Do the potty police have science on their side?

[sailorboy1]

Originally Posted by sailormed

Post 1 on 13/09
Post 401 on 29/10
That is 400 posts on this subject in 46 days.
Roughly 10 a day and growing!


Must be a passionate subject.

everyone likes to talk crap

[Lake-Effect]

Originally Posted by senormechanico

Try to keep up, l-e.

If you did your research, you would find there is such a thing.

It's called Hold'n Treat. Made by Raritan.

If you actually read the thread , you'd have learned that some people are complaining that they didn't have the space for a large holding tank. The Hold-n-Treat is 15 gallon.


But what if the "tank" part was only 5 gallon? Enough for a couple of days' holding without requiring much more space than the Electro-San alone.

[sailingharry]

Originally Posted by john61ct

Maybe peeing, but poo?

Among adults, in any country I've lived in, that would be a crazy high overestimate.

Would usually be treated as a public safety emergency.

John, You are 100% correct and that was the intent of my post. However, on re-reading it, my intent was certainly NOT clear! LOL

[sailingharry]

Originally Posted by Lake-Effect

I suspect that market pressure could convince Electro-Scan and others to incorporate some sort of mini holding tank arrangement in there so that they could go a day or two without discharging til they are back in open (non-NDZ) water. Win-win.

No convincing necessary. It's been on the market for years (decades, perhaps?). For those with who can support the significant space requirement, it's a very interesting option. It's called a "Hold n'Treat" and for $2-3K (plus another $1-2K to install) does exactly what you describe. Unfortunately, it goes from a total volume of 2 gallons (which mostly fills the space I have) to 17 gallons (which wouldn't fit anywhere in my boat except the forepeak bunk (not UNDER the bunk, IN the bunk!). It's base 18"x26", and it is 18" tall -- quite a large object for a small boat.

[sailingharry]

Originally Posted by Lake-Effect

If you actually read the thread , you'd have learned that some people are complaining that they didn't have the space for a large holding tank. The Hold-n-Treat is 15 gallon.


But what if the "tank" part was only 5 gallon? Enough for a couple of days' holding without requiring much more space than the Electro-San alone.

Actually, they address this too. You can buy parts of the kit to allow the L/S to be used with an existing (or owner provided) holding tank. The problem remains for retrofit, that the only way I can get a 5 gallon holding tank is to remove my L/S. But, your point is good, and if I were really motivated, I might well be able to get enough holding tank to get an overnight at least. As long as the Bay is "mostly" not an NDZ, that would work -- but if the entire Bay is made an NDZ (they tried that a couple years ago), then to be "legal" you would need much more holding tank (and wouldn't need the L/S anyway!).

[jtsailjt]

Originally Posted by Lake-Effect

You're right about the photo, but I'm certain that other shots would show many boats large enough to have heads. it is Florida... The point there being: what if every NSD equipped boat was discharging after every flush in that concentrated space; would you be happy about that? In this thread, there seem to be several who would be...




^^^ This, Senor.

btw, the newest ElectroScan (2014+) seems to be significantly advanced. It would be great to see retests using that device.

I suspect that market pressure could convince Electro-Scan and others to incorporate some sort of mini holding tank arrangement in there so that they could go a day or two without discharging til they are back in open (non-NDZ) water. Win-win.

The point (at least one of many) you seem to be missing is that we don’t boat like those in the photo are. We are cruisers who like privacy and space, not daysailors or runabout owners who like being in as dense a cluster as possible. In other words, that photo is just a visual straw man so you can successfully argue against something. I’ll willingly concede that IF a couple hundred live aboards somehow managed to get themselves in that tight a cluster and all flushed at once, there would be a mess. But we all know that has very little to do with this discussion.

The problem with an additional holding tank to contain LectraSan effluent is that it’s impractical so nobody would do it. The whole point of spending money on a treatment device is so you aren’t tied to pump-outs or going 3 miles offshore. Most NDZ’s are big enough so if you’re going to be forced to exit before using your treatment system, you might as well skip the complication and expense of installing it and stick with a holding tank that you get pumped out or dump overboard if necessary.

The real win-win would be for NDZ’s to include an exemption for treatment devices that environmentally conscious boaters have installed in order to be more environmentally friendly. This will require educating those who make these rules and also persuading them to put political grandstanding aside in favor of a more fact based and pragmatic approach to this issue.

[Lake-Effect]

Originally Posted by jtsailjt

The point (at least one of many) you seem to be missing is that we don’t boat like those in the photo are. We are cruisers who like privacy and space, not daysailors or runabout owners who like being in as dense a cluster as possible. In other words, that photo is just a visual straw man so you can successfully argue against something.

[ ]

I’ll willingly concede that IF a couple hundred live aboards somehow managed to get themselves in that tight a cluster and all flushed at once, there would be a mess. But we all know that has very little to do with this discussion.

The picture, together with the hypothetical question, was for the benefit of those here who stated that the ElectroSan type of treatment is suitable for discharging anywhere, at any time, from any so-equipped boats.

As you say, cruisers are just a small part of the whole boating community. The NDZ laws apply to ALL boats. And to other sources of discharge as well.

The problem with an additional holding tank to contain LectraSan effluent is that it’s impractical so nobody would do it.

... yet Raritan already markets a version of their system with integrated holding (not on the effluent side, I imagine.) ... I guess nobody told them it's impractical.


btw, The idea of NDZ is no sewage, not even disinfected sewage.

[thinwater]

Originally Posted by jtsailjt

... The real win-win would be for NDZ’s to include an exemption for treatment devices that environmentally conscious boaters have installed in order to be more environmentally friendly. This will require educating those who make these rules and also persuading them to put political grandstanding aside in favor of a more fact based and pragmatic approach to this issue.

Well put.


I would add that loudly proclaiming our "right to poo anywhere" and talking about whales probably does nothing to strengthen our case in the public eye. while facts are important, so is perception.


In the case of the Puget Sound it is worth understanding that it is a unique body of water, because it is not regulated as an inland water. Although it sounds as through a simple solution would have been to close the 3-mile exclusion inside the US portion of the sound, I believe this action would have been without precedent and thus very difficult. It would have required federal regulators to go bgeyond their mandate, which in the current climate is probably unrealistic. I'm trying hard to keep this non-political, but this is a factor; declaring it an NDZ had a simple, established procedure. The action was mechanical and below the radar. Going outside their established mandate would require a rule-making procedure, which simply isn't realistic.


The politics aren't hard to understand. The NDZ decision was a practical one.


This thread would expand geometrically if we included it to discuss all the regulations that could be improved. The problem has evolved over 200 years. Regulations are written, often imperfect, but there simply are no resources to go back to fix them. The regulators know they aren't perfect, but they can't just fix them. They have to go through a rule making procedure, which costs time and money. The seemingly subtle difference between and NDZ and removing the 3-mile limit exclusion pales in comparison with other regulatory efforts. This is NOT a partizan statement; rules get made, become outdated, and there is simply no practical way to go back and fix all of them. Priorities. Whether Republican or Democrat, this is low priority.

[sailingharry]

Originally Posted by Lake-Effect

The NDZ laws apply to ALL boats. And to other sources of discharge as well.

I think I may now understand why we keep talking across each other on this point. You are Canadian, and so don't have the framework of US laws to understand the NDZ.


I don't know if Canadian's have NDZ's, and what they mean, since I don't understand the Canadian framework.


Here in the US, it is illegal to discharge ANY untreated sewage from a boat, and has been since 1975 or so, when the Clean Water Act was passed. The CWA defines Type I and Type II MSD's, and exempts them. It also defines NDZ's.


For us, in the US, an NDZ specifically targets Type I and Type II, and has ZERO impact on anything else. It absolutely does not address, in your words, "other sources of discharge as well." Except in very limited cases (Lake Champlain, I think is one), it does not address gray water, for instance. In order for an NDZ to be established, you must show that there are adequate pumpout facilities (a vague, and usually unenforced, criteria).


NDZ may sound like a broad, generalized, "No Discharge Area." It is not. It does not impact any shore facility. It does not have any impact on vessels with holding tanks (only), as they are not allowed to discharge. It does not impact vessels using the "bucket and chuck-et" approach, as that has been illegal for 45 years. It does not impact peeing over the side, as that continues to remain legal. It ONLY impacts Type I and Type II MSDs -- that is the stated intent of an NDZ, at least in the US.

[Lake-Effect]

Originally Posted by sailingharry

I think I may now understand why we keep talking across each other on this point. You are Canadian, and so don't have the framework of US laws to understand the NDZ.

Here in the US, it is illegal to discharge ANY untreated sewage from a boat, and has been since 1975 or so, when the Clean Water Act was passed. The CWA defines Type I and Type II MSD's, and exempts them. It also defines NDZ's.

For us, in the US, an NDZ specifically targets Type I and Type II, and has ZERO impact on anything else.

NDZ may sound like a broad, generalized, "No Discharge Area." It is not. It does not impact any shore facility. It does not have any impact on vessels with holding tanks (only), as they are not allowed to discharge. It does not impact vessels using the "bucket and chuck-et" approach, as that has been illegal for 45 years. It does not impact peeing over the side, as that continues to remain legal. It ONLY impacts Type I and Type II MSDs -- that is the stated intent of an NDZ, at least in the US.

I appreciate your intent to clarify. We do have similar laws.

I have been making reference to "all boats" because, in effect, it is a prohibition against all boats dumping. Yes the other boats have the 3 mi limitation as well, but isn't it the case that there are some places where the NDZ extends beyond that 3 mi limit?

Also, if there are special exemptions for types 1 and 2, or just LectraSans, then I imagine that the enforcement of the NDZ becomes harder. And there will still be yelling.

As I proposed earlier, maybe some sort of grandfathering is reasonable for boats so equipped; as the MSD systems are replaced or boats sold, the exemption then drops away.

[jtsailjt]

Originally Posted by Lake-Effect

I appreciate your intent to clarify. We do have similar laws.


I have been making reference to "all boats" because, in effect, it is a prohibition against all boats dumping. Yes the other boats have the 3 mi limitation as well, but isn't it the case that there are some places where the NDZ extends beyond that 3 mi limit?



Also, if there are special exemptions for LectraSans, then the enforcement of the NDZ becomes that much harder.


As I proposed earlier, maybe some sort of grandfathering is reasonable for boats so equipped; as the MSD systems are replaced or boats sold, the exemption then drops away.

I'm not sure why it's harder to enforce a NDZ if there is an exemption for Lectrasans. If a boat is suspect or is boarded for inspection, it's pretty easy to see if there's a working Lectrasan onboard. I'd compare Lectrasan effluent to gray water. It's not difficult to discern between raw sewage and either of those.

Why do you have this instinct to come up with some sort of 'compromise' that would prevent existing MSD systems from being used in the way they were intended when installed? Whether you paid directly for the installation or the prior owner paid for it and you paid him for the boat and all its installed equipment, why should it matter? Your proposal would incentivize people who buy boats with MSD's installed to remove them and go back to the time tested method of either pumping directly overboard or using a holding tank and if a pumpout isn't handy, dumping its raw sewage into the NDZ when no one is looking. Why not just accept that MSD's themselves are a huge improvement from that and are themselves a pretty good compromise that, one way or the other, the boat owner has paid for and should be allowed to use. You'll never notice any negative impact on the environment and I think you know that but for some odd reason feel compelled to argue in favor of restricting the use of these treatment devices without regard to the effect your position is likely to actually have on the environment that you profess to care so much about.

[Lake-Effect]

Originally Posted by jtsailjt

I'm not sure why it's harder to enforce a NDZ if there is an exemption for Lectrasans. If a boat is suspect or is boarded for inspection, it's pretty easy to see if there's a working Lectrasan onboard. I'd compare Lectrasan effluent to gray water. It's not difficult to discern between raw sewage and either of those.

Why do you have this instinct to come up with some sort of 'compromise' that would prevent existing MSD systems from being used in the way they were intended when installed? Whether you paid directly for the installation or the prior owner paid for it and you paid him for the boat and all its installed equipment, why should it matter? Your proposal would incentivize people who buy boats with MSD's installed to remove them and go back to the time tested method of either pumping directly overboard or using a holding tank and if a pumpout isn't handy, dumping its raw sewage into the NDZ when no one is looking. Why not just accept that MSD's themselves are a huge improvement from that and are themselves a pretty good compromise that, one way or the other, the boat owner has paid for and should be allowed to use. You'll never notice any negative impact on the environment and I think you know that but for some odd reason feel compelled to argue in favor of restricting the use of these treatment devices without regard to the effect your position is likely to actually have on the environment that you profess to care so much about.

I love how the goalposts are shifting around. Right now it's the Electro-San, which seems to be the best of the lot. So... I'll grant that. (-waves wand... POOF!-) Any ElectroSan that meets factory spec for output is hereby granted an exemption for NDZs.


Except...

• How can a LEO recognize a real ElectroSan? Ok, training.
• how do we know that the ElectroSan is operating up to spec? I know - USCG-approved testing and certification every 5 years? 2 years?
• waaah! what about my non ElectroSan Type 1 or 2 MSD (most of which are NOT up to the ElectroSan spec?) I'll throw this one out to the audience.

Kick it around, while i get a quote on Raritan stock...

Why do you have this instinct to come up with some sort of 'compromise'

Because I'm a reasonable guy.



Because standards aren't fixed in stone. No-one promised that any MSD system would meet all future specs, forever and ever. When the patents come off and the market gets bombarded with inferior, low-cost ElectroSan knockoffs, you'll have more people using them... with more pollution. That's not moving forward.

[sailingharry]

Originally Posted by Lake-Effect

When the patents come off and the market gets bombarded with inferior, low-cost ElectroSan knockoffs, you'll have more people using them... with more pollution. That's not moving forward.

I'm not an expert on patent law, but we had our first Lectra San on our boat in the 70's, or 40+ years ago. I suspect the basic patent is long since expired.


Unfortunately, while Raritan makes a very high quality product with top shelf customer support (really, they do!), they are the only game in town. To my knowledge, there are NO other Type I MSD manufacturers on the market. Hardly "flooded." So prices are... typical of a monopoly. Also typical of a very small market.


Part of the problem is, as I've said many times, no one uses them. Try and buy a Benne or Jenne or Hunter without a holding tank -- I suspect that is not an option. LectraSan's are only installed on very old boats (it was an option in 1979 when my Sabre was made), or retrofitted on boats that find holding tanks don't work (my 1 hour each way trip to a pump out is dwarfed by a friend -- with a L/S -- who is 2 hours from the nearest pumpout!)



It's hard to mass market and economize on scale when only 1-2% of the boating public uses a product, and it has a virtually unlimited lifespan (remember, most boats are used less than 15 days a year -- just a guess -- so over 20 years the unit gets 300 days of use!).

[Lake-Effect]

Originally Posted by sailingharry

Part of the problem is, as I've said many times, no one uses them.

Well, we'll just grant "no one" an exception, so they'll stop complaining

Try and buy a Benne or Jenne or Hunter without a holding tank -- I suspect that is not an option. LectraSan's are only installed on very old boats (it was an option in 1979 when my Sabre was made), or retrofitted on boats that find holding tanks don't work (my 1 hour each way trip to a pump out is dwarfed by a friend -- with a L/S -- who is 2 hours from the nearest pumpout!)

It's hard to mass market and economize on scale when only 1-2% of the boating public uses a product, and it has a virtually unlimited lifespan (remember, most boats are used less than 15 days a year -- just a guess -- so over 20 years the unit gets 300 days of use!).

_If_ ElectroSans or similar do get an exception for NDZs, you might see an uptick in sales, and some competition again. And someone will have some accomodating factory in the Far East make a look-alike case with a cheap macerating sump pump and some purple LEDs in it. The "Electro-Spin".

[Exile]

Originally Posted by Lake-Effect

I love how the goalposts are shifting around. Right now it's the Electro-San, which seems to be the best of the lot. So... I'll grant that. (-waves wand... POOF!-) Any ElectroSan that meets factory spec for output is hereby granted an exemption for NDZs.


Except...

• How can a LEO recognize a real ElectroSan? Ok, training.
• how do we know that the ElectroSan is operating up to spec? I know - USCG-approved testing and certification every 5 years? 2 years?
• waaah! what about my non ElectroSan Type 1 or 2 MSD (most of which are NOT up to the ElectroSan spec?) I'll throw this one out to the audience.

Kick it around, while i get a quote on Raritan stock...



Because I'm a reasonable guy.



Because standards aren't fixed in stone. No-one promised that any MSD system would meet all future specs, forever and ever. When the patents come off and the market gets bombarded with inferior, low-cost ElectroSan knockoffs, you'll have more people using them... with more pollution. That's not moving forward.

You really have no idea, do you, as to whether old or newly mfg. Type 1's or 2's meet "spec" or otherwise create discharge that is harmful to the environment. As usual, you are assuming, without evidence, that just because the newer models discharge fewer pathogens it necessarily follows that the water will become more polluted. (Hint: it's the concentration/dilution thing again). The "spec" is established by the EPA not the mfg., and presumably takes into account the low volume as compared to, for e.g., a municipal sewage plant. For a Type 1 it's "no visible floating solids and a fecal coliform bacterial count not greater than 1000 per 100 milliliters." For a Type 2 it's "a fecal coliform bacterial count not greater than 200 per 100 milliliters and no more than 150 milligrams of total suspended solids per liter." Mfgs. have to meet specs created by EPA scientists, not uninformed members of the public with too much time on their hands and an obvious political agenda.

https://www.epa.gov/vessels-marinas-...n-devices-msds

Despite all the street corner shouting, posturing, and , there has been no evidence presented thus far that these large, tidal, saltwater bodies of water primarily at issue are or would be negatively impacted by discharge from Type 1 & 2 MSDs which meet these EPA standards. On the contrary, thinwater's posts suggest that at least one of these NDZs -- Puget Sound -- may have been created for reasons other than what the law intends & requires, namely a determination that the body of water requires a greater level of environmental protection.

https://www.epa.gov/vessels-marinas-...rge-zones-ndzs

Again, where is the science supporting a conclusion that these large bodies of water require greater levels of protection as the law requires? Or put another way, why are the existing EPA standards inadequate to sufficiently protect these waters? Why all of Puget Sound, Cape Cod Sound & Narragansett Bay? If the problem in Puget Sound is cruise ships not being subject to the 3-mile limit, then why address that issue with such a broad brush? Large commercial vessels -- esp. those carrying lots of passengers -- are already subject to all sorts of maritime regs which small vessels are exempted from. And why not all of Chesapeake Bay? Aren't there oyster beds struggling to survive? In the absence of such science, then the answer to the OP's original question -- "Do the potty police have science on their side? -- seems to be a pretty obvious "NO".

It would be one thing if the EPA/USCG never authorized discharge from onboard treatment systems and created the exception to the pumpout/3-mile rule. It's quite another to grant the exception, have people act on it in good faith, and then have the discharge exception removed. Discharges surrounding busy marinas or other crowded areas can and are addressed in their own right to best meet those areas' needs. As are city parks! L-E, please tell us you were just bored and didn't seriously intend to analogize to these two examples. Talk about a !