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TWL: Discharge in the Keys

MK
M. Kenneth McQuage
Thu, Jun 27, 2002 4:28 AM

Dick and Keith ,

   I fully agree that the actions of the EPA bureaucrats in DC seem to

reflect an uninformed  attitude toward the contribution of polution , of
both air and water  - by boaters .Further ,  That boat owners are easy
targets since we lack an organized or cordinated response  to enlighten our
politicians and protect our interests .

   ( Though I disagree with several of their positions - I admire the

professional capabilities of the NRA in this reguard - which is both a
National, Regional and  intensely Local - response capability )

Unfortunately these EPA blunders seem to have had the affect of setting

boaters to bickering between ourselves  about the unfairness of it all -
rather than directing our collective ire in any productive way .

 ( One of the definations of Bitching - is to complain ineffectively -

and we, I believe we are caught up in that process - a total waste of time )

The Tragic Comic  Theater of  Meaningful Government Antipolution
Inaction - in the arena of regulation enforcement of large scale industrial,
mining , energy generation etc  and municipal  sewage poluters - I expect to
continue unless and until Local and National  politicians feel their own re
election compromised .

It would seem however that the reporting of the continuing

effects of polution by Newspapers is not enough to raise the public ire
enough to accomplish this - and the rest of the medias local and nationals
eposodic expose approach is likewise ineffective - in spite of the very real
negative public  health effects which are well documentated .

 I have an elec san - and have written letters of support of the Saxton

bill to my reps - ane sincerely  hope that ALL members of the TWL have done
the same . whether this will accomplish anything - darn if I know - but it
is better than Bitching about it :)

All the Best
     Ken
Dick and Keith , I fully agree that the actions of the EPA bureaucrats in DC seem to reflect an uninformed attitude toward the contribution of polution , of both air and water - by boaters .Further , That boat owners are easy targets since we lack an organized or cordinated response to enlighten our politicians and protect our interests . ( Though I disagree with several of their positions - I admire the professional capabilities of the NRA in this reguard - which is both a National, Regional and intensely Local - response capability ) Unfortunately these EPA blunders seem to have had the affect of setting boaters to bickering between ourselves about the unfairness of it all - rather than directing our collective ire in any productive way . ( One of the definations of Bitching - is to complain ineffectively - and we, I believe we are caught up in that process - a total waste of time ) The Tragic Comic Theater of Meaningful Government Antipolution Inaction - in the arena of regulation enforcement of large scale industrial, mining , energy generation etc and municipal sewage poluters - I expect to continue unless and until Local and National politicians feel their own re election compromised . It would seem however that the reporting of the continuing effects of polution by Newspapers is not enough to raise the public ire enough to accomplish this - and the rest of the medias local and nationals eposodic expose approach is likewise ineffective - in spite of the very real negative public health effects which are well documentated . I have an elec san - and have written letters of support of the Saxton bill to my reps - ane sincerely hope that ALL members of the TWL have done the same . whether this will accomplish anything - darn if I know - but it is better than Bitching about it :) All the Best Ken
K
Keith
Thu, Jun 27, 2002 1:48 PM

Well, I'd agree that most regulatory agencies would opt for the "easy"
solution.
On the practical side, how DO they enforce a NDZ? Board a boat to see
how it's set up? If so, seems just as easy to verify a type I or II MSD
as to verify a holding tank. If you're going to verify that a discharge
seacock is locked closed, again, you can also verify the onboard MSD.
Same with plugging a through-hull. Simply saying "no one can discharge
in this area" isn't going to be effective, and can actually be counter
productive. I strongly believe that if Type I&II MSD's were allowed to
be used in these NDZ, more people would use them, and the manufacturers
would have an incentive to make lower cost and more effective models.
The more NDZ's that come into being, the less attractive the Type I&II
MSD's will be. I hate to think of the long term consequences of that.

Gregory Nicholls wrote:

"M. Kenneth McQuage" wrote:

Dick and Keith ,

    I fully agree that the actions of the EPA bureaucrats in DC seem to

reflect an uninformed  attitude toward the contribution of polution , of
both air and water  - by boaters .Further ,  That boat owners are easy
targets since we lack an organized or cordinated response  to enlighten our
politicians and protect our interests .

 The attitude isn't uninformed it's simply easier to implement a total ban

than make exceptions for properly equipped boats. There's also the realisation
that properly equipped boats are in the minority. The only other alternative
would be to require all boats to be fitted with proper MSD's. Unrealistic
really.
I mean think about it in terms of flying. Would you fly commercial if an
airplane's nav system could really be screwed up by a walkman ?? Same thing.
It's easier to implement a total ban than one with caveats and exceptions.
G.


http://lists.samurai.com/mailman/listinfo/trawler-world-list

--


Keith
Dogs have owners; Cats have staff.

Well, I'd agree that most regulatory agencies would opt for the "easy" solution. On the practical side, how DO they enforce a NDZ? Board a boat to see how it's set up? If so, seems just as easy to verify a type I or II MSD as to verify a holding tank. If you're going to verify that a discharge seacock is locked closed, again, you can also verify the onboard MSD. Same with plugging a through-hull. Simply saying "no one can discharge in this area" isn't going to be effective, and can actually be counter productive. I strongly believe that if Type I&II MSD's were allowed to be used in these NDZ, more people would use them, and the manufacturers would have an incentive to make lower cost and more effective models. The more NDZ's that come into being, the less attractive the Type I&II MSD's will be. I hate to think of the long term consequences of that. Gregory Nicholls wrote: > > "M. Kenneth McQuage" wrote: > > > Dick and Keith , > > > > I fully agree that the actions of the EPA bureaucrats in DC seem to > > reflect an uninformed attitude toward the contribution of polution , of > > both air and water - by boaters .Further , That boat owners are easy > > targets since we lack an organized or cordinated response to enlighten our > > politicians and protect our interests . > > The attitude isn't uninformed it's simply easier to implement a total ban > than make exceptions for properly equipped boats. There's also the realisation > that properly equipped boats are in the minority. The only other alternative > would be to require _all_ boats to be fitted with proper MSD's. Unrealistic > really. > I mean think about it in terms of flying. Would you fly commercial if an > airplane's nav system could _really_ be screwed up by a walkman ?? Same thing. > It's easier to implement a total ban than one with caveats and exceptions. > G. > _______________________________________________ > http://lists.samurai.com/mailman/listinfo/trawler-world-list -- __________________ Keith Dogs have owners; Cats have staff.
GN
Gregory Nicholls
Thu, Jun 27, 2002 3:08 PM

"M. Kenneth McQuage" wrote:

Dick and Keith ,

    I fully agree that the actions of the EPA bureaucrats in DC seem to

reflect an uninformed  attitude toward the contribution of polution , of
both air and water  - by boaters .Further ,  That boat owners are easy
targets since we lack an organized or cordinated response  to enlighten our
politicians and protect our interests .

The attitude isn't uninformed it's simply easier to implement a total ban

than make exceptions for properly equipped boats. There's also the realisation
that properly equipped boats are in the minority. The only other alternative
would be to require all boats to be fitted with proper MSD's. Unrealistic
really.
I mean think about it in terms of flying. Would you fly commercial if an
airplane's nav system could really be screwed up by a walkman ?? Same thing.
It's easier to implement a total ban than one with caveats and exceptions.
G.

"M. Kenneth McQuage" wrote: > Dick and Keith , > > I fully agree that the actions of the EPA bureaucrats in DC seem to > reflect an uninformed attitude toward the contribution of polution , of > both air and water - by boaters .Further , That boat owners are easy > targets since we lack an organized or cordinated response to enlighten our > politicians and protect our interests . The attitude isn't uninformed it's simply easier to implement a total ban than make exceptions for properly equipped boats. There's also the realisation that properly equipped boats are in the minority. The only other alternative would be to require _all_ boats to be fitted with proper MSD's. Unrealistic really. I mean think about it in terms of flying. Would you fly commercial if an airplane's nav system could _really_ be screwed up by a walkman ?? Same thing. It's easier to implement a total ban than one with caveats and exceptions. G.
MK
M. Kenneth McQuage
Thu, Jun 27, 2002 3:39 PM
 The attitude isn't uninformed it's simply easier to implement a total

ban

than make exceptions for properly equipped boats.

Hi Greg,

    As I recall the EPA plan for improvement of Air Quality in the

Washington DC regional area initially included severe , but not total ,
restrictions on recreational boating on the Patomac River in the D.C. area -
complete with projections of how many tons of air pulutants from the ditry
exhausts of boats these restrictions would  save .

     The EPA Bureaucrats were most embarrased when informed of  the

reality that - there is only a negligable amount of recreational boating  in
that area - and that entire section was deleted  without comment - but
deserving on the singular comment of  Duh !

Reality checks do not seem to be the forte of Bureaucrats - of any

stripe - EPA or Otherwise - but then the entertainment of the governed is
one of the major functions of government !

All the Best
Ken

> The attitude isn't uninformed it's simply easier to implement a total ban > than make exceptions for properly equipped boats. Hi Greg, As I recall the EPA plan for improvement of Air Quality in the Washington DC regional area initially included severe , but not total , restrictions on recreational boating on the Patomac River in the D.C. area - complete with projections of how many tons of air pulutants from the ditry exhausts of boats these restrictions would save . The EPA Bureaucrats were most embarrased when informed of the reality that - there is only a negligable amount of recreational boating in that area - and that entire section was deleted without comment - but deserving on the singular comment of Duh ! Reality checks do not seem to be the forte of Bureaucrats - of any stripe - EPA or Otherwise - but then the entertainment of the governed is one of the major functions of government ! All the Best Ken
RB
Robert Bryett
Fri, Jun 28, 2002 12:50 AM

On the practical side, how DO they enforce a NDZ? Board a boat to see

how it's set up? If so, seems just as easy to verify a type I or II MSD as
to verify a holding tank. If you're going to verify that a discharge seacock
is locked closed, again, you can also verify the onboard MSD.<<<<

Just how easy would it to be to "verify" an MSD? Indeed what would it mean?
Just checking that it's there?

As I understand it from reading Peggy Hall's web site, your type I and II
MSD units are certified in prototype only. I take that to mean that at some
time prototype devices are tested at the factory, pass the test and then the
manufacturer is allowed to put a sticker on the device proclaiming that it
is an approved MSD. The presence of the sticker doesn't mean that any
particular MSD unit installed in any specific boat still meets (or ever
met), the certification criteria.

I believe the standards MSD units are supposed to meet include ensuring that
the effluent they produce contains no more than specified concentrations of
bacteria. Wouldn't adequate enforcement of MSD performance involve carrying
round Petri dishes or microscopes or something? By contrast enforcing a NDZ
would presumably only involve inspecting pipes and valves which could be
done by eyeball, or with the assistance of some flouricine dye.

A while ago someone was circulating an e-mail exhorting the list membership
to support the "Saxton Bill". I was extremely dubious about a number of the
arguments it contained, but I kept quiet, because it's a US issue, and I'm
sure you Yanks don't want some bloody Aussie minding your business. However
these arguments included this same unexamined assumption, that MSD
enforcement would be at least no more difficult or onerous than NDZ
enforcement.

Sydney Harbour is an NDZ by the way.

Regards, Robert Bryett
Sydney, Australia.
mailto:rbryett@mail.com

>>>>On the practical side, how DO they enforce a NDZ? Board a boat to see how it's set up? If so, seems just as easy to verify a type I or II MSD as to verify a holding tank. If you're going to verify that a discharge seacock is locked closed, again, you can also verify the onboard MSD.<<<< Just how easy would it to be to "verify" an MSD? Indeed what would it mean? Just checking that it's there? As I understand it from reading Peggy Hall's web site, your type I and II MSD units are certified in prototype only. I take that to mean that at some time prototype devices are tested at the factory, pass the test and then the manufacturer is allowed to put a sticker on the device proclaiming that it is an approved MSD. The presence of the sticker doesn't mean that any particular MSD unit installed in any specific boat still meets (or ever met), the certification criteria. I believe the standards MSD units are supposed to meet include ensuring that the effluent they produce contains no more than specified concentrations of bacteria. Wouldn't adequate enforcement of MSD performance involve carrying round Petri dishes or microscopes or something? By contrast enforcing a NDZ would presumably only involve inspecting pipes and valves which could be done by eyeball, or with the assistance of some flouricine dye. A while ago someone was circulating an e-mail exhorting the list membership to support the "Saxton Bill". I was extremely dubious about a number of the arguments it contained, but I kept quiet, because it's a US issue, and I'm sure you Yanks don't want some bloody Aussie minding your business. However these arguments included this same unexamined assumption, that MSD enforcement would be at least no more difficult or onerous than NDZ enforcement. Sydney Harbour is an NDZ by the way. Regards, Robert Bryett Sydney, Australia. mailto:rbryett@mail.com
A
ancora
Fri, Jun 28, 2002 3:34 PM

In Avalon Harbor on Catalina Island, the "poop police" board your vessel and
place dye tablets in all your heads. If you discharge into the harbor, your
vessel becomes encircled by a halo of bright red. This causes the poop cops
to board with pencils and ticket books, not the way to enjoy a week-end.

                                    Ralph Salerno
                                    M/V ANCORA

"May the farce be with you!"

In Avalon Harbor on Catalina Island, the "poop police" board your vessel and place dye tablets in all your heads. If you discharge into the harbor, your vessel becomes encircled by a halo of bright red. This causes the poop cops to board with pencils and ticket books, not the way to enjoy a week-end. Ralph Salerno M/V ANCORA "May the farce be with you!"
AW
Andy Woods
Fri, Jun 28, 2002 11:25 PM

On the practical side, how DO they enforce a NDZ? Board a boat to see

how it's set up? If so, seems just as easy to verify a type I or II MSD as
to verify a holding tank. If you're going to verify that a discharge

seacock

is locked closed, again, you can also verify the onboard MSD.<<<<

Just how easy would it to be to "verify" an MSD? Indeed what would it

mean?

Just checking that it's there?

When we bought our boat the forward head had a LectraSan control unit on the
bulkhead behind the toilet.  It was powered up and looked operational.
Further investigation revealed the rest of the system was missing!  The
toilet was plumbed into a holding tank, and the holding tank was plumbed
directly overboard.  There was no deck pump out.

I don't think this was an intentional effort to deceive anyone.  The PO did
most of his cruising in the ocean so pumping overboard was legal.  I think
the system failed and he simply removed it and installed the holding tank.
The control unit was  just never removed.

I pass this along just to illustrate that this looked like a proper MSD.
Unless you looked further and knew what you were looking at, you could be
fooled.

A while ago someone was circulating an e-mail exhorting the list

membership

to support the "Saxton Bill". I was extremely dubious about a number of

the

arguments it contained, but I kept quiet, because it's a US issue, and I'm
sure you Yanks don't want some bloody Aussie minding your business.

However

these arguments included this same unexamined assumption, that MSD
enforcement would be at least no more difficult or onerous than NDZ
enforcement.

I must admit I wasn't real interested in the Saxton Bill until this thread
came along, and I am not totally educated in the issues.  Mainly because I
do not have a Type I or Type II MSD and I must pump out.  I personally think
the NDZ is a good idea.  I don't want to see waste floating around the
harbor whether it's treated or not.    Seems to me it would be better to put
pressure on the government to change the rules about pumpout grants and make
sure the pumpouts are working and accessible.

Regards,

Andy

Andy & Linda Woods
Grand Folly
1970 Grand Banks 36 Classic
Georgetown, MD
awoods@surfbest.net

> >>>>On the practical side, how DO they enforce a NDZ? Board a boat to see > how it's set up? If so, seems just as easy to verify a type I or II MSD as > to verify a holding tank. If you're going to verify that a discharge seacock > is locked closed, again, you can also verify the onboard MSD.<<<< > Just how easy would it to be to "verify" an MSD? Indeed what would it mean? > Just checking that it's there? When we bought our boat the forward head had a LectraSan control unit on the bulkhead behind the toilet. It was powered up and looked operational. Further investigation revealed the rest of the system was missing! The toilet was plumbed into a holding tank, and the holding tank was plumbed directly overboard. There was no deck pump out. I don't think this was an intentional effort to deceive anyone. The PO did most of his cruising in the ocean so pumping overboard was legal. I think the system failed and he simply removed it and installed the holding tank. The control unit was just never removed. I pass this along just to illustrate that this looked like a proper MSD. Unless you looked further and knew what you were looking at, you could be fooled. > A while ago someone was circulating an e-mail exhorting the list membership > to support the "Saxton Bill". I was extremely dubious about a number of the > arguments it contained, but I kept quiet, because it's a US issue, and I'm > sure you Yanks don't want some bloody Aussie minding your business. However > these arguments included this same unexamined assumption, that MSD > enforcement would be at least no more difficult or onerous than NDZ > enforcement. I must admit I wasn't real interested in the Saxton Bill until this thread came along, and I am not totally educated in the issues. Mainly because I do not have a Type I or Type II MSD and I must pump out. I personally think the NDZ is a good idea. I don't want to see waste floating around the harbor whether it's treated or not. Seems to me it would be better to put pressure on the government to change the rules about pumpout grants and make sure the pumpouts are working and accessible. Regards, Andy Andy & Linda Woods Grand Folly 1970 Grand Banks 36 Classic Georgetown, MD awoods@surfbest.net
MM
Michael Maurice
Sat, Jun 29, 2002 12:58 AM

At 07:25 PM 6/28/02, you wrote:

When we bought our boat the forward head had a LectraSan control unit on the
bulkhead behind the toilet.  It was powered up and looked operational.
Further investigation revealed the rest of the system was missing!  The
toilet was plumbed into a holding tank, and the holding tank was plumbed
directly overboard.  There was no deck pump out.

The last boat, a 37 footer with LectraSan. Found out after getting down the
coast that the LectraSan part wasn't working. Seems the boat had a
VacuFlush unit, which uses fresh water. The Lectra San requires salt water
or a separate salt pump unit to put salt into the system. This boat did not
have the salt unit. It would seem the LectraSan could be operating
properly. There was also a low voltage issue which has not been taken care
of even yet. But at least the system was set up to be dumped into the
holding tank.
Just when you think it is safe to go out on the water.

Capt. Mike Maurice
Near Portland Oregon.

At 07:25 PM 6/28/02, you wrote: >When we bought our boat the forward head had a LectraSan control unit on the >bulkhead behind the toilet. It was powered up and looked operational. >Further investigation revealed the rest of the system was missing! The >toilet was plumbed into a holding tank, and the holding tank was plumbed >directly overboard. There was no deck pump out. The last boat, a 37 footer with LectraSan. Found out after getting down the coast that the LectraSan part wasn't working. Seems the boat had a VacuFlush unit, which uses fresh water. The Lectra San requires salt water or a separate salt pump unit to put salt into the system. This boat did not have the salt unit. It would seem the LectraSan could be operating properly. There was also a low voltage issue which has not been taken care of even yet. But at least the system was set up to be dumped into the holding tank. Just when you think it is safe to go out on the water. Capt. Mike Maurice Near Portland Oregon.
RB
Robert Bryett
Sat, Jun 29, 2002 6:18 AM

In Avalon Harbor on Catalina Island, the "poop police" board your vessel

and place dye tablets in all your heads. If you discharge into the harbor,
your vessel becomes encircled by a halo of bright red. This causes the poop
cops to board with pencils and ticket books, not the way to enjoy a
week-end.<<<<

That's rather the point I was trying to make. NDZ enforcement involves a
fairly simple judgement:

IF anything is discharged at all THEN you're nicked!

Presumably "Saxton Bill" type enforcement would go:

IF anything is discharged AND the discharge fails to meet effluent standards
THEN you're nicked!

I don't see how effluent quality assessment could be made all that quick or
easy. How would the Poo Patrol take a sample (eeeew!), especially if the MSD
outlet was underwater? Then, how would they test it? I'm not a
bacteriologist so I don't know - mobile lab maybe?

Regards, Robert Bryett
Sydney, Australia.
mailto:rbryett@mail.com

>>>>In Avalon Harbor on Catalina Island, the "poop police" board your vessel and place dye tablets in all your heads. If you discharge into the harbor, your vessel becomes encircled by a halo of bright red. This causes the poop cops to board with pencils and ticket books, not the way to enjoy a week-end.<<<< That's rather the point I was trying to make. NDZ enforcement involves a fairly simple judgement: IF anything is discharged at all THEN you're nicked! Presumably "Saxton Bill" type enforcement would go: IF anything is discharged AND the discharge fails to meet effluent standards THEN you're nicked! I don't see how effluent quality assessment could be made all that quick or easy. How would the Poo Patrol take a sample (eeeew!), especially if the MSD outlet was underwater? Then, how would they test it? I'm not a bacteriologist so I don't know - mobile lab maybe? Regards, Robert Bryett Sydney, Australia. mailto:rbryett@mail.com
BR
Bob Richards
Sat, Jun 29, 2002 4:37 PM

Hi All:

I have been following this thread keenly. Tamara B is in the yard having
major re-fit work done. We have intentionally NOT addressed the heads
(2) situation because of the uncertainty about the future regulations.

Tamara B currently has 2 X 40g  holding tanks, one for each head. There
is NO pumpout facility as such, there are 2 "pump out" pumps which
discharge the holding tanks to the sea. The current plan is to just pass
the 3 mile line once a week, and clear the tanks (we will be full-time
live-aboards, and on-the-go almost constantly).

If TypeII MSD's were legal, I would install them between the head and
the holding tanks; but the legality of this setup seems to be spotty and
uncertain at best.

Given what has been reported here and elsewhere about the availability
and condition of "pumpout" facilities, it seems a waste of time and
money to even have external pumpout hoses and deck fittings installed!

Our intended range of operation is from Main, the east-coast, the
Caribbean, Central and South America.

Questions....

  1. Will Tamara B's setup present a legal problem within her intended
    cruising range?

  2. Will the lack of dock-side pumpout facilities be viewed as
    non-compliance with current standards?

  3. Is the "3-mile" line rule  pretty much standard within her range?

  4. Since Tamara B was built in 1979, is there some "grandfathering" with
    regard to the rules?

Regards
Bob

--


m/v Tamara B. Cape Elizebeth Me. http://www.tamara-b.org
kelly@tamara-b.org bob@tamara-b.org

Hi All: I have been following this thread keenly. Tamara B is in the yard having major re-fit work done. We have intentionally NOT addressed the heads (2) situation because of the uncertainty about the future regulations. Tamara B currently has 2 X 40g holding tanks, one for each head. There is NO pumpout facility as such, there are 2 "pump out" pumps which discharge the holding tanks to the sea. The current plan is to just pass the 3 mile line once a week, and clear the tanks (we will be full-time live-aboards, and on-the-go almost constantly). If TypeII MSD's were legal, I would install them between the head and the holding tanks; but the legality of this setup seems to be spotty and uncertain at best. Given what has been reported here and elsewhere about the availability and condition of "pumpout" facilities, it seems a waste of time and money to even have external pumpout hoses and deck fittings installed! Our intended range of operation is from Main, the east-coast, the Caribbean, Central and South America. Questions.... 1) Will Tamara B's setup present a legal problem within her intended cruising range? 2) Will the lack of dock-side pumpout facilities be viewed as non-compliance with current standards? 3) Is the "3-mile" line rule pretty much standard within her range? 4) Since Tamara B was built in 1979, is there some "grandfathering" with regard to the rules? Regards Bob -- --------------------------------------------------------- m/v Tamara B. Cape Elizebeth Me. http://www.tamara-b.org kelly@tamara-b.org bob@tamara-b.org ---------------------------------------------------------