Do the potty police have science on their side?

[Exile]

Originally Posted by Lake-Effect

Basically, a minority of boaters are whining about having to use their holding tank once in a while. Oh the injustice.

You're apparently still not sufficiently well-versed with the issue. The USCG/EPA authorization for Type 3 devices eliminates the requirement for holding tanks. If the sewage is treated then what's the point? So boaters who maybe have no facility for a holding tank or who want to offset the cost of installing one, now have no options. In many cases -- like Puget Sound or RI Sound where it's practically all NDZ -- this is their entire cruising ground.

Are you now starting to understand why this issue goes well beyond your personal preferences & sensitivities?

[Exile]

My mistake: "Type 3" MSD's are the more typical ones that use holding tanks for untreated sewage. Types 1 & 2 do not require holding tanks since the sewage is treated per EPA standards. https://www.epa.gov/vessels-marinas-...n-devices-msds

Originally Posted by Exile

The USCG/EPA authorization for Type 3 onboard treatment devices eliminates the requirement for holding tanks. If the sewage is treated then what's the point? So boaters who maybe have no facility for a holding tank or who want to offset the cost of installing one, now have no options. In many cases -- like Puget Sound or RI Sound where it's practically all NDZ -- this is their entire cruising ground.

[Lake-Effect]

Originally Posted by Exile

If the sewage is treated then what's the point?

Type 1 & 2 MSDs do not sufficiently treat sewage for an NDZ, where the concern is as much or more for the nutrients and other chemicals that are not removed or reduced by those systems.

[senormechanico]

Puget Sound NDZ is strictly a political mandate to buy votes.
If it really had science behind it, there would be a lot of pressure by the Greenies who wanted the NDZ to force King County Metro and other sewer districts to redesign the system to separate storm water from sewage.
No more multi million gallon sewage spills when it rains!


Like THAT'S going to happen...

[Exile]

Originally Posted by Lake-Effect

Type 1 & 2 MSDs do not sufficiently treat sewage for an NDZ, where the concern is as much or more for the nutrients and other chemicals that are not removed or reduced by those systems.

Now you're talking science but I'm still not seeing any support. Only thing that's come up thus far is the area near Ft. Jefferson in the Dry Tortugas where there's sensitive coral. Great Lakes/freshwater may be a different deal, dunno. What we do know is that Types 1 & 2 meet EPA standards which the USCG bases its approval on.

[Exile]

Originally Posted by senormechanico

Puget Sound NDZ is strictly a political mandate to buy votes.
If it really had science behind it, there would be a lot of pressure by the Greenies who wanted the NDZ to force King County Metro and other sewer districts to redesign the system to separate storm water from sewage.
No more multi million gallon sewage spills when it rains!


Like THAT'S going to happen...

Not too hard to surmise that the impact from such spills on water quality is just a tad more than 0.0017%. If you're a selfishly motivated, absolutist Greenie it doesn't matter, but if you're a pragmatist who cares more about water quality than some emotional fear of "turds floating by while you're swimming," you'd be able to see that such meaningless restrictions on boaters only give politicians an out for dealing with what's actually significant.

[Lake-Effect]

Originally Posted by Exile

What we do know is that Types 1 & 2 meet EPA standards which the USCG bases its approval on.

The EPA must approve the declaration of NDZs, so we also know that the EPA does NOT approve discharging from a Type 1 or 2 system inside an NDZ.

[Paul L]

Originally Posted by Exile

....?. What we do know is that Types 1 & 2 meet EPA standards which the USCG bases its approval on.

As I posted back post #10 On this thread

A type 1 MSD still has higher fecal coliform discharge than is allowed on a Chesapeake Bay oyster bed at harvest time. So they aren't that clean.
Quote:
Type I is a flow through discharge device that produces effluent having a fecal coliform bacteria count not greater than 1,000 per 100 milliliters and no visible floating solids.

[DumnMad]

Originally Posted by valhalla360

In fact the one suggested if all boat related sewage was eliminated it would reduce the nutrient load on the Chesapeake by 0.0017%...basically any scientist worth his salt would tell you that's not measurable by any reliable methods.

I wonder if they deducted the nurients of the fish caught from the boats that produced this 0.0017% nutrient load

[Exile]

Originally Posted by Lake-Effect

The EPA must approve the declaration of NDZs, so we also know that the EPA does NOT approve discharging from a Type 1 or 2 system inside an NDZ.

When a state makes the environmental determination (that more protection is needed), the only approval required of the EPA is that adequate pump-out facilities are available. You are only correct if the EPA makes the determination. https://www.epa.gov/vessels-marinas-...rge-zones-ndzs

[Exile]

Originally Posted by Paul L

As I posted back post #10 On this thread

'A type 1 MSD still has higher fecal coliform discharge than is allowed on a Chesapeake Bay oyster bed at harvest time. So they aren't that clean.'

Yes, I read that. But I also read the ensuing discussion about effluent concentrations, and how discharge from boats compares to those from overflowing water treatment plants. Did you read the 0.0017% figure recently posted? Besides, given all the justified attention & efforts being made to restoring the oyster population on the Chesapeake Bay, it doesn't appear to be listed as a NDZ (either the VA or MD portions). Did I read this wrong?

https://www.epa.gov/vessels-marinas-...-ndzs-state#va

[Lake-Effect]

Originally Posted by Exile

When a state makes the environmental determination (that more protection is needed), the only approval required of the EPA is that adequate pump-out facilities are available. You are only correct if the EPA makes the determination. https://www.epa.gov/vessels-marinas-...rge-zones-ndzs

From your link: the 3 ways in which an NDZ is created:

1. The state determines that the water body requires greater environmental protection, and EPA finds that adequate pump-out facilities are available. (Commonly known as a 312(f)(3) NDZ) A state may completely prohibit sewage discharge from vessels, whether the sewage is treated or not, into some or all of its waters if:
   1. the state determines that the protection and enhancement of the quality of the waterbody requires greater environmental protection than the current federal standards allow; and
   2. EPA determines that adequate facilities for the safe and sanitary removal and treatment of sewage from vessels are reasonably available. (33 U.S.C. 1322(f)(3) (PDF)(10 pp, 170 K)).
2. The EPA, upon application by the state, determines that the protection and enhancement of the water body requires establishment of an NDZ. (Commonly known as a 312(f)(4)(A) NDZ) If the EPA determines, upon application by a state, the protection and enhancement of specified waters requires sewage discharges to be prohibited, the EPA will prohibit, by regulation, sewage discharge from a vessel. This prohibition will occur whether the sewage is treated or not into those waters. Unlike NDZs established pursuant to CWA section 312(f)(3) (described above), the state does not have to show adequate pump-out facilities are reasonably available to request this type of NDZ be established (33 U.S.C.1322(f)(4)(A) (PDF)(10 pp, 170 K)).
3. Drinking water intake zones. (Commonly known as a 312(f)(4)(B) NDZ) The EPA, upon application by a state, will prohibit, by regulation, sewage discharge from vessels within a drinking water intake zone. The purpose of this NDZ is to safeguard human health through the protection of intake waters used for drinking. The state does not need to show that adequate pump-out facilities are reasonably available to establish this type of NDZ. (33 U.S.C.1322(f)(4)(B) (PDF)(10 pp, 170 K)).

Yes, it's not always the EPA making the call on an NDZ. But again, the EPA is not allowing (or approving or similar) any discharge from types 1 & 2 MSDs into an NDZ.

[Exile]

Originally Posted by Lake-Effect

From your link: the 3 ways in which an NDZ is created:

1. The state determines that the water body requires greater environmental protection, and EPA finds that adequate pump-out facilities are available. (Commonly known as a 312(f)(3) NDZ) A state may completely prohibit sewage discharge from vessels, whether the sewage is treated or not, into some or all of its waters if:
   1. the state determines that the protection and enhancement of the quality of the waterbody requires greater environmental protection than the current federal standards allow; and
   2. EPA determines that adequate facilities for the safe and sanitary removal and treatment of sewage from vessels are reasonably available. (33 U.S.C. 1322(f)(3) (PDF)(10 pp, 170 K)).
2. The EPA, upon application by the state, determines that the protection and enhancement of the water body requires establishment of an NDZ. (Commonly known as a 312(f)(4)(A) NDZ) If the EPA determines, upon application by a state, the protection and enhancement of specified waters requires sewage discharges to be prohibited, the EPA will prohibit, by regulation, sewage discharge from a vessel. This prohibition will occur whether the sewage is treated or not into those waters. Unlike NDZs established pursuant to CWA section 312(f)(3) (described above), the state does not have to show adequate pump-out facilities are reasonably available to request this type of NDZ be established (33 U.S.C.1322(f)(4)(A) (PDF)(10 pp, 170 K)).
3. Drinking water intake zones. (Commonly known as a 312(f)(4)(B) NDZ) The EPA, upon application by a state, will prohibit, by regulation, sewage discharge from vessels within a drinking water intake zone. The purpose of this NDZ is to safeguard human health through the protection of intake waters used for drinking. The state does not need to show that adequate pump-out facilities are reasonably available to establish this type of NDZ. (33 U.S.C.1322(f)(4)(B) (PDF)(10 pp, 170 K)).

Yes, it's not always the EPA making the call on an NDZ. But again, the EPA is not allowing (or approving or similar) any discharge from types 1 & 2 MSDs into an NDZ.

I don't understand what point you are trying to make. Under scenario #1 (which seems to be the one people are objecting to) the state makes the call. Under all three, however, both the state and the USCG have enforcement powers. Either way this begs the question at issue & what is the thread topic, namely whether there's any scientific justification for creating the above-listed exceptions to the general rule authorizing boaters to discharge treated sewage within the 3-mile limit.

If all of Puget Sound & Narragansett Bay are NDZs but the Chesapeake Bay is not, this suggests the science may be scant and the determinations are being made arbitrarily (i.e. for political reasons). Prove me wrong with some science or continue advocating for regs which appear to only benefit your personal but scientifically unsupportable sensibilities.

[DumnMad]

Originally Posted by Exile

Prove me wrong with some science or continue advocating for regs which appear to only benefit your personal but scientifically unsupportable sensibilities.

Some people have jobs in the administration of excessive regulations.

Threats to their own income often makes them deaf to science and reason.

[Paul L]

Originally Posted by Exile

'A type 1 MSD still has higher fecal coliform discharge than is allowed on a Chesapeake Bay oyster bed at harvest time. So they aren't that clean.'

Yes, I read that. But I also read the ensuing discussion about effluent concentrations, and how discharge from boats compares to those from overflowing water treatment plants. Did you read the 0.0017% figure recently posted? Besides, given all the justified attention & efforts being made to restoring the oyster population on the Chesapeake Bay, it doesn't appear to be listed as a NDZ (either the VA or MD portions). Did I read this wrong?

https://www.epa.gov/vessels-marinas-...-ndzs-state#va

My point was that the level of treatment of onboard systems is not as high as a lot of people think. They aren't panecias. That said I think NDZs are completely counter productive. They harm the boaters that are trying do the cleaner thing. They do nothing to reduce direct discharge as it was already prohibited within 3 miles.