Do the potty police have science on their side?

[Exile]

Originally Posted by Lake-Effect

For the real nerds...
https://digitalcommons.mainelaw.main...8&context=oclj


it offers a "big" reason why some states have pursued an NDZ declaration.

Yup, and one that is overbroad and unnecessarily restricts small vessels with Type 1's & 2's. A more sensible approach is what Calif. did 8 years after your linked article was written.

[Exile]

Originally Posted by valhalla360

Here's the real problem with this example (in addition to issues others that have pointed out):

No one said there should be "no rules". The rules should be supported by sound logic and SCIENCE. Dumping a 20 gal holding tank in this situation, it's pretty easy to document the number of people who will be brought into immediate and direct contact with the sewage with the follow up health risks easily identifiable. Most logical people would support a rule that you can't dump your holding tank in the situation shown in the picture.

If you make a rule to that effect with reasonable alternatives, most people will voluntarily abide by it.

The "zero tolerance" approach applied to areas where logic and SCIENCE do not support the rule is where people take exception and the result is one of two possibilities:
- You have draconian ongoing enforcement. LEO's lose respect from the population and it makes it much harder for them to gain assistance in solving real problems.
- You have a rule that no one follows and you can pat yourself on the back for cleaning up the Cheasapeak while everyone knows, your rule didn't do a darn thing to make it better.

Neither option is productive.

You nailed it. The choice the self-anointed "environmental stewards" often have is pretty obvious. What's the most reasonable approach to improve the environment or what's best to make themselves feel good. The problem with the latter is anyone who challenges what they believe as conventional thinking gets mindlessly labeled & stereotyped as "anti-environmental." It explains the growing disrespect for otherwise well-intended environmental laws which overreach or are counterproductive.

[Lake-Effect]

Originally Posted by jtsailjt

nobody can realistically claim that all the waters adjacent to Rhode Island out to 3 miles offshore are so sensitive that the tiny amount of treated effluent from a transiting sailboat equipped with a LectraSan would do ANY harm at all.

Sorry, are we talking ElectroSans, or any type 1 or 2 system?

This prohibition, as applied to small boat cruisers, is unrealistic, unenforceable, and is definitely not scientifically based.

I'm fairly certain there's a scientific basis to the prohibition, which applies to more than just recreational cruisers. Whether it's reasonable to apply the same prohibition to recreational boaters with a type 1 or 2 MSD is a different question.

Your so called 'compromise' is completely illogical because you would keep the older, less effective versions in use, while outlawing the more modern, more effective ones that are being produced and sold today.

... Again, are you talking just ElectroSans or all type 1 & 2 MSDs? I'd be more inclined to exempt new ElectroSans.. But that's not what's being asked, is it?


If there's a genuine reason for reducing discharge in an area, it should be applied to all boats; that's only fair. Starting from that point, then you can consider grounds for exemption. Complying once with a 40 year old spec isn't a compelling reason, if the area is truly sensitive to discharge.

[Pelagic]

Originally Posted by Exile

Something doesn't quite add up with this issue. Leaving aside the apparently unique scenario on the Puget Sound, are there more significant polluters inland of the 3-mile limit that the NDZ regs are designed to restrict? Do large commercial vessels have onboard treatment systems that may be authorized to discharge inland of 3 miles that the NDZs then prohibit? It seems odd that this entire regulatory scheme is set up only for the relatively few recreational boaters with Type 1 or 2 MSDs.

The Superyacht industry has been leading the charge on large treatment systems.

They have the money, their actions are scrutinized closely by the media and of course most billionaires believe that their sh** don't stink! [emoji2]

I have been specifying the best systems for 50m+ yachts since the 1990's and the systems keep getting better.
But it is a complicated process that involves training and monitoring the hotel department on cleaning products to use and the engineering on managing heavy loads from a day cruise with 100 on board.

This article explains the challenges and solutions and is keyed to International standards that most Super yachts far exceed by discharging only treated black and grey water

Inland or at large marinas, the easiest solution is pump out to trucks or barges for local disposal.
Here in Subic Philippines, that is what the US Navy do when in a foreign port.

https://superyachttechnology.com/201...hats-solution/

[Exile]

Originally Posted by Lake-Effect

And my point is that one 40 year old EPA spec isn't guaranteed to be sufficient for all situations, for all time.

Your technical insight never fails to impress. But again, what is your point? The EPA sets minimum standards for solids & pathogens which technological developments by mfgs. now exceed. If there is a scientific basis for raising those minimum standards based on a scientific determination that water quality needs to be improved, then so be it. Whether old units should then be grandfathered or not, or under what circumstances, should be responsibly weighed. This happens all the time in countless areas of govt. regulation. Or do you believe you're the first one to address this and have the expertise?

You do appreciate that the way shellfish feed is the reverse of dilution; they concentrate whatever's in the water, even in trace amounts, right?

Thanks, but I do get the importance of restoring the oyster population, along with other creatures which will help restore a healthier balance to depleted areas such as the Chesapeake Bay. If you've ever spent time sailing there it's hard not to.

You've said, more than once, that NDZs were not created for demonstrated ecological reasons, and that banning discharge from a type 1 or 2 MSD would lead to more ecological harm through non-compliance. I can dredge the quotes up, if I must...

Dredge away if you'd like with your usual truncated, parsed, and misleading characterizations of posters' comments so you can label them as opponents of good environmental stewardship, Trump supporters, or whatever nonsense suits your personal need for political partisanship. What I've said is that NDZs were created ostensibly for ecological reasons, which in some smaller/confined areas, or areas with particular sensitivities, are amply justified by the science. But in large bodies of water which comprise many boaters entire cruising areas they don't seem scientifically justified, as least as applied to small recreational vessels with Type 1's & 2's. Large passenger cruise ships are obviously a different story, but do I really need to say that?? I've also said that this type of overreach will logically & likely discourage the use of onboard treatment systems which have already been approved and should instead be encouraged. My comments, echoed by many others, seem to have been endorsed by the EPA in addressing concerns over NDZs in Calif. per Gord's link. The bottom line is that you haven't been able to produce any credible, non-partisan scientific evidence that small vessel discharge is materially contributing to water pollution. The rest of your incessant banter has been just that.

Oh, ffs. Another for you. I am interested in these issues, and I've had some involvement in the recreational marine industry. I also suspect that I sail more often, in more and different places, than many on CF. Just sayin.

Just sayin' what? What you are saying in your posts suggest a consistent lack of knowledge, experience, and aptitude for the issues presented in this thread. Read the entirety of Gord's link to the EPA decision in Calif. The law requires science not emotion in fashioning rules & regs.

Wow. You really, really do hate anything to do with the environment.

Look, you've clung faithfully to your macerated version of that Tom Neale rant for the whole thread. Full marks for consistency. But that rant itself wasn't terribly cohesive, and it's over 8 years old. Things change, we learn new stuff, standards get raised.

Anyway, I don't know why you're so unhappy. You have an administration whose position on the environment and its advocates seems very closely aligned with your own. Have faith that they'll find some way to stop or unwind any recent water protection measures.

At this point I don't even remember the Tom Neale comment, but I also don't recall it being a "rant." You are the only one injecting political partisanship into this issue, probably because for most the only politics involved is how such large bodies of inland waters get designated NDZs without adequate scientific support. I certainly don't see the issue as partisan, fully endorse most maritime rules & regs, and have undergone much time & expense insuring that my boat's two heads have state-of-the-art holding tank systems which fully comply with the law. So with my Type 3's, I really don't have a personal dog in this fight, but then neither do you. But speaking out about what seems like the application of an unfair, illogical, and counterproductive regulation doesn't & shouldn't make me anything other than a responsible boater.

[Lake-Effect]

Originally Posted by Exile

the only politics involved is how such large bodies of inland waters get designated NDZs without adequate scientific support.

And there's that unsubstantiated claim AGAIN, mere inches from where you assure us that you haven't said that.


Can you name ONE NDZ that you think has no scientific support?

[Exile]

Originally Posted by Lake-Effect

If there's a genuine reason for reducing discharge in an area, it should be applied to all boats; that's only fair. Starting from that point, then you can consider grounds for exemption.

Unless the increased discharge is primarily due to the growth in the cruise ship industry frequenting the area, as was the case in Calif. coastal waters. What's "fair" should be based on what's mainly responsible for the pollution since that's what the law is primarily intended to correct.

Complying once with a 40 year old spec isn't a compelling reason, if the area is truly sensitive to discharge.

Unless that 40 year-old spec still meets EPA standards.

[Exile]

Originally Posted by Lake-Effect

And there's that unsubstantiated claim AGAIN, mere inches from where you assure us that you haven't said that.


Can you name ONE NDZ that you think has no scientific support?

Nice try, but the statute & regs clearly puts the burden of demonstrating scientific justification on the proponent of the NDZ. And with the EPA ruling in Calif. determining that small vessels with Type 1's & 2's don't warrant being included in the coastal NDZ (they are included on inland lakes, etc.), that burden now seems higher. But I'll check it out since you apparently don't want to.

[Exile]

Originally Posted by Pelagic

The Superyacht industry has been leading the charge on large treatment systems.

They have the money, their actions are scrutinized closely by the media and of course most billionaires believe that their sh** don't stink! [emoji2]

I have been specifying the best systems for 50m+ yachts since the 1990's and the systems keep getting better.
But it is a complicated process that involves training and monitoring the hotel department on cleaning products to use and the engineering on managing heavy loads from a day cruise with 100 on board.

This article explains the challenges and solutions and is keyed to International standards that most Super yachts far exceed by discharging only treated black and grey water

Inland or at large marinas, the easiest solution is pump out to trucks or barges for local disposal.
Here in Subic Philippines, that is what the US Navy do when in a foreign port.

https://superyachttechnology.com/201...hats-solution/

Makes a lot more sense in a busy port, and with large, professionally run inspected vessels.

[Lake-Effect]

Originally Posted by Exile

Unless that 40 year-old spec still meets ONE 40 yr old EPA standard, which may have subsequently proven insufficient for certain situations.

Fixed it for ya.

[Exile]

Originally Posted by Lake-Effect

Fixed it for ya.

The system should meet whatever the current EPA standard is, or be legally grandfathered (if applicable). I think you're a little confused about this area.

[Lake-Effect]

Originally Posted by Exile

...And with the EPA ruling in Calif. determining that small vessels with Type 1's & 2's don't warrant being included in the coastal NDZ (they are included on inland lakes, etc.), that burden now seems higher.

Justifying the inclusion of ONE small subset of all boats in a NDZ reg is not the same thing as "how such large bodies of inland waters get designated NDZs without adequate scientific support". (eg how the NDZ came to be)

[Exile]

Originally Posted by Lake-Effect

Justifying the inclusion of ONE small subset of all boats in a NDZ reg is not the same thing as "how such large bodies of inland waters get designated NDZs without adequate scientific support". (eg how the NDZ came to be)

Parse all you want. With the exception of the coastal Calif. NDZ, I don't know what the principal target of the NDZs are or were, only that in the large bodies of water at issue here small recreational vessels with approved Type 1's & 2's were not exempted (i.e. they are prohibited from discharging treated waste). AFAIK that's still the case.

I don't think there's a whole lot of pushback around here from regs requiring cruise ships to dump offshore before they enter inland waters. There are ways to accomplish that without targeting small vessels which don't contribute appreciably to water pollution. So how about we don't waste time red herring yet another one of your strawmen?

I did a search on the Federal register for the RI NDZ but have thus far struck out. I'll look again later when I have more time. Maybe Gord can help.

[Exile]

Originally Posted by Lake-Effect

Justifying the inclusion of ONE small subset of all boats in a NDZ reg is not the same thing as "how such large bodies of inland waters get designated NDZs without adequate scientific support". (eg how the NDZ came to be)

In the meantime, you sure you really want to go down what may well be another rabbit hole? Maybe worth repeating from the EPA ruling in CA:

"The information obtained by EPA did not show that extension of the rule to all vessels was required to protect and enhance the quality of the State's waters. The commenters also did not provide information which shows that it is necessary to include these other classes of vessels within the scope of the rule to protect and enhance the quality of these waters."

The EPA decision included a lot of language recognizing the sensitivity of coastal CA waters deserving of protection. So unless there's something more sensitive or unique to the waters of Puget Sound, Narragansett Bay, etc., etc., I would imagine this precedent would create a higher burden. Not necessarily on the establishment of the NDZ if otherwise justified, but on its inclusion of small vessels. That's what this thread is about after all.

[Lake-Effect]

Originally Posted by Exile

In the meantime, you sure you really want to go down what may well be another rabbit hole? Maybe worth repeating from the EPA ruling in CA:

"The information obtained by EPA did not show that extension of the rule to all vessels was required to protect and enhance the quality of the State's waters. The commenters also did not provide information which shows that it is necessary to include these other classes of vessels within the scope of the rule to protect and enhance the quality of these waters."

The EPA decision included a lot of language recognizing the sensitivity of coastal CA waters deserving of protection. So unless there's something more sensitive or unique to the waters of Puget Sound, Narragansett Bay, etc., etc., I would imagine this precedent would create a higher burden. Not necessarily on the establishment of the NDZ if otherwise justified, but on its inclusion of small vessels. That's what this thread is about after all.

Well, first we cleared up your little misunderstanding of "how such large bodies of inland waters get designated NDZs without adequate scientific support"... an assertion that is far from proven,...when you apparently just meant "where is the justification for including recreational boats with type 1 or 2 MSDs". You're welcome. With this new understanding we can move forward.