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CURRENT LAWS REGARDING DISCHARGE OF HOLDING TANKS OR HEADS DIRECTLY INTO THE
WATER, AND MYTHS OF AN EPA NO DISCHARGE ZONE.
Specific Points Listed Toward the Bottom of this Page
Recommendation:
Do not implement an EPA No Discharge Zone. Enforce existing laws and forego
any new and unnecessary laws regarding sewage & discharge. Make a
"honey-barge" available in the Harbor at an affordable cost.
Boaters should be encouraged to invest in and use the onboard Marine
Sanitation Devices, because they treat waste more effectively than most
municipal plants. (See the article on HOLDING TANKS
by Charles Kanter of the Boot Key Harbor Advisory Committee, and the
Jan 2000 SOUTHERN BOATING EDITORIAL
on the Key West NDZ) Those boaters who have holding tanks should
conscientiously use proper pumpout facilities, or legally pump offshore past
the reef and sanctuary waters. By the same token, pumpouts should be encouraged
by making available working pumpouts throughout the Harbor and the Keys. Right
now they're few and far between - and some are expensive. In addition, Marathon should recommission the
"Honey Barge" as a floating pumpout facility for cruisers and
liveaboards alike (operational now as of 2002!) Closed off canals and
creeks into the Harbor should be opened to allow tidal flow. We believe this
single item will have the major impact on the water quality.
Current regulations fully prohibit discharge of sewage into the Harbor and no
new regulations are required. It just doesn't make any sense. If the issue
becomes that of "illegal" dumping, then adding new regulations will do
nothing more to prevent it because these violators will do the same with the
additional laws. If compliance is the issue then the solution becomes the
enforcement of existing laws. If there are complaints that any one vessel is
dumping sewage directly overboard, then there are ways to trace the discharge to
a specific boat. Though we discourage random or frequent boardings as a
violation of rights of privacy, should there be probable cause established for
any particular vessel, special dye tablets may be placed temporarily in heads or
holding
tanks to trace and discharge into the harbor. The violators are spotted and may
be fined or prosecuted.
IN A NUTSHELL - Specific Points:
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Current Regulations already
prohibit boaters in the harbor from pumping holding tanks (sewage)
directly into the water. These are well known to all cruising boaters.
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The boaters who live in the harbor
have more of an interest in water quality than those on shore, because the
boaters must live in it, get into the water to work on their boats or swim,
etc..
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Current Regulations prohibit the
discharge of such sewage any closer than 3 miles to shore. This
applies to coastal waters anywhere, and totally prohibit it in the Great
Lakes.
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Current Sanctuary regulations increase
this 3 mile zone even farther - outside sanctuary waters
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The WATER QUALITY PROTECTION Report
from the EPA to the Florida Keys National Marine Sanctuary (FKNMS) show
that boats contribute only 1% to1.5% of pollutants in Keys Waters. The rest
is entirely from landside sources. This issue of land based pollution is
addressed in the Boot Key Harbor Advisory report to the County
Commissioners, 1997. (EPA Report available from
the Florida Keys National Marine Sanctuary at 305-743-2437)
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Do you know? Key West's
municipal sewage system pumps out sewage that is only partially
treated directly into the water a few hundred feet off one of the
beaches through a 12 inch pipe? The output is SEVEN MILLION GALLONS PER
DAY OF SECONDARILY TREATED SEWAGE! Doing the math, and assuming even very
large holding tanks on boats of 50 gallons, this is the equivalent of 20,000
Boats every day simultaneously dumping their entire septic holding tanks within one
small confined area just off a beach. Boot Key Harbor has about 300
boats when crowded.
It's easy to see why all the boats combined only contribute 1% to water
pollution.
(Information is from the Water Quality Protection
Report from the EPA to the FKNMS, 305-743-2437)
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Establishment of a No Discharge zone
in the Harbor or the keys adds no additional restrictions to such boaters
who might think of illegally dumping raw sewage overboard. (See the SOUTHERN
BOATING EDITORIAL regarding the Key West NDZ) The Reef
Relief organization in Key West, who supported the Key West No Discharge
Zone, acknowledges that the existing laws of the Clean Vessel Act are
entirely adequate to maintain clean water, but the push for the No Discharge
Zone comes from the increased "teeth" of enforcement and federal
funding it provides.
They acknowledge that the existing laws would work if they were enforced (private
communications between G. Absten, Commander of the Marathon Power Squadron
and Reef Relief in Key West on 12/23/99, G. Absten's office # 305-289-9056)
Instead, an EPA No
Discharge Zone here in the keys can have the following adverse effects:
1. Water Quality can become WORSE: Those few boaters who
have approved sewage treatment devices aboard their boats will be the only
additional ones affected by no discharge for sewage. This means they must pumpout at a
dockside facility to be treated by a local sewage plant, rather than
discharge into the water. Key West waters, as an example, will BECOME MORE
POLLUTED because the sewage systems onboard the boats treat the sewage to a
more purified degree than does Key West's municipal system. Depending on
Marathon's final municipal system, the results will be the same.
2. For all the rest of the boaters who are already prohibited
from pumping out sewage, the only effect the No Discharge Zone will have
have is to prevent them from venting overboard the rinse water from
their sink, or their shower. Most people would agree that rinsing off a head
of lettuce in the kitchen sink with fresh drinking water is hardly a
pollutant. The only potential argument for this is in one's choice of soaps,
and environmentally friendly soaps are readily available.
3. Shoreside activities will be equally affected by law.
For all those homeowners who have fish cleaning stations on their docks, the
No Discharge Zone will make it illegal for you clean the fish and rinse the
blood and leftover parts into the canal with your freshwater hose. No
Discharge means exactly that - Nothing goes into the water.. Likewise you'll
not be able to wash your boat at your dock with soap. This will apply to ANY
waterfront property in the Keys, not just Boot Key Harbor.
4. One of the main environmental impacts of an EPA No Discharge
Zone is lost on the Keys. The No Discharge Zone prevents industrial
plants from venting their sometimes toxic or polluting discharges into
creeks, rivers, bays and harbors where No Discharge Zones are established.
The Keys conspicuously lack any such major industrial plants.
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