Welcome to the RBAW Web Site

Our web site pages continue to be full of anouncements and updates.
Please scroll down the entire page to view all that is happening with RBAW and its members.


EPA, recognizing the importance of stakeholder input on this sweeping issue, has extended comment period until December 23rd

The All-Puget-Sound No-Discharge Zone...
RBAW now urges you to comment by December 23rd

We have posted at our website earlier (see below) that EPA's comment-period ending December 7, is strictly speaking only for comments pertaining to whether there ARE or ARE NOT sufficient pump-out facilities in Puget Sound -- and our analysis is that the number is well over twice what EPA requires for the known population of boats. Nonetheless, we now find that various environmental groups, not fully understanding that discharge from type I and type II on-board  treatment systems will IN NO CASE cause impairment of Puget Sound's water-quality, are using that portal to swamp EPA with "feel-good" affirmations that such NDZ is "certainly" necessary.  We have been advised to create a record in opposition.

Therefore,RBAW is now urging concerned boaters to register a protest that declaration of such Sound-Wide NDZ is wild regulatory over-reachespecially since our State's Department of Ecology has NOT presented credible arguments that such treated discharge will ever impair the state's already-established water-quality standards, even for shellfish-beds and swimming beaches.  Their "flow-modeling" could show detrimental effects ONLY when the inputs to the rigorous  Puget Sound mathematical flow-model were wildly un-realistic:  as our consultants' refutation study noted, the ONLY cases where DoE's own analysis showed possible harm is when the modeled sewage discharge rates were erroneously as if the entire populations of China and United States were simultaneously traveling on a single boat and discharging their untreated wastewaters to Puget Sound - in all other cases without such obvious "mistaken" inputs, the effects of Type I and Type II onboard treatment plants were orders-of-magnitude safer than water-quality standards require. 

When confronted with such glaring in-accuracies in their scientific approach, DoE's answer was to advise they do not have any requirement to "back up" their declaration of need for a Puget-Sound-wide NDZ with ANY scientific basis: directly quoting their legal filing: " Neither the CleanWaterAct nor EPA's no discharge zone regulation requires a technical or scientific basis to support a state's determination that the protection and enhancement of a particular water body requires greater environmental protection. States are free to make this determination based on factors that are neither technical nor scientific"

If you have specific instances where you believe there are not enough pump-out facilities for recreational boats, please present THAT information first.  If you also are upset about such arbitrary and non-scientific basis for PUBLIC POLICY, this EPA comment-gathering site is our only portal to reach decision-makers right now. Click here to go to further explanation and a suggested letter to "cut-n- paste" into the EPA's comment site.

Regards,
Wayne Gilham, New President ("Change of Watch" each November)
Recreational Boating Association of Washington

PROPOSED NO DISCHARGE ZONE FOR PUGET SOUND

The state Department of Ecology (DOE) has submitted a proposal for a no discharge zone for the entire Puget Sound to the Federal Environmental Protection Agency (EPA).  EPA published a notice in the Federal Register yesterday inviting comments on the proposal with a 30 day comment period.

Also yesterday, the Seattle Times published an article which was picked up by the Tacoma News Tribune today at http://www.thenewstribune.com/news/local/article113200428.html
The article is terribly slanted accusing boaters of using Puget Sound as a toilet!  As we all know that statement is totally false. It is already illegal by Federal law for discharge of RAW sewage into Puget Sound waters; what the NDZ addresses is whether TREATED discharge from Federally-approved onboard Sewage treatment systems should ALSO be banned, and only holding-tank systems should be relied upon.

RBAW has been participating with a Marine Alliance of over 30 commercial and recreational stakeholders trying to get DOE to limit the NDZ to areas where water quality is impaired.  The Alliance submitted information that totally refuted the faulty science of DOE’s justification for curtailing treated sewage discharge by establishing this NDZ, but we were ignored.

EPA’s comments invitation is strictly limited to determining that adequate pumpout facilities exist.  This has never been in doubt on the recreational side with the number of State Parks program installed pumpouts meeting the established EPA standard.  Ecology has misled the EPA on the commercial side as there are essentially no pumpouts currently available to that sector. What is in doubt is the need for the NDZ on a scientific basis, but by Federal law, EPA is not permitted to review our State DOE’s faulty determination of need.

Because of EPA’s limited parameters, submitting comments attacking the basis for the determination of need for an NDZ appears to be a waste of time as they will be ignored and hence organizationally RBAW will not comment via this path. Knowing the above, individual boaters are free to comment regarding the perceived proposal and/or injustice of the system.

The Marine Alliance is pursuing a legal challenge to DOE’s action in State Appeals Court and we will keep you informed of the outcome of that challenge and any other ongoing actions.

Yours in boating,
Paul Thorpe
President
Recreational Boating Association of Washington




Aquatic Lands Lease Guide

Will you be renewing a lease with Department of Natural Resources on aquatics land?
Seeking a new lease?
Seeking to make modifications that impact your current lease?

Check out this leasing guide from DNR...

RBAW and our colleagues from the Northwest Marine Trade Association have instituted quarterly meetings with senior staff at the Department of Natural Resources (DNR). One thing we have asked for is a "no surprises" policy on aquatic lands leases. We've also encouraged DNR to meet early with those who are renewing leases or establishing new ones. We pushed for DNR to produce a guidance document to give Yacht Clubs and other boating organizations a sense of what to expect with aquatic lands leases - and DNR has produced the guide that we have linked here.

Please note in particular the "step by step" information leasing on Page 3, as well as the information that "Most often, changes will not be required until docks or other structures are due for replacement." We have also discussed with DNR the 'stewardship' items on Page 4 of the leasing guide. While they represent the types of desired outcomes DNR aims to achieve with leases, we have been assured they are not rigid, "thou shalt" prescriptive requirements, and that DNR can and will negotiate trade-offs with lessees that are site-specific, realistic, and achievable. Remember, DNR is acting in an "ownership" role of these State lands, not as a regulatory agency hamstrung by rigid rules.


DNR also provided four samples leases with identifying info redacted which you may find helpful...

Lease 1 Lease 2 Lease 3 Lease 4

We hope this leasing guide is helpful and encourage you to contact RBAW Board Officers, or state lobbyist Doug Levy (Levy4@msn.com) with any questions or concerns!

Paul Thorpe
President
Recreational Boating Association of Washington