Proposed California NDZ

 The US Environmental Protection Agency (EPA) proposes to establish a “no discharge zone” comprising all California marine waters within three nautical miles of shore.  This NDZ would be unique for two reasons.  First, it would be the largest NDZ ever established under the Federal Water Pollution Control Act (FWPCA), also known as the Clean Water Act, extending approximately 840 miles from Oregon to Mexico.  Second, it would be the first NDZ that did not apply to all vessels operating within the zone.  Instead, the prohibition against the discharge of sewage would only apply to cruise ships and other ocean-going vessels of 300 gross tons or greater.  Under the FWPCA, any vessel equipped with a toilet must also have an approved marine sanitation device (MSD) for processing the waste before it can be discharged into the surrounding waters.  The State of California, rightly, is concerned about sewage (treated or otherwise) being discharged into its waters.  In addition to the (low) risk of disease-causing organisms, the sewage also imposes a nutrient load on the waters that can cause a variety of adverse impacts to local flora and fauna.  I understand the concern of the State and the EPA with sewage discharges from cruise ships, each carrying thousands of people.  I am less understanding of the application of the NDZ to regular commercial oceangoing vessels.  These latter ships have crews of 15-25, less persons than are found on a respectable charter fishing boat.  The NDZ, as proposed, would not apply to charter fishing boats, yachts, or many other vessels, which will remain free to dump treated sewage in California waters as before.  The NDZ also ignores the untreated and partially treated sewage discharged by communities, large and small, all along the California coast.  My concern is that, once again, the merchant marine is being viewed as a convenient target for increased regulation that is being applied unevenly in an attempt to solve a widespread problem while causing a minimum of political backlash.