the bay it's hull will need to be cleaned more frequently than the usual once yearly pull out. I think that all the objectors here would object even more furiously if CA instituted legislation requiring you to pull your boat for every cleaning?

You don't have to be a racer to want your bottom cleaned more than once a year???

[Dsanduril]

Originally Posted by fstbttms

The are a requirement of the Cal EPA, which states that they must be written by an industry professional association.

Exactly. And the fact that they are a requirement of the Cal EPA (or various other organizations depening on location and industry) and that the regulations specify that they must be written by an industry professional organization is thanks to major industry lobbying (the same major industry lobbying that you are trying to "expose" with your thread here). "Don't worry about having to develop pesky little regulations for everything, we'll take care of that for you so you don't have to, after all, we know best".

Right up until March 11, 2011 (and even after) TEPCO claimed that it followed BMPs at Fukushima Daiichi. Only after exposure of those BMPs and scrutiny after the fact was it found that the BMPs were not the "best" and we in fact quite lax and antiquated.

The BMPs you point to (they took a bit of finding, http://50.87.139.198/prodivers/wp-co...nual-Rev5a.pdf) are full of the typical weasel-words of industrial BMPs everywhere:

until sufficient fouling accumulates to warrant wiping the hull

Be as gentle as practical

Both of those pretty much mean you can clean as often as you want to and brush as hard as you want to, simply claiming that the current accumulation "warranted" cleaning and you were as gentle as "practical". BMPs lacking definition of such critical terms/items are a scam and are intended to whitewash things so we all feel better.

Doesn't mean that doing the job properly doesn't result in less discharge, or that any one individual is deliberately doing things improperly. Doesn't mean that there aren't better (and worse) ways of accomplishing things. The BMPs are just a tick-box item used by an industry to get the regulators off their back with the least effort possible.

[fstbttms]

As somebody who thinks about and uses the CPDA BMPs on every boat I service, I can assure you that they are effective and worthwhile. I know there are divers out there using a brown pad on every single boat they clean, regardless of paint type or condition. I also know that by religiously following the BMPs, my clients enjoy longer periods between haulouts for paint and better performance under both power and sail between cleanings. Maybe you consider that a bad thing, but my clients do not.

[Bash]

Originally Posted by Kenomac

When are California boaters going to figure out that because of the environmental extremeists, they are being hosed financially.

Extremeists?

Must be the latest thing on Fox "news."

[sailorboy1]

based on the bottom growth rate in the SF Bay that always gets posted, maybe it needs more copper

[Dsanduril]

Originally Posted by fstbttms

As somebody who thinks about and uses the CPDA BMPs on every boat I service, I can assure you that they are effective and worthwhile. I know there are divers out there using a brown pad on every single boat they clean, regardless of paint type or condition. I also know that by religiously following the BMPs, my clients enjoy longer periods between haulouts for paint and better performance under both power and sail between cleanings. Maybe you consider that a bad thing, but my clients do not.

I don't consider that a bad thing. You are clearly a conscientous diver who takes pride in in his work and doing the job properly. The practices you follow are admirable. However, the written definition of those practices is so poor (and this tends to be deliberate) that another diver doing all the things you consider "wrong" could easily defend his/her activity using the same BMPs ("a brown pad was the softest 'practical' pad for the job" - where "practical" means "it's what I had in my truck").

I don't even espouse additional regulation as the solution, I just don't care for trotting out BMPs as something to hide behind. They were created by, and are used by the very organizations/factions that you started this thread to complain about.