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ANOTHER BARRIER

NMMA’s President Thom Dammrich said it best when he told a crowd at MAATS: “This is the most threatening issue to our industry since the luxury tax!” I agree. But, I’m concerned. Is anyone listening and, most important, is anyone moved to action?
He was outlining the prospect that, beginning in Sept. 2008, all our customers will be forced to acquire a federal water pollution permit from the EPA. What’s at stake is ugly and two-fold.

First, existing boaters, faced with still another regulatory hassle, could easily say “that’s it” and get out of boating.

Second, getting such a permit clearly sets up still another barrier-to-entry for the prospective boating family, considering our sport. And let’s face it – we don’t need another barrier to boating. 

Briefly, a U.S. District Court ruling primarily addressing ballast water from ships wiped out a 3-dacades-old EPA exemption for recreational boaters from provisions of the Clean Water Act. For example, we’re talking here about deck runoff (no more washing the boat) and gray water (or your hands) without a permit — activities incidental to the normal operation of a boat.

A bill, HR 2550, has been introduced in Congress to exempt recreational boats from the Clean Water Act. While the court ruling is being appealed on one front, without a legislative change by Congress on a second front, the EPA must meet the 2008 deadline. Here are the two practical problems that now should concern us:
1. Passing legislation through the maze in Congress usually takes years. (It took 3 years to repeal the luxury tax.) We don’t have years to get this one done!
2. Its so easy for all of us to assume NMMA or MRAA or our local marine trades associations will handle it. Admit it – we often think “that’s what we pay our dues for,” right? Sorry, all the king’s men can’t get this one done in a year.

The only possibility is to rally the boaters. It’s those constituents most effected that can get the attention of Congress to pass HR 2550 before the damage is done.

So, here’s the deal: We dealers must become involved now. We must inform our customers of the looming debacle now (they don’t know) and convince them to contact their Representative, now, to urge the speedy passage of HR 2550. If we don’t act now it won’t happen in time.

Will you act? And let me know that you are?

Comments

5 comments on “ANOTHER BARRIER

  1. bill gardella jr cmm114

    We can send out an email and snail mail blast- could/has someone drafted a letter to request out custommers to take specific action? My attempt will likely be less efective than someone more familiar with this important issue.

  2. Willis E. Sibley

    HR 2550 will greatly assist the marine recreational industry. The really trivial pollution involved by recreational boaters washing their boats, etc., does not warrant Draconian enforcement by the EPA.

  3. Deborah McQueen, Exec. Director

    We will do our part in letting our boating public know about this isssue. I will be contacting our membership today.

    Thank you for the “call to action”

    Deborah McQueen
    Exec. Director,
    Oregon Marine Trade Association (OMTA)
    33470 SW Chinook Plaza #285,
    Scappoose OR 97056

  4. shomer

    <p>The letter below was sent to Mr. Benjamin Grumbles of the EPA earlier today. This is a serious issue for boaters, the marine industry and US coastal economies. Please take a minute to read and act as your conscience deems best.</p>
    <p>Respectfully,</p>
    <p>Susanne Homer<br />
    President<br />
    CWSI &<br />
    Mastor USCG 100 Ton (Ret)</p>
    <p>Boaters Last Chance To Influence EPA. NMMA Begs US Boaters to Register Complaints with EPA Today!</p>
    <p>Deadline for “comments” is “before August 6, 2007?. </p>
    <p>EPA permits for recreational boaters could cost $800 or more, according to NMMA President Thom Dammrich. </p>
    <p>——————————————————————————–</p>
    <p>In a nutshell: A Federal Judge has ruled that the EPA was not given the power by Congress 34 years ago to exempt recreational boats from a provision in the 1972 Clean Water Act aimed at the discharge of ballast water from commercial ships. Virtually everyone – including the EPA – realizes that recreational boats should be exempted, but it is now being forced by statute to require permitting of 13 million boats. Help the EPA help boaters by registering your comments NOW—</p>
    <p>E-Mail your comments RIGHT NOW. 3 Easy Steps:</p>
    <p>1. EPA’s E-Mail Address: ow-docket@epa.gov</p>
    <p>2. Subject Line: Docket ID No. OW-2007-0483</p>
    <p>3. Your Comments.</p>
    <p>Snail-Mail Your Comments TODAY to:</p>
    <p>Mr. Benjamin H. Grumbles<br />
    Assistant Administrator for Water<br />
    c/o Water Docket<br />
    EPA<br />
    Mailcode 2822T<br />
    1200 Pennsylvania Ave., NW<br />
    Washington DC 2-460 </p>
    <p>NMMA’s “Talking Points” on Ballast Water Permit EPA Issue – 08/01/2007 with additions from Clean Water Solutions, Inc.<br />
    ________________________________________<br />
    Dear Mr. Grumbles: </p>
    <p>I am deeply concerned that the government can be so ill-informed as to compare the discharge of bilges in recreational boats to the discharge of ballast tanks onboard commercial tankers and then legislates statutes that will have long reaching ill effects on boating here in the US. The Environmental Protection Agency (EPA) should not lump small family-owned recreational boats into the same class as large commercial ships when the agency develops its new vessel permit program. </p>
    <p>I am a boater and as such have traveled extensively worldwide as I was a Master Mariner holding a 100 ton USCG license. I have seen first hand the ravages caused by, and disease that comes from contamination. Also, the profound loss of wildlife habitat due to human impact. I understand that controlling invasive species was the genesis for the ballast water legislation, however painting recreational bilges with the same brush is faulty thinking at best. There are other alternatives that can be easily implemented and managed at a fraction of the cost to boaters, without the necessity of having the government crush an industry that brings hundreds of millions of dollars annually to coastal communities and the economy, as well as an important leisure activity to countless Americans.</p>
    <p>Our business, Clean Water Solutions, Inc (CWSI) is dedicated to the elimination of hydrocarbons and pathogens from water, both fresh and salt. We manufacture award winning, cost effective, non-toxic, products for bilges that utilize naturally occurring microbes that literally eat and convert contaminants into beneficial products – fatty acids which are food for fish and plant life. Boaters can help manage and maintain our most precious resource for the seventh generations to come. Legislating zero tolerance is not tolerance at all, only a recipe for failure where no one wins. </p>
    <p>Recreational boats cannot be equated with commercial ships and should not be subjected to complex permit requirements for the following reasons:</p>
    <p>Recreational boat bilge and gray water discharges should not be compared with the large quantities of commercial ship ballast water and gray water discharged into U.S. waters. By function of shipping across oceans, ballast water is from other bodies of water and ecosystems. In contrast, recreational boats discharge water from their local waters, emitting only minor amounts of bilge water, deck runoff, engine cooling water, and gray water. These discharges are necessary for the safe and normal functioning of these boats as all boats are sinking, just some more alarming so. Most boats with an inboard engine have a shaft bearing, which by function leaks to lubricate the turning of the shaft. </p>
    <p>Recreational boats are owned and operated for leisure and fun by individuals and families, not large companies with experts on retainer. Commercial vessel owners include in their cost of doing business the hiring of experts and employees to figure out EPA’s complex rules, permit applications and reporting requirements. Boaters cannot be expected to navigate a complex permit system and cannot afford to pay large permit fees. </p>
    <p>Boaters will no longer have free access to the water if they must first get a separate permit to boat in each and every state. Requiring boaters to get one permit is daunting – requiring them to get a permit for every state whose waters they may travel is absurd and amounts to a national boating ban.</p>
    <p>There is little that a recreational boater can do to change the way their boats operate. Boaters cannot be expected to outlay hundreds of dollars to install new untested equipment on their boats, as well as pay onerous fees to comply with EPA or state permits. </p>
    <p>In fact, the recreational marine engine and boat manufacturers are currently making large investments in new technology to implement the new emission requirements proposed on May 18, 2007 by EPA for boat engines and marine fuel systems.</p>
    <p>This EPA proposal will require outboard and personal watercraft engines to be certified to the same stringent exhaust emission standards as will be required by the California Air Resources Board (CARB) in 2008. For sterndrive and inboard engines, the EPA rule proposes catalyst-based exhaust emission standards that will apply beginning in 2009. In addition, boat builders will be required to change fuel systems to comply with new requirements for fuel hoses, plastic fuel tanks and to control emissions from the fuel tank vent. These fuel system changes will eliminate fuel vent spills. </p>
    <p>Does OW-2007-0483 actually solve the problem? </p>
    <p>EPA will not be able to alert and educate all U.S. boat owners in time about the need to obtain Clean Water Act NPDES permits from the EPA and the 45 states with authority to issue these permits. Thirty-two percent of U.S. adults went boating in 2006 and there are nearly 18 million recreational boats in use in the U.S. It will be a major undertaking to alert and explain to all registered and U.S. documented boat owners the need for new boat permits. In addition, there is simply no reliable way for EPA to identify and contact the many non-registered or non-documented boat owners. </p>
    <p>It will be much more effective and result in less government waste to put EPA and the states’ energies instead into working closely with boating organizations to help educate boaters about already existing boater best practices. There will be no improvement in the environment by requiring boaters to fill out long government forms and pay large fees for the privilege of boating. Instead, EPA and the states should look to boost the funding and profile of the many programs nationwide that educate boaters on the simple steps they can take to reduce their impact on the environment such as using beneficial remediation products or sorbant pads when refueling or using biodegradable soaps and cleaners. </p>
    <p>I strongly urge my Senators and Congressmen to support H.R. 2550, the Recreational Boating Act of 2007 as well as consider education, new technology and remediation as the positive alternatives.</p>
    <p>Thank you for considering my views on EPA’s notice of its intention to create a new permitting program for discharges from vessels. </p>
    <p>Please contact me at my office or visit our website at http://www.cwsius.com if you have further questions or would like to know more about CWSI and the benefits of nature’s way of recycling – remediation.</p>
    <p>Sincerely, </p>
    <p>Susanne Homer</p>

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