The National Marine Manufacturers Association submitted comments to the National Oceanic and Atmospheric Administration regarding NOAA's proposed ban on marine sanitation device discharges from vessels in the Florida Keys National Marine Sanctuary.
If NOAA's effort is successful, similar regulations could be enacted in other marine sanctuaries, the NMMA said.
The NMMA said NOAA's policy and procedures for designating no-discharge zones in marine sanctuaries should be consistent system-wide and not determined solely on the specific needs of one sanctuary. It said NOAA should adopt the procedure already established by the Clean Water Act by which states obtain permission from the Environmental Protection Agency to designate state waters as no-discharge zones.
Click here to read the NMMA's letter, which asks NOAA to reconsider its proposal.
NOAA's proposal ignores all of the relevant facts, including the total lack of means for enforcement on what is best recognized as the high seas. Use of Type I MSDs in these waters will actually benefit the environment since the processed waste discharged from these devices is often cleaner than what is discharged from a shore side treatment plant. This is especially true for the Raritan ElectroScan which, in a recent EPA test was shown to "eliminate 99.99% of all pathogens". Readers will find my submission to the Federal Register Docket. It contains a wealth of factual material.
Actions such as this one from NOAA are disappointing, their scientific personnel should know better than to make a proposal that smacks of the "illusion of security" engaged in by the Department of Homeland Security and the TSA. We deserve better from the fine people in NOAA.