What is the No Discharge Zone Petition?
The Department of Ecology is considering petitioning the Federal EPA to designate Puget Sound as a No Discharge Zone (NDZ) for sewage from boats. Ecology is asking for public comments until April 21, 2014, to get details on the subject take a look at Ecology’s NDZ webpage at : http://www.ecy.wa.gov/programs/wq/nonpoint/CleanBoating/nodischargezone.html. For those of you that want lots of detail, this webpage also has links to the supporting information developed by a consultant to Ecology that include details on the water quality condition in Puget Sound, the costs and benefits, a survey of boaters and information on pump out stations.
This would prohibit the discharge of toilet waste, either treated or untreated, within three miles from shore (WA State waters). This would include all of Puget Sound inside of line in the eastern Strait of Juan de Fuca between New Dungeness Light on the Olympic Peninsula and Discovery Island Light near Victoria. See the attached map. This includes treated waste from Marine Sanitation Devices (MSDs) and (as is the case already) untreated sewage directly from a head or from a holding tank.
This only covers discharge from toilets, MSDs and holding tanks for toilet waste, i.e. blackwater. Graywater, waste from sinks and showers is not included in the NDZ.
Why is it happening?
First of all, is this a new idea unique to Puget Sound? In general no, there are over 80 similar NDZs, mostly on the East Coast, although California has just approved a NDZ for all California coastal waters, but only for commercial vessels. Some of the East Coast areas include most of Long Island Sound in both New York and Rhode Island, Nantucket Sound, most of the Florida Keys, Barnegat Bay, and a number of large lakes.
While the open waters of Puget Sound generally have good water quality, this is not the case for many bays and restricted areas such as southern Puget Sound, Liberty Bay, Dyes Inlet, parts of Hood Canal and many beaches in urban areas. Pollutants of major concern in these areas are fecal colifom bacteria from human and animal sources, excess nutrients, mostly nitrogen based nutrients such as nitrate and ammonia and toxic chemicals. All of these pollutants are found in sewage waste, often even after treatment from MSDs.
As a part of the long standing efforts by Ecology, the EPA and many counties, cities and towns around Puget Sound to clean up Puget Sound by focusing on wastewater discharges, stormwater discharges, toxic sediments and spills; this NDZ is just another step in tightening up on how we all treat the Sound.
The major resources that need protecting are also important to us as boaters, mostly safe swimming, clam and oyster harvesting and fishing. For many of us, these are important reasons that we own a boat.
Does it make any difference to me?
Whether this will make any difference to you depends on your boat and where you use it.
You won’t be affected:
–If you have a small boat with no toilet facilities.
–If you have a porti potty and dispose of the waste at a pump out or into the sewer system on land.
–If you have a toilet and have a holding tank (the holding tank is considered a Type III MSD) and you use pump out stations now.
–If you spend most of your boating time outside of the NDZ zone, i.e the western Strait of Juan de Fuca or the outer Washington Coast.
–If you have a MSD Type I or II and a holding tank. The Type I and II MSD’s treat the waste. You already pump out the holding tank.
You will be affected:
–If you have an Type I or II MSD and no holding tank
–If you have a toilet and a holding tank but usually empty your holding tank untreated into the Sound.
–If you have a toilet and no holding tank, (this is not legal already and every boat manufactured in the US since 1978 was required to have a holding tank if it had a toilet installed )
Why aren’t the Type I and II MSDs good enough?
There have been a number of studies on MSD treatment effectiveness, Ecology quotes a recent EPA study, http://water.epa.gov/polwaste/vwd/upload/Type-I-MSDs-2010-Report.pdf, this study tested Type I MSDs and found that they were inconsistent in their treatment effectiveness.
How about cruising to Canada and Alaska?
Canada has similar NDZs for many areas in the inside passage, but fewer pumpout stations for the huge area of marine waters as compared to Puget Sound, but its also easier to get farther than 3 miles from land. An interesting note is that if you are discharging in BC outside of three miles you need to be running your vessel at a normal cruising speed to dilute the waste.
The situation in Alaska is similar to the regulations at present in Washington, you must have a holding tank if you have a toilet and need to pump out the holding tank or discharge greater than 3 miles from land, or use a Type I or Type II MSD.
Will this NDZ help Puget Sound? Why should I make the required changes by either adding a holding tank and always using pump out facilities?
There are many sources of fecal bacteria, nutrients and toxics chemicals flowing into Puget Sound that are greater than boater’s waste, so why should they pick on us? First of all, they aren’t picking only on us, the other sources of municipal waste, stormwater, septic tanks, industrial waste and agriculture have been under the enforcement pressure for much longer; our boater input may often be small but we need to do our part. That said, the contribution of boaters isn’t always small, fecal bacteria is elevated around marinas and in small bays with many occupied recreation boats. These are often just the areas where boaters and others want to swim, dig shellfish and fish. We really can make a difference.
Next there is the yuck factor, even though you might resent having to change your sewage discharge habits, the idea of somebody else’s boat that is anchored next to you at Sucia pumping out their raw or poorly treated sewage into the water where you want to swim and dig clams is disgusting and may be a danger to your health. You may not appreciate having the government telling you what to do on your boat, but you sure want them to tell the other guys in the bay what to do with their waste.
So if the real problem with boat waste is in the restricted bays, in marinas and on the beaches, why not let us pump in the open waters and use the holding tank in the problem areas ?
That makes good sense from a basic point of view, but there are two problems, The first is that the tide can carry waste from open Puget Sound onto a beach or a sensitive bay before the waste has a chance to disperse or degrade. We have all seen how a tide line will concentrate junk on the surface and move quickly with the tide and not disperse, this would also go for raw sewage. The second practical problem is enforcement, it would be very difficult to see the position of boat’s waste valves in different places in the Sound, none of us want that kind of on the water police.
How about cruise ships ?
The big cruise ships have much more sophisticated sewage treatment plants and they have voluntarily agreed to use the shoreside sewer systems when docked and not to discharge their treated water in the NDZ.
The details of enforcement and fines haven’t been worked out according to the petition to the EPA, but a combination of Coast Guard, harbormasters, fish and wildlife agents and health officials could be involved. Department of Ecology’s desire would be to have any fine proceeds be designated for water quality efforts.
Probably if you are inspected within the NDZ having the overboard discharge valve secured with a cable tie or wire or removing the seacock handle would be adequate to prove compliance.
Can I comment ?
Go to the Ecology website at http://www.ecy.wa.gov/programs/wq/nonpoint/CleanBoating/nodischargezone.html or just email Amy Jankowiak at email@example.com before April 21.
I think this proposal is a good idea. Although it will require little or no additional investment for most of us that have holding tanks, and it is a reminder that we all need to do our small part and get in the habit of going to pump out stations. If your regular marina or fuel dock has no pump out, ask them to put one in, you might stop by more often to buy gas and groceries.
In some ways it is analogous to littering – we no longer feel that it is acceptable to throw trash into Puget Sound. The same should be true of sewage, especially since it is often more damaging to the Sound although less visible.
The proposal is more burdensome on owners of larger vessels with the Type I and II MSDs that will need to add a holding tank and pumpout, but it usually isn’t too much investment to plumb in a holding tank for these vessels and the higher number of passengers on these boats means that they are often discharging more waste per boat, especially if their unit isn’t effective. We hold our municipal sewage plants to a higher standard that are discharging in to the same waters, unless these MSDs can guarantee the same level of treatment and be inspected for performance they should use a holding tank like the rest of us.
Ed. Note: It’s very exciting to be able to feature this, Randy’s first post. He’s qualified both as a boater who understands practical considerations, and as a serious environmentalist who knows the true environmental conditions and what will help keep it clean. The Northwest Marine Trade Association has come out opposed to the NDZ. This issue will be one to keep track of, though as Randy makes clear, it shouldn’t affect many of us because we’re all using our holding tanks already. Right? Don’t forget the mobile pumpout operations that are gaining favor as an alternative to heading to the pumpout station.