Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices
Prepared
by
the
Office
of
Water
June
19,
2003
2
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices
Table
of
Contents
Subject
Page
Part
A
Introduction
6
Organization
of
Information
Collection
Request
Statement
7
Approach
Taken
in
this
Information
Collection
Request
7
Section
1:
Identification
of
the
Information
Collection
9
1(
a)
Title
of
Information
Collection
9
1(
b)
Short
Characterization/
Abstract
9
Section
2:
Need
for
Use
of
the
Collection
12
2(
a)
Need/
Authority
for
the
Collection
12
2(
b)
Practical
Utility/
Users
of
the
Data
14
Section
3:
Nonduplication,
Consultations,
and
Other
Collection
Criteria
16
3(
a)
Nonduplication
16
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
17
3(
c)
Consultations
17
3(
d)
Effects
of
Less
Frequent
Collection
18
3(
e)
General
Guidelines
18
3(
f)
Confidentiality
18
3(
g)
Sensitive
Questions
19
Section
4:
The
Respondents
and
Information
Requested
19
4(
a)
Respondents/
SIC
Codes
19
4(
b)
Information
Requested
20
(
i)
Data
items,
including
recordkeeping
requirements
20
Data
items
20
Recordkeeping
22
Section
5:
The
Information
Collected
 
Agency
Activities,
22
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
22
3
5(
b)
Collection
Methodology
and
Management
23
5(
c)
Small
Entity
Flexibility
25
5(
d)
Collection
Schedule
27
Section
6:
Estimating
the
Burden
and
Cost
of
the
Collection
27
6(
a­
b)
Estimating
Respondent
Burden
and
Costs
27
6(
c)
Estimating
Agency
Burden
and
Cost
29
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
29
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
30
6(
f)
Reasons
for
Change
in
Burden
30
6(
g)
Burden
Statement
30
Part
B
Section
1:
Survey
Objectives,
Key
Variables,
and
38
Other
Preliminaries
1(
a)
Survey
Objectives
38
1(
b)
Key
Variables
40
1(
c)
Statistical
Approach
40
1(
d)
Feasibility
41
Section
2:
Survey
Design
for
the
Statistical
Approach
42
2(
a)
Target
Population
and
Coverage
42
2(
b)
Sample
Design
44
2(
b)(
i)
Sampling
Frame
44
2(
b)(
ii)
Sample
Size
46
2(
b)(
iii)
Stratification
Variables
48
2(
b)(
iv)
Sampling
Method
48
2(
c)
Precision
Requirements
2(
c)(
i)
Precision
Targets
49
2(
c)(
ii)
Nonsampling
Errors
49
2(
d)
Questionnaire
Design
52
2(
d)(
i)
Boater
Operators
Survey
53
2(
d)(
ii)
Marina
Owner/
Operator
Survey
61
2(
d)(
iii)
State/
Local
Survey
69
2(
d)(
iv)
Marine
Sanitation
Device
(
MSD)
71
Manufacturer
Survey
2(
d)(
v)
Marine
Sanitation
Device
(
MSD)
Testing
72
Laboratory
Survey
Section
3:
Pretests
and
Pilot
Tests
72
Section
4:
Collection
Methods
and
Follow­
up
73
4(
a)
Collection
Methods
73
4
4(
b)
Survey
Response
and
Follow­
up
76
Section
5:
Analyzing
and
Reporting
Survey
Results
77
5(
a)
Data
Preparation
77
5(
b)
Analysis
88
5(
c)
Reporting
Results
82
References
82
Appendices
A.
Section
312
of
Clean
Water
Act
84
B.
EPA
Marine
Sanitation
Device
Regulations
90
C.
Coast
Guard
Marine
Sanitation
Device
Regulations
94
D.
1st
Federal
Register
Notice
 
Surveys
to
Determine
the
99
Effectiveness
of
No­
Discharge
Zones
and
Marine
Sanitation
Devices
E.
Response
to
Comments
102
F.
Survey
Text
136
5
Tables
Table
#
Page
1.
Average
Annual
Respondent
Burden
and
32
Costs
 
Boat
Owners
and
Operators
2.
Average
Annual
Respondent
Burden
and
32
Costs­
Marina
Owners
and
Operators
3
Average
Annual
Respondent
Burden
and
33
Costs
 
U.
S.
Coast
Guard
Accepted
Independent
Laboratories
4
Average
Annual
Respondent
Burden
and
Costs
 
U.
S.
33
Coast
Guard
Accepted
Independent
Laboratories
5
Average
Annual
Respondent
Burden
and
Costs
 
State
and
34
Local
Government
Officials
6
Average
Annual
Respondent
Burden
and
Costs
 
Agency
35
7
Average
Annual
Respondent
Burdens
and
Costs
Composite
36
8
Average
Annual
Burdens
and
Costs
Composite
 
All
Entities
37
6
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices
EPA
ICR
#
2107.01
Part
A
Introduction
This
document
responds
to
the
requirements
of
the
Paperwork
Reduction
Act.
The
purposes
of
the
Paperwork
Reduction
Act
of
1980
(
P.
L.
96­
511)
are
to:
(
1)
minimize
the
Federal
paperwork
burden
for
small
businesses,
State
and
local
governments,
and
other
individuals;
(
2)

minimize
the
Federal
government's
cost
of
collecting,
maintaining,
using,
and
disseminating
information;
and
3)
maximize
the
usefulness
of
information
collected
by
Federal
agencies.

This
application
is
made
by
the
Oceans
and
Coastal
Protection
Division
of
the
Office
of
Wetlands,
Oceans,
and
Watersheds
in
the
Office
of
Water
of
the
U.
S.
Environmental
Protection
Agency
(
EPA).
As
will
be
demonstrated
in
this
application,
the
proposed
information
collection
activities
are
accomplished
by
the
least
burdensome
and
costly
means;
are
not
duplicated
by
other
sources;
and
are
pivotal
to
EPA's
responsibilities
in
designating
no­
discharge
zones
(
NDZs)
for
treated
or
untreated
vessel
sewage
and
for
establishing
standards
for
marine
sanitation
devices
(
MSDs)
under
the
Clean
Water
Act
(
CWA)
§
312.
7
Organization
of
Information
Collection
Request
Statement
This
document
follows
the
format
for
Information
Collection
Requests
(
ICR)
outlined
in
the
Information
Collection
Review
Handbook
(
Office
of
Management
and
Budget,
1989)
and
the
Instructions
for
Standard
Form
83
(
revised
version
dated
September
1983).
No
exceptions
to
this
format
are
taken.
Those
topics
identified
in
the
Information
Collection
Review
Handbook
that
are
not
relevant
to
this
application
are
noted,
and
the
basis
for
this
determination
stated.
EPA's
Information
Resources
Management
Policy
Manual
(
July
1987),
Regulation
Development
in
EPA
(
September
1992),
and
EPA's
ICR
Handbook
(
February
1999)
also
guided
the
development
of
this
document.

Approach
Taken
in
this
Information
Collection
Request
Some
of
the
information
collection
and
record
keeping
requirements
under
this
activity
are
"
borderline"
relative
to
the
requirements
to
prepare
and
submit
an
ICR
as
defined
in
the
ICR
Handbook.
However,
a
conservative
approach
(
i.
e.,
overstate
potential
burden
and
costs)
has
been
taken
throughout
this
analysis,
and
all
information
collection
and
record
keeping
requirements
associated
with
conducting
the
surveys
have
been
described,
regardless
of
the
magnitude
of
the
burden.

This
ICR
was
developed
based
on
program
office
knowledge
of
the
process,
a
review
of
selected
ICRs
that
have
applications
and
survey
strategies
similar
to
those
being
called
for
under
8
this
ICR,
a
review
of
Coast
Guard
certification
data,
a
review
of
U.
S.
Fish
and
Wildlife
Service
Clean
Vessel
Act
grant
pumpout
facility
information,
interviews
with
Federal
and
local
officials
working
on
vessel
discharge
issues,
and
by
soliciting
the
expertise
of
organizations
that
have
instituted
such
information
collections
in
the
past
(
e.
g.,
Battelle,
Eastern
Research
Group,
Inc.).
9
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices
SECTION
1:
Identification
of
the
Information
Collection
1(
a)
Title
of
Information
Collection
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices
1(
b)
Short
Characterization/
Abstract
This
information
collection
request
(
ICR)
is
for
a
series
of
surveys
to
be
conducted
to
determine
the
effectiveness
of
no­
discharge
zones
(
NDZs)
for
vessel
sewage
and
of
marine
sanitation
devices
(
MSDs)
in
removing
harmful
pollutants
from
the
waste
stream
of
the
device.

This
ICR
requests
approval
to
collect
information
from
boat
owners
and
operators,
marina
owners
and
operators,
and
State
and
local
government
officials
regarding
the
effectiveness
of
NDZs.
This
information
will
be
gathered
from
MSD
manufacturers
and
U.
S.
Coast
Guard
accepted
independent
laboratories.
The
information
collected
from
the
surveys
will
be
used
to
assess
the
overall
effectiveness
of
NDZs
for
vessel
sewage
established
under
Clean
Water
Act
Section
312(
f)(
3)
and
MSDs
to
help
determine
if
modifications
to
the
program
are
needed.
10
The
survey
developed
for
boat
owners
and
operators
will
address
the
boater's
experience
with
using
pump­
out
or
dump
facilities
in
NDZs.
The
survey
will
collect
general
information
regarding
the
respondent's
boating
activity.
It
will
seek
information
on
whether
the
pump­
out
or
dump
facilities
were
working
or
not
working
when
the
boater
attempted
to
use
them.
It
will
address
whether
the
boater
would
use
the
facilities
if
they
were
available
and
how
often
the
boaters
actually
use
the
facilities.
It
will
also
seek
information
on
the
boater's
knowledge
about
NDZs.
Respondents
will
be
selected
from
North­
Atlantic
States,
Mid­
Atlantic
States,
South­

Atlantic
States,
California,
and
the
Great
Lakes.
Approximately
1400
respondents
from
the
geographical
regions
will
be
selected
for
response.
EPA
predicts
to
receive
completed
surveys
from
1200
boat
owners
and
operators.
The
information
collection
will
be
voluntary
and
will
not
include
confidential
business
information
(
CBI).

The
survey
developed
for
marina
owners
and
operators
located
in
NDZs
will
seek
general
information
on
pump­
out
and
dump
facility
operations,
the
downtime
of
these
facilities,
and
their
use
by
boaters.
It
will
seek
information
regarding
the
marina
owner/
operator's
knowledge
of
NDZs.
Respondents
will
be
selected
from
North­
Atlantic
States,
Mid­
Atlantic
States,
South­

Atlantic
States,
California,
and
the
Great
Lakes.
Approximately
100
marina
owners
or
operators
from
the
geographical
regions
will
be
selected
for
response.
EPA
predicts
to
receive
completed
surveys
from
75
marina
owners
and
operators
in
total.
The
information
collection
will
be
voluntary
and
will
not
include
CBI.

Also,
a
survey
will
be
developed
for
State
and
local
government
officials
to
determine
if
11
the
designation
of
NDZs
has
been
effective
in
addressing
water
quality
issues,
State
roles
and
responsibilities
associated
with
the
NDZ,
and
if
boaters
comply
with
NDZ
requirements.

Respondents
will
be
selected
from
North­
Atlantic
States,
Mid­
Atlantic
States,
South­
Atlantic
States,
California,
and
the
Great
Lakes.
Approximately
80
respondents
from
the
geographical
regions
will
be
selected
for
response.
EPA
predicts
54
State
and
local
government
officials
will
complete
the
survey
in
total.
The
information
collection
will
be
voluntary
and
will
not
include
CBI.

An
additional
survey
will
be
developed
to
review
current
MSD
technology.
The
information
on
MSDs
that
will
be
requested
includes
effluent
constituents
and
their
concentrations;
bacteria
eradication
processes
and
suspended
solids
removal;
and
cost
and
installation.
This
information
will
be
used
to
help
determine
the
effectiveness
of
the
current
MSD
technologies.
This
information
may
be
used
in
future
decisions
regarding
the
effectiveness
of
the
MSD
standards.
It
will
particularly
be
important
in
determining
if
revisions
to
the
MSD
standards
or
if
other
program
modifications
are
necessary.
This
information
may
also
be
used
to
assist
EPA
in
promulgating
regulations
implementing
Title
XIV:
Certain
Alaskan
Cruise
Ship
Operations.

Approximately
60
MSD
manufacturers
and
8
U.
S.
Coast
Guard
accepted
independent
laboratories
will
be
selected
for
response.
EPA
predicts
that
30
MSD
manufacturers
and
7
U.
S.

Coast
Guard
accepted
independent
laboratories
will
complete
the
survey.
Responding
to
the
collection
of
information
would
be
voluntary.
Any
information
covered
by
a
CBI
claim
will
be
treated
in
accordance
with
the
procedures
set
forth
in
40
CFR
part
2,
subpart
B.
12
EPA
estimates
that
the
respondent
total
burden
and
costs
associated
with
this
ICR
is
474
hours
reflecting
$
13,053.
The
Agency
burden
and
cost
is
estimated
at
6,672
hours
reflecting
$
282,642
SECTION
2.
Need
for
and
Use
of
the
Collection
This
section
describes
the
statutory
and
regulatory
authorities
associated
with
this
information
collection.
It
also
summarizes
the
use
of
the
information.

2(
a)
Need/
Authority
for
the
Collection
EPA's
Office
of
Water
is
responsible
for
protecting
and
maintaining
the
quality
of
the
nation's
waters.
In
order
for
EPA
to
make
effective
policy
decisions,
policy
makers
need
information
on
how
the
current
programs
are
working
to
protect
human
and
animal
health
and
the
aquatic
and
wildlife
environments.

EPA
desires
to
obtain
information
on
the
effectiveness
of
NDZs
and
MSDs
to
implement
its
statutory
and
regulatory
requirements.
The
statutory
requirements
are
under
Clean
Water
Act
Sections
312(
a­
m),
and
the
regulatory
requirements
are
under
40
CFR
140
and
33
CFR
159.

Section
312
of
the
Clean
Water
Act
and
40
CFR
140.3
require
the
use
of
MSDs
on
all
vessels
with
installed
toilets.
There
are
three
types
of
MSDs.
Type
I
and
Type
II
MSDs
provide
treatment
of
sewage
that
is
to
be
discharged,
and
rely
on
a
variety
of
different
technologies
for
treatment
prior
to
discharge
including
maceration,
chlorination,
heating,
filtering,
and
biological
processing.
Type
III
MSDs
are
holding
tanks
that
provide
minimal
sewage
treatment
and
can
be
13
installed
on
vessels
of
any
size
(
33
CFR
159).
Installed
toilets
on
vessels
of
65
ft.
or
less
in
length
may
be
equipped
with
any
of
the
three
types
of
MSDs
(
33
CFR
159).
Type
I
MSDs,
which
may
only
be
used
on
vessels
up
to
65
ft.
in
length
(
33
CFR
159),
are
required
to
produce
an
effluent
with
a
fecal
coliform
bacteria
count
less
than
or
equal
to
1000
bacteria
per
100
ml
of
seawater,

and
with
no
visible
floating
solids.
For
vessels
greater
than
65
ft.,
all
installed
toilets
must
be
equipped
with
either
Type
II
or
Type
III
MSDs
(
33
CFR
159).
The
Type
II
MSDs
are
required
to
produce
effluent
with
a
fecal
coliform
count
less
than
or
equal
to
200
bacteria
per
100
ml
of
seawater
and
suspended
solids
less
than
or
equal
to
150
mg/
l.
Type
III
MSDs
are
holding
tanks
that
are
designed
to
prevent
overboard
discharge
of
any
sewage.

Under
Section
312(
f)
of
the
Clean
Water
Act
(
CWA)
and
40
CFR
140.4,
with
EPA's
approval,
States
may
designate
a
portion
or
all
of
their
waters
as
NDZs,
making
all
vessel
sewage
discharges
illegal.
The
establishment
of
NDZs
provides
State
and
local
governments
with
additional
protection
of
waters
from
treated
or
untreated
vessel
sewage
discharges,
which
is
one
of
many
types
of
water
pollution.
States
may
designate
their
waters
as
a
NDZ
for
vessel
sewage
to
achieve
any
of
the
following
objectives:
(
1)
to
protect
aquatic
habitats;
(
2)
to
protect
special
aquatic
habitats
or
species
such
as
coral
reefs
and
shellfish
beds;
and
(
3)
to
safeguard
human
health
by
protecting
drinking
water
intake
zones.
Under
Section
312(
f)(
3)
of
the
CWA
and
40
CFR
140.4(
a),
States
designate
NDZs
for
their
waters
by
demonstrating
to
EPA
that
safe
and
adequate
pump­
out
and
toilet
dump
facilities
are
available.
Currently
about
95%
of
the
NDZs
have
been
designated
under
this
provision.
At
a
State's
request,
under
CWA
Sections
312(
f)(
4)(
A)
and
(
B)
and
40
CFR
140.4(
b)
and
(
c),
NDZs
for
special
aquatic
habitats
and
14
drinking
water
intake
zones,
respectively,
also
can
be
established
by
regulation
by
EPA
if
it
is
determined
that
additional
protection
of
the
aquatic
environment
is
required.
NDZs
established
by
EPA
regulation
do
not
require
the
availability
of
pump­
out
or
dump
facilities.
Currently,
about
5%
of
the
NDZs
for
vessel
sewage
have
been
designated
by
regulations
promulgated
by
EPA.

Also,
under
40
CFR
140.3(
a)(
1),
water
bodies
that
do
not
support
the
ingress
or
egress
of
vessels
subject
to
these
regulations
or
do
not
support
interstate
traffic
are
NDZs.

This
information
collection
request
will
focus
on
the
effectiveness
of
NDZs
for
vessel
sewage
designated
by
States
under
Clean
Water
Act
Section
312(
f)(
3)
and
40
CFR
140.4(
a).
It
will
also
address
the
effectiveness
of
current
MSD
technologies.
The
standards
for
the
MSDs
can
be
found
at
40
CFR
140.3.
The
relevant
sections
of
the
CWA
are
included
in
Appendix
A
and
the
relevant
sections
of
the
implementing
regulations,
40
CFR
140,
are
included
in
Appendix
B.

Included
in
Appendix
C
are
the
U.
S.
Coast
Guard
implementing
regulations
for
MSDs.
The
Coast
Guard
is
responsible
for
certifying
MSDs
and
enforcing
the
NDZ
requirements.

2(
b)
Practical
Utility/
Users
of
the
Data
The
purpose
of
this
study
is
to
determine
the
effectiveness
of
NDZs
and
of
MSDs
in
removing
harmful
pollutants
from
the
waste
stream
of
the
device.

EPA
will
determine
the
effectiveness
of
NDZs
by
collecting
information
from
boaters,

marina
owners
and
operators,
and
State
and
local
government
officials.
This
information
will
be
analyzed
statistically.
15
The
information
collected
from
boaters
will
be
used
to
evaluate
awareness
of
the
NDZ
rules,
probable
level
of
compliance,
and
experience
with
availability
of
pump­
out
facilities.

Specifically,
the
information
from
boaters
will
include:

°
Their
experience
using
pump­
out
or
dump
facilities
in
NDZs;

°
Whether
pump­
out
or
dump
facilities
were
working
when
the
boater
attempted
to
use
them;
and
°
Whether
the
boater
would
use
the
facilities
if
they
were
available
and
how
often
the
boater
actually
uses
the
facilities.

Additional
information
will
be
collected
from
marina
owners
and
operators
through
another
survey.
This
information
will
include:

°
The
size
of
the
marina;

°
Whether
the
marina
obtained
Clean
Vessel
Act
(
CVA)
funding
(
which
provides
money
for
pump­
out
facilities;

°
The
downtime
of
pump­
out
and
dump
facilities
at
the
marinas
located
in
the
NDZs;

°
The
reason
for
the
downtime;

°
The
use
of
pump­
out
and
dump
facilities
by
boaters;
and
°
Whether
boaters
are
in
compliance
with
NDZ
requirements.

A
survey
will
be
conducted
seeking
information
from
State
and
local
government
officials
addressing
whether
the
designation
of
NDZs
has
been
effective
in
reducing
pollution
impacts
on
aquatic
environments
from
sewage
in
the
NDZs.
Specifically,
the
information
includes:
16
°
Whether
beach
closures,
shellfish
bed
health,
or
other
water
quality
data
indicate
a
change
in
the
water
quality
of
the
NDZ
since
its
designation;

°
Whether
there
are
promotional
or
advertising
activities
associated
with
the
NDZ;
and
°
How
the
requirements
of
the
NDZ
are
enforced.

Also,
information
regarding
the
performance
of
MSDs
will
be
collected
from
MSD
manufacturers
and
U.
S.
Coast
Guard
accepted
independent
laboratories
and
will
not
be
analyzed
statistically.
This
information
includes
the
effluent
constituents
and
their
concentrations;
bacteria
eradication
processes
and
suspended
solids
removal;
and
cost
and
installation.
This
information
will
be
used
to
determine
the
effectiveness
of
current
MSD
technology.
This
information
may
be
used
in
future
decisions
regarding
the
effectiveness
of
the
MSD
standards.
It
will
particularly
be
important
in
determining
if
revisions
to
the
MSD
standards
or
other
program
modifications
are
necessary.
Also,
this
information
may
be
used
to
support
EPA's
current
promulgation
of
regulations
implementing
Title
XIV:
Certain
Alaskan
Cruise
Ship
Operations.

SECTION
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
This
information
collection
will
target
boaters,
marina
owners
and
operators,
State
and
local
government
officials,
MSD
manufacturers,
and
U.
S.
Coast
Guard
accepted
independent
laboratories.
It
will
gather
information
that
will
be
used
to
determine
the
effectiveness
of
NDZs
and
of
MSDs
in
removing
harmful
pollutants
from
the
waste
stream
of
the
device.
Under
Section
17
312(
c)(
1)(
A),
EPA
has
the
authority
to
revise
the
NDZ
requirements
and
MSD
standards.
In
order
for
EPA
to
do
this,
NDZ
effectiveness
and
MSD
performance
information,
at
the
national
level,
is
needed.
This
ICR
characterizes
how
EPA
plans
to
get
that
information,
and
this
effort
has
not
been
duplicated
at
the
national
level
before.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
this
ICR
was
made
in
the
Federal
Register
on
March
27,
2003
(
Volume
68,
Number
59),
see
Appendix
D.
EPA
received
20
sets
of
comments.
None
of
the
comments
recommended
that
EPA
should
not
conduct
the
surveys.
The
vast
majority
of
comments
provided
information
regarding
the
potential
questions
that
the
surveys
should
ask,
some
provided
information
regarding
the
effectiveness
of
the
current
NDZs
and
MSDs,
and
additional
comments
provided
recommendations
on
how
EPA
should
modify
its
current
vessel
sewage
discharge
program.
EPA
prepared
a
response
to
comment
document
that
is
available
at
the
Water
Docket.
A
copy
of
the
document
can
be
found
in
Appendix
E.

3(
c)
Consultations
Several
EPA
workgroups
were
formed
to
assist
in
the
design
of
the
surveys.
One
workgroup
included
members
of
the
EPA's
Oceans
and
Coastal
Protection
Division
in
the
Office
of
Water.
Another
workgroup
included
all
EPA
Regional
staff
responsible
for
implementing
the
vessel
sewage
discharge
program.
A
third
workgroup
consisted
of
members
of
other
EPA
offices
that
have
peripheral
interests
in
and
concerns
regarding
NDZs
and
MSDs.
18
EPA
consulted
with
persons
outside
the
agency
on
a
regular
basis
throughout
the
design
and
testing
of
these
surveys.
Because
of
cross­
program
issues,
EPA
consulted
with
staff
from
the
U.
S.
Coast
Guard
(
responsible
for
enforcement
of
NDZs
and
certifying
that
MSDs
meet
the
EPA
standards)
of
the
Department
of
Homeland
Security
and
the
Fish
and
Wildlife
Service
(
implements
the
Clean
Vessel
Act
grant
program,
which
provides
funding
for
education,
and
the
installation
and
maintenance
of
pump­
out
facilities
at
marinas)
of
the
Department
of
Interior
regarding
the
design
and
delivery
of
the
surveys.
EPA
also
consulted
with
representatives
from
the
Marina
Operators
Association
of
America
and
the
Virginia
Clean
Marina
Program.

3(
d)
Effects
of
Less
Frequent
Collection
This
is
a
one­
time
data
collection
exercise
for
the
respondent.

3(
e)
General
Guidelines
Information
will
be
collected
according
OMB
guidelines
in
5
CFR
1320
and
EPA's
Quality
Assurance
Guidance.
Information
to
be
disseminated
will
comply
with
EPA's
Information
Quality
Guidelines
which
were
developed
for
implementing
OMB's
Guidelines
for
Ensuring
and
Maximizing
the
Quality,
Objectivity,
Utility,
and
Integrity
of
Information
Disseminated
by
Federal
Agencies.

3(
f)
Confidentiality
The
survey
will
fully
conform
to
federal
regulations
 
specifically
the
Privacy
Act
of
1974
(
5
U.
S.
C.
552a)
and
the
Hawkins­
Stafford
Amendments
of
1988
(
P.
L.
100­
297).
The
respective
19
respondents
will
be
informed
that
their
participation
in
each
survey
is
voluntary,
and
their
identities
will
be
kept
confidential
and
not
associated
with
their
responses.
Neither
EPA
nor
any
other
agency
will
have
access
to
the
names
of
the
respondents,
and
no
identifying
information
will
be
included
in
the
final
survey
data
provided
to
EPA
except
for
the
State
surveys.
EPA
believes
that
the
information
gathered
from
the
State
and
local
government
survey
will
not
include
confidential
business
information.
The
surveys
are
designed
to
gather
reports
and
information
that
is
already
available
to
the
public.
If
instances
occur
where
the
information
should
be
treated
confidentially,
it
will
be
treated
in
accordance
with
the
procedures
set
forth
in
40
CFR
Part
2,

Subpart
B.
Information
gathered
from
MSD
manufacturers
and
U.
S.
Coast
Guard
accepted
independent
labs
could
potentially
contain
confidential
business
information
and
will
be
treated
in
accordance
with
the
procedures
set
forth
in
40
CFR
Part
2,
Subpart
B..

3(
g)
Sensitive
Questions
There
are
no
questions
on
sexual
behavior
and
attitudes,
religious
beliefs,
and
other
matters
that
are
commonly
considered
private
or
sensitive
in
these
survey
instruments.

SECTION
4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
following
is
a
list
of
respondents
(
including
their
North
American
Industry
Classification
System
identification
number)
affected
by
this
information
collection
request:

°
Boat
owners
and/
or
operators
(
532411,
532292,
487210);

°
Marina
owners
and/
or
operators
(
713930);
20
°
State
and
local
government
officials
responsible
for
implementing
the
requirements
of
NDZs
in
their
waters
or
are
familiar
with
such
implementation;

°
Marine
sanitation
device
manufacturers
(
541330,
336612,
3366);
and
°
U.
S.
Coast
Guard
accepted
independent
laboratories
(
926120).

4(
b)
Information
Requested
(
i)
Data
items,
including
recordkeeping
requirements.

Data
Items.

Respondents
will
be
asked
to
complete
only
one
survey.
The
surveys
developed
for
boat
and
marina
owners
and
operators
and
State
and
local
government
officials
will
be
part
of
a
statistical
study
addressing
the
effectiveness
of
NDZs.
The
surveys
for
MSD
manufacturers
and
Coast
Guard
accepted
independent
laboratories
are
designed
to
gather
MSD
performance
data
to
be
used
to
help
determine
the
current
capabilities
of
MSDs
and
provide
information
for
determining
if
revisions
to
the
MSD
standards
or
other
program
modifications
are
necessary,
and
in
support
of
regulations
implementing
Title
XIV:
Certain
Alaskan
Cruise
Ship
Operations.

The
text
of
the
surveys
appears
in
Appendix
F.
The
surveys
will
be
conducted
as
face­

toface
interviews,
phone
interviews,
and
mail
solicitations.
The
specific
information
gathering
will
be
conducted
as
follows:

°
Boat
and
marina
owners
and
operators
will
be
interviewed
face­
to­
face.

°
State
and
local
government
officials
will
be
interviewed
over
the
phone.

°
MSD
manufacturers
and
U.
S.
Coast
Guard
accepted
independent
laboratories
will
be
21
contacted
via
mail.

The
first
section
of
the
survey
for
boat
owners
and
operators
seeks
information
regarding
the
size
of
their
boat
and
if
there
is
an
installed
toilet
on
it.
The
next
section
addresses
the
boating
activity
of
the
respondent
and
whether
there
were
functional
pump­
out
facilities
available.
Lastly,
the
survey
seeks
information
regarding
boater
awareness
of
NDZs,
and
if
the
boater
believes
there
has
been
a
water
quality
change
since
the
water
body
was
designated
an
NDZ.

The
survey
for
marina
owners
and
operators
will
gather
information
regarding
the
size
of
the
marina
and
the
services
it
provides;
pump­
out
facility
operations
and
capacity;
roles
and
responsibilities
of
the
marina
in
advertizing
that
the
water
body
associated
with
the
marina
is
a
NDZ;
whether
the
marina
has
enforcement
responsibilities;
what
role
the
State
in
which
the
marina
is
located
has
in
the
implementation
of
the
NDZ;
and
if
the
marina
owner/
operator
has
observed
water
quality
changes
since
the
water
body
was
designated
an
NDZ.

The
survey
for
State
and
local
government
officials
seeks
water
quality
data
associated
with
the
NDZ.
It
also
addresses
roles
and
responsibilities
of
the
State
in
implementing
the
NDZ.

The
survey
for
the
MSD
manufacturers
and
U.
S.
Coast
Guard
accepted
independent
laboratories
seeks
information
on
the
type
of
device
manufactured
or
certified,
its
pretreatment
and
primary
treatment
processes,
and
the
performance
of
the
device
in
removing
particular
22
constituents.
The
MSD
manufacturers
and
labs
will
be
asked
to
gather
and
provide
data
for
each
device
manufactured
or
tested.

Recordkeeping.

This
is
a
one
time
information
collection
effort.
There
will
be
no
need
for
any
of
the
respondents
to
maintain
records
or
submit
proprietary
trade
secrets.
For
boat
owners
and
operators,
this
request
seeks
information
regarding
the
boater's
behavior
and
their
understanding
of
the
requirements
of
the
NDZ.
The
marina
owners
and
operators
survey
seeks
information
characterizing
the
particular
marina,
the
availability
of
pump­
out
facilities
and
services,
and
their
awareness
of
the
NDZ
requirements.
Neither
of
these
entities
are
required
to
produce
or
provide
records.
Even
though
the
information
requested
from
State
and
local
governments
and
the
MSD
manufacturers
and
U.
S.
Coast
Guard
Labs
include
reports
and
other
data,
that
information
should
already
be
available.
This
request
does
not
require
these
entities
to
develop
reports.

SECTION
5.
The
Information
Collected
 
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
Agency
activities
associated
with
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices
include:

°
Development
of
Federal
Register
notices;

°
Development
of
survey
instruments;
23
°
Development
of
ICR;

°
Review
by
OEI;

°
Training
of
surveyors;

°
Execution
of
surveys;

°
Input
and
maintenance
of
the
gathered
data;

°
Analysis
of
the
data
gathered
during
the
surveys;

°
Preparation
of
a
Report;
and
°
Presentation
of
findings
to
EPA
and
other
interested
parties.

5(
b)
Collection
Methodology
and
Management
The
data
collection
for
this
project
will
be
accomplished
by
a
number
of
approaches
depending
on
the
entities
targeted
for
the
particular
survey.
The
surveys
will
be
conducted
as
face­
to­
face
interviews,
phone
interviews,
and
mail
solicitations
as
follows:

°
Boat
and
marina
owners
and
operators
will
be
interviewed
face­
to­
face.
The
interviewer
will
ask
the
questions
and
collect
the
responses.
In
certain
instances
where
the
respondent
is
unavailable
or
refuses
to
participate
in
an
interview,
the
respondent
will
be
allowed
to
write
his/
her
own
responses.
Those
surveys
will
be
identified
to
reflect
they
were
completed
by
the
boater
without
the
interviewer
being
present.
These
surveys
will
either
be
mailed
in
or
returned
by
the
respondent
at
a
later
time.
The
interviews
will
be
conducted
over
a
weekend
(
between
Saturday
morning
and
Sunday
evening).
24
°
State
and
local
government
officials
will
be
interviewed
over
the
phone.
The
interviewer
will
ask
the
questions
and
collect
the
responses.
In
some
cases,
the
respondent
will
be
asked
to
provide
additional
information
either
by
email
or
regular
mail
at
a
later
date.
The
interviewer
will
continue
to
call
potential
respondents
until
he/
she
has
the
appropriate
individual.
Followup
phone
calls
may
be
conducted
to
remind
the
respondent
to
complete
the
survey.

°
MSD
manufacturers
and
U.
S.
Coast
Guard
accepted
independent
laboratories
will
be
contacted
via
mail.
The
questionnaire
will
be
completed
by
the
respondent,
and
he/
she
will
be
given
a
finite
period
of
time
to
complete
the
questionnaire.
Followup
phone
calls
may
be
conducted
to
remind
the
respondent
to
complete
the
survey.

The
following
process
is
being
used
to
ensure
that
the
data
are
of
the
quality
that
supports
this
statistically
valid
study.

°
Each
survey
instrument
has
been
reviewed
by
EPA
staff
familiar
with
the
vessel
sewage
discharge
program,
by
EPA
staff
that
have
peripheral
interest
in
the
issues
associated
with
the
program,
and
other
Agency
staff
with
particular
expertise
in
designing
and
analyzing
data
from
this
type
of
survey.
These
reviews
will
ensure
that
the
surveys
are
clear
and
unambiguous,
and
that
they
will
elicit
the
information
intended
to
be
collected.

°
The
survey
instruments
and
sampling
protocols
were
carefully
designed
to
ensure
that
the
process
results
in
a
statistically
valid
sample
that
addresses
EPA's
information
needs.

°
Interviewer
training
sessions
designed
specifically
for
this
project
will
be
held
to
ensure
25
consistent
and
accurate
data
gathering
that
corresponds
to
the
survey
design.

°
The
contractor
is
experienced
in
data
analysis,
problem
specification,
and
output
interpretation.

°
The
contractor
will
provide
necessary
support
to
ensure
data
quality
and
survey
objectives
are
met.

°
Return
postage
will
be
paid
by
EPA
for
the
surveys
that
are
mailed
and
must
be
returned
to
the
contractor
by
mail.

The
data
collected
from
the
surveys
will
be
stored
in
various
databases.
Data
from
the
boat
and
marina
owners
and
operators
and
the
State
and
local
government
surveys
will
be
stored
in
a
database
and
analyzed
statistically
to
determine
the
effectiveness
of
NDZs.
Data
from
the
MSD
surveys
will
be
stored
in
a
separate
database
and
used
to
analyze
the
current
performance
of
MSDs
for
potential
future
MSD
standards
modifications
and
for
current
promulgation
of
regulations
implementing
Title
XIV:
Certain
Alaskan
Cruise
Ship
Operations.

5(
c)
Small
Entity
Flexibility
Information
will
be
collected
from
small
businesses.
EPA
believes
that
the
small
businesses
will
consist
of
the
MSD
manufacturers,
U.
S.
Coast
Guard
accepted
independent
laboratories,
and
marinas.
EPA
will
minimize
the
burden
on
MSD
manufacturers,
and
U.
S.
Coast
Guard
accepted
independent
laboratories
by
requesting
only
available
data
in
the
format
in
which
it
is
maintained.
That
is,
EPA
will
not
ask
the
respondents
to
collect
new
information
or
re­
work
existing
data
into
an
EPA­
specified
format.
EPA
is
designing
the
surveys
to
be
clear
and
easy
to
26
follow.
Most
of
surveys
require
a
multiple
choice
or
"
yes/
no"
selection.
Survey
questions
that
require
additional
information,
EPA
will
accept
that
information
in
any
form
that
the
respondent
wishes
to
submit
it.
At
this
time,
EPA
is
uncertain
how
many
small
businesses
there
might
be
among
MSD
manufacturers
or
U.
S.
Coast
Guard
accepted
independent
laboratories.
However,

EPA
will
seek
to
limit
the
burden
on
those
respondents
by
tailoring
each
MSD
manufacturer
questionnaire
package
to
identify
MSDs
that
may
be
manufactured
by
that
company.
Each
laboratory
questionnaire
package
will
include
a
copy
of
the
U.
S.
Coast
Guard
equipment
list.

That
list
will
provide
the
labs
with
an
inventory
of
those
devices
that
have
been
certified.
This
list
may
help
them
determine
which
devices
they
may
have
provided
data
for
during
the
device's
certification
by
the
U.
S.
Coast
Guard.
Return
postage
will
be
paid
by
EPA
for
the
surveys
that
are
to
be
returned
to
EPA.

EPA
will
minimize
the
burden
on
marinas
by
designing
the
surveys
to
be
clear
and
easy
to
follow.
Most
of
surveys
require
a
multiple
choice
or
"
yes/
no"
selection.
Survey
questions
that
require
additional
information,
EPA
will
accept
that
information
in
any
form
that
the
respondent
wishes
to
submit
it.
The
surveys
will
be
conducted
face­
to­
face.
The
respondents
will
not
have
to
read
them
(
except
for
those
instances
were
the
respondent
could
not
participate
in
a
face­

toface
survey
but
wanted
to
participate
otherwise).
Also,
return
postage
will
be
paid
by
EPA
for
the
surveys
that
are
to
be
returned
to
EPA.
Maps
depicting
where
the
NDZs
are
located
will
be
provided
to
marinas
if
appropriate.
27
5(
d)
Collection
Schedule
The
proposed
timeline
for
the
data
collection
is
as
follows.
The
marina
and
boat
owner
and
operator
surveys
will
be
conducted
over
weekends
in
late
August
through
September,
2003.

These
surveys
will
be
conducted
face­
to­
face
except
for
those
that
will
be
either
returned
later
that
day
or
mailed
in.
EPA
will
not
accept
marina
or
boat
owner
and
operator
surveys
after
one
month
from
the
date
that
the
respondent
received
it.
The
MSD
manufacturer,
U.
S.
Coast
Guard
accepted
independent
lab,
and
State
surveys
will
be
sent
to
the
potential
respondents
in
late
August,
2003.
The
respondents
will
be
asked
to
return
the
completed
surveys
within
one
month,

thus,
EPA
expects
to
have
all
of
them
by
late
October,
2003.
Analysis
of
the
information
will
began
in
November,
2003
and
will
be
completed
in
February.

SECTION
6.
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a­
b)
Estimating
Respondent
Burdens
and
Costs
This
information
collection
does
not
involve
any
special
equipment,
thus
respondents
will
not
incur
any
capital
or
operation
and
maintenance
(
O
&
M)
costs.
All
hourly
rates
are
based
on
the
"
Total
Compensation,
all
workers,
all
civilian,
2003,"
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics,
Employer
Costs
for
Employee
Compensation.
It
includes
employer
costs
of
all
employee
benefits.

The
boat
owner
and
operator
survey
is
designed
to
take
less
than
10
minutes
to
complete.

It
was
pre­
tested
among
EPA
staff
and
was
completed
in
under
10
minutes
consistently.
It
will
be
pre­
tested
using
actual
boaters
to
establish
a
more
realistic
completion
time.
As
illustrated
in
28
Table
1,
EPA
conservatively
estimates
that
it
will
take
an
average
of
15
minutes
to
complete
the
survey.
With
a
total
of
1200
respondents,
this
involves
a
total
of
300
hours.
Based
on
an
average
hourly
rate
of
$
23.66,
EPA
expects
that
the
average
per­
respondent
cost
of
the
survey
will
be
$
5.92
and
the
corresponding
one­
time
total
cost
for
all
boating
respondents
will
be
$
7098.

Table
2
illustrates
the
average
annual
respondent
burden
and
costs
for
marina
owners
and
operators
to
complete
the
survey.
This
survey
was
pre­
tested
among
EPA
staff
and
was
completed
in
under
10
minutes
consistently,
and
it
will
be
pre­
tested
with
actual
marina
owners
and
operators
to
establish
a
more
realistic
completion
time.
EPA
conservatively
estimates
that
it
will
take
an
average
of
15
minutes
to
complete
the
survey.
With
a
total
of
75
respondents,
this
involves
a
total
of
19
hours.
Based
on
an
average
hourly
rate
of
$
23.66,
EPA
expects
that
the
average
per­
respondent
cost
for
this
survey
will
be
$
5.92
and
the
corresponding
one­
time
total
cost
for
all
marina
owner/
operator
respondents
will
be
$
444.

Tables
3
and
4
illustrate
the
average
annual
respondent
burden
and
costs
for
MSD
manufacturers
and
U.
S.
Coast
Guard
accepted
independent
laboratories.
EPA
estimates
that
the
average
completion
time
for
these
surveys
will
be
2
hours.
With
a
total
of
30
respondents
for
the
manufacturers
and
7
respondents
for
the
labs,
this
will
involve
a
total
of
60
and
14
hours,

respectively.
Based
on
an
hourly
rate
of
$
29.42,
EPA
expects
that
the
average
per­
respondent
cost
for
these
surveys
will
be
$
58.84.
EPA
estimates
that
the
corresponding
one­
time
total
cost
for
the
MSD
manufacturers
and
the
labs
will
be
$
1,765
and
$
412,
respectively.

The
average
annual
respondent
burden
and
costs
for
the
completion
of
the
survey
for
29
State
and
local
government
officials
is
provided
in
Table
5.
EPA
estimates
that
the
average
completion
time
for
this
survey
will
be
1.5
hours.
With
a
total
of
54
respondents
for
the
State
and
local
government
officials,
EPA
estimates
that
it
will
involve
a
total
of
81
hours.
Based
on
an
hourly
rate
of
$
41.17,
EPA
expects
that
the
average
per­
respondent
cost
for
this
survey
will
be
$
61.76,
and
the
one­
time
total
cost
for
all
State
and
local
government
respondents
will
be
$
3335.

6(
c)
Estimating
Agency
Burden
and
Costs
Survey
implementation
will
be
conducted
through
a
contractor.
The
burden
and
costs
associated
with
the
Agency's
responsibilities
in
implementing
the
surveys
include:
Federal
Register
development,
survey
design,
ICR
development,
surveyor
training,
survey
implementation,
data
input
and
storage,
data
analysis,
report
preparation,
and
findings
dissemination.

Table
6
illustrates
the
average
annual
respondent
burden
and
cost
for
EPA
to
develop
and
implement
all
of
the
surveys.
The
total
burden
for
this
effort
will
be
7,146
hours
resulting
in
a
total
cost
of
$
281,642.
EPA
estimates
that
the
total
cost
will
include
startup/
capital
and
operations
and
maintenance
costs
of
$
500
each,
for
a
total
of
$
1,000.
These
costs
are
for
the
developing
the
database
and
purchasing
and
operating
the
software
to
analyze
the
data.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
EPA
expects
completed
surveys
from
1,366
respondents.
Table
7
illustrates
the
total
30
burden
of
474
hours
and
a
total
cost
of
$
13,053
for
all
respondents.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
and
cost
is
illustrated
in
Table
8.
The
total
burden
for
this
effort
is
7,146
hours
with
a
total
cost
of
$
295,696.

6(
f)
Reasons
for
Change
in
Burden
Not
applicable
6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
21
minutes
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
Agency.
This
includes
the
time
needed
to
review
instructions,
develop,
acquire,

install
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;

adjust
the
existing
ways
to
comply
with
any
previous
applicable
instructions
and
requirements;

train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
information.
An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
current
valid
OMB
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
31
To
receive
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OW­
2003­
0014
,
which
is
available
for
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Water
Docket
is
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
to
access
the
index
listing
or
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.(
OW­
2003­
0014)
in
any
correspondence.
32
Table
1.
Average
Annual
Respondent
Burden
and
Costs
 
Boat
Owners
and
Operators
Hours
and
Costs
Per
Respondent
Estimated
Total
Hours
and
Cost
Respondent
Hourly
Rate
($
23.66
/
hour)
Respondent
Time
Burden
(
Hours
/
year)
Labor
Cost
(
Dollars
/

year)
Capital
/

Startup
Cost
($)
O
&
M
Cost
($)
Number
of
Respondents
Total
Time
Burden
(
Hours
/

year)
Total
Cost
(
Dollars
/

year)

Complete
Questionnaire
23.66
.25
5.92
0
0
1,200
300
7,098
Table
2.
Average
Annual
Respondent
Burden
and
Costs­
Marina
Owners
and
Operators
Hours
and
Costs
Per
Respondent
Estimated
Total
Hours
and
Cost
Respondent
Hourly
Rate
($
23.66/
hour)
Respondent
Time
Burden
(
Hours/
year)
Labor
Cost
(
Dollars/
y
ear)
Capital/

Startup
Cost
($)
O
&
M
Cost
Number
of
Respondents
Total
Time
Burden
(
Hours/
year)
Respondent
Hourly
Rate
($
23.66
/

hour)

Complete
Questionnaire
23.66
.25
5.92
0
0
75
19
444
Table
3.
Average
Annual
Respondent
Burden
and
Costs
 
U.
S.
Coast
Guard
Accepted
Independent
Laboratories
33
Hours
and
Costs
Per
Respondent
Estimated
Total
Hours
and
Cost
Respondent
Hourly
Rate
($
29.42/
hour)
Respondent
Time
Burden
(
Hours/
year)
Labor
Cost
(
Dollars/
ye
ar)
Capital/

Startup
Cost
($)
O
&
M
Cost
($)
Number
of
Respondents
Total
Time
Burden
(
Hours/
year
)
Total
Cost
(
Dollars
/
year)

Read
Questionnaire
29.42
0.16
4.71
0
0
30
4.8
141
Gather
data
for
each
device
29.42
1.25
36.78
0
0
30
37.5
1103
Complete
Questionnaire
29.42
0.59
17.36
0
0
30
17.7
521
Total
2.00
58.84
0
0
30
60
1,765
Table
4.
Average
Annual
Respondent
Burden
and
Costs
 
U.
S.
Coast
Guard
Accepted
Independent
Laboratories
Hours
and
Costs
Per
Respondent
Estimated
Total
Hours
and
Cost
Respondent
Hourly
Rate
($
29.42/
hour)
Respondent
Time
Burden
(
Hours/
year)
Labor
Cost
(
Dollars/
y
ear)
Capital/

Startup
Cost
($)
O
&
M
Cost
($)
Number
of
Respondents
Total
Time
Burden
(
Hours/
year
)
Total
Cost
(
Dollars
/
year)

Read
Questionnaire
29.42
.16
4.71
0
0
7
1.12
33
Gather
Data
for
Each
Device
29.42
1.25
36.78
0
0
7
8.75
257
Complete
Questionnaire
29.42
.59
17.36
0
0
7
4.13
122
Total
2.00
58.84
0
0
7
14
412
34
Table
5.
Average
Annual
Respondent
Burden
and
Costs
 
State
and
Local
Government
Officials
Hours
and
Costs
Per
Respondent
Estimated
Total
Hours
and
Cost
Respondent
Hourly
Rate
($
41.17/
hour)
Respondent
Time
Burden
(
Hours/
year)
Labor
Cost
(
Dollars/
y
ear)
Capital/

Startup
Cost
($)
O
&
M
Cost
($)
Number
of
Respondents
Total
Time
Burden
(
Hours/
year
)
Total
Cost
(
Dollars
/
year)

Read
Questionnaire
41.17
0.16
6.59
0
0
54
8.64
356
Gather
Data
for
Each
NDZ
41.17
0.50
20.59
0
0
54
27.00
1112
Complete
Questionnaire
41.17
0.84
34.58
0
0
54
45.36
1867
Total
41.17
1.50
61.76
0
0
54
81
3,335
35
Table
6.
Average
Annual
Respondent
Burden
and
Costs
 
Agency
Hours
and
Costs
Per
Respondent
Estimated
Total
Hours
and
Cost
Time
(
hours)
EPA
Hours
Survey
Researcher
Hours
Computer
Hours
Capital/

Startup
Cost
($)
O
&
M
Cost
($)
Number
of
Respondents
Total
Hours/
year
Total
Cost
(
Dollars
/
year)

EPA
Cost
($
53.82
/
hour)
Researcher
Cost
($
42.56
/
hour)
Computer
Cost
($
42.38
/
hour)

Develop
1st
FR
12
12
0
0
0
0
1
12
646
645.80
0
0
Design
Survey
320
160
160
0
0
0
1
320
15,421
8611.20
6809.60
0
Develop
ICR
300
120
180
0
0
0
1
300
14,119
6458.40
7660.80
0
OEI
Review
80
80
0
0
0
0
1
80
4,306
4305.6
0
0
Develop
2nd
FR
40
40
0
0
0
0
1
40
2,153
2152.80
0
0
Train
Surveyors
120
80
40
0
0
0
1
120
6,008
1291.68
1021.44
0
Implement
Survey
4000
200
3,800
0
0
0
1
4000
172,492
1291.68
70479.36
0
36
Input
and
Store
Data
200
0
0
200
500
500
1
200
9,476
0
0
8476
Analyze
Data
800
120
400
280
0
0
1
800
35,349
6,458
17,024
11,866
Prepare
Report
700
100
350
250
0
0
1
700
30,873
5,382
14,896
10,595
Disseminate
Findings
100
60
40
0
0
0
1
100
4,932
3229
1702
0
Totals
6672
972
4970
730
500
500
1
6672
282,642
39,181
211,523
30937
Table7.
Average
Annual
Respondent
Burdens
and
Costs
Composite
Entity
Number
of
Respondents
Hours
Costs
($)

Boaters
1,200
300
7,098
Marinas
75
19
444
MSD­
Manufacturers
30
60
1,765
MSD­
US
Coast
Guard
Accepted
Independent
Labs
7
14
412
State
and
Local
Government
Officials
54
81
3,335
Totals
1,366
474
13,053
37
Table
8.
Average
Annual
Burdens
and
Costs
Composite
 
All
Entities
Entity
Affected
Entities
Hours
Costs
($)

Boaters
1,200
300
7,098
Marinas
75
19
444
MSD­
Manufacturers
30
60
1,765
MSD­
US
Coast
Guard
Accepted
Independent
Labs
7
14
412
State
and
Local
Government
Officials
54
81
3,335
EPA
1
6,672
282,642
Totals
1,367
7,146
295,696
38
Part
B
SECTION
1:
Survey
Objectives,
Key
Variables,
and
Other
Preliminaries
1(
a)
Survey
Objectives
EPA
regulates
vessel
sewage
discharge
under
Clean
Water
Act
(
CWA)
Section
312.
The
statute
mandates
that
EPA
set
standards
for
the
performance
of
marine
sanitation
devices
(
MSDs)
 
on
board
equipment
for
treating
and
discharging
or
storing
sewage
 
on
all
commercial
and
recreational
vessels.
Section
312
also
provides
for
the
designation
of
no­
discharge
zones
(
NDZs),
where
the
discharge
of
sewage
from
vessels,
whether
treated
or
not,
is
prohibited.
Three
types
of
NDZ
may
be
established
under
the
statute:

°
Under
CWA
Section
312(
f)(
3),
a
State
may
establish
an
NDZ
if
it
determines
that
the
protection
and
enhancement
of
the
quality
of
such
waters
require
greater
environmental
protection.
In
order
for
a
State
NDZ
to
be
effective,
EPA
must
determine
that
adequate
facilities
for
the
safe
and
sanitary
removal
and
treatment
of
sewage
are
reasonably
available.

°
Under
CWA
Section
312(
f)(
4)(
A),
EPA
may
establish
an
NDZ
by
regulation
upon
the
request
of
a
State
if
EPA
determines
that
the
protection
and
enhancement
of
the
quality
of
such
waters
require
such
a
prohibition.
Adequate
facilities
for
the
safe
and
sanitary
removal
and
treatment
of
sewage
are
not
required
for
such
an
NDZ
to
be
effective.

°
Under
CWA
Section
312(
f)(
4)(
B),
EPA
may
establish
a
drinking
water
intake
zone
by
regulation
upon
the
request
of
a
State
and
prohibit
the
discharge
of
sewage
from
vessels
within
that
zone.
Adequate
facilities
for
the
safe
and
sanitary
removal
and
treatment
of
sewage
are
not
required
for
such
an
NDZ
to
be
effective.
39
Since
1976,
50
NDZs
have
been
designated
nationwide;
47
of
these
have
been
designated
under
CWA
312(
f)(
3);
2
have
been
designated
under
312(
f)(
4)(
A);
and
1
has
been
designated
under
312(
f)(
4)(
B).

This
Information
Collection
Request
includes
three
statistical
surveys
to
gather
information
on
the
effectiveness
of
NDZs
established
by
States
under
CWA
Section
312(
f)(
3),

and
two
census
surveys
to
gather
information
on
MSD
performance.

Three
aspects
of
NDZ
effectiveness
will
be
evaluated.
The
first
aspect
is
awareness
of
and
compliance
with
NDZ
requirements.
The
second
aspect
is
effectiveness
of
NDZs
in
addressing
water
quality
issues.
The
third
aspect
is
enforcement
of
NDZ
requirements.
For
an
NDZ
to
be
effective,
boat
owners
and
operators
must
comply
with
the
no
discharge
requirement,
and
marina
owners
and
operators
must
supply
pumpout
services.
EPA
will
ask
boat
owners/
operators
and
marina
owners/
operators
about
their
experience
with
NDZs
and
pumpout
facilities.
EPA
will
also
request
NDZ
water
quality
data
already
collected
by
State
and
local
governments.

Surveys
will
also
be
sent
to
all
MSD
manufacturers
and
independent
testing
laboratories
to
evaluate
MSD
performance.
These
surveys
will
help
to
identify
the
current
universe
of
MSDs
and
gather
performance
data
(
i.
e.,
removal
or
pathogens,
suspended
solids,
and
other
pollutants)
on
all
MSDs
certified
for
use
on
U.
S.
waters.
Because
these
surveys
are
designed
to
gather
information
on
all
MSDs
from
all
manufacturers,
these
are
not
statistical
surveys,
and
will
not
be
discussed
in
the
remainder
of
this
section.
40
1(
b)
Key
Variables
For
our
assessment
of
NDZ
effectiveness,
key
variables
differ
according
to
whether
the
respondent
is
a
boat
owner/
operator,
a
marina
owner/
operator,
or
a
State/
local
government.

Accordingly,
EPA
developed
a
unique
survey
instrument
for
each
group.
The
survey
variables,

discussed
in
detail
in
Section
2(
d),
are
designed
to
address
the
issue
of
whether
NDZs
established
under
CWA
section
312(
f)(
3)
are
effective
at
keeping
vessel
sewage
out
of
the
water
by
evaluating
three
key
questions:

°
Are
adequate
pumpout
facilities
available
in
NDZs,
and
if
not,
why
not?

°
Are
boaters
using
available
pumpout
facilities
in
NDZs,
and
if
not,
why
not?

°
Are
NDZs
effective
in
addressing
water
quality
issues
based
on
indicators
such
as
shellfish
bed
health,
beach
closures,
water
quality
monitoring
data,
or
other
appropriate
measures?

1(
c)
Statistical
Approach
EPA
evaluated
two
options
other
than
a
statistical
approach
for
information
collection
on
NDZ
effectiveness.
EPA
rejected
the
first
alternative
 
anecdotal
evidence
 
because
of
a
potential
for
bias,
e.
g.,
anecdotes
are
given
only
when
there
are
difficulties
in
complying
with
NDZ
requirements.
EPA
considered
a
second
alternative
 
a
census
of
all
boaters
living
within
a
certain
distance
of
an
NDZ
 
but
discarded
the
approach
because
the
Agency
could
identify
no
method
of
stratifying
the
boat
owner/
operator
population
by
whether
they
boated
in
an
NDZ
or
not.
In
addition,
while
a
census
approach
would
provide
more
complete
information,
such
an
approach
is
prohibitively
expensive.
EPA
therefore
determined
that
a
statistically
designed
sample
survey
would
result
in
inferences
and
analyses
that
are
as
unbiased
and
as
precise
as
practicable.
41
These
surveys
have
been
designed
and
will
be
implemented
with
the
assistance
of
a
contractor.
Battelle
will
provide
assistance
under
EPA
Contract
No.
68­
C­
03­
041
through
its
subcontractor
ERG,
Inc.
(
110
Hartwell
Avenue,
Lexington,
Massachusetts
02421­
3136).
ERG
is
also
responsible
for
compiling
the
data
collected
in
the
boat
owner/
operator
and
marina
owner/
operator
surveys
into
electronic
form
and
tabulating
the
data.
For
the
State/
local
government
survey,
ERG
will
perform
telephone
interviews
and
request
available
water
quality
data.

1(
d)
Feasibility
The
survey
instrument(
s)
have
been
carefully
designed
and
will
be
pre­
tested
on
boat
owners/
operators
and
marina
owners/
operators
prior
to
initiating
the
full
survey
effort.
The
sampling
methods
 
personal
and
telephone
interviews
 
have
been
chosen
to
maximize
the
response
and
completion
rates,
and
to
ensure
that
the
data
are
collected
within
the
available
time
frame.

°
EPA
designed
the
surveys
to
be
clear
and
easy
to
follow.
Most
of
surveys
require
a
multiple
choice
or
"
yes/
no"
selection.
For
surveys
that
request
additional
information,

EPA
will
accept
that
information
in
any
form
that
the
respondent
wishes
to
submit
it.

Most
often
this
may
be
copies
of
developed
reports.
Where
appropriate,
maps
will
be
provided
so
that
the
respondent
will
know
where
the
area
of
interest
(
i.
e.,
the
NDZ)
is
located.
Return
postage
will
be
paid
by
EPA
for
the
surveys
that
are
mailed.
The
boater
and
marina
owner/
operator
surveys
will
be
conducted
face­
to­
face.
The
respondents
will
not
have
to
read
them
(
except
for
those
instances
were
the
respondent
wishes
to
write
in
42
responses).

°
EPA
has
sufficient
funding
to
complete
the
surveys.

°
EPA
has
designed
the
surveys
to
be
executed
during
the
late
Summer
and
early
Fall
of
2003.
This
schedule
was
chosen
because
the
experiences
of
boaters
and
marina
owners
and
operators
during
the
recent
boating
season
would
most
likely
be
captured.
We
anticipate
that
the
analysis
will
be
completed
during
the
winter
of
2003/
2004.
Therefore,

potential
program
modification
decisions
may
be
made
or
announced
prior
to
the
next
boating
season.

SECTION
2:
Survey
Design
for
the
Statistical
Approach
This
information
collection
request
includes
three
separate
but
related
questionnaire
instruments
that
are
part
of
the
statistical
design:
(
1)
boat
owners/
operators
survey;
(
2)
marina
owners/
operators
survey;
and
(
3)
States/
local
governments
survey.
The
procedures
for
collecting
information
associated
with
each
instrument
are
detailed
below.

2(
a)
Target
Population
and
Coverage
The
purpose
of
these
surveys
is
to
assess
the
effectiveness
of
NDZs
established
under
CWA
section
312(
f)(
3)
by
evaluating
whether
adequate
pumpout
facilities
are
available
and
whether
boaters
are
using
available
pumpout
facilities.
In
order
to
do
this,
we
will
survey
boat
owners/
operators,
marina
owners/
operators,
and
State
and
local
government
officials.
The
target
populations
are:
43
°
Boat
owners/
operators
who
own
boats
with
toilets
(
MSDs)
and
who
must
comply
with
NDZ
requirements
(
i.
e.,
who
boat
in
at
least
one
NDZ);

°
Marina
owners
and
operators
located
in
NDZs
who
supply
the
pumpout
services
that
allow
boaters
to
meet
the
no­
discharge
requirements;
and
°
State
and
local
government
officials
that
designate
NDZ(
s),
collect
information
about
water
quality
associated
with
the
NDZ(
s),
enforce
NDZ
prohibitions,
and/
or
develop
outreach
materials
to
promote
NDZ(
s).

There
are
47
NDZs
established
under
CWA
section
312(
f)(
3).
Due
to
resource
constraints,
we
will
be
interviewing
boater
owners/
operators,
marina
owners/
operators
and
State/
local
government
officials
at
14
of
these
NDZs.
In
order
to
ensure
adequate
geographic
coverage,
two
NDZs
will
be
chosen
from
each
of
the
following
regions:

°
Northern
Atlantic
A
(
Massachusetts,
New
Hampshire),

°
Northern
Atlantic
B
(
Rhode
Island),

°
Mid­
Atlantic
(
New
York,
New
Jersey),

°
South
Atlantic
A
(
Maryland,
Virginia),

°
South
Atlantic
B
(
North
Carolina,
South
Carolina,
Georgia,
Florida),

°
California,
and
°
Great
Lakes
(
Michigan).

These
regions
have
been
chosen
based
on
their
coastal
tidal
and
Great
Lakes
locations.

The
majority
of
NDZs
are
located
on
the
East
Coast
and
off
the
coast
of
California.
There
are
44
very
few
in
the
Gulf
of
Mexico.

Because
we
are
also
interested
in
any
potential
differences
between
older
and
newer
NDZs,
we
will
be
choosing
one
"
old"
NDZ
(
established
more
than
10
years
ago)
and
one
"
new"

NDZ
(
established
between
1
and
10
years
ago)
from
each
region.
In
other
words,
for
each
region,
all
NDZs
will
be
identified
and
will
be
categorized
as
"
old"
or
"
new;"
then
one
NDZ
from
each
age
category
in
each
region
will
be
randomly
chosen
for
assessment.

For
each
NDZ
chosen
for
assessment,
we
will
be
interviewing
5
randomly
chosen
marinas,

and
at
least
72
boaters
(
spread
across
all
5
marinas;
see
Sample
Design
below
for
details).
While
we
may
interview
up
to
4
State/
local
government
officials
to
collect
information,
there
will
only
be
one
State/
local
government
summary
survey
response
for
each
NDZ
chosen
for
assessment.

NDZs
can
also
be
designated
under
CWA
Section
312(
f)(
4).
Only
three
such
zones
have
been
designated,
hence
the
population
is
too
small
to
include
within
this
sampling
effort.

However,
EPA
will
perform
the
three
surveys
at
the
Florida
Keys
National
Marine
Sanctuary
as
a
case
study.

2(
b)
Sample
Design
2(
b)(
i)
Sampling
Frame
The
sampling
frame
is
the
set
of
potential
respondents
from
which
the
sample
will
be
drawn.
45
Boat
owners/
operators
The
sampling
frame
for
boat
owners/
operators
is
all
boat
owners/
operators
who
have
boats
with
toilets
(
MSDs)
and
who
operate
their
boats
within
one
of
the
14
NDZs
chosen
for
assessment.
Because
there
is
no
reliable
list
of
such
boaters,
EPA
is
using
an
intercept
sampling
method
(
i.
e.,
interviewing
boaters
at
marinas
within
the
chosen
NDZs)
to
identify
such
boaters.

Marina
owners/
operators
The
sampling
frame
for
marina
owners/
operators
is
all
owners/
operators
of
marinas
that
provide
pump­
out
services
within
each
of
the
14
NDZs
chosen
for
assessment.
We
will
compile
these
lists
from
the
lists
of
marinas
provided
to
EPA
by
States
when
the
NDZs
were
established
(
EPA
requires
States
to
provide
a
listing
of
such
marinas
in
order
to
make
its
determination
that
adequate
pumpout
facilities
are
available),
from
personal
knowledge
of
EPA
regional
staff
and
State
staff,
from
lists
available
on
State
internet
sites,
and
from
books
for
vacationers.

State/
local
Governments
The
sampling
frame
for
State/
local
governments
is
the
State
government
that
established
the
NDZ
and
any
local
governments
that
share
responsibility
with
the
States
in
collecting
information
about
water
quality
associated
with
the
NDZ(
s),
enforcing
NDZ
prohibitions,
and/
or
developing
outreach
materials
to
promote
NDZ(
s).
The
State
government
official
for
each
NDZ
is
available
from
the
original
application
materials
for
the
NDZ;
local
government
contacts
will
be
requested
from
the
State
government
officials.
46
2(
b)(
ii)
Sample
Size
Boat
owners/
operators
The
sample
size
for
boat
owners/
operators
is
at
least
76
per
NDZ
for
a
total
of
at
least
1064
respondents.
In
theory,
choosing
a
sample
size
for
use
in
a
cluster
sampling
design
like
this
requires
taking
into
account
variability
at
the
sampling
unit
level
(
e.
g.,
boaters)
and
at
the
cluster
levels
(
e.
g.,
marinas).
There
are
well­
developed
methods
for
choosing
cluster
sample
sizes.
All
of
these
methods
fit
into
the
general
sample
selection
framework:
choose
a
sample
size
that
meets
certain
criteria
(
precision
and
confidence)
while
accounting
for
the
relevant
variability.
The
methods
used
to
choose
cluster
sample
sizes,
however,
require
significant
a
priori
information
on
the
population
and
the
clusters,
including:

44.
Variability
among
the
population
units
(
boaters);

45.
Variability
within
each
cluster
(
each
marina);
and
46.
Variability
between
each
cluster.

None
of
this
information
is
available
for
the
populations
of
interest
in
this
case.
However,

we
can
estimate
sample
size
for
a
cluster
design
by
estimating
sample
size
for
a
simple
random
sample
(
SRS)
case,
and
then
multiplying
this
value
by
a
"
design
effect."
The
design
effect
for
a
cluster
sample
is
the
ratio
of
the
variance
from
the
cluster
sample
to
the
variance
of
an
SRS
for
a
given
sample
size.
In
other
words,
it
tells
you
how
much
more
variable
a
cluster
sample
of
size
N
will
be
compared
to
a
SRS
of
size
N.
Additionally,
it
can
be
shown
mathematically
that
multiplying
a
SRS
sample
size
by
the
design
effect
will
result
in
a
cluster
sample
size
that
has
the
same
precision
and
confidence
as
the
SRS
sample
size.
47
To
estimate
the
minimum
sample
size
for
the
SRS
case,
we
assumed
that
the
"
test"
case
is
where
there
is
maximum
variability.
For
a
yes/
no
question,
maximum
variability
occurs
when
50
%
of
the
population
would
answer
yes
and
50
%
would
answer
no.
At
a
confidence
level
of
90
%,
we
would
need
a
sample
size
of
38
to
obtain
a
precision
level
of
10
percentage
points
(
i.
e.,
the
ratio
of
yes/
no
answers
in
the
sample
being
within
10
percentage
points
of
the
ratio
of
yes/
no
answers
in
the
population).

The
design
effect
most
commonly
applied
in
cluster
designs
such
as
the
one
we
are
using
is
2.
Multiplying
the
SRS
sample
size
of
38
by
the
design
effect
of
2
results
in
a
minimum
sample
size
of
76
boat
owner/
operator
surveys
per
NDZ.

Marina
owners/
operators
In
order
to
account
for
variability
among
different
marinas
in
an
NDZ,
we
will
attempt
to
sample
five
marinas
per
NDZ
for
a
total
of
60
marinas.
As
explained
below,
we
will
only
interview
boat
owners/
operators
at
(
or
nearby)
marinas
that
agree
to
answer
the
marina
owners/
operators
survey.
In
this
way,
we
will
be
better
able
to
compare
the
results
and
identify
problems
regarding
pumpout
availability.

State/
local
government
officials
While
there
will
only
be
one
State/
local
government
summary
survey
response
for
each
NDZ
chosen
for
assessment,
we
estimate
that
up
to
four
State/
local
government
officials
per
NDZ
may
be
contacted
to
gather
the
information,
for
a
total
of
56
contacts.
48
2(
b)(
iii)
Stratification
Variables
Stratification
is
a
method
used
to
segment
a
population
into
homogeneous
groups,
often
based
on
size
or
output.
We
will
be
stratifying
NDZs
by
their
age
(
i.
e.,
those
established
more
than
10
years
ago
and
those
established
between
1
and
10
years
ago).
There
may
be
an
effect
of
NDZ
"
age"
on
a
number
of
factors,
such
as
boater
awareness
of
the
NDZ
(
e.
g.,
more
boaters
may
be
aware
of
older
NDZs
because
there
has
been
more
time
for
outreach
and
education)
and
availability
of
pump­
out
facilities
(
e.
g.,
older
NDZs
may
have
fewer
pump­
out
facilities
because
more
time
has
elapsed
since
the
facilities
were
determined
to
be
adequate).

2(
b)(
iv)
Sampling
Method
The
sampling
method
is
the
set
of
rules
or
procedures
for
selecting
the
individuals,
or
"
sample,"
for
the
survey
from
the
sampling
frame.
Multi­
stage
sampling
is
a
method
for
selecting
the
sample
of
respondents
that
employs
more
than
one
sample
frame
and
sampling
procedure.

In
this
case,
we
are
using
multi­
stage
sampling.
In
the
first
stage,
14
NDZs
will
be
chosen
out
of
a
total
population
of
47.
In
order
to
ensure
adequate
geographic
coverage,
two
NDZs
will
be
chosen
from
each
of
seven
regions
around
the
country
(
see
section
2(
a)
above).
Because
we
are
also
interested
in
any
potential
differences
between
older
and
newer
NDZs,
we
will
be
choosing
one
"
old"
NDZ
(
established
more
than
10
years
ago)
and
one
"
new"
NDZ
(
established
between
1
and
10
years
ago)
from
each
region.
In
other
words,
for
each
region,
all
NDZs
will
be
identified
and
will
be
categorized
as
"
old"
or
"
new;"
then
one
NDZ
from
each
age
category
in
each
region
will
be
randomly
chosen
for
assessment.
49
For
each
NDZ
chosen
for
assessment,
we
will
randomly
choose
5
marinas
to
interview.
If
any
of
the
5
randomly
chosen
marinas
do
not
agree
to
answer
the
survey
questions,
we
will
randomly
resample
the
sampling
frame
until
we
have
5
marinas
willing
to
answer
the
survey
questions,
or
until
all
marinas
on
the
NDZ
have
been
exhausted.

We
will
ask
each
marina
answering
the
survey
questions
if
it
will
allow
us
to
interview
boaters
at
the
marina.
If
the
marina
allows
it,
we
will
interview
boaters
on
site.
If
the
marina
does
not
allow
it,
we
will
interview
boaters
at
a
nearby
public
location
(
for
which
we
will
arrange
permission).

Because
there
is
no
way
to
compile
a
reliable
list
of
boaters
in
our
sampling
frame
(
i.
e.,

boaters
with
experience
in
an
NDZ)
from
which
to
randomly
choose
potential
survey
respondents,

we
will
use
an
intercept
sampling
method
to
identify
respondents.
In
other
words,
we
will
approach
boaters
at
(
or
near)
marinas
in
each
NDZ.
This
will
ensure
that
boaters
who
answer
the
survey
questions
will
have
at
least
some
experience
boating
in
an
NDZ.
The
intercept
surveys
will
be
performed
over
weekends
to
maximize
the
potential
number
of
respondents.
There
will
be
a
booth
to
attract
boaters
to
answer
the
surveys;
interviewers
will
also
seek
additional
respondents
throughout
the
marina.
We
will
attempt
to
get
at
least
14
or
15
respondents
per
marina.

2(
c)
Precision
Requirements
2(
c)(
i)
Precision
Targets
EPA
is
performing
the
survey
because
the
effectiveness
of
NDZs
is
not
known.
That
is,

the
"
true"
value
of
any
variable
within
the
survey
is
not
known
and,
hence,
it
is
difficult,
if
not
50
impossible
to
predict
precision.
However,
many
of
the
questions
are
in
a
binomial
format
(
e.
g.,

"
Yes/
No").
Maximum
variability
occurs
when
the
"
true"
fraction
of
responses
answering
"
yes"
is
equal
to
0.5.
With
a
sample
size
of
76
surveys
per
NDZ,
we
will
be
able
to
estimate
the
"
true"

proportion
of
people
answering
"
yes"
within
10
percentage
points
precision
at
a
confidence
level
of
90%.

2(
c)(
ii)
Nonsampling
Errors
Nonsampling
errors
These
types
of
errors
will
potentially
arise
in
any
survey,
whether
census­
based
or
statistical.
The
most
common
categories
of
nonsampling
error
are
coverage
error,
nonresponse
error,
response
error,
and
processing
error.
We
have
taken
steps
to
reduce
and
minimize
sources
of
nonsampling
errors.

Coverage
errors
Coverage
errors
will
be
minimized
by
a
well­
defined
subset
of
a
well­
defined
target
population.
Because
EPA
must
work
with
States
when
they
establish
NDZs,
we
can
identify
the
complete
population
of
NDZs.
By
using
intercept
sampling
at
marinas
within
NDZs,
we
can
identify
boaters
with
experience
in
an
NDZ.

Nonresponse
errors
EPA
minimized
the
potential
for
nonresponse
errors
by
the
methods
used
to
conduct
the
survey.
These
methods
rely
on
personal
interaction
either
by
personal
interview
for
the
marina
owner/
operator
survey
and
for
the
boat
owner/
operator
survey,
and
telephone
interviews
for
the
51
States/
Local
governments.
The
questions
have
been
phrased
to
solicit
information
in
a
nonjudgemental
nonthreatening
manner.
Each
survey
instrument
is
designed
to
gather
the
information
of
interest
in
the
most
straightforward
and
simple
manner,
and
is
designed
to
be
as
short
as
possible.
While
boaters
who
violate
NDZ
requirements
are
less
likely
to
take
time
to
respond
to
the
survey,
we
will
seek
to
minimize
this
potential
source
of
nonresponse
through
language
in
the
introductory
paragraph
and
non­
judgmental
wording
of
the
questions.

Response
error
EPA
will
minimize
the
potential
for
incomplete
or
inaccurate
responses
using
the
following
techniques:

°
Use
of
an
easily­
followed
sequence
of
questions.

°
Review
of
questions
for
ambiguity.

°
Use
of
"
yes/
no"
responses
for
as
many
of
the
questions
as
possible.

°
Provision
of
a
limited
number
of
carefully
considered
responses
to
each
of
the
remaining
questions.

°
Provision
of
clear
definitions
of
units
for
response,
such
as
"
feet"
for
"
what
is
the
length
of
your
boat."

°
Provision
of
instructions
with
the
text
of
a
question
rather
than
in
a
separate
part
of
the
survey
instrument.

°
Provision
of
interviewers
to
answer
any
questions
that
arise
when
responding
to
the
survey.
52
Processing
error
EPA
will
minimize
processing
error
by
using
double­
entry
data­
entry
verification
on
all
surveys.

2(
d)
Questionnaire
Design
The
survey
instruments
appear
in
Appendix
A.
The
boat
owner/
operator
instrument
is
administered
as
an
intercept
survey
and
the
marina
owner/
operator
instrument
is
administered
as
an
in­
person
interview.
The
State/
Local
government
instrument
is
administered
through
a
telephone
survey.
The
remaining
two
questionnaires
are
mail
surveys.
Question
design,
selection,

and
formatting
follows
the
guidance
and
practices
described
in
Converse
and
Presser
(
1986),

Dillman
(
2000),
Foddy
(
1993)
and
EPA
(
2002).

Reliability
and
Usefulness
of
Information
To
ensure
the
reliability
and
usefulness
of
the
information
gathered
with
the
surveys,
all
survey
questions
were
reviewed
by
staff
from
EPA
and
other
Federal
Agencies.
These
staff
include
both
individuals
with
expertise
in
the
relevant
subject
matter
and
those
with
little
experience
in
the
relevant
subject
matter.
In
addition,
comments
on
the
federal
register
notice
announcing
the
intent
to
perform
this
survey
were
received
from
individuals
stakeholders
representing
states,
industry
groups,
boating
associations,
and
individuals.
The
surveys
incorporate
many
of
the
suggestions
received.

Rationale
for
choosing
the
format
of
the
questions
The
majority
of
the
questions
are
structured
as
yes
or
no
questions.
This
format
was
53
chosen
to
both
minimize
the
burden
on
the
respondent
and
to
facilitate
the
analysis
of
the
survey
results.
Some
yes
or
no
questions
contain
multiple
parts.
Each
part
of
the
yes
or
no
question
is
intended
to
ask
about
a
specific
issue
not
addressed
elsewhere
in
the
survey.
Multiple
choice
questions
were
used
when
a
yes
or
no
question
would
be
ineffective.
In
general,
fill
in
the
blank
questions
were
chosen
when
we
wanted
to
solicit
an
exact
value
from
the
respondent
rather
than
asking
them
what
range
the
value
fell
in.
EPA
believes
that
this
approach
will
minimize
the
burden
on
the
respondent
and
still
provide
specific
and
useful
information.
Use
of
open­
ended
questions
was
avoided
in
most
cases.
We
included
opportunities
for
open­
ended
responses
on
some
multiple­
choice
questions
so
that
respondents
could
provide
answers
that
were
not
included
among
the
choices.

2(
d)(
i)
Boat
Operators
Survey
Question
1.
The
question
asks
the
respondent
whether
they
own
the
boat
they
operate.

The
response
to
this
question
will
facilitate
an
assessment
of
the
relative
level
of
knowledge
of
owners
vs.
operators.
The
response
to
this
question
will
also
be
compared
with
the
responses
to
other
survey
questions
that
appraise
the
respondent's
cognizance
of,
and
familiarity
with
boat
systems,
no­
discharge
zone
requirements,
and
pump­
out
systems
and
procedures.
Question
1
is
a
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Questions
2
and
3.
These
questions
ask
the
respondent
to
describe
the
boat
they
operate
in
terms
of
length
and
draft.
The
responses
are
important
because
different
sizes
of
vessels
have
different
requirements
for
pump­
out
facilities,
and
may
be
outfitted
with
vessel
sewage
processing
54
equipment
of
different
types
and
capacities.
In
addition,
length
and
draft,
among
other
design
features,
will
give
insight
into
the
primary
use
and
operational
profile
of
a
given
vessel,
and
the
capability
of
pump­
out
facilities
to
accommodate
them.
This
information
will
support
evaluation
of
the
availability
of
pump­
out
facilities
for
all
vessels.
States
sometimes
use
assumptions
such
as
"
all
boats
less
than
x
feet
in
length
do
not
have
installed
or
portable
toilets"
when
estimating
pump­
out
capacity
needed
to
support
an
NDZ
designation.
Collecting
the
length
data
in
terms
of
a
discreet
measurement
(
rather
than
in
ranges)
and
combining
it
with
the
equipment
information
requested
in
Questions
6
and
7
allows
EPA
to
examine
and
update
such
assumptions.
Questions
2
and
3
are
fill
in
the
blank
questions
so
that
the
respondent
can
provide
the
exact
length
and
draft
of
the
boat
they
operate.

Question
4.
The
question
asks
the
respondent
if
the
boat
they
operate
is
commercial
or
recreational.
EPA
believes
that
the
experience
of
commercial
and
recreational
boaters
with
NDZs
and
pump­
out
facilities
may
be
distinct.
This
question
will
allow
EPA
to
distinguish
between
the
responses
operators
of
different
types
of
vessels.
Question
4
is
a
two
part
yes
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
5.
The
question
asks
the
respondent
if
the
boat
they
operate
is
a
powerboat
or
sailboat.
Powerboats
and
sailboats
have
different
levels
of
maneuverability
and
different
requirements
for
equipment.
Therefore,
they
may
manage
their
sewage
in
different
ways.
EPA
believes
that
the
experience
of
sail­
and
powerboats
within
NDZs
and
pump­
out
facilities
may
be
distinct.
This
question
will
allow
EPA
to
distinguish
between
the
responses
operators
of
different
55
types
of
vessels.
Question
5
is
a
two
part
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Questions
6
and
7.
These
questions
ask
the
respondent
to
characterize
the
equipment
they
use
for
treating
or
storing
their
sewage.
The
type
of
sewage
treatment
and
storage
equipment
influences
what
type
of
pump­
out
facilities
are
needed,
which
in
turn
will
aid
EPA
in
determining
whether
adequate
pump­
out
facilities
are
currently
available.
The
responses
will
also
provide
information
on
how
many
boats
have
the
capacity
to
store
and
treat
sewage.
Storage
capacity
may
influence
boaters'
ability
and
willingness
to
abide
by
no­
discharge
zone
requirements.
Questions
6
and
7
have
two
parts
requesting
a
yes
or
no
response.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
8.
Questions
8
asks
the
respondent
about
operation,
maintenance,
and
performance
of
their
boat's
MSD.
This
question
is
important
because
existing
anecdotal
information
suggests
that
MSDs
do
not
continue
to
perform
adequately
once
installed.
One
potential
reason
for
the
poor
performance
of
MSDS
is
that
the
device
is
not
correctly
maintained
after
installation
and
use.
The
response
to
this
question
will
be
useful
for
evaluating
this
possibility.
Question
8
is
a:
multiple
part
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
9.
The
question
asks
the
respondent
how
they
operate
their
MSD
while
in
NDZs.
In
order
to
minimize
respondent
confusion
over
the
precise
boundaries,
the
boater
will
be
shown
a
map
of
the
NDZ
when
being
asked
to
respond.
Responses
to
this
question
will
be
used
56
to
determine
how
many
boaters
are
storing
sewage
for
later
pump­
out.
Responses
will
also
determine
whether
the
boater
understands
how
to
operate
the
device,
and
if
the
boater
is
closing
the
Y
valve
on
their
MSDs
to
ensure
that
sewage
is
not
discharged
into
NDZs.
The
responses
to
this
question
will
aid
in
determining
the
effectiveness
of
NDZs
at
preventing
boater
sewage
from
being
discharged.
Question
9
is
a
multiple
choice
question.

Qestion
10.
The
question
asks
the
respondent
how
many
days
they
have
boated
this
season.
The
responses
to
this
question,
along
with
the
responses
to
questions
21­
25,
will
aid
EPA
in
determining
if
boater
knowledge
of
NDZ
requirements
is
related
to
how
often
the
respondent
boats.
How
often
the
boat
is
used
may
correlate
to
how
often
it
will
need
to
pump
out
or
dump.

This
information
will
also
be
useful
for
determining
how
outreach
and
education
efforts
can
be
focused
in
the
future.
Question
10
is
a
multiple
part
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
11.
The
question
asks
the
respondent
how
many
days
they
have
boated
in
this
NDZ
this
season
(
A
map
depicting
the
subject
NDZ
will
be
shown,
See
discussion
question
9
above).
The
responses
to
this
question
along
with
the
responses
to
questions
21­
25
will
aid
EPA
in
determining
if
boater
knowledge
of
NDZ
requirements
is
related
how
often
the
respondent
boats
in
NDZs.
This
information
will
be
useful
for
determining
how
outreach
and
education
efforts
can
be
focused
in
the
future.
Comparison
of
the
responses
to
this
question,
with
the
responses
to
questions
15
will
help
evaluate
compliance
with
NDZs
requirements.
In
addition,

Questions
10
and
11
provides
an
indication
of
the
proportion
of
trips
that
included
transit
into
the
NDZ
at
which
the
survey
is
administered.
Responses
with
a
high
percentage
of
trips
into
the
57
NDZ
provide
better
information
about
conditions
at
that
NDZ
than
responses
where
most
of
the
trips
involve
other
areas.
Question
11
is
a
fill­
in­
the­
blank
question.
A
fill­
in­
the­
blank
question
was
used
so
that
the
boater
could
provide
the
exact
number
of
days
they
have
boated
this
year
in
the
NDZ
they
are
being
questioned
about.

Question
12.
The
question
asks
the
respondent
if
they
used
one
of
four
different
kinds
of
pump­
out
facilities
this
boating
season.
The
responses
to
this
question
will
aid
EPA
in
evaluating
compliance
with
NDZ
requirements
and
will
provide
information
on
what
type
of
pump­
out
facilities
are
being
used.
This
information
will
directly
support
the
analysis
of
the
effectiveness
of
NDZ
and
potential
barriers
to
compliance
Question
12
is
a
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
13.
The
question
asks
the
respondent
if
they
have
a
means
to
notify
marina
staff
to
pump­
out
their
sewage
holding
tanks
during
their
absence.
Along
with
information
from
questions
14­
19,
the
responses
to
this
question
will
aid
EPA
in
determining
if
the
availability
of
pump­
out
operations
while
the
boat
operator
is
absent
reduces
problems
accessing
pump­
out
facilities.
Question
13
is
a
yes
or
no
question.

Question
14.
The
question
asks
the
respondent
whether
they
have
used
a
pump­
out
facility
in
the
subject
NDZ
(
illustrated
by
map)
this
season.
A
follow­
up
subpart
question
asks
the
number
of
times
a
pump­
out
was
used.
Responses
to
this
question,
in
combination
with
the
responses
to
questions
10
,
11,
and
19,
will
be
used
to
evaluate
compliance
with
NDZ
provisions.

If
respondents
have
boated
in
NDZs,
but
not
used
pump­
out
facilities
or
discharged
beyond
3
58
miles,
they
are
more
likely
to
have
discharged
within
NDZs.
Question
14
is
a
fill­
in­
the­
blank
question
so
that
the
boater
can
provide
an
exact
number
of
times
they
have
used
the
pump­
out
facilities.

Question
15.
The
question
asks
the
respondent
if
they
have
had
trouble
using
pump­
out
facilities
this
year.
The
responses
to
this
question
will
support
evaluation
of
whether
or
not
problems
with
pump­
out
facilities
may
be
a
hindrance
to
compliance
with
NDZ
requirements.

EPA
is
particularly
interested
in
identifying
situations
where
a
boater
might
not
have
been
able
to
meet
NDZ
requirements.
Troubles
with
these
facilities
may
indicate
an
inability
to
comply
with
NDZ
requirements.
Question
15
is
a
two
part
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.
The
second
part
requests
a
fillin
the­
blank
response
so
that
the
respondent
can
provide
an
exact
number
of
times
they
have
had
trouble
with
pump­
out
facilities.

Question
16.
The
question
asks
the
respondent
if
they
had
trouble
with
pump­
out
facilities
on
their
last
attempt
within
the
subject
NDZ.
This
question
is
included
to
minimize
the
problem
of
accurately
recalling
events
over
an
extended
period
of
time
(
see
Foddy,
1993,
Chapter
7).
The
responses
to
this
question
will
support
evaluation
of
whether
or
not
problems
with
pump­
out
facilities
may
be
a
hindrance
to
compliance
with
NDZ
requirements.
Question
16
is
a
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
17.
The
question
asks
the
respondent
if
they
have
had
occasions
this
season
59
when
pump­
out
facilities
were
not
available.
The
responses
to
this
question
will
support
evaluation
of
whether
or
not
boaters
are
not
able
to
pump­
out
their
sewage
holding
tanks
because
pump­
out
facilities
are
not
available.
Question
18
is
a
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
18.
The
question
asks
the
respondent
if
they
have
discharged
sewage
outside
of
the
NDZ,
and
if
so
how
many
times.
The
responses
to
this
question
will
help
characterize
how
boaters
manage
their
sewage
in
NDZs
and,
in
combination
with
responses
to
questions
10­
17
determine
if
boaters
are
discharging
within
the
NDZ.
The
first
part
is
a
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

The
second
part
is
a
fill­
in­
the­
blank
so
that
the
respondent
can
provide
an
exact
number
of
times
they
have
discharged
outside
NDZs
Question
19.
The
question
asks
respondents
to
identify
any
of
a
number
of
conditions
(
list
provided)
that
they
may
have
encountered
at
pump­
out
or
toilet
dump
facilities
in
the
NDZ
this
boating
season.
The
responses
to
this
question
will
provide
information
about
the
specific
kinds
of
problems
encountered
at
pump­
out
facilities
within
the
subject
NDZ,
and
will
be
illustrative
of
the
responses
from
questions
15­
18,
and
20.
The
response
may
also
specifically
identify
the
reason
for
a
boater's
inability
to
perform
the
pump­
out
operation.
The
question
format
is
multiple
choice,

with
an
open­
ended
fill­
in­
the­
blank
option
for
conditions
not
covered
in
the
list.

Question
20.
The
question
asks
the
respondent
if
he
or
she
has
been
unable
to
perform
pump­
out
operations
due
to
any
of
the
conditions
indicated
in
question
19,
and
if
so,
the
number
60
of
occurrences.
The
response
will
identify
the
specific
cause
of
an
incident
that
could
lead
to
improper
disposal
of
sewage
in
the
NDZ.
This
question
has
multiple
parts,
yes­
no
and
fill­
in­

theblank

Question
21.
Question
21
asks
the
respondent
if
they
are
aware
that
discharging
sewage
in
a
no­
discharge
zone
is
prohibited.
The
responses
to
this
question
will
help
determine
if
boaters
lack
of
knowledge
of
the
restrictions
on
sewage
discharge
in
NDZs
is
a
hindrance
to
compliance.

Question
21
is
a
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
22.
The
question
asks
the
respondent
if
they
have
received
any
information
on
NDZ
requirements
from
numerous
sources.
The
responses
to
this
question
will
aid
EPA
and
other
entities
in
targeting
future
outreach
and
education
efforts.
It
may
also
be
useful
for
assessing
the
level
of
knowledge
each
boater
has.
This
question
is
a
multiple
part
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
23.
The
question
asks
the
respondent
if
they
know
who
enforces
the
provisions
of
a
NDZ.
The
responses
to
this
question
will
help
to
characterize
the
level
of
knowledge
about
NDZ
enforcement
to
determine
if
enforcement
efforts
provide
a
deterrent
to
discharging
sewage
in
NDZs.
This
question
is
a
multiple
part
yes,
no,
or
don't
know
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
24.
The
question
asks
the
respondent
if
they
are
aware
of
any
enforcement
61
actions
against
vessel
sewage
discharges
in
this
area.
The
responses
to
this
question
will
help
EPA
assess
whether
enforcement
actions
could
be
a
deterrent
to
prohibited
discharges
in
NDZs
This
question
is
a
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
25.
The
question
asks
the
respondent
if
they
have
noticed
a
change
in
water
quality
since
the
NDZ
was
established.
The
responses
to
this
question
will
assist
EPA
in
evaluating
the
boaters
perception
of
water
quality
changes
since
the
designation
of
the
NDZs.

Question
25
is
a
multiple
choice
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

2(
d)(
ii)
Marina
Owner/
Operator
Survey
Questions
1­
6
are
designed
to
generally
describe
the
marina
and
its
sewage
collection
facilities.

Question
1.
The
question
is
designed
to
collect
information
about
the
total
number
of
boaters
the
marina
can
accommodate.
The
response
to
this
question
will
contribute
to
the
characterization
of
the
facility
and
the
potential
demands
on
its
service
infrastructure.
Question
1
is
a
fill­
in­
the
blank
with
sub­
parts
to
elicit
the
marina
owner/
operators
knowledge
of
his
own
facility.

Question
2.
The
question
requests
the
respondent's
best
estimate
of
the
current
occupancy
of
the
marina.
The
response
to
this
question
will
provide
further
characterization
of
the
demand
62
on
the
marina's
and
local
area's
facilities.
This
question
is
a
fill­
in­
the­
blank
to
illicit
the
owner/
operator's
best
estimate
of
the
facility's
occupancy
as
of
the
date
of
the
survey.
This
information
will
provide
a
`
snapshot'
of
the
number
of
people
using
the
marina.

Question
3.
The
question
is
designed
to
determine
the
occurrence,
type,
and
number
of
boat
sewage
pump­
out
facilities
at
the
marina.
The
response
will
further
characterize
the
marina,

by
determining
the
availability
of
sewage
collection
devices.
For
ease
of
administration
and
analyses,
the
question
is
structured
with
four
sub­
parts,
each
with
a
yes
or
no
response.

Affirmative
responses
are
followed
by
a
request
for
the
number
of
that
type
of
facility
or
device
are
located
at
the
subject
marina.
If
the
marina
has
no
sewage
collection
or
storage
facilities,
the
respondent
is
directed
to
the
final
section
of
the
survey.

Question
4.
The
question
requests
information
regarding
other
types
of
facilities
or
services
that
the
marina
may
offer.
The
response
contributes
to
the
characterization
of
the
facility
and
provides
a
description
of
features
that
may
attract
boaters
to
the
marina.
Question
4
has
multiple
sub­
parts
corresponding
to
different
facilities
or
services,
requiring
a
simple
yes/
no
response.

Question
5.
This
question
requests
from
those
marinas
with
shore
side
facilities
(
whether
stationary
or
mobile)
specific
information
regarding
the
manufacturer
and
age
of
the
equipment
being
used.
The
information
collected
will
provide
EPA
a
baseline
with
which
to
track
the
brands
and
models
of
equipment
used
and
their
service
age,
which
may
be
used
to
analyze
trends
in
equipment
functionality.
EPA
will
correlate
the
answers
with
relative
functionality
(
Question
15)
63
to
identify
markedly
well­
performing
or
poorly­
performing
equipment.
Question
5
is
fill­
in­

theblank
to
allow
the
respondent
to
provide
sufficient
information
to
briefly,
but
adequately
characterize
the
equipment.

Question
6.
The
question
requests
information
on
the
draft
restrictions
at
the
shore
side
facilities.
The
response
will
identify
physical
limitations
to
the
use
of
these
facilities
by
power
and
sailboats
with
specific
draft
(
water
depth)
requirements.
The
question
is
fill­
in­
the­
blank
requesting
the
maximum
vessel
draft
in
feet.

Questions
7­
9
request
information
about
the
costs
associated
with
the
operation
of
facilities,
who
bears
which
costs,
and
whether
the
marina
has
received
specific
Federal
support.

Question
7.
The
question
requests
information
about
the
receipt
of
dedicated
outside
funding
(
i.
e.,
The
Clean
Vessel
Act)
to
facilitate
the
use
of
facilities.
The
response
will
provide
information
regarding
potential
regulatory
compliance
assistance
for
this
facility.
In
addition,
the
responses
will
provide
information
on
whether
facilities
receiving
funding
provide
better
services
than
those
that
do
not.
This
is
a
yes­
no
question
which
does
not
inquire
about
the
amount
received,
or
its
allocation.

Question
8.
The
question
requests
the
marina's
fee
structure
for
the
use
of
its
facilities
or
services.
The
response
will
provide
information
about
the
costs
to
boat
owners
of
proper
disposal,
and
could
be
used
for
comparison
among
surveyed
facilities.
This
information
will
be
helpful
for
evaluating
whether
cost
is
a
significant
barrier
to
using
pump­
out
facilities.
The
64
question
is
fill­
in­
the­
blank
to
the
nearest
dollar,
and
may
be
expressed
as
a
flat
fee,
at
a
specified
rate
per
unit
volume
transferred,
or
some
other
formulation.

Question
9.
The
question
requests
the
approximate
annual
costs
to
the
marina
owner
or
operator
related
to
operation
and
maintenance
of
its
facilities.
The
response
will
be
used
to
examine
the
costs
associated
with
providing
these
services
to
boat
owners/
operators
in
the
surveyed
NDZs,
and
will
be
used
for
comparison
between
marinas.
EPA
will
look
for
relationships
between
operation
and
maintenance
expenditures
and
the
availability
of
functional
equipment
to
boaters
in
the
NDZ.
The
question
is
fill­
in­
the­
blank
with
the
response
estimated
to
the
nearest
dollar.

Questions
10­
15
are
intended
to
gather
information
about
equipment
operations
and
training.
EPA
will
attempt
to
correlate
these
responses
to
the
results
from
subsequent
questions
regarding
user
experiences
and
functionality
of
the
equipment,
thus
allowing
comparisons
among
surveyed
marinas.

Question
10.
The
question
asks
who
operates
the
marina's
facilities.
The
response
will
indicate
whether
the
equipment
is
exclusively
staff­
operated,
self­
service
for
the
boat
owner/
operator,
or
some
combination
of
the
two.
This
information,
in
conjunction
with
responses
to
other
questions,
will
help
EPA
determine
if
boater
operated
or
staff
operated
facilities
are
more
likely
to
be
functional.
The
question
is
multiple
choice
with
three
possible
answers:
marina
staff,
boat
owners/
operators,
or
both.
65
Question
11.
This
question
inquires
whether
the
marina
has
a
training
requirement
for
those
staff
involved
in
operation
and/
or
maintenance
of
their
facilities.
The
responses
to
this
question
along
with
results
from
the
boater
survey
will
support
evaluation
of
whether
the
level
of
staff
training
impacts
the
availability
and
access
to
pump­
out
facilities.
The
question
has
a
yes
or
no
response.

Question
12.
The
question
requests
additional
information
regarding
training
of
marina
staff
for
operations.
The
response
to
this
question
indicates
the
number
of
hours
of
organized
operations
training
each
marina
staff
person
is
given,
ranging
from
less
than
30
minutes
to
more
than
10
hours.
The
responses
to
this
question
along
with
results
from
the
boater
survey
will
support
evaluation
of
whether
the
level
of
staff
training
impacts
the
availability
and
access
to
pump­
out
facilities.
The
question
is
multiple
choice
with
each
choice
representing
a
discrete
training
duration.

Question
13.
The
question
further
describes
the
nature
of
the
training.
The
response
to
this
question
leads
to
a
more
detailed
description
of
the
marina's
training
program.
The
responses
to
this
question
along
with
results
from
the
boater
survey
will
support
evaluation
of
whether
the
level
of
staff
training
impacts
the
availability
and
access
to
pump­
out
facilities.
The
question
is
multiple
choice
with
an
array
of
five
separate
selections
that
address
who
will
be
administering
the
training,
and
its
content.

Question
14.
This
question
requests
the
marina's
hours
of
operation.
This
response,
taken
in
context
with
the
answers
to
questions
15
and
16
will
be
used
to
evaluate
the
number
of
hours
66
the
facilities
are
theoretically
available
for
use.
Determining
the
number
of
hours
that
marina
services
are
available
will
aid
in
evaluating
access
to
pump­
out
facilities.
The
question
is
fill­

inthe
blank.

Question
15.
The
question
asks
for
information
on
the
schedule
of
operation
for
the
marina's
facilities.
This
response,
taken
in
context
with
the
answers
to
questions
14
and
16
will
be
used
to
evaluate
the
number
of
hours
the
facilities
are
theoretically
available
for
use.
This
will
provide
information
on
access
(
and
lack
of
access)
to
pump­
out
facilities.
The
response
is
fill­

inthe
blank.

Questions
16­
19
are
designed
to
explore
the
issues
related
to
availability
of
facilities
and
the
causes
of
the
reported
lack
of
functionality.

Question
16.
The
question
asks
the
respondent
to
estimate
the
percentage
of
time
the
facilities
are
functional
during
the
time
when
the
facilities
are
theoretically
available
for
use.
In
addition
to
a
simple
appraisal
of
facility
availability,
responses
to
this
question
may
be
compared
to
responses
to
Marina
survey
questions
relating
to
staff
training
and
hours
of
operation,
and
to
Boater
survey
questions
about
perceived
problems
with
availability
and
functionality.
The
question
is
multiple
choice,
each
representing
a
range
of
percentage
of
availability
of
the
equipment.

Question
17.
This
question
seeks
additional
information
about
those
incidences
where
facilities
have
been
identified
in
Marina
survey
Question
16,
or
in
the
Boater
survey
as
non­
67
functional
during
operating
hours
during
the
current
boating
season.
The
potential
responses
are
designed
to
identify
the
causes
for
the
lack
of
availability.
EPA
can
combine
information
to
infer
possible
reasons
for
some
of
the
responses,
e.
g.,
a
correlation
of
marina
staff
performing
the
operation,
marina
staff
training,
and
the
lack
of
available
marina
staff.
Question
17
is
a
yes­
no
question
with
multiple
sub­
parts
for
each
potential
reason.
The
question
also
contains
an
openended
response
in
order
to
collect
otherwise
unidentified
causes.

Question
18.
This
question
is
designed
to
determine
whether
a
boater
has
been
forced
to
wait
for
an
extended
period
of
time
(>
15
minutes)
to
use
a
during
the
current
boating
season
at
this
marina.
This
question
will
assist
in
determining
how
often
long
waiting
times
are
potential
barriers
to
using
facilities.
The
question
requires
a
simple
yes­
no
response.

Question
19.
This
question
is
the
companion
to
question
18.
It
is
designed
to
determine
the
frequency
of
extended
waiting
periods.
The
responses
will
assist
EPA
in
determining
how
often
waiting
time
may
be
a
barrier
to
boater
use
of
facilities..
The
question
is
structured
as
multiple
choice
with
5
possible
answers
generally
depicting
frequency
of
occurrence.

Question
20.
The
question
asks
for
the
respondent's
best
estimate
of
the
number
of
sewage
collection
operations,
or
the
volume
of
sewage
collected
at
this
marina
so
far
during
the
current
boating
season.
The
response
could
be
used
in
conjunction
with
results
from
other
surveys
to
estimate
an
average
volume
of
sewage
collected
in
the
NDZ.
This
will
support
evaluation
of
the
effectiveness
of
NDZ
provisions.
The
question
is
fill­
in­
the­
blank
in
either
number
of
operations,
or
gallons
of
transferred
material.
68
Question
21.
This
question
is
designed
to
assess
marina
owner/
operator
efforts
to
inform
the
boating
public
of
their
responsibilities
in
no­
discharge
zones.
The
response
will
be
used
in
conjunction
with
the
results
of
the
State
and
Local
survey
to
learn
about
the
types
of
outreach
and
education
efforts
that
exist.
Boaters
cannot
abide
by
no
discharge
requirements
if
they
do
not
know
what
a
No­
Discharge
Zone
is,
how
to
tell
when
they
are
in
one,
or
what
specific
requirements
apply
to
their
activities.
This
information
may
be
used
to
tailor
and
focus
future
outreach
and
education
efforts.
The
question
format
is
yes­
no
with
three
sub­
parts.

Questions
22­
25
are
designed
to
assess
the
marina
owner/
operator's
cognizance
of
nodischarge
zone
requirements
and
their
enforcement.

Question
22.
The
question
asks
the
respondent
if
they
know
who
enforces
the
provisions
of
a
NDZ.
The
responses
to
this
question
will
help
to
characterize
the
level
of
knowledge
about
NDZ
enforcement
to
determine
if
enforcement
efforts
provide
a
deterrent
to
discharging
sewage
in
NDZs.
The
responses
to
this
question
will
also
aid
EPA
and
other
entities
in
targeting
future
outreach
and
education
efforts.
This
question
is
a
multiple
part
yes,
no,
or
don't
know
question.

This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
23.
The
question
asks
the
respondent
if
they
are
aware
of
any
enforcement
actions
against
vessel
sewage
discharges
in
this
area.
The
responses
to
this
question
will
help
EPA
assess
whether
enforcement
actions
could
be
a
deterrent
to
prohibited
discharges
in
NDZs
This
question
is
a
yes
or
no
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
69
respondent
and
to
facilitate
analysis.

Question
24.
The
question
is
designed
to
test
the
respondent's
knowledge
and
perception
of
the
State
government's
responsibilities
in
a
no­
discharge
zone.
The
responses
to
this
question
will
help
to
characterize
marina
operators
understanding
of
the
roles
and
responsibilities
of
the
government
entities
administering
the
NDZs.
This
question
is
a
multiple
part
yes,
no,
or
don't
know
question,
with
an
additional
option
to
identify
other
State
functions
not
listed.

Question
25.
The
question
asks
the
respondent
if
they
have
noticed
a
change
in
water
quality
since
the
NDZ
was
established.
The
responses
to
this
question
will
assist
EPA
in
evaluating
the
impression
that
marina
operators
have
of
water
quality
changes
in
NDZs.

Question
25
is
a
multiple
choice
question.
This
question
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

2(
d)(
iii)
State/
Local
Survey
Question
1.
Question
1
asks
the
respondent
if
their
organization
has
records
of
beach
closures,
shellfish
bed
health
or
water
quality
data
for
2000,
2001,
or
2002.
If
this
information
is
available,
the
person
giving
the
survey
will
request
a
copy.
In
combination
with
the
response
to
question
2,
this
data
may
provide
information
on
how
the
water
quality
in
the
NDZ
has
changed.

This
question
is
a
multiple
part
yes
or
no
question.
This
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
2.
This
question
asks
the
respondent
if
their
organization
has
records
of
beach
70
closures,
shellfish
bed
health
or
water
quality
data
for
the
area
before
the
designation
of
the
NDZ.

In
combination
with
the
response
to
question
1,
this
data
may
provide
information
on
how
the
water
quality
in
the
NDZ
has
changed.
If
this
information
is
available,
the
person
giving
the
survey
will
request
a
copy.
This
question
is
a
multiple
part
yes
or
no
question.
This
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis
Question
3.
Question
3
asks
if
their
organization
has
any
information
on
the
NDZs
the
survey
is
focusing
on.
If
this
information
is
available,
the
person
giving
the
survey
will
request
a
copy.
The
information
gathered,
in
combination
with
the
results
from
the
boater
and
marina
survey
will
help
determine
whether
or
not
NDZs
are
effective.
This
question
is
a
multiple
part
yes
or
no
question.
This
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis
Question
4.
Question
4
asks
the
respondent
if
their
organization
has
any
published
reports
summarizing
or
interpreting
data
on
beach
closures,
shellfish
bed
health
or
water
quality
data
for
2000,
2001,
or
2002.
If
this
information
is
available,
the
person
giving
the
survey
will
request
a
copy.
The
published
reports
solicited
with
this
question
will
assist
in
interpreting
information
obtained
in
question
1
and
may
help
to
put
the
information
in
context..
This
question
is
a
multiple
part
yes
or
no
question.
This
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
5.
Question
4
asks
the
respondent
if
their
organization
has
any
reports
of
beach
closures,
shellfish
bed
health
or
water
quality
data
prior
to
the
NDZ
being
designated.
If
this
71
information
is
available,
the
person
giving
the
survey
will
request
a
copy.
The
information
gathered
will
assist
in
interpreting
data
obtained
in
question
2.
This
question
is
a
multiple
part
yes
or
no
question.
This
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
6.
Question
6
asks
the
respondent
who
is
responsible
for
enforcing
NDZ
requirements.
The
response
to
this
question
will
be
used
by
EPA
to
identify
organizations
to
work
with
on
enforcement
issues.
This
question
is
a
multiple
part
yes
or
no
question.
This
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
7.
Question
7
asks
the
respondent
to
identify
the
role
of
their
organization
regarding
NDZs.
This
information
will
be
used
by
EPA
to
evaluate
how
active
various
organizations
are
in
enforcing
implementing
NDZs.
This
question
is
a
multiple
part
yes
or
no
question.
This
format
was
chosen
to
minimize
the
burden
on
the
respondent
and
to
facilitate
analysis.

Question
8.
Question
8
asks
the
respondent
to
identify
another
individual
if
they
are
unable
to
provide
the
information
requested
in
the
rest
of
the
survey.
Persons
identified
with
this
question
will
be
surveyed
to
get
answers
to
the
previous
questions.
This
question
asks
the
respondent
to
simply
fill
in
a
name
and
phone
number
for
the
person
they
designate.

2(
d)(
iv)
Marine
Sanitation
Device
(
MSD)
Manufacturer
Survey
The
marine
sanitation
device
surveys
will
be
sent
to
all
marine
sanitation
device
72
manufacturers,
therefore
it
is
not
a
census
survey.
The
results
will
not
be
statistically
analyzed.

2(
d)(
v)
Marine
Sanitation
Device
(
MSD)
Testing
Laboratory
Survey
The
Coast
Guard
certified
labs
survey
will
be
sent
to
all
Coast
Guard
certified
labs,

therefore
it
is
not
a
census
survey.
The
results
will
not
be
statistically
analyzed.

SECTION
3:
Pretest
and
Pilot
Tests
The
survey
instruments
have
been
designed
to
follow
EPA
guidance
and
state
of
the
art
survey
design,
see
list
of
references
given
in
Section
6.
EPA
incorporated
comments
and
suggestions
received
in
response
to
the
Federal
Register
notice
proposing
the
information
collection
activity
(
FR
68:
14975,
Marcy
27,
2003).
EPA
will
develop
materials
for
and
conduct
training
for
all
interviewers
administering
the
surveys.

EPA
will
pretest
the
boat
owner/
operator,
marina
owner/
operator,
state
and
local
government,
MSD
manufacturer,
and
MSD
testing
laboratory
survey
instruments
after
the
NDZ
sample
is
drawn.
The
contractor
will
pretest
the
surveys
on
no
more
than
9
respondents
in
each
category
in
compliance
with
Paperwork
Reduction
Act
guidelines.
EPA
plans
to
draw
the
NDZ
sample
and
perform
the
pre­
test
during
the
90­
day
review
period
for
the
questionnaire.
Any
problems
in
questionnaire
design,
e.
g.,
poor
phrasing
or
misinterpreted
questions,
can
be
identified
and
corrected
prior
to
final
OMB
consideration.

Due
to
the
relatively
small
number
of
participants,
EPA
does
not
plan
to
pilot
test
the
survey
instruments.
73
SECTION
4:
Collection
Methods
and
Follow­
up
4(
a)
Collection
Methods
EPA
selected
different
collection
methods
for
the
different
survey
instruments.
Each
method
was
selected
to
reduce
respondent
burden
and
maximize
the
number
of
accurately
completed
surveys.

Boat
Owner/
Operator
EPA
determined
that
personal
interviews
at
marinas
within
an
NDZ
will
be
the
principal
method
by
which
to
effectively
engage
the
target
population
of
boat
owner/
operators.
Upon
obtaining
permission
to
operate
on
marina
property,
an
interviewer
will
be
stationed
for
a
predetermined
period
of
time
at
selected
marinas
within
the
NDZ.
The
plan
is
to
administer
the
survey
for
eight
hours
each
on
a
Saturday
and
Sunday,
operating
with
the
assumption
that
weekend
marina
use
is
higher
than
weekday
use.
The
short,
concentrated
sampling
effort
is
likely
to
maximize
survey
participation
with
lower
implementation
costs.
Sampling
will
represent
all
hours
of
marina
operation
because
users
may
differ
during
the
day
(
e.
g.,
anglers
leaving
early
in
the
morning
and
sun
bathers
leaving
later
in
the
day).
Although
one­
on­
one
interaction
with
respondents
is
desirable
to
ensure
thoughtful
participation,
the
surveys
were
designed
so
that
they
could
be
completed
by
the
boat
owners/
operators
themselves.
Copies
of
the
survey
questions
will
be
available
for
unassisted
completion
of
the
survey
form
if
the
interviewer
is
occupied
with
other
respondents,
or
is
otherwise
unavailable.
If
no
marina
within
an
NDZ
grants
permission
to
EPA
for
conducting
the
survey
on
their
property,
EPA
will
obtain
permission
from
local
authorities
to
administer
the
survey
on
nearby
public
land
where
boaters
are
likely
to
congregate.
74
Ideally,
the
interviews
will
be
conducted
in
person.
Interviewers
will
identify
potential
respondents
by
walking
around
marina
property
and
making
direct
contact.
To
encourage
participation,
the
boaters
would
be
offered
refreshments
at
a
central
location
and
asked
to
complete
the
survey
or
answer
a
few
questions.
(
The
current
state
of
the
art
in
survey
design
suggests
offering
incentives,
but
not
to
make
receipt
of
the
incentive
dependent
on
survey
completion;
see
Dillman,
2000)
The
survey
instrument
could
be
completed
by
the
boat
owners/
operators
themselves
or
as
an
interview.
In
addition,
the
interviewer
has
blank
index
cards
to
collect
anonymous
anecdotal
evidence
of
the
effectiveness
of
NDZs
should
the
boater
choose
to
do
so.
The
interviewers
will
be
drawn
from
the
contractor's
staff.
Interviewers
will
receive
training
on
the
goal
of
the
survey,
survey
forms,
and
interviewing
approaches.

By
administering
the
survey
at
a
marina
in
a
selected
NDZ,
EPA
collects
information
about
boat
owner/
operator
experience
with
NDZ
requirements.
Respondent
burden
and
coverage
error
are
reduced
because
people
who
are
not
boat
owners/
operators,
or
boat
owners/
operators
with
no
experience
with
NDZ
requirements
are
not
in
the
sample.
The
survey
instrument
can
be
completed
by
either
the
interviewer
or
the
boat
owner/
operator,
according
to
the
respondent's
preference.
The
interviewer
is
immediately
available
to
answer
any
questions
the
boat
owner/
operator
might
have
about
interpreting
the
questions.
The
respondent
does
not
have
to
take
action
to
return
the
completed
form;
the
interviewer
collects
it
at
the
time
it
is
completed.

The
survey
instruments
will
be
printed
on
color­
coded
paper
where
different
colors
will
be
used
at
different
NDZs.
Surveys
on
white
paper
will
be
used
when
and
if
the
supply
of
surveys
on
colored
paper
for
that
NDZ
is
exhausted.
After
the
interviewer
has
collected
all
of
the
surveys
from
the
intercept
sampling,
he
or
she
will
attach
previously
printed
stick­
on
labels
with
the
name
75
of
the
NDZ
to
each
of
the
surveys
on
white
paper.
These
features
minimize
respondent
burden,

non­
response
errors
and
response
errors.

Marina
Owner/
Operator
EPA
selected
an
in­
person
interview
preceded
by
telephone
contact.
The
initial
telephone
call
is
to
(
1)
explain
the
purpose
of
the
survey,
(
2)
review
the
questions
for
the
marina
survey
to
identify
any
that
might
not
be
able
to
be
answered
on
a
moment's
notice,
such
as
Question
7
(
how
many
times
have
pump­
out/
toilet
dump
services
been
used
so
far
this
season),
(
3)
review
the
boat
owner/
operator
questions,
if
the
marina
owner/
operator
prefers
to
do
so,
(
4)
obtain
permission
to
administer
the
boat
owner/
operator
survey
on
their
premises,
and
(
5)
arrange
for
a
date
and
time
for
the
in­
person
and
intercept
surveys.
The
initial
telephone
contact
and
in­
person
interviews
will
be
performed
by
the
same
staff
that
receive
the
training
for
the
intercept
survey.

By
administering
the
survey
at
marinas
in
a
selected
NDZ,
EPA
collects
information
about
marina
owner/
operator
experience
with
NDZ
requirements.
Respondent
burden
and
coverage
error
are
reduced
because
marinas
not
located
within
an
NDZ
are
not
in
the
sample.
The
survey
instrument
is
completed
by
the
interviewer
and
the
interviewer
is
immediately
available
to
answer
any
questions
the
marina
owner/
operator
might
have
about
interpreting
the
questions.
The
respondent
does
not
have
to
take
action
to
return
the
completed
form;
the
interviewer
collects
it
at
the
time
it
is
completed.
As
with
the
boat
owner/
operator
surveys,
the
marina
owner/
operator
surveys
will
be
on
colored
paper
to
distinguish
surveys
from
different
NDZs.
These
features
minimize
respondent
burden,
nonresponse
errors
and
response
errors.
76
States/
Local
governments
EPA
selected
a
telephone
interview
approach
to
collect
data
from
States
and
Local
governments.
EPA
is
seeking
only
data
that
the
organization
has
already
collected
and
the
focus
is
on
the
ability
to
identify
the
person
who
can
release
the
data
to
EPA.
There
is
no
need
to
elicit
personal
experience
with
NDZ
requirements,
hence,
the
need
for
on­
site
person­
to­
person
interactions
is
less
than
for
the
boat
and
marina
owner/
operator
surveys.
The
contractor
that
will
perform
the
State/
Local
government
survey
has
many
years
of
experience
in
finding
and
obtaining
data
from
States
and
Local
governments
for
EPA
analysis.

4(
b)
Survey
Response
and
Follow­
up
Non­
response
is
difficult
to
define
for
an
intercept
survey.
For
example,
a
person
who
the
interviewer
approaches,
or
a
potential
respondent
that
encounters
the
refreshment
inducement
might
decide
not
to
complete
the
survey
because
he
or
she
is
not
a
boat
owner/
operator.
Second,

a
boat
owner/
operator
that
does
not
comply
with
NDZ
requirements
may
decide
not
to
participate
in
the
survey
prior
to
reading
or
hearing
any
of
the
questions.
Third,
potential
respondents
may
not
be
encountered
by
the
roaming
interviewer
or
might
walk
by
and
not
observe
the
sampling
effort
at
all.
It
is
not
certain
whether
or
how
to
classify
these
situations
as
non­
response.

However,
by
following
state
of
the
art
guidance
and
the
contractor's
experience
in
administering
surveys,
EPA
seeks
to
minimize
non­
response
to
the
boat
and
marina
owner/
operator
surveys.

EPA
selected
intercept
survey
and
in­
person
interview
methods
to
meet
a
targeted
completion
rate
of
100
percent
for
these
surveys.
The
survey
data
are
recorded
on
the
forms
provided
in
Appendix
A,
collected
at
the
time
of
the
survey,
and
transferred
to
the
data
entry
77
process.
No
follow­
up
is
required
in
these
circumstances.

EPA
selected
a
telephone
interview
approach
to
collect
data
from
States
and
Local
governments
based
on
the
success
of
similar
previous
data­
gathering
efforts.
For
this
survey,
the
need
for
follow­
up
is
minimized
by
accepting
the
data
in
whatever
format
they
are
maintained,

paying
any
necessary
user
fees,
and
paying
for
postage/
courier
to
transfer
the
data.
Follow­
up
efforts
consist
of
weekly
phone
contacts
once
the
anticipated
due
date
for
receipt
of
the
data
is
past
until
the
material
has
been
sent.

SECTION
5:
Analyzing
and
Reporting
Survey
Results
5(
a)
Data
Preparation
Boat
Owner/
Operator
ERG,
Inc.
will
deliver
a
complete
database
of
the
survey
responses
in
a
flat­
file
format
suitable
for
spreadsheet
or
database
programs.
Each
row
will
contain
an
observation.
That
is,
it
will
contain
responses
made
by
an
individual
respondent.
EPA
did
not
collect
personal
respondent
information
in
the
survey,
such
as
name
or
address,
hence
the
responses
are
anonymous
and
maintain
the
respondent's
confidentiality.
Columns
in
the
database
will
contain
the
responses
to
each
question
as
well
as
NDZ
and
sample
block
identifier
(
date
and
time
block).

ERG
will
provide
EPA
with
a
data
dictionary
to
ensure
that
response
categories
for
variables
can
be
mapped
back
to
the
questionnaire
and
that
proper
definitions
of
the
variables
are
used
in
the
subsequent
analysis.
As
mentioned
in
Section
2(
c)(
ii),
double
data
entry
procedures
will
be
used
to
eliminate
processing
errors.
78
Marina
Owner/
Operator
ERG,
Inc.
will
deliver
a
complete
database
of
the
survey
responses
in
a
flat­
file
format
suitable
for
spreadsheet
or
database
programs.
Each
row
will
contain
an
observation.
That
is,
it
will
contain
responses
made
by
an
individual
respondent.
Columns
in
the
database
will
contain
the
responses
to
each
question
as
well
as
NDZ
and
marina
identifier.
ERG
will
provide
EPA
with
a
data
dictionary
to
ensure
that
response
categories
for
variables
can
be
mapped
back
to
the
questionnaire
and
that
proper
definitions
of
the
variables
are
used
in
the
subsequent
analysis.
As
mentioned
in
Section
2(
c)(
ii),
double
date
entry
procedures
will
be
used
to
eliminate
processing
errors.

States/
Local
governments
The
purpose
of
the
State/
Local
government
survey
is
to
obtain
the
data
already
collected
by
the
organization.
Due
to
the
heterogenous
nature
of
format
and
content
of
the
data
supplied
by
States
and
Local
governments,
EPA
does
not
plan
to
create
a
single
database
from
the
supplied
material.
Instead,
individual
data
files
will
be
developed
in
support
of
individual
analyses
that
can
be
formulated
from
the
material.
The
data
files
will
undergo
quality
control
procedures
for
accurate
data
entry.

5(
b)
Analysis
By
designing
the
survey
to
collect
information
for
different
groups
within
an
NDZ,
i.
e.,
the
boaters
that
need
to
comply
with
no
discharge
requirements,
the
marinas
that
provide
services
to
allow
the
boater
to
comply
with
the
no
discharge
requirements,
and
the
States
and
Local
governments
that
collect
water
quality
data
to
characterize
the
NDZ,
EPA
will
be
able
to
examine
79
all
three
data
sources
to
produce
a
consistent
narrative
explaining
the
effectiveness
or
barriers
to
the
effectiveness
of
NDZs
with
respect
to
water
quality.

The
responses
to
each
question
in
the
boat
and
marina
owner/
operator
surveys
will
be
tabulated
and
presented
in
summary
tables.
We
will
develop
descriptive
statistics
for
each
of
the
parameters,
such
as
means,
standard
deviations,
values
at
specific
confidence
limits,
and
precision
estimates.
We
will
perform
exploratory
data
analysis
to
investigate
multi­
modality,
skewness,
and
other
population
characteristics.
Objective
are
to
produce
a
narrative
and
quantitative
characterization
of
the
boat
and
marina
owner/
operator
experience
with
NDZ
requirements,

identify
problems
associated
with
meeting
NDZ
requirements,
and
infer
possible
causes
for
the
problems.

For
certain
key
questions
from
the
boaters
survey,
we
will
examine
the
differences
among
regions
and
between
old
and
new
NDZs
using
a
chi
square
test.
These
key
questions
include
whether
the
boater
is
aware
that
the
area
is
an
NDZ,
whether
the
boater
has
been
able
to
successfully
use
a
pumpout
facility
this
season
in
the
NDZ,
and
whether
the
boater
has
had
trouble
finding
or
using
a
pumpout
facility
this
season
in
the
NDZ.

For
example,
we
can
test
the
null
hypothesis
that
boaters
within
an
NDZ
established
fewer
than
10
years
ago
(
new
NDZs)
are
as
aware
as
boaters
within
an
NDZ
established
more
than
years
ago
(
old
NDZs).
The
alternative
hypothesis
may
be
that
boaters
in
old
NDZs
are
more
aware
than
those
in
new
NDZs.
To
compute
the
chi­
square
statistic
we
classify
our
data
into
the
following
two­
by­
two
table:
80
Boater
Awareness
Age
of
NDZ
New
Old
Aware
Not
Aware
Before
constructing
the
chi­
square
statistic,
we
must
estimate
our
cell
frequencies
and
marginal
frequencies
in
the
above
table.
Our
objective
in
a
probability­
based
sample
survey
is
to
take
our
sample
data
and
make
projections
to
the
level
of
our
survey
universe.
There
may
also
be
interest
in
making
projections
to
the
level
of
certain
sub­
populations.
Rather
than
using
the
frequencies
from
the
sample,
we
would
want
to
use
our
population
projections
of
the
number
of
boaters
in
each
of
the
four
cells
and
the
row
and
column
marginal
frequencies.
We
calculate
our
population
estimates
or
projections
with
the
use
of
sampling
weights.
A
sampling
weight
for
a
boater
selected
for
the
survey
will
be
the
reciprocal
of
the
boater's
chance
of
being
selected
for
an
interviewer.
For
a
boater
to
be
selected
for
participation
in
the
survey,
the
marina
that
he
or
she
uses
must
be
selected
in
the
second­
stage
sampling
of
marinas.
Furthermore,
for
the
boater's
marina
to
be
selected,
it
must
be
within
one
of
the
14
NDZs
selected
from
the
population.
The
selection
probabilities
at
the
stages
of
sample
selection
can
be
used
to
calculate
an
overall
probability
of
selection
for
the
surveyed
boater.
The
inverse
of
the
boater
selection
probability
is
the
boater
sampling
weight.
If
the
sampling
weight
for
a
boater
was
28,
then
we
could
say
that
that
boater
represents
28
boaters
in
the
survey
universe.

Using
the
sampling
weights
we
can
estimate
the
number
of
boaters
in
the
population
in
each
of
four
cells
of
our
table.
Our
chi­
square
statistic
can
be
computed
by
calculating
for
each
of
the
four
cells
of
our
table:
(
Actual
frequency
 
Expected
Frequency)
/
Expected
Frequency.

Since
the
actual
frequency
and
expected
frequency
are
population
estimates
from
a
complex
81
survey
design,
we
must
account
for
the
sampling
variability
present
in
our
estimates
of
actual
frequency
and
expected
frequency.
The
variance
of
the
test
statistic
can
be
computed
reflecting
the
components
of
variance
at
the
design
stages,
stratification,
and
the
variability
in
the
sampling
weights.
Note
that
in
the
proposed
design
there
are
three
components
of
variance:
(
1)
variability
between
NDZs
within
a
regional/
age
stratum;
(
2)
variability
between
marinas
within
NDZs;
and
(
3)
variability
among
boaters
within
a
marina.
If
the
vector

'
=
(

11,

12,

21,

22)
denotes
the
ratios
involving
the
actual
and
expected
frequencies,
then
it
can
be
shown
that
the
test
statistic,

following
a
chi­
square
distribution,
for
the
hypothesis
in
this
example
is:

Q
=

'
(

)


=
matrix
of
the
variances
and
covariances
of
our

terms
We
will
also
cross­
tabulate
awareness
with
a
number
of
factors
and
look
at
the
differences
in
awareness
associated
with
the
different
cross­
tabulations.
For
example,
we
can
cross­
tabulate
awareness
with
different
boat
sizes
to
determine
whether
awareness
varies
by
the
size
of
boat
operated.
Significant
differences
could
be
determined
by
a
chi­
square
test
for
equal
proportions
across
categories.
Factors
that
we
would
consider
include:
boat
size,
type
of
on­
board
toilet
(
installed,
portable),
and
number
of
boating
trips.

These
factors
could
then
be
combined
in
a
logit
or
probit
regression
which
has
the
advantage
of
controlling
for
other
influences.
For
example,
a
significant
coefficient
on
boat
size
with
number
of
boating
trips
in
the
equation
would
indicate
that
boat
size
has
an
effect
on
awareness
independent
of
the
possibility
that
people
with
larger
boats
may
make
more
trips.
The
influence
of
number
of
trips
on
awareness
is
controlled
for
by
including
it
in
the
equation.
82
Similarly,
a
dummy
variable
for
interviewer
could
control
for
an
observed
interviewer
effect.

5(
c)
Reporting
Results
All
findings
will
be
presented
on
an
aggregated
basis;
no
marina
will
be
identified
in
any
of
the
reported
results.
The
survey
results
will
be
presented
in
a
publicly
available
report
possibly
placed
on
EPA's
web
site.

SECTION
6:
References
Converse,
Jean
M.
and
Stanley
Presser.
1986.
Survey
Questions:
Handcrafting
the
Standardized
Questionnaire.
Sage
University
Paper
series
on
Quantitative
Applications
in
the
Social
Sciences
07­
073.
Beverly
Hills,
CA:
Sage
Publications.

Dillman,
Don
A.
2000.
Mail
and
Internet
Surveys:
The
Tailored
Design
Method.
2nd
Edition.

New
York,
NY:
John
Wiley&
Sons,
Inc.

Foddy,
William.
1993.
Constructing
Questions
for
Interviews
and
Questionnaires:
Theory
and
Practice
in
Social
Research.
Cambridge,
United
Kingdom:
Cambridge
University
Press.

U.
S.
Environmental
Protection
Agency.
1999.
"
ICR
Handbook:
EPA's
Guide
to
Writing
Information
Collection
Requests
under
the
Paperwork
Reduction
Act
of
1995."
83
U.
S.
Environmental
Protection
Agency.
2002.
"
Guide
for
Measuring
Compliance
Assistance
Outcomes."
EPA
300­
B­
02­
011.
June.
Available
at
<
www.
epa.
gov/
compliance/
resources/
reports/
planning/
results/
cameasuring.
pdf>
84
Appendix
A
Section
312
of
Clean
Water
Act
85
86
87
88
89
90
Appendix
B
EPA
Marine
Sanitation
Device
Regulations
91
92
93
94
Appendix
C
Coast
Guard
Marine
Sanitation
Device
Regulations
95
96
97
98
99
Appendix
D
1st
Federal
Register
Notice
 
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
and
Marine
Sanitation
Devices
100
101
102
Appendix
E
Response
to
Comments
103
INTRODUCTION
On
March
27,
2003,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
published
"
Agency
Information
Collection
Activities:
Proposed
Collection;
Comment
Request;
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices"
in
the
Federal
Register
(
68
FR
14975).
In
68
FR
14975,
EPA
announced
that
the
Agency
was
planning
to
submit
the
Information
Collection
Request
(
ICR)
entitled
"
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices"
(
EPA
ICR
No.
2107.01)
to
the
Office
of
Management
and
Budget
(
OMB).
Before
submitting
the
ICR
to
OMB
for
review
and
approval,
EPA
solicited
comments
on
specific
aspects
of
the
proposed
information
collection
in
68
FR
14975.
This
document
entitled,
"
Response
to
Comments
on
the
March
27,
2003
Proposed
Information
Collection
Request:
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices"
presents
the
comments
received
and
EPA's
responses
to
those
comments.

This
ICR
requests
approval
to
collect
information
regarding
the
effectiveness
of
no­
discharge
zones
(
NDZs)
from
boat
owners
and
operators,
marina
owners
and
operators,
and
State
and
local
government
officials.
It
also
requests
approval
to
collect
information
regarding
the
effectiveness
of
marine
sanitation
devices
in
removing
harmful
pollutants
from
the
waste
stream
of
the
device.
Section
312
of
the
Clean
Water
Act
mandates
the
use
of
marine
sanitation
devices
(
MSDs)
on
all
vessels
with
installed
toilets.
There
are
three
types
of
MSDs.
Type
I
and
Type
II
MSDs
provide
treatment
of
sewage
that
is
to
be
discharged
and
rely
on
a
variety
of
different
technologies
for
treatment
prior
to
discharge
including
maceration,
chlorination,
heating,
filtering,
and
biological
processes.
Type
III
MSDs
are
holding
tanks
that
provide
minimal
sewage
treatment
and
can
be
installed
on
vessels
of
any
size.
Installed
toilets
on
vessels
of
65
ft.
or
less
in
length
may
be
equipped
with
any
of
the
three
types
of
MSDs.
Type
I
MSDs,
which
may
only
be
used
by
vessels
up
to
65
ft.
in
length,
are
required
to
produce
an
effluent
with
a
fecal
coliform
bacteria
count
equal
to
or
less
than
1000
bacteria
per
100
ml
of
seawater
with
no
visible
floating
solids.
For
vessels
greater
than
65
ft.,
all
installed
toilets
must
be
equipped
with
either
Type
II
or
Type
III
MSDs.
The
Type
II
MSDs
are
required
to
produce
an
effluent
with
a
fecal
coliform
count
less
than
or
equal
to
200
bacteria
per
100
ml
of
seawater
and
suspended
solids
less
than
or
equal
to
150
mg/
l.
Type
III
MSDs
are
holding
tanks
that
are
designed
to
prevent
overboard
discharge
of
any
sewage.
Also
under
Section
312
of
the
Clean
Water
Act,
with
EPA's
approval,
States
may
designate
a
portion
or
all
of
their
waters
as
NDZs
making
all
vessel
sewage
discharges
illegal.
States
designate
their
waters
as
no­
discharge
zones
for
vessel
sewage
to
achieve
any
of
the
following
objectives:
(
1)
to
protect
aquatic
habitats
where
pump­
out
facilities
are
available;
(
2)
to
protect
special
aquatic
habitats
or
species,
and
the
State
does
not
have
to
show
that
there
are
reasonably
available
pump­
out
or
dump
stations;
and
(
3)
to
safeguard
human
health
by
protecting
drinking
water
intake
zones,
and
the
State
does
not
have
to
show
that
there
are
reasonably
available
pump­
out
or
dump
stations.
Under
Section
312(
f)(
3),
States
designate
NDZs
for
vessel
sewage
by
demonstrating
to
EPA
that
safe
and
adequate
pump­
out
and
dump
facilities
are
available.
Currently
about
95%
of
the
no­
discharge
zones
designated
have
been
done
so
under
this
provision.
At
a
State's
request,
under
Sections
312(
f)(
4)(
A)
and
(
B),
NDZs
for
vessel
sewage
designations
also
can
be
established
by
regulation
by
EPA
if
the
State
demonstrates
that
additional
protection
of
the
aquatic
environment
is
required
to
protect
environmentally
sensitive
areas
such
as
shellfish
beds,
coral
reefs,
fish
spawning
areas,
or
if
the
water
body
is
a
drinking
104
water
source.
No­
discharge
zones
established
by
regulations
promulgated
by
EPA
do
not
require
the
availability
of
pump­
out
or
dump
facilities.
Currently,
about
5%
of
the
NDZs
for
vessel
sewage
have
been
designated
by
regulations
promulgated
by
EPA.
This
information
collection
request
will
focus
on
the
effectiveness
of
NDZs
for
vessel
sewage
designated
under
Clean
Water
Act
Section
312(
f)(
3).

The
EPA
solicited
comments
on
the
development
of
the
ICR
to:
(
i)
evaluate
whether
the
proposed
collection
of
information
is
necessary
for
the
proper
performance
of
the
functions
of
the
agency,
including
whether
the
information
will
have
practical
utility;
(
ii)
evaluate
the
accuracy
of
the
agency's
estimate
of
the
burden
of
the
proposed
collection
of
information,
including
the
validity
of
the
methodology
and
assumptions
used;
(
iii)
enhance
the
quality,
utility,
and
clarity
of
the
information
to
be
collected;
and
(
iv)
minimize
the
burden
of
the
collection
of
information
on
those
who
are
to
respond,
including
through
the
use
of
appropriate
automated
electronic,
mechanical,
or
other
technological
collection
techniques
or
other
forms
of
information
technology,
e.
g.,
permitting
electronic
submission
of
responses.

Following
the
review
and
incorporation
of
the
comments
received
by
the
EPA,
the
ICR
entitled,
"
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices,"
(
EPA
ICR
No.
2107.01)
was
completed.
A
Federal
Register
notice
will
appear
announcing
EPA's
submittal
of
ICR
No.
2107.01
to
the
OMB.

EPA'S
RESPONSES
TO
COMMENTS
EPA
received
20
sets
of
comments
and
has
addressed
them
below.
None
of
the
comments
suggested
that
EPA
not
conduct
the
proposed
surveys.
The
comments
were
from
States
and
a
U.
S.
Territory,
non­
governmental
organizations,
trade
associations,
a
marine
sanitation
device
(
MSD)
manufacturer,
a
laboratory,
and
private
citizens.
The
vast
majority
of
comments
provide
information
regarding
the
potential
questions
that
the
surveys
should
ask,
some
provided
information
regarding
the
perception
of
the
effectiveness
of
the
current
no­
discharge
zones(
NDZs)
and
MSDs,
and
additional
comments
provided
recommendations
on
how
EPA
should
modify
the
current
Vessel
Sewage
Discharge
Program.
Lastly,
some
offered
their
assistance
in
this
effort.
EPA
would
like
to
thank
all
of
the
individuals
and
organizations
that
provided
comments
on
this
ICR.
These
comments
will
assist
the
EPA
in
creating
an
ICR
that
will
allow
the
Agency
to
better
determine
the
effectiveness
of
no­
discharge
zones
for
vessel
sewage
and
marine
sanitation
devices.

Comment
#
1:
Puerto
Rico
Department
of
Natural
and
Environmental
Resources
May
23,
2003
RE:
Surveys
to
Determine
the
Effectiveness
of
No
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices.

To
Whom
It
May
Concern:
105
I
totally
agree
with
the
proposed
intention
to
survey
the
effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices.

I
understand
that
the
survey
will
include
respondents
from
the
North
and
Mid
Atlantic
States,
California,
the
Florida
Keys
and
the
Great
Lakes.
However,
the
Caribbean
Region
has
been
excluded.
There
is
also
a
great
amount
of
recreational
boaters
at
this
geographical
area
including
PR
and
the
U.
S.
Virgin
Islands.
Several
Pump
out/
Dump
Stations
had
been
placed
in
PR
with
an
Island­
wide
distribution.
The
nautical
community
in
this
region,
have
a
lot
of
interest
and
a
legitimate
intention
to
help
control
sewage
discharge
to
protect
the
marine
environment.

Response
#
1­
1:
The
current
survey
effort
is
intended
to
address
the
effectiveness
of
existing
NDZs.
Because
there
are
no
NDZs
established
in
Puerto
Rico
or
the
Caribbean,
boaters
and
marinas
in
these
areas
will
not
be
included
in
the
present
effort.
EPA
hopes
that
the
results
of
the
surveys
will
assist
Puerto
Rico
in
any
future
MSD
and
NDZ
activities.

As
a
matter
of
fact,
Puerto
Rico
has
almost
60,000
recreational
boaters
distributed
at
23
Marinas
detached
as
follows:
7
Yacht
Clubs,
6
Condo
Hotels,
1
Public
and
9
privately
owned
Marinas.

The
discharge
of
raw
sewage
and
partially
treated
sewage
poses
a
serious
threat
to
ecological
sensitive
areas.
The
degradation
of
water
quality
has
a
strong
effect
not
only
on
the
marine
habitat
but
on
recreational
and
tourism
activities.

The
Information
Collection
Request
(
ICR)
does
not
state
if
comments
should
be
received
from
States
or
Territories
with
designated
No
Discharge
Zones.
I
respectfully
submit
this
comments
and
strongly
support
every
effort
toward
the
effectiveness
of
No
Discharge
Zone
Designation
as
a
management
tool.

Response
#
1­
2:
The
survey
will
address
NDZs
designated
by
States
and
concurred
by
EPA
under
Clean
Water
Act
Section
312(
f).
The
definition
of
"
State"
for
this
provision
includes
U.
S.
Territories.
All
comments
regarding
the
ICR
received
from
any
citizen
or
organization
within
the
United
States
including
U.
S.
Territories
are
welcome.

Cordially,

Mayra
T.
García
PRDNER­
PO
Box
906600,
Puerta
de
Tierra
Station,
SJ
PR
00906­
6600
Comment
#
2:
Marine
Industries
Association
of
South
Florida
2312
So.
Andrews
Ave.,
Fort
Lauderdale,
FL
33316
(
954)
524­
2733
·
FAX
(
954)
524­
0633
www.
miasf.
org;
e­
mail:
miasf@
miasf.
org
May
27,
2003
106
Re:
Comments
on
No
Discharge
Zones
To
Whom
It
May
Concern:

The
current
application
criteria
for
and
subsequent
EPA
designation
of
No
Discharge
Zones
(
NDZ)
under
section
312(
f)(
3)
is
seriously
flawed
and
as
is
in
the
case
of
the
Florida
Keys
a
bad
policy
that
in
all
likelihood
exists
throughout
most
if
not
all
NDZ's
in
the
countries
coastal/
tidal
navigable
waters.

Comments:

EPA
does
not
recognize
the
advances
in
Type
I
&
II
MSD
technologies
and
disallows
their
use
in
coastal/
tidal
navigable
bodies
of
water
designated
as
an
NDZ.

Response
#
2­
1:
A
State
can
establish
a
NDZ
pursuant
to
Section
312(
f)(
3)
of
the
CWA
if
the
State
can
demonstrate
(
and
EPA
concurs)
that
adequate
facilities
for
the
safe
and
sanitary
removal
and
treatment
of
sewage
from
all
vessels
is
reasonably
available
for
the
waters
to
which
such
prohibition
would
apply.
In
such
a
NDZ,
no
vessel
discharges
of
any
kind
are
allowed.
EPA
has
developed
guidance
to
assist
States
in
preparing
their
application
for
a
NDZ.
Information
collected
from
MSD
manufacturers
and
Coast
Guard­
certified
laboratories
through
these
surveys
will
help
EPA
determine
the
current
level
of
MSD
technology.
Future
decisions
regarding
the
vessel
sewage
discharge
program
may
be
influenced
by
this
information.

The
ban
on
the
use
of
these
Type
I
&
II
MSD's
is
not
based
on
any
"
in
the
field"
scientific
evidence
that
the
use
of
these
devices
has
negatively
or
will
impair
water
quality.

Response
#
2­
2:
Under
Section
312
of
the
Clean
Water
Act,
no
discharges
of
sewage,
whether
treated
or
not,
are
allowed
in
areas
designated
as
NDZs.
States
may
designate,
or
request
that
EPA
issue
a
regulation
designating,
all
or
a
portion
of
their
waters
as
a
NDZ
to
improve
(
a)
water
quality,
(
b)
protect
aquatic
habitats
and
resources,
and/
or
(
c)
protect
human
health
through
drinking
water
intakes.
The
current
regulations
implementing
the
MSD
standards
address
only
two
pollutants
of
concern
 
fecal
coliform
bacteria,
which
indicate
the
presence
of
pathogens,
and
suspended
solids.
States
have
designated
NDZs
to
address
nutrients,
as
well
as
other
pollutants
such
as
disinfection
by­
products,
that
may
degrade
the
water
quality
of,
or
otherwise
harm,
the
aquatic
environment.
This
survey
effort
will
help
EPA
gather
"
in
the
field"
information
about
MSDs
and
NDZs.

Field
reports
of
failed
pump
out
equipment
in
NDZ's
combined
with
no
legal
requirement
for
pump
out
equipment
to
function
had
led
to
chronic
complaints
from
boaters
who
no
longer
have
alternatives
to
holding
tanks
and
pumpouts.

Response
#
2­
3:
EPA
partners
with
States
to
ensure
continued
operation
of
pumpout
facilities
in
NDZs.
If
boaters
have
complaints
about
non­
working
pump­
out
equipment
in
an
EPA­
approved
NDZ,
they
should
contact
the
State
authorities
107
(
and/
or
EPA
Regional
staff)
where
the
NDZ
is
located.
The
State
should
have
EPA
Regional
contact
information.
If
not,
the
information
can
be
found
on
EPA's
Vessel
Sewage
Discharge
Program
webpage
at
www.
epa.
gov/
owow/
oceans/
regulatory/
vessel_
sewage.
The
current
EPA
surveys
for
boaters,
as
well
as
marina
owners
and
operators,
are
designed
to
gather
information
on
pump­
out
availability,
failure
rates,
and
functional
efficiency.
Future
Vessel
Sewage
Discharge
Program
modifications
may
be
influenced
by
the
information
obtained
from
these
surveys.

The
Florida
Keys
was
granted
NDZ
designation
by
the
EPA
with
full
knowledge
that
"
adequate
pump
outs"
were
not
available
for
vessels
in
the
NDZ.

Response
#
2­
4:
EPA
is
not
certain
to
which
NDZ
in
the
Florida
Keys
the
Marine
Industries
Association
of
South
Florida
is
referring.
The
waters
surrounding
the
City
of
Key
West
were
designated
as
a
NDZ
in
August
1999.
That
designation
was
pursuant
to
the
provisions
of
Section
312(
f)(
3)
of
the
Clean
Water
Act
(
CWA).
The
State
of
Florida
certified
to
EPA
that
adequate
and
reasonably
available
pump­
out
facilities
were
available
for
all
vessels
in
the
proposed
NDZ;
EPA
concurred
in
that
assessment.
The
waters
within
the
Florida
Keys
National
Marine
Sanctuary
(
FKNMS)
were
designated
as
a
NDZ
in
May
2002.
That
designation
was
pursuant
to
the
provisions
of
Section
312(
f)(
4)(
A)
of
the
CWA.
Under
that
provision,
if
EPA
determines,
upon
application
by
a
State,
that
the
protection
and
enhancement
of
the
quality
of
specified
waters
within
that
State
requires
a
prohibition
of
sewage
discharges
from
vessels,
EPA
shall
prohibit
any
sewage
discharges
(
whether
treated
or
not)
from
all
vessels
into
the
specified
waters.
The
demonstration
by
the
State
of
the
adequacy
and
reasonable
availability
of
pump­
out
facilities
is
not
required
under
Section
312(
f)(
4)(
A).
However,
when
the
FKNMS
was
designated
in
May
2002,
there
were
30
pump­
out
facilities
in
the
Florida
Keys
region
and
more
are
coming
online.

The
EPA
does
not
base
NDZ
designation
on
any
field
studies
by
EPA
officials
to
confirm
that
there
actually
are
"
reasonable
and
adequate"
numbers
of
functional
pump
out
facilities
in
a
proposed
NDZ
to
service
all
the
vessels
with
installed
marine
toilets
in
the
NDZ.

Response
#
2­
5:
EPA
is
required
to
determine
if
the
proposed
pump­
out
facilities
are
adequate
and
reasonably
available.
The
Agency
has
developed
guidance
regarding
what
is
required
in
the
NDZ
application
package
from
the
State.
It
also
provides
guidance
on
what
information
should
be
used
to
assess
the
adequacy
and
reasonable
availability
of
pump­
out
facilities
to
support
the
proposed
NDZ.
The
Agency
uses
information
presented
in
the
NDZ
application
from
the
State,
as
well
as
any
public
comments
received,
to
make
its
assessment
and
final
determination
on
the
NDZ
application.

NDZ's
require
the
use
of
Type
III
MSD's
only
which
are
not
certified.
These
are
holding
tanks
and
portable
toilets
that
store
raw
untreated
sewage.
The
use
of
Y­
valves
and
sewage
discharge
pumps
on
vessels
is
commonplace
and
are
designed
to
allow
the
discharge
of
raw
untreated
sewage
overboard.
This
practice
although
illegal
in
all
waters
occurs
more
predominately
in
a
108
NDZ
because
boaters
have
no
alternatives
legally
available
when
pump
outs
are
not
working
or
readily
available.

Response
#
2­
6:
One
of
the
reasons
EPA
is
conducting
these
surveys
is
to
determine
the
extent
and
frequency
of
violations
in
NDZs
and
the
availability
of
pump­
out
facilities
in
those
areas.
The
boater
and
marina
owners
and
operators
surveys
contain
questions
regarding
the
availability
of
functioning
pump­
outs
and
how
boaters
deal
with
their
sewage
in
NDZs.
This
information
will
be
used
to
help
determine
boater
compliance
with
the
NDZ
requirements.

NDZ's
especially
large
ones
like
the
current
2900
square
miles
within
the
Florida
Keys
National
Marine
Sanctuary
are
largely
unenforceable.

Response
#
2­
7:
EPA
agrees
that
enforcement
against
sewage
discharges
into
large
NDZs,
such
as
the
FKNMS,
is
difficult.
Notwithstanding
such
burdens,
the
U.
S.
Coast
Guard,
local
marine
police,
and
State
agencies
have
enforcement
responsibility
for
designated
NDZs,
such
as
the
FKNMS.
EPA
also
helps
to
address
boater
compliance
by
educating
boaters
and
the
general
public
about
the
impact
of
vessel
sewage
discharges
on
the
marine
environment.
These
survey
efforts
are
intended
to
collect
information
on
current
enforcement
practices,
activities
associated
with
providing
the
public
with
appropriate
information
regarding
the
NDZ,
and
other
associated
trends
in
NDZs.

Conclusion:
The
EPA
should
factor
in
the
many
problems
associated
with
NDZ
designations
and
what
environmental
problems
result
from
such
designations.
Due
to
lack
of
enforcement,
reliability
of
pump
out
equipment
and
the
fact
that
holding
tanks
must
be
emptied
when
full,
combined
with
the
sole
but,
in
most
cases,
undesirable
means
of
onboard
waste
management,
you
have
a
recipe
for
environmental
disaster.
Boaters
experience
real
world
problems
that
EPA
does
not
seem
to
recognize.
It's
time
to
bring
EPA
NDZ
rules
and
regulations
up
to
date
with
these
problems
and
allow
current
Type
I
&
II
MSD
technological
alternatives
to
a
one
size
fits
all
approach
to
marine
sanitation
needs
and
environmental
protection.

Response
#
2­
8:
The
surveys
will
assess
the
potential
problems
associated
with
NDZ
designation.
EPA
will
use
the
survey
results
to
determine
the
current
performance
levels
of
MSDs.
This
information
may
be
used
in
future
Vessel
Sewage
Discharge
Program
modifications,
including
potential
regulatory
revisions.

Sincerely,

Frank
Herhold
Executive
Director
Marine
Industries
Association
of
South
Florida
Comment
#
3:
Raritan
Engineering
Company
109
Raritan
Engineering
Company
Manufactures
both
Type
I
and
Type
II
Marine
Sanitation
Devices
(
MSD's).
While
Raritan
has
never
objected
to
the
creation
of
No
Discharge
zones
under
312
(
f)
(
4)(
A)
and
(
B)
we
remain
concerned
over
the
proliferation
of
No
Discharge
Zones
in
coastal
tidal
waters.

To
that
extent
we
wish
to
comment
on
the
following
as
requested
in
the
Federal
Register
Notice.
(
i)
Evaluate
whether
the
proposed
collection
of
information
is
necessary
for
the
proper
performance
of
the
functions
of
the
agency,
including
whether
the
information
will
have
practical
utility:
EPA's
own
document
40
CFR
Ch
I
(
7­
1­
92
edition)
Part
140
clearly
states
that
applications
made
by
states
pursuant
to
section
312(
f)(
3)
of
the
act
shall
include:
1)
A
certification
that
the
protection
and
enhancement
of
the
waters
described
in
the
petition
require
greater
environmental
protection
than
the
applicable
federal
standard .
Time
and
time
again
it
has
been
shown
in
applications
that
a
certification
simply
consists
of
a
written
statement
from
the
Governor
or
Department
of
Environmental
Protection
(
DEP)
stating
that
their
waters
need
greater
protection
than
allowed
for
by
federal
standards.
There
is
no
burden
of
proof
on
the
state
to
supply
information
that
indicates:
1)
The
current
federal
law
is
being
enforced
2)
The
waters
have
been
severely
or
even
moderately
impacted
by
the
discharge
of
treated
sewage
3)
That
there
is
a
system
in
place
to
ensure
that
pump­
outs,
or
at
least
the
majority
of
them,
will
continue
to
function
once
the
No
Discharge
Status
is
granted.

Response
#
3­
1:
EPA
is
conducting
these
surveys
to
address
the
issues
you
have
raised.
There
are
questions
in
the
surveys
regarding
enforcement
issues,
and
EPA
continues
to
work
with
the
U.
S.
Coast
Guard
regarding
the
availability
of
pumpouts
and
vessel
sewage
compliance
in
NDZs.
There
are
questions
in
the
State
agency
surveys
that
seek
information
on
water
quality
data;
EPA
is
also
interested
in
the
perception
by
boaters
and
marina
owners
and
operators
of
any
water
quality
changes
since
the
designation
of
NDZs.
EPA
partners
with
the
States
to
ensure
continued
operation
of
pump­
out
facilities
in
NDZs
and
with
the
Fish
and
Wildlife
Service
to
ensure
the
States,
with
or
seeking
Clean
Vessel
Act
pump­
out
grant
funding,
comply
with
the
requirement
of
the
NDZ
designation.
If
boaters
have
complaints
about
non­
working
pump­
out
equipment
in
an
EPA­
approved
NDZ,
they
should
contact
the
State
authorities
in
the
State
where
the
NDZ
is
located.

Further
#
3
above,
less
than
1
year
after
the
Shark
River
in
New
Jersey
was
granted
No
Discharge
Status
not
a
single
pump­
out
station
was
functioning.
A
call
placed
to
the
EPA
Region
II
office
yielded
the
following
response
from
Jim
Olander:
It
is
not
the
EPA's
responsibility
to
be
sure
pump­
outs
continue
to
function,
that
is
the
States
responsibility.
While
Raritan
Engineering
agrees
with
the
response
to
the
extent
that
it
does
not
expect
the
EPA
to
police
pump­
outs,
we
do
question
the
logic
of
granting
a
No
Discharge
Zone
better
referred
to
as
a
No
Treatment
Zone
with
no
accountability
to
the
State
or
Marina
Owners
while
boat
owners
are
being
penalized.
This
example
should
demonstrate
to
the
EPA
that
it
might
be
time
to
re­
evaluate
their
policies
regarding
the
implementation
of
more
No
Discharge
Zones.
110
Response
#
3­
2:
EPA
is
conducting
these
surveys
to
assess
pump­
out
facility
availability
and
functionality.
The
MSD
standards
do
not
mandate
that
the
State
assure
continued
pump­
out
functionality.
EPA
has
developed
guidance
for
States
that
suggests
that
NDZ
applications
include
maintenance
plans
for
their
proposed
pump­
out
facilities.
EPA
expects
that
owners
and
operators
of
pump­
out
facilities
will
maintain
these
facilities,
and
that
both
State
and
local
enforcement
entities
will
use
their
authority
to
ensure
that
facilities
remain
functional.
EPA
continues
to
work
with
State
and
local
government
entities
to
improve
accountability
for
pumpout
functionality
in
NDZs
and
with
Fish
and
Wildlife
Service
to
address
maintenance
and
education
regarding
pump­
out
facility
operation
and
maintenance
in
NDZs
that
are
supported
by
Clean
Vessel
Act
funding.

(
ii)
Evaluate
the
accuracy
of
the
agency's
estimate
of
the
burden
of
the
proposed
collection
of
information,
including
the
validity
of
the
methodology
and
assumptions
used;
and
(
iii)
Enhance
the
quality,
utility,
and
clarity
of
the
information
to
be
collected.

The
Notice
says
80
marina
owners
from
the
geographical
regions
will
be
selected.
It
estimates
only
35
will
respond.
This
number
is
too
small
to
make
any
determination,
while
we
realize
the
cost
of
doing
the
survey
is
a
burden
the
EPA
must
absorb
perhaps
it
would
be
wise
to
include
each
states
Marine
Trades
Association
to
help.
The
more
accurate
the
information
the
EPA
gets
from
Marinas
the
more
likely
the
EPA
are
to
gain
a
good
overall
"
picture"
of
the
current
system.

Response
#
3­
3:
These
surveys
are
designed
to
provide
information
that
can
be
used
to
statistically
evaluate
the
overall
NDZ
program.
The
survey
design
includes
surveys
conducted
in
15
NDZs
located
in
the
North,
Mid,
and
South
Atlantic
regions,
the
Great
Lakes,
and
California.
It
will
include
a
maximum
of
5
marinas
per
NDZ
(
If
there
are
less
than
5
marinas
in
a
NDZ,
all
will
be
included).
Marina
owners
and
operators
at
each
of
the
marinas
will
be
surveyed
along
with
boaters.
The
surveys
will
be
conducted
on
a
Saturday
and
Sunday
for
each
marina,
which
will
give
EPA
access
to
the
greatest
number
of
boaters.
Given
the
resources
available
to
EPA
for
these
survey
efforts,
we
believe
meaningful
information
will
be
obtained
from
the
data
received.
EPA
will
use
any
appropriate
assistance
on
this
effort
from
any
organization,
including
the
Marine
Trades
Association.
Assistance
includes
organizations
letting
their
constituents
know
that
these
surveys
may
be
conducted
in
their
area
and
for
them
to
encourage
their
constituents
to
participate.

The
most
important
questions
to
ask
Marina
owners
are:


How
many
pump­
outs
do
you
average
a
week
vs.
a
weekend

How
often
is
your
equipment
broken
or
not
operating?


Is
your
pump­
out
self­
serve
or
do
you
operate
it?

Response
#
3­
4:
Your
suggestions
have
been
incorporated
into
our
surveys.

We
caution
that
if
the
survey
comes
from
the
EPA
or
Government
agency
the
results
may
not
be
accurate.
An
independent
survey
company
would
be
better
suited
for
both
marinas
and
boat
111
owners.
If
observation
of
pump­
outs
is
to
be
conducted
the
site
visits
should
be
unannounced
and
in
cases
of
an
all
day
observation
should
be
done
at
a
distance.

Response
#
3­
5:
The
surveys
will
not
be
conducted
by
any
government
agency;
they
will
be
administered
by
an
EPA
contractor.
The
surveys
of
boaters
will
be
unannounced;
the
surveys
of
marina
facilities
will
be
undertaken
at
a
time
of
mutual
agreement.
This
effort
does
not
include
observations
or
inspections
of
pump­
out
facilities.

The
Boat
Owner
survey
MUST
include
a
variety
of
boaters
and
include
boats
that
operate
over
reasonable
distances
and
time
periods
to
avoid
a
skew
in
favor
of
day
sailors
whose
need
for
intelligent
management
of
sewage
is
likely
to
be
minimal.
The
survey
should
also
include
a
question
that
asks
what
problems
have
you
experienced
with
Type
I,
Type
II
and
Type
III
MSD's
along
with
problems
experienced
with
the
use
of
pump­
out
or
dump
stations.

Response
#
3­
6:
EPA
recognizes
that
there
are
concerns
about
the
operation
and
maintenance
of
MSDs.
The
survey
addresses
boats
and
boaters
that
operate
within
NDZs;
however,
the
time
spent
by
boaters
within
the
NDZs
is
outside
the
scope
of
this
survey.
There
are
questions
within
the
boater
survey
that
address
the
boater's
knowledge
regarding
the
performance
of
their
MSDs
and
their
boating
activities.

(
iv)
Minimize
the
burden ..
Electronic
submittal
is
a
wonderful
solution,
however,
the
caution
again
goes
out
that
respondents
may
not
submit
accurate
information
if
they
know
the
purpose
for
which
their
input
is
being
used.
While
surveys
can
be
annoying
Boaters,
Marina
Owners,
MSD
manufacturers,
EPA
and
Coast
Guard
all
want
clean
water
at
the
end
of
the
day.
The
request
to
fill
out
a
survey
should
not
be
viewed
as
a
burden
but
a
positive
step
in
achieving
clean
water.

Response
#
3­
7:
EPA
expects
that
the
surveys
for
marina
and
boat
owners
and
operators
will
be
completed
on
site.
EPA
will
accept
electronic
submission
of
any
reports
of
data
that
States
and/
or
MSD
manufacturers
and
labs
wish
to
supply
to
support
their
answers.

We
hope
that
this
information
will
encourage
the
EPA
to
consider
evaluation
of
No
Discharge
Zones
and
their
effectiveness
in
conjunction
with
a
review
of
the
current
standards
for
MSD's.

Response
#
3­
8:
This
information
may
be
used
in
future
Vessel
Sewage
Discharge
Program
modifications,
including
potential
regulatory
revisions.

In
considering
effectiveness
of
No
Discharge
Zones
it
may
be
worthy
to
note
that
improvements
in
many
water
bodies
have
come
from
stricter
standards
in
POTW's
along
with
increasing
numbers
of
public
sewer
systems
in
favor
of
septic
systems
and
a
decrease
in
the
amount
of
fertilizer
being
applied
combined
with
the
requirement
of
livestock
to
be
further
away
from
a
water
body.

Response
#
3­
9:
EPA
agrees
that
significant
strides
have
been
made
in
protecting
our
waters
by
improvements
in
point
and
non­
point
source
controls.
112
Raritan
Engineering
Company
P.
O.
Box
1157
Millville,
NJ
08332
856­
825­
4900
Comment
#
4:
Maryland
Department
of
Natural
Resources
May
7,
2003
EVALUATE
NECESSITY
OF
ICR

The
collection
of
the
proposed
information
would
help
address
issues
raised
in
some
areas
about
the
need
to
restrict
MSD
use
in
NDZs
as
well
as
the
overall
effectiveness
of
NDZs.
This
would
help
states
determine
the
extent
they
want
to
pursue
these
designations.

Response
#
4­
1:
We
concur.

EVALUATION
OF
ESTIMATED
BURDEN
OF
THE
ICR

Although
there
was
no
survey
instrument
available
for
review,
the
estimate
of
20
minutes
to
complete
the
survey
of
boaters
and
marinas
seems
high.
Since
the
subject
matter
is
quite
limited,
the
survey
should
take
about
10
minutes,
certainly
no
longer
than
12­
15
minutes.
Times
allotted
for
other
components
seems
about
right.

Response
#
4­
2:
We
appreciate
your
comments
on
this
matter.
Our
current
estimate
is
that
the
survey
should
take
less
than
15
minutes
to
complete.
We
have
used
conservative
assumptions
to
estimate
survey
completion
time.
Thus,
the
estimated
time
of
completion
may
be
greater
than
the
actual
time.

QUALITY,
UTILITY,
AND
CLARITY
OF
INFORMATION
TO
BE
COLLECTED
Comments
on:
Proposed
Survey
of
Boaters

How
will
boaters
be
identified?
In
Maryland,
there
are
two
relatively
small
NDZs.
A
random
sample
of
registered
boaters
(
our
standard
survey
method)
may
not
produce
any
boaters
with
any
experience
boating
within
an
NDZ.

Response
#
4­
3:
Boaters
will
be
surveyed
only
at
marinas
within
14
selected
NDZs.
Thus,
all
survey
respondents
will
at
least
have
some
experience
operating
within
NDZs.


In
asking
about
the
availability
(
working
or
non­
working)
of
pumpout
facilities
within
the
NDZs,
it
would
be
useful
to
identify
the
specific
problems.
Maryland
conducted
a
boating
waste
disposal
survey
in
2000
and
asked
boaters
who
said
that
pumpouts
were
not
conveniently
located
to
specify:
too
crowded;
not
close
by;
frequently
non­
operational;
closed
for
season;
other.
113
Response
#
4­
4:
The
surveys
contain
questions
that
will
help
EPA
identify
the
potential
problems
you
have
listed.


Since
proper
operation
and
maintenance
of
MSDs
is
required
for
effective
treatment
of
vessel
sewage,
it
would
also
be
useful
to
ask
boaters
if
they
feel
that
most
boat
operators
(
and
guests)
understand
how
to
effectively
operate
MSDs,
employ
proper
operating
procedures,
and
conduct
regular
maintenance.
(
The
Maryland
survey
showed
a
significant
percentage
of
boaters
who
said
additional
education
on
MSD
operation
is
needed.
Improper
use
could
result
in
harmful
discharges.)

Response
#
4­
5:
EPA
recognizes
that
there
are
concerns
about
the
operation
and
maintenance
of
MSDs.
The
survey
contains
questions
that
address
boaters'
knowledge
of
the
proper
operation
of
MSDs.


The
biggest
flag
raised
by
boaters
in
Maryland
who
question
the
effectiveness
of
NDZs
is
the
ability
to
detect
violations
and
enforce
the
regulation.
It
would
be
worth
asking
a
question
about
this,
perhaps
something
like:
Do
you
think
NDZs
are
beneficial
despite
the
difficulty
in
detecting
violations?

Response
#
4­
6:
Illegal
MSD
discharges
are
indeed
often
difficult
to
detect,
and
to
enforce
against.
Enforcement
against
such
discharges
is
the
responsibility
of
the
U.
S.
Coast
Guard,
State
agencies,
the
local
marine
police,
or
a
combination
of
those
entities.
The
surveys
contain
questions
intended
to
determine
how
boaters
perceive
the
effectiveness
of
NDZs,
as
well
as
whether
current
enforcement
measures
are
effective.
In
addition,
the
surveys
ask
questions
about
hindrances
to
complying
with
NDZs.

Comments
on:
Proposed
Survey
of
State
and
Local
Government
Officials

Please
consider
including
regional
entities
such
as
the
Chesapeake
Bay
Program
and
Coastal
Bays
Program.

Response
#
4­
7:
The
surveys
are
intended
to
gather
information
from
the
State
and
local
governments
that
are
responsible
for
designating,
and/
or
enforcing
NDZs.
Because
the
Chesapeake
Bay
Program
and
Maryland
Coastal
Bays
Program
are
not
responsible
for
designating
or
enforcing
NDZs,
these
two
entities
will
not
be
included
in
our
surveys.

Comments
on:
Proposed
survey
of
MSD
Manufacturers
and
Laboratories

It
would
be
useful
to
have
the
laboratories
check
the
effectiveness
of
new
MSDs
as
well
as
MSDs
that
have
been
in
use
for
several
years.
Since
MSDs
are
potentially
subject
to
human
error,
the
impacts
associated
with
common
mistakes,
misuse,
or
malfunctions
would
also
be
relevant.
The
concern
to
be
addressed
is,
if
certifications
are
performed
only
at
the
time
of
manufacture,
can
it
be
assumed
that
the
day­
to­
day
operation
by
individuals
over
long
periods
of
time
will
achieve
the
same
results
as
the
lab
at
the
time
of
certification?
And
if
not,
how
big
a
concern
is
it?
114
Response
#
4­
8:
EPA
concurs
with
your
concerns.
The
surveys
contain
questions
about
long­
term
performance
of
Coast
Guard­
certified
MSDs.

Comment
#
5:
Maryland
Coastal
Bays
Program
Comments
on
Agency
Information
Collection
Activities:
Proposed
Collection;
Comment
Request;
Surveys
to
Determine
the
effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices.

OW­
2003­
0014,
FRL­
7473­
6
Agency:
Environmental
Protection
Agency
The
Information
Collection
Request
(
ICR)
will
be
an
important
tool
to
evaluate
the
existing
regulations
pertaining
to
the
health
of
marine
and
estuarine
waters.
A
focus
of
EPA's
efforts
to
improve
the
health
of
the
Nation's
ocean
and
coastal
waters
should
be
to
enhance
regulations
of
discharges
of
pollution
from
vessels.
Some
of
the
key
work
includes
designation
of
No­
Discharge
Zones
(
NDZ);
assessing
the
effectiveness
of
current
regulations
and
revising
them
as
needed;
revising
performance
standards
for
marine
sanitation
devices
in
cooperation
with
the
Coast
Guard;
and
promoting
technological
advancement
in
those
devices
to
reduce
sewage
discharges
from
vessels.

Response
#
5­
1:
The
surveys
are
intended
to
evaluate
the
effectiveness
of
NDZs
and
U.
S.
Coast
Guard­
certified
MSDs
in
removing
harmful
pollutants
from
their
waste
stream.
The
information
obtained
from
these
survey
efforts
may
be
used
in
the
future
when
EPA
considers
various
Vessel
Sewage
Discharge
Program
modification
options.

The
following
are
comments
submitted
by
the
Maryland
Coastal
Bays
Program
(
a
portion
of
which
was
designated
an
NDZ
in
2002)
for
each
of
the
requested
comment
topics:

1.
Evaluate
whether
the
proposed
collection
of
information
is
necessary
for
the
proper
performance
of
the
functions
of
the
agency,
including
whether
the
information
will
have
practical
utility:

The
survey
will
provide
valuable
information
regarding
issues
related
to
Marine
Sanitation
Device's
(
MSD)
and,
pumpout
stations
in
No­
Discharge
Zones
(
NDZ).
The
summary
results
would
be
useful
in
determining
compliance
with
NDZ's.

However,
it
should
be
made
clear
that
the
objective
of
this
survey
is
to
focus
on
the
effectiveness
of
compliance
of
the
NDZ
designation
and
effectiveness
of
MSD's.
It
will
not
be
able
to
determine
any
information
regarding
the
objectives
of
the
No­
Discharge
Zone
designations.
The
objectives
are
to
(
1)
protect
aquatic
habitats;
(
2)
protect
special
aquatic
habitats;
and
(
3)
safeguard
human
health
by
protecting
drinking
water
intake
zones.
In
order
to
evaluate
the
effectiveness
of
these
three
objectives,
further
scientific
and
technical
studies
should
be
accomplished.
The
impact
of
NDZ's
on
water
quality,
habitats
and
natural
resources
could
be
115
evaluated
over
the
long
term.
Improvements
to
the
biological,
chemical
and
physical
impacts
on
the
environment,
which
are
not
included
here,
will
ultimately
be
the
overall
judge
of
success
of
the
efforts
to
reduce
sewage
discharges
into
aquatic
habitats.

Response
#
5­
2:
As
part
of
our
efforts,
EPA
will
be
soliciting
water
quality
data
from
States.
This
information
may
assist
EPA
in
determining
the
effectiveness
of
NDZs
in
protecting
and
improving
water
quality.
EPA
will
also
be
gathering
information
from
boaters
as
well
as
marina
owners
and
operators
on
their
perception
of
water
quality
changes
associated
with
NDZ
designations.
That
information
may
be
used
to
determine
if
a
correlation
exists
between
perception
of
water
quality
change
and
boater
compliance
with
NDZ
requirements.

2.
Evaluate
the
accuracy
of
the
agency's
estimate
of
the
burden
of
the
proposed
collection
of
information,
including
the
validity
of
the
methodology
and
assumptions
used;

The
estimate
and
assumptions
of
the
burden
appear
accurate.
It
is
difficult
to
determine
the
overall
burden
without
reviewing
the
actual
survey.

Response
#
5­
3:
The
draft
surveys
and
the
ICR
will
be
available
for
public
comment.
A
notice
of
their
availability
will
be
published
in
the
Federal
Register.
We
have
estimated
that
the
total
burden
will
be
$
296,000
over
a
total
of
7,146
hours
expended.

3.
Enhance
the
quality,
utility
and
clarity
of
the
information
to
be
collected;

Survey
of
Boaters
One
concern
of
surveying
boaters
will
be
how
to
identify
boaters
that
have
experience
boating
in
the
NDZ
in
our
area
of
Maryland's
Coastal
Bays.
Maryland
has
a
large
boating
public
but
the
population
that
uses
Maryland's
Coastal
Bays
is
a
small
percentage.
Additionally,
many
of
our
boaters
are
transient
in
nature
and
come
from
Delaware
and
Pennsylvania.

Response
#
5­
4:
Because
the
surveys
will
be
conducted
at
marinas
in
NDZs,
all
boaters
questioned
will
have
been
operating
in
a
NDZ.
The
surveys
should
reach
a
substantial
number
of
boaters,
including
those
traveling
from
other
areas.

The
Maryland
State
and
Worcester
County
governments
may
be
able
to
provide
information
for
the
survey
on
the
boating
public
that
uses
the
local
area.

The
State
of
Maryland
completed
surveys
in
2000
in
the
Coastal
Bays
and
Herring
Bay
areas.
Several
issues
were
revealed
as
a
result
of
the
initial
survey
that
could
be
helpful
to
focus
specific
questions
for
this
effort.
*
The
reason
that
pumpout
facilities
may
not
be
functioning
or
available.
Are
they
not
in
accessible
location,
too
crowded,
broken
down,
closed
for
the
season,
etc.
*
Do
boaters
and
guests
effectively
operate
MSD's
including
proper
operating
procedures
and
maintenance.
*
The
effectiveness
of
enforcement
and
detecting
violations.
This
was
an
issue
and
concern
among
boaters.
116
Response
#
5­
5:
EPA
concurs
with
your
assessment
of
the
focus
of
the
questions
to
be
asked.
The
surveys
contain
questions
addressing
the
issues
you
raised.

Survey
of
Marinas
The
Maryland
Coastal
Bays
Program
and
Department
of
Natural
Resources
completed
a
Survey
of
Marinas
in
2001.
A
question
about
types
or
methods
of
training
for
employees
and
staff
on
the
operation
of
pumpouts
should
be
asked.
Can
they
document
or
have
they
noticed
an
increase
in
the
usage
of
pumpouts?

Response
#
5­
6:
The
surveys
contain
questions
about
the
training
of
marina
employees
on
pump­
out
operation.

Survey
of
State
and
Local
Governments
Recommend
including
other
local
programs
that
have
assisted
with
surveys,
offered
information
and
provided
education
on
the
topic
of
NDZ's
and
where
they
occur
in
their
area.
For
example,
National
Estuary
Programs
(
NEP's)
such
as
the
Maryland
Coastal
Bays
Program,
Barnegat
Bay
Program
in
New
Jersey,
and
Narragansett
Bay
Program
in
Rhode
Island
have
participated
in
efforts
such
as
these.
Others
to
include
may
be
National
Estuarine
Research
Reserves
(
NERR's),
the
Chesapeake
Bay
Program,
and
Chesapeake
Bay
Commission.

Response
#
5­
7:
The
surveys
are
intended
to
reach
the
State
and
local
governments
that
are
responsible
for
designating
and/
or
enforcing
NDZs.
Because
the
National
Estuary
Programs,
National
Estuarine
Research
Reserves,
and
the
Chesapeake
Bay
Commission
are
not
responsible
for
designating
or
enforcing
NDZs,
these
entities
will
not
be
included
in
our
surveys.

Survey
of
MSD
Manufacturers
and
Coast
Guard
accepted
Laboratories
This
section
of
the
survey
could
be
very
valuable.
It
would
be
useful
to
have
the
laboratories
check
the
effectiveness
of
new
MSDs
as
compared
to
MSDs
that
have
been
in
use
for
several
years.
Since
MSDs
are
potentially
subject
to
human
error,
the
impacts
associated
with
common
mistakes,
misuse,
or
malfunctions
would
also
be
relevant.
The
concern
to
be
addressed
is,
if
certifications
are
performed
only
at
the
time
of
manufacture,
can
it
be
assumed
that
the
day­
to­
day
operation
by
individuals
over
long
periods
of
time
will
maintain
the
same
results
as
the
lab
at
the
time
of
certification?
And
if
not,
how
big
a
concern
is
it?

Response
#
5­
8:
The
surveys
of
Coast
Guard­
certified
laboratories
are
being
undertaken
to
obtain
data
on
their
testing
of
MSDs
for
certification
purposes.
The
MSD
manufacturer
surveys
are
being
performed
to
obtain
their
original
MSD
performance
data.
EPA
recognizes
that
there
are
concerns
about
the
long­
term
performance
of
MSDs.
EPA
will
be
gathering
data
on
the
age
of
the
device
at
the
time
it
was
tested.
The
surveys
also
contain
questions
on
the
extended
performance
abilities
of
Coast
Guard­
certified
MSDs.
If
the
Maryland
Coastal
Bays
Program
has
any
information
regarding
MSD
performance,
EPA
welcomes
the
submission
of
117
the
data.
The
Agency
may,
in
future
efforts,
continue
to
address
the
issue
of
continuing
performance
of
MSDs.

4.
Minimize
the
burden
of
the
collection
of
information
on
those
who
are
to
respond.

Proposal
appears
reasonable.

Thank
you
for
the
opportunity
to
comment
on
the
proposal.

David
Blazer,
Executive
Director
Maryland
Coastal
Bays
Program
9609
Stephen
Decatur
Highway
Berlin,
Maryland
21811
410­
213­
2297
phone
410­
213­
2574
fax
director@
mdcoastalbays.
org
http://
www.
mdcoastalbays.
org
Comment
#
6:
Marina
Operators
Association
of
America
Memo
to:
EPA
Office
of
Water,
Environmental
Protection
Agency
From:
Mari
Lou
Livingood,
Director
of
Program
Development,
Marina
Operators
Association
of
America
Date:
April
28,
2003
Re:
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices
The
Marina
Operators
Association
of
America
(
MOAA)
submits
the
following
comments
on
the
proposed
EPA
ICR
to
the
Office
of
OMB
regarding
the
Surveys
to
Determine
the
Effectiveness
of
NO­
discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices,
EPA
ICR
N.
2107.01.

MOAA
suggests
that
the
survey
include
some
emphasis
on
the
following
topics,
issues
and
questions:

For
marina
operators:

I.
Marina
operators
need
information
regarding
the
best
MSD
equipment.
Questions
that
may
assist
in
determining
the
best
equipment
available
to
them
to
consider
are:


What
types
of
repairs
are
most
frequent
or
common
on
your
pumpout
system?


How
many
times
is
the
pumpout
out
of
service
per
year?


How
many
hours
of
pumpout
operation
per
year?


What
are
the
reasons
the
pumpout
was
out
of
order
with
a
ranking
of
mechanical
error
possibilities?

Response
#
6­
1:
The
first
question
is
outside
the
scope
of
this
survey.
Your
last
three
suggested
questions
have
been
incorporated.
118
II.
Ascertain
amount
the
waste
collected
by
calculating
gallons
of
waste
pumped
out
on
a
yearly
basis
to
determine
benefit
of
pumpout
to
water
body.

Response
#
6­
2:
Your
suggestion
has
been
incorporated
into
the
surveys.

III.
To
determine
the
amount
of
training
the
marina
staff
is
given
on
pumpout
use
and
application.
1)
What
type
of
training
is
marina
staff
given
for
pumpout
collection?
2)
Who
trained
the
staff?
3)
How
many
hours
of
training
were
staff
given?
4)
What
are
the
marina's
Best
Management
Practices
of
its
MSD
use,
if
available?
5)
What
type
of
training
does
MSD
retailer
give
to
the
marina
operator?

Response
#
6­
3:
Your
suggestions
(
1
­
4)
have
been
incorporated
into
the
surveys.
Regarding
question
5,
surveys
have
questions
regarding
training
the
marina
staff
may
be
given
associated
with
operation
of
the
pump­
out
facilities
in
an
environmentally
protective
manner.
However,
best
management
practices
training
associated
with
MSDs
are
not
within
the
scope
of
the
surveys.

III.
The
coordination
or
system
a
marina
may
use
to
accommodate
sailboat
vs.
motor
boat
pumpout
use
at
dock
to
accommodate
fuel
dispensing
vs.
pumpout
only.

Response
#
6­
4:
The
surveys
address
boat
type
(
e.
g.,
sailboat
or
motorboat).
They
also
contain
questions
regarding
the
services
that
the
marina
offers.

IV.
What
is
the
location
(
on
a
bulkhead,
T­
head,
or
gas
dock)
of
the
pumpout
at
the
marina?
What
is
the
mean
water
depth
at
pumpout,
ease
of
access
to
pumpout
and
size
of
boat
able
to
access
pumpout?

Response
#
6­
5:
The
exact
location
of
the
pump­
out
facility
is
not
within
the
scope
of
the
survey;
however,
the
surveys
do
address
the
maximum
draft
vessel
that
the
marinas'
pump­
out
facilities
can
accommodate
as
well
as
pump­
out
accessability.

For
Boaters:

I.
The
length
or
time
of
training
boaters/
slipholders
is
given
on
MSD
use
from
the
boat
supplier
or
marina
operator.

Response
#
6­
6:
The
surveys
contain
questions
regarding
the
general
knowledge
of
boaters
about
the
operation
of
their
MSDs
and
the
use
of
their
MSDs
within
the
NDZ.
The
specific
training
boaters
receive
regarding
their
MSDs
is
not
within
the
scope
of
the
surveys.

The
Marina
Operators
Association
has
a
terrific
interest
in
the
proliferation
and
use
of
pumpout
systems.
We
support
an
effort
to
collect
information
on
the
use
of
pumpouts
so
that
the
most
informed
decisions
can
be
made
with
respect
to
regulation
of
pumpouts
and
no­
discharge
zones.
119
Response
#
6­
7:
Your
name
has
been
added
to
the
distribution
list.

Comment
#
7:
Joiner
Micro
Laboratories,
Inc.

Dear
Mr.
Woodley,

I
am
interested
in
reviewing
the
survey
for
boat
owners
regarding
NDZ's
and
MSD's.
Also
any
information
regarding
the
study
that
is
on­
going
to
assess
the
effectiveness
of
NDZ's
and
MSD's
in
removing
pollutants.

Robyn
W.
Joiner,
Lab
Director
Joiner
Micro
Laboratories,
Inc.
77­
F
West
Lee
Street
Warrenton,
VA
20186
540­
347­
7212
Fax:
540­
347­
1606
rwjoiner@
joinermicrolab.
com
Response
#
7:
Your
name
has
been
added
to
our
distribution
list.

Comment
#
8:
Taylor
Shellfish
Company,
Inc.

Bill
Dewey
<
BillD@
taylorshellfish.
com>

04/
03/
2003
01:
54
PM
To:
James
Woodley/
DC/
USEPA/
US@
EPA
Subject:
no
discharge
zone
study
Mr.
Woodley,

I
read
of
the
study
to
be
done
on
the
effectiveness
of
no
discharge
zones
in
EPA's
WaterNews.
I
would
be
interested
in
being
added
to
a
mailing
list
to
receive
information
or
results
from
this
study.

I
serve
on
the
Puget
Sound
Council
overseeing
the
implementation
of
the
Puget
Sound
Management
Plan.
No
discharge
zones
are
a
tool
I
have
been
trying
to
get
the
Council
to
consider
for
addressing
boater
discharge.
Information
regarding
their
effectiveness
would
be
very
useful.

Thanks,

Bill
Dewey
Taylor
Shellfish
Company,
Inc.
130
SE
Lynch
Rd.
Shelton,
WA
98584
Office
(
360)
426­
6178
Cell
(
360)
790­
2330
Fax
(
360)
427­
0327
120
email:
billd@
taylorshellfish.
com
web:
www.
taylorshellfish.
com
Response
#
8:
Your
name
has
been
added
to
our
distribution
list.

Comment
#
9:
New
York
Sea
Grant
Program
Jay
Tanski
<
jjt3@
cornell.
edu>
04/
02/
2003
02:
58
PM
To:
James
Woodley/
DC/
USEPA/
US@
EPA
Subject:
NDZ
&
MSD
Studies
Dear
Mr.
Woodley,

I
am
very
interested
in
study
on
the
effectiveness
of
the
NDZ's
and
the
effectiveness
of
No
Discharge
Zones
mentioned
below.
I
would
appreciate
any
information
you
have
on
these
efforts
and
would
also
like
to
be
put
on
any
mailing
list
you
may
have
for
future
updates.
My
address
telephone
number
etc,
can
be
found
at
the
bottom
of
this
message.

Thank
you
in
advance
and
I
look
forward
to
hearing
from
you.

Jay
Tanski
New
York
Sea
Grant
Program
Coastal
Processes
and
Facilities
Specialist
146
Suffolk
Hall
SUNY,
Stony
Brook,
NY
11794­
5002
Phone:
(
631)
632­
8730
Fax:
(
631)
632­
8216
Response
#
9:
Your
name
has
been
added
to
our
distribution
list.

Comment
#
10:
Mississippi
Headwaters
Board
Jane
VanHunnik
<
cass.
mhb@
co.
cass.
mn.
us>
04/
02/
2003
12:
43
PM
To:
James
Woodley/
DC/
USEPA/
US@
EPA
Subject:
NDZ
Dear
Mr.,
Woodley,

I
am
the
Director
of
the
Mississippi
Headwaters
Board
(
MHB).
Our
agency
protects
and
provides
oversight
to
local
government
in
the
land
use
surrounding
the
first
400
miles
of
the
Mississippi
river,
from
Lake
Itasca
through
eight
counties
including
the
Leech
Lake
Reservation
to
the
City
of
Royalton.

My
interest
in
writing
to
you
is
in
the
No­
Discharge
Zones
(
NDZ)
proposed
for
the
Clean
Water
Act.
It
appears
in
my
professional
opinion
that
NPDES
permits
most
often
do
not
account
for
the
carrying
capacity
of
the
body
into
which
they
discharge.
This
is
most
certainly
true
of
emergency
discharges.
121
Response
#
10­
1:
Vessel
sewage
discharges
are
not
regulated
under
the
National
Permit
Discharge
Elimination
System
(
NPDES)
requirements.
However,
the
carrying
capacity
of
a
water
body,
including
NPDES­
permitted
discharges,
is
taken
into
consideration
under
the
CWA
Total
Maximum
Daily
Load
(
TMDL)
Program.
TMDLs
and
NPDES­
permitted
discharges
are
beyond
the
scope
of
this
effort.

In
addition,
waste
discharges
from
boats
or
ice
fishing
houses
on
the
Rivers
and
Headwaters
Lakes
are
completely
unregulated.

Response
#
10­
2:
Discharges
of
sewage
from
vessels
are
regulated
by
Section
312
of
the
Clean
Water
Act
(
CWA).
That
section
requires
that
sewage
from
vessels
with
installed
toilets
must
be
treated
by
a
U.
S.
Coast
Guard­
approved
MSD
prior
to
discharge.
There
is
an
existing
NDZ
at
the
junction
of
the
Minnesota
and
Mississippi
Rivers
where
all
discharges
of
vessel
sewage
are
prohibited.
Enforcement
against
illegal
sewage
discharges
from
vessels
with
installed
toilets,
depending
on
the
particular
location,
may
be
the
responsibility
of
the
State
of
Minnesota,
municipal
authorities,
local
U.
S.
Coast
Guard
personnel,
or
a
combination
of
those
offices.
Ice
fishing
houses
would
not
meet
the
statutory
definition
of
a
vessel;
therefore,
they
would
not
be
regulated
by
Section
312
of
the
CWA
and
are
outside
the
scope
of
this
effort.

As
the
Mississippi
Headwaters
Board
and
its
partners
strive
to
protect
the
most
pristine
and
sensitive
portion
of
the
Mississippi
River,
it
appears
NDZ's
could
be
a
valuable
tool.

Please
send
MHB
more
information.
Thank
you
for
your
assistance
and
ongoing
work
in
this
critical
field.

Response
#
10­
3:
Your
name
has
been
added
to
the
distribution
list.

Best
regards,

Jane
E.
Van
Hunnik,
MS
MHB
Director
Comment
#
11:
Alaska
Department
of
Environmental
Conservation
"
Koch,
Denise"
<
denise_
koch@
dec.
state.
ak.
us>

04/
02/
2003
08:
19
PM
To:
James
Woodley/
DC/
USEPA/
US@
EPA
cc:
"
Morehouse,
Carolyn"
<
Carolyn_
Morehouse@
dec.
state.
ak.
us>
Subject:
EPA
Study
of
No­
Discharge
Zones
and
Marine
Sanitation
122
Mr.
Woodley,

I
read
about
this
project
in
the
EPA
WaterNews.
Carolyn
Morehouse
and
I
work
in
the
Alaska
Department
of
Environmental
Conservation
(
ADEC)
cruise
ship
program
(
http://
www.
state.
ak.
us/
dec/
press/
cruise/
cruise.
htm
)
As
you
may
be
aware,
as
part
of
the
voluntary
Alaska
Cruise
Ship
Initiative
there
was
some
voluntary
wastewater
sampling
done
on
large
cruise
ships
with
MSD
systems
during
2000.
The
results
showed
that
the
tested
MSDs
did
not
meet
the
federal
fecal
coliform
or
TSS
standards
(
http://
info.
dec.
state.
ak.
us/
DECPermit/
ACSIReport.
pdf).
Alaska
currently
has
its
own
law
that
regulates
cruise
ship
wastewater
discharges.
The
trend
that
we
see
is
that
large
cruise
ships
that
travel
to
Alaska
are
installing
advanced
wastewater
treatment
systems
(
Rochem,
Zenon,
etc.)
We
would
be
very
interested
in
seeing
the
results
of
your
study.

Regards,

Denise
Koch
ADEC
Cruise
Ship
Program
My
new
e­
mail
address
is
denise_
koch@
dec.
state.
ak.
us
Response
#
11:
Your
name
has
been
added
to
our
distribution
list.

Comment
#
12:
The
Cadmus
Group,
Inc.

Rick
Zeroka
<
RZeroka@
cadmus
group.
com>
To:
James
Woodley/
DC/
USEPA/
US@
EPA
cc:
Ann
Rodney/
R1/
USEPA/
US@
EPA
Subject:
NDZ
Study
You
may
recall
my
name
from
my
days
(
1992­
99)
as
the
Massachusetts
No
Discharge
Area
(
NDA)
Coordinator
while
with
the
Massachusetts
Coastal
Zone
Management
Office.
I
worked
very
closely
with
Ann
Rodney
from
Region
1
to
establish
four
or
five
NDAs
in
Massachusetts'
coastal
waters.
I
recently
saw
in
the
electronic
WaterNews
that
EPA
has
initiated
a
study
of
the
effectiveness
of
No
Discharge
Zones
(
NDZs)
and
the
performance
of
marine
sanitation
devices
(
MSDs)
in
removing
harmful
pollutants.

I
would
like
to
take
this
time
to
offer
my
(
and
Cadmus')
assistance
with
this
effort.
I
would
like
to
speak
with
you
about
this
possibility.
Even
if
there
is
not
an
opportunity
to
formally
support
this
EPA
study,
I
would
still
like
to
talk
to
you
about
this
effort.
I
believe
that
my
7.5­
year
role
as
NDA
Coordinator
for
the
Commonwealth
of
Massachusetts
might
be
of
interest
and
value
to
you
and
EPA.

Currently,
Cadmus
supports
EPA
in
many
ways.
We
are
the
prime
for
one
of
the
four
teams
selected
by
OWOW­
AWPD
TMDL
contract.
We
provide
a
great
deal
of
support
to
OGWPD
HQ
and
Cincinnati
on
a
variety
of
SDWA­
related
issues.
123
I
hope
to
hear
from
you.

Sincerely,

Richard
G.
Zeroka,
Associate,
The
Cadmus
Group,
Inc.
57
Water
Street,
Watertown,
MA
02472
(
617)
673­
7160;
(
617)
673­
7001
(
fax)
rzeroka@
cadmusgroup.
com
Response
#
12:
Your
name
has
been
added
to
our
distribution
list.

Comment
#
13:
Coastal
States
Organization
"
Geiger,
Andrea"
<
ageiger@
sso.
org>

04/
14/
2003
12:
07
PM
To:
James
Woodley/
DC/
USEPA/
US@
EPA
Subject:
Question
Concerning
Study
on
No­
Discharge
Zones/
MSD
Mr.
Woodley,

I
was
very
interested
in
the
story
on
the
Study
of
the
Effectiveness
of
No­
Discharge
Zones
and
Marine
Sanitation
Devices
in
the
WaterNews
on
April
1,
2003.
However,
I
was
unsuccessful
in
locating
the
announcement
in
the
Federal
Register
for
the
given
date.
I
was
interested
in
confirming
if
the
announcement
was
published
and
the
date.

Thank
you
for
assistance,

Andrea
Geiger
Coastal
States
Organization
444
N.
Capitol
Street,
NW,
Suite
322
Washington,
D.
C.
20001
P.
202­
508­
3860,
F.
202­
508­
3843
ageiger@
sso.
org
Response
#
13:
Your
name
has
been
added
to
our
distribution
list.

Comment
#
14:
Puget
Sound
Water
Quality
Team
"
Wulkan,
Bruce"
<
BWulkan@
PSAT.
WA.
GOV>
To:
James
Woodley/
DC/
USEPA/
US@
EPA
Subject:
no
discharge
zone
study
Hello:
I
heard
that
EPA
is
initiating
a
study
of
no­
discharge
zones
and
the
use
of
MSDs.
Would
you
please
add
me
to
your
mailing
list
and
forward
all
findings
from
this
project
to
me?
Thanks
very
much.
124
Bruce
T.
Wulkan
Puget
Sound
Water
Quality
Action
Team
Office
of
the
Governor
(
360)
407­
7332
bwulkan@
psat.
wa.
gov
Response
#
14:
Your
name
has
been
added
to
our
distribution
list.

Comment
#
15:
California
Department
of
Health
Services
"
Commandatore,
Angelo
(
DHSDDWEM
<
ACommand@
dhs.
ca.
gov>

04/
24/
2003
04:
52
PM
To:
James
Woodley/
DC/
USEPA/
US@
EPA
Subject:
No
Discharge
Zone
ICR
I
am
still
a
little
confused
as
to
what
you
need
from
the
State
of
California
on
this
issue.
I
work
in
the
State
shellfish
program
and
in
all
of
our
Commercial
shellfish
growing
areas
there
are
no
designated
"
No
Discharge
zones".
We
also
have
a
conflict
with
the
"
treatment"
of
waste
from
an
MSD.......
Please
advise......
Here
are
some
of
the
concerns
we
have
in
a
Draft
letter
to
your
agency:

This
letter
is
written
in
response
to
the
"
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices,
EPA
ICR
No.
2107.01".

Many
of
the
Bays
in
California
are
natural
paradises
that
serve
a
variety
of
uses,
including
commercial
fishing,
recreational
boating,
clamming,
and
commercial
shellfish
growing.
But
pollution
from
a
number
of
sources
continues
to
threaten
the
Bays
in
California
and
impact
public
health
and
the
environment.
Sewage
from
boats
is
one
source
of
pollution
that
can
impair
water
quality
thus
damaging
commercial
fisheries
and
recreational
opportunities
for
all
users
and
creating
serious
public
health
problems.

In
May
1998,
an
illness
outbreak
involving
at
least
171
people
occurred
in
California
that
was
associated
with
the
consumption
of
raw
oysters
from
Tomales
Bay,
California.
The
cause
of
the
illness
was
determined
to
be
a
Norwalk­
like
virus.
The
only
source
for
this
virus
is
human
sewage.
The
California
Department
of
Health
Services
(
DHS)
determined
that
the
most
likely
sources
of
human
sewage
contamination
to
Tomales
Bay
included
an
overboard
discharge
from
a
boat,
improper
waste
handling
by
a
camper,
or
a
discharge
from
an
onsite
sewage
disposal
system.

As
you
are
well
aware
there
are
only
11
federal
"
No
Discharge"
Areas
in
California
where
the
discharge
of
any
untreated
or
treated
boat
waste
is
prohibited:
125
Lake
Tahoe
Mission
Bay
San
Diego
Bay
­
Less
than
30
feet
mean
lower
low
water
Oceanside
Harbor
Dana
Point
Harbor
Upper
and
Lower
Newport
Bay
Sunset
Aquatic
Park
(
Sunset
Bay)
­
Inland
of
Pacific
Coast
Highway
Bridge
Huntington
Harbor
Channel
Islands
Harbor
Avalon
Bay
Harbor
Richardson
Bay
DHS
is
concerned
with
the
use
of
an
MSD
in
a
shellfish
growing
areas
throughout
the
state
of
California.
In
three
primary
bays
where
both
commercial
and
recreational
shellfish
are
harvested
MSD
can
be
used.
These
bays
are
currently
not
designated
as
"
No
Discharge
Zones".
The
Bays
are
Humboldt
Bay,
Tomales
Bay,
and
Morro
Bay.

The
Shellfish
growing
water
standards
in
Conditionally
Approved
shellfish
growing
waters
must
meet
water
quality
standards
below
a
geometric
mean
of
14
MPN/
100
mL
and
below
a
90th
percentile
of
43
MPN/
100
mL
for
fecal
coliform.
The
Type
I
and
II
MSD's
do
not
treat
to
this
standard
and
there
ability
to
treat
viruses
and
other
pathogens
is
not
well
documented:

·
A
Type
I
MSD
must
macerate
the
sewage
to
no
visible
solids,
and
then
reduce
the
bacteria
count
to
less
than
1,000
per
100
milliliters.

·
A
Type
II
MSD
macerates
the
sewage
even
finer
so
that
it
contains
no
suspended
particles
and
the
bacteria
count
must
be
below
200
per
100
milliliters.
Again
for
comparison,
fecal
coliform
levels
must
be
below
14
per
100
milliliters
for
shellfish
to
be
safe
for
human
consumption.
Therefore,
discharge
of
even
these
partially
treated
wastes
poses
a
threat
to
Bay
water
quality
and
human
health.

·
Type
III
MSD's
are
holding
tanks.
This
is
the
most
common
type
of
MSD
found
on
boats.
These
systems
are
designed
to
retain
or
treat
the
waste
until
it
can
be
disposed
of
at
the
proper
shore
side
facilities.
Portable
toilets
are
the
simplest
type
of
MSD's.
They
represent
the
easiest
solution
to
marine
sanitation
on
small
boats
because
they
require
minimal
space,
and
are
inexpensive,
reliable
and
easy
to
operate.

DHS
is
urging
the
USEPA
to
please
consider
the
concerns
and
issues
documented
in
this
letter
when
updating
any
Federal
Regulations
related
to
MSD's.
It
is
our
belief
that
Bays
where
commercial
and
recreational
shellfishing
occurs
(
Humboldt
Bay,
Tomales
Bay,
Drakes
Estero,
and
Morro
Bay)
should
be
designated
a
"
No
Discharge
Zone"
(
eliminating
the
discharge
from
Type
I
and
II
MSD's).
This
would
eliminate
problems
associated
with
MSD's.

If
you
should
have
any
questions,
please
feel
free
to
contact
me
at
(
510)
540­
3317.

Sincerely,
126
A.
Marc
Commandatore
Environmental
Scientist
Environmental
Management
Branch
Shellfish
Sanitation
Unit
California
Department
of
Health
Services
2151
Berkeley
Way,
Room
104
Berkeley,
CA
94704
(
510)
540­
3317
acommand@
dhs.
ca.
gov
Response
#
15­
1:
The
State
of
California
can
establish
a
NDZ
pursuant
to
Section
312
of
the
Clean
Water
Act
(
CWA)
to
protect
shell
fishing
areas
if
the
State
can
demonstrate
(
and
EPA
agrees)
that
adequate
facilities
for
the
safe
and
sanitary
removal
and
treatment
of
sewage
from
all
vessels
are
reasonably
available
for
the
waters
to
which
such
prohibition
would
apply.
Under
Section
312(
f)(
4)(
A),
a
State
can
also
request
EPA
to
promulgate
regulations
designating
particular
State
waters
as
a
NDZ,
if
the
State
demonstrates
that
such
a
prohibition
is
required
to
protect
and
enhance
the
quality
of
those
waters.
Adequate
and
reasonably
available
pump­
out
facilities
are
not
part
of
the
criteria
for
establishing
such
a
NDZ.
The
protection
of
shellfish
beds
also
could
be
covered
under
that
provision.
Even
though
the
scope
of
these
surveys
does
not
include
the
evaluation
of
the
effectiveness
of
NDZs
established
pursuant
to
Section
312
(
f)(
4)(
A),
our
efforts
will
include
a
case
study
of
the
Florida
Keys
National
Marine
Sanctuary
(
FKNMS).
The
FKNMS
was
designated
as
a
NDZ
pursuant
to
Section
312(
f)(
4)(
A)
of
the
CWA.
The
same
surveys
will
be
conducted
at
the
FKNMS
but
the
data
will
not
be
compiled
with
the
data
associated
with
NDZs
established
under
Section
312(
f)(
3).
The
data
will
be
assessed
and
reported
separately.
In
addition,
the
surveys
will
query
State
governments
about
their
experiences
with
NDZs.
Some
of
the
questions
explore
the
need
for,
and
the
effectiveness
of,
NDZs.
There
are
a
number
of
NDZs
in
California,
and
we
expect
to
examime
two
of
these
in
our
surveys.

Comment
#
16:
Baywood
Marina,
Barnegat
Bay,
NJ
COMMENT
FROM:
Ed
Harrison,
Baywood
Marina,
Barnegat
Bay,
NJ
DATE:
04­
10­
2003
Baywood
Marina
is
a
200
slip
marina
on
Barnegat
Bay
which
is
about
to
become
a
no­
discharge
zone.
We
are
in
favor
of
clean
water
as
our
livelihood
depends
on
same.
Many
years
ago
a
law
was
passed
that
only
allowed
untreated
waste
to
be
discharged
three
miles
offshore,
not
in
the
bay
or
any
inshore
waters.
The
positive
effect
of
this
law
is
questionable
because
the
N.
J.
Marine
Police
have
been
heard
to
say
they
are
not
enforcing
it.

Response
#
16­
1:
Barnegat
Bay
was
designated
as
a
NDZ
on
June
12,
2003.
The
State
is
responsible
for
enforcing
the
state
code
regarding
untreated
sewage
discharge
in
Barnegat
Bay
prior
to
the
recent
NDZ
designation.
Enforcement
against
sewage
discharges,
whether
treated
or
untreated,
in
Barnegat
Bay
is
now
the
jurisdiction
of
the
U.
S.
Coast
Guard,
the
State
environmental
protection
agencies,
the
local
marine
police,
or
a
combination
of
these
authorities.
This
issue
should
be
raised
with
the
127
Commander
of
the
Marine
Police,
the
appropriate
State
officials,
and
the
Coast
Guard.

A
similar
problem
occurs
on
land
where
local
police
will
not
enforce
"
pooper­
scooper"
laws
which
by
the
way
is
a
larger
source
of
fecal
matter
that
enters
the
bay
than
boaters.
If
you
ever
boated
you
would
realize
that
using
the
head
downstairs
in
a
rocking
boat
is
no
vacation
so
everyone
"
goes"
before
they
leave
the
dock
and
hope
they
can
holdout
until
the
boat
gets
back.
Baywood
Marina
installed
a
pumpout
system
a
few
years
back.
The
unit
is
mounted
on
a
easy
access
floating
dock.
The
service
is
free
to
dock
renters
and
has
a
$
5
charge
to
non
renters.
The
system
is
fully
maintained
and
always
operational
yet
we
only
provide
an
average
of
about
6
uses
per
week
during
the
Summer
season!
One
reason
is
that
boaters
do
not
really
use
the
head
that
often.
The
big
question
is
wether
the
water
is
cleaner
than
before
the
previous
law
mentioned
above.
I
have
been
boating
and
swimming
etc.
in
these
waters
since
1965.
The
most
notable
change
in
this
area
came
after
Ocean
County
built
the
regional
sewage
system
which
ended
the
practice
of
cesspools
and
drain
fields
which
were
used
by
about
300,000
houses
in
the
basin.
That
occurred
in
the
early
'
70s,
about
the
same
time
boats
could
no
longer
discharge
raw
sewage.
The
improvement
was
notable
until
another
200,000
houses
were
built
and
storm
water
runoff
overloaded
the
water
with
nutrients.
A
no
discharge
zone
may
have
benefits
if
it
makes
people
more
aware
of
the
consequences
of
discharging
but
most
boaters
know
that
already.
My
fear
is
that
the
other,
more
major
sources,
are
ignored
because
of
$.

Response
#
16­
2:
Your
comments
reflect
the
type
of
data
that
these
surveys
are
designed
to
obtain.
However,
the
other
sources
of
pollution
into
Barnegat
Bay
such
as
storm
water
runoff,
while
very
important,
are
not
within
the
scope
of
the
surveys.
There
are
other
EPA
programs
addressing
those
sources.

Comment
#
17:
Landings
Marina,
Rockland,
ME
COMMENT
FROM:
Kevin
Taylor,
Landings
Marina,
Rockland,
ME
DATE:
04­
16­
2003
As
a
marina
owner/
operator
in
Maine
with
70
slips,
I
can
tell
you
that
in
four
seasons,
my
pump­
out
revenue
at
$
5.00
each
was
less
than
$
175.00.
The
boaters
are
dumping
out
at
sea
and
most
boaters
do
not
go
beyond
3
miles
offshore.
Most
boaters
hug
the
shore
line
and
that's
where
they
are
discharging.
Furthermore,
find
me
an
employee
who
enjoys
doing
a
pump­
out.
Boaters
also
cite
inconvenience
as
the
number
1
reason
for
not
using
pumpouts.

Response
#
17:
The
surveys
contain
questions
that
will
gather
the
type
of
data
that
your
comments
reflect.

Comment
#
18:
The
American
Waterways
Operators
The
American
Waterways
Operators
Atlantic
Region
office
128
241
Water
Street
New
York,
NY
10038
PHONE:
(
212)
406­
1884
FAX:
(
212)
406­
1882
E­
MAIL:
L­
oleary@
msn.
com
April
15,2003
U.
S.
Environmental
Protection
Agency
ED0
Docket
Center
Water
Docket
The
American
Waterways
Operators
(
AWO)
is
the
national
trade
association
for
the
inland
and
coastal
tugboat,
towboat
and
barge
industry.
The
tug
and
barge
industry
is
the
largest
segment
of
the
domestic
fleet
and
the
most
energy
efficient
and
environmentally
friendly
mode
of
transportation
for
bulk
commodities.
AWO
supports
programs
that
seek
to
protect
the
environment
and
enhance
aquatic
resources
on
our
nation's
waterways.
The
Clean
Water
Act
mandates
the
use
of
sewage
treatment
systems
on
board
vessels
to
remove
harmful
pollutants
from
the
waste
stream.
In
compliance
with
U.
S.
Coast
Guard
equipment
requirements
and
U.
S.
EPA
effluent
standards,
all
tugboats,
towboats
and
manned
barges
have
Type
II
marine
sanitation
devices
(
MSDs)
to
treat
sewage
before
discharge.

We
have
closely
followed
the
evolution
of
the
EPA's
program
to
designate
waterways
as
"
no
discharge
areas"
(
NDAs)
under
the
authority
of
the
Clean
Water
Act
(
Section
312)
and
EPA's
approval
of
petitions
submitted
by
states.
We
are
quite
familiar
with
the
potential
impact
on
tugboat
and
barge
operations
when
an
NDA
is
designated
on
a
commercial
waterway.
AWO's
primary
objection
to
the
designation
of
an
NDA
on
a
commercial
waterway
is
simply
that
it
renders
the
MSDs
aboard
a
tugboat
and
barge
prematurely
obsolete!
AWO
has
also
objected
to
such
determinations
where
the
state's
petition
fails
to
consider
the
impact
on
commercial
vessels;
when
the
pump­
out
facilities
are
unable
to
accommodate
the
mix
of
commercial
traffic
along
the
waterway;
and
when
the
potential
degradation
of
water
quality
from
tug
and
barge
discharges
is,
comparatively
speaking,
de
minimus.

Response
#
18­
1:
Section
312
(
f)(
3)
of
the
Clean
Water
Act
(
CWA)
stipulates
that
a
State
may
completely
prohibit
the
discharge
from
all
vessels
of
any
sewage,
whether
treated
or
not,
into
some
or
all
of
the
waters
of
that
State.
For
that
prohibition
to
become
effective,
EPA
must
determine
that
adequate
facilities
for
the
safe
and
sanitary
removal
and
treatment
of
sewage
from
all
vessels
are
reasonably
available
for
the
specified
waters.
Also,
under
312(
f)(
4)(
A)
and
(
B)
of
the
CWA,
States
may
petition
EPA
to
promulgate
a
regulation
designating
the
State
waters
as
a
NDZ
if
the
objective
is
to:
(
1)
protect
aquatic
habitats
and
resources;
or
(
2)
to
protect
human
health
through
drinking
water
intakes.
If
EPA
promulgates
a
regulation
designating
a
NDZ
under
312(
f)(
4)(
A)
and
(
B),
the
assessment
of
the
adequacy
and
availability
of
pump­
out
facilities
is
not
required.
One
of
the
objectives
of
these
surveys
is
to
determine
whether
there
are
adequate
and
reasonably
available
pump­
out
facilities
for
recreational
and
commercial
vessels
in
current
NDZs
designated
under
the
provisions
of
Section
312(
f)(
3)
of
the
CWA.
129
AWO
has
suggested
to
EPA
and
state
environmental
agencies
that
a
pilot
program
to
evaluate
commercial
vessel
effluent
be
initiated.
In
this
regard,
the
EPA
effluent
standards
would
be
analyzed
and
compared
with
innovative
and
potentially
more
efficient
treatment
modalities
for
MSDs.
Additionally,
AWO
has
officially
requested
that
EPA
consider
granting
waivers
to
commercial
vessels
with
Type
II
MSDs
until
such
time
as
a
determination
is
made
that
a
higher
treatment
standard
is
available
and
warranted.
To
date,
neither
of
these
suggestions
has
generated
a
response.
Nonetheless,
the
states
continue
to
submit
petitions
for
NDA
designation
and
EPA
continues
to
provide
"
affirmative
determinations"
to
the
petitioning
states.

Response
#
18­
2:
These
comments
pertain
to
a
petition
regarding
a
proposed
NDZ
for
a
portion
of
the
Hudson
River
in
New
York
State
and
are
not
within
the
scope
of
this
effort.
EPA
will
respond
to
comments
in
the
record
for
the
proposed
NDZ
in
a
separate
action.

A
state's
analysis
of
vessel
traffic
and
the
size
of
tug
and
barge
units
traversing
state
waters
often
underestimates
the
volume
of
vessel
traffic
and
the
dimensions
of
the
vessels.
Consequently,
although
there
may
be
pump­
out
facilities
located
on
a
waterway,
they
are
located
in
shallow
water
or
on
piers
that
cannot
accommodate
commercial
vessels.
An
AWO
analysis
of
the
state
petitions
submitted
by
Massachusetts
and
New
York
revealed
that
not
one
of
the
pump­
out
facilities
enumerated
could
possibly
accommodate
a
tug/
barge
unit
given
the
depth
of
water,
seasonal
operation
and/
or
structural
integrity
of
the
facility.
Although
AWO
met
with
EPA
Region
I
and
II
representatives,
as
well
as
the
state
environmental
agencies,
and
submitted
written
comments
to
Federal
Register
notices
in
a
timely
fashion,
the
information
AWO
submitted
was
simply
disregarded.
The
end
result
is
that
all
of
Buzzard's
Bay
is
presently
a
NDA,
although
there
are
no
pump­
out
facilities
that
can
accommodate
a
contemporary
tug
and
barge
unit;
there
is
a
"
tentative
affirmative
determination"
by
EPA
to
designate
the
entire
Hudson
River
as
a
NDA
which
will
preclude
home
heating
oil
and
gasoline
from
being
transported
to
communities
between
Manhattan
and
Albany;
and
there
is
a
proposal
to
designate
virtually
all
of
Casco
Bay,
Maine
as
an
NDA.

Response
#
18­
3:
The
proposed
Hudson
River
NDZ
is
not
within
the
scope
of
this
effort.
EPA
will
respond
to
comments
in
the
record
for
that
petition
in
a
separate
action.
The
state
of
Massachusetts
application
indicated
that
there
was
a
commercial
facility
to
handle
large
vessels
in
the
Buzzard's
Bay
NDZ,
located
at
the
U.
S.
Coast
Guard
facility;
this
was
confirmed
by
EPA
during
the
site
inspection.

Therefore,
a
survey
of
the
effectiveness
of
the
NDA
program,
as
described
in
the
notice
to
collect
information,
is
most
welcome
and
timely.
AWO
believes
that
there
are
environmentally
sensitive
practices
and
equipment
that
can
be
adopted
without
rendering
Type
II
MSDs
obsolete.
Additionally,
there
must
be
a
consistency
among
and
between
the
states
for
the
coastal
vessel
operating
community.
This
argues
for
a
system
of
effluent
standards
established
by
the
EPA
and
equipment
approved
by
the
Coast
Guard
that
facilitates
interstate
commerce
and
enhances
the
protection
of
the
marine
environment.
AWO
maintains
that
a
Type
II
MSD
is
the
most
efficient
and
safe
way
to
treat
sewage
generated
aboard
a
tug
and
barge
unit.
Interrupting
the
voyage
of
tug/
barge
unit
moving
millions
of
gallons
of
petroleum
product
is
simply
foolhardy
and
dangerous!
The
majority
of
pump­
out
facilities
were
designed
for
recreational
vessels
and
the
small
pump­
out
130
boats
cannot
possibly
come
alongside
a
tug/
barge
unit
without
endangering
the
crews
aboard
both
vessels.
The
Type
II
sewage
treatment
equipment
works
well
given
the
geographic
scope
of
operations
in
the
coastal
trades
and
the
specific
waterways
tug
and
barge
units
transit.

A
re­
evaluation
of
Type
II
MSD
equipment
and
effluent
standards
may
reveal
that
an
even
greater
level
of
environmental
protection
may
be
achieved
with
some
modification
to
the
Type
II
equipment.
Once
this
analysis
is
complete,
AWO
pledges
to
work
with
the
Coast
Guard
and
EPA
to
implement
the
requisite
modifications
to
Type
II
MSDs.

Response
#
18­
4:
EPA's
survey
efforts
are
intended
to
collect
information
on
the
current
performance
levels
for
MSDs
including
Type
II
devices;
that
information
may
be
used
in
determining
the
future
direction
of
vessel
sewage
discharge
programs.

AWO
appreciates
the
opportunity
to
comment
on
the
scope
of
the
survey
and
to
provide
information
on
our
member's
experiences
with
NDAs.
I
have
enclosed
several
communications
with
EPA
and
the
state
environmental
agencies
that
describe
in
detail
some
of
the
difficulties
AWO
members
have
experienced
to
date.
If
you
have
my
questions,
pleases
do
not
hesitate
to
call
(
212)
406­
1884
or
e­
mail
me
at
Loleary@
msn.
com.

Response
#
18­
5:
Thank
you
for
the
information
you
provided
describing
your
members'
experiences.
EPA's
survey
efforts
are
intended
to
collect
this
type
of
information
from
a
representative
group
of
boaters
to
determine
the
overall
effectiveness
of
NDZs
and
their
associated
pump­
out
facilities.
Your
enclosures
have
helped
us
design
the
survey
questions
for
this
ICR.

Linda
O'Leary
Vice
President,
Atlantic
Region
Comment
#
19:
Massachusetts
Office
of
Coastal
Zone
Management
Dear
Mr.
Woodley:

The
Massachusetts
Office
of
Coastal
Zone
Management
(
CZM)
is
pleased
that
EPA
is
undertaking
surveys
to
assess
the
effectiveness
of
Marine
Sanitation
Devices
(
MSDs)
and
No
Discharge
Zones
(
NDZs).
Along
1,500
miles
of
coastline,
the
Commonwealth
of
Massachusetts
has
100
vessel
pumpout
facilities
and
seven
No
Discharge
Zones.

CZM
believes
that
the
information
gathered
through
the
surveys
will
have
utility
to
marina
operators,
harbormasters,
and
government
programs
that
issue
grants
to
promote
pumpout
use,
as
well
as
the
boating
community.
In
fact,
both
CZM
and
the
University
of
Massachusetts
Urban
Harbors
Institute
have
conducted
similar
surveys
to
better
understand
boater
pumpout
use
and
satisfaction
in
targeted
areas
along
the
Massachusetts
coast.
We
would
be
happy
to
provide
EPA
with
our
study
methodology
and
results.

Response
#
19­
1:
Please
send
your
survey
methodology
and
results
to
the
EPA
contact
person
at
the
address
indicated
in
this
Federal
Register
notice.
131
CZM
remains
committed
to
the
idea
that
the
best
way
to
protect
our
waters
from
the
contaminants
in
boat
sewage
is
to
have
boaters
hold
the
waste
in
a
Type
III
MSD
and
to
discharge
at
a
certified
waste
treatment
facility.
We
believe
that
the
U.
S.
Coast
Guard­
mandated
specifications
to
which
Type
I
and
Type
II
MSDs
must
adhere
are
inadequate
to
protect
shellfish
harvesting
or
protect
primary
contact
uses
such
as
swimming
and
surfing.
In
addition,
MSDs
do
very
little
to
remove
Biochemical
Oxygen
Demand
or
the
nutrients
responsible
for
eutrophication.

Response
#
19­
2:
The
EPA
standards
allow
the
use
of
Type
I
and
II
MSDs
in
coastal
waters
and
estuaries,
the
Great
Lakes
and
interconnected
waterways,
and
other
flowing
waters
that
are
navigable
interstate.
EPA
concurs
with
the
above
assessment
that
current
MSDs
may
not
adequately
address
all
BOD
materials,
nutrients,
or
other
contaminants.
Therefore,
where
additional
protection
may
be
needed,
the
program
provides
for
the
establishment
of
NDZs.
Revision
of
the
current
standard
or
adoption
of
newer
MSD
technologies
may
be
addressed
in
future
Agency
actions.

While
we
believe
there
is
value
to
surveying
manufacturers
and
U.
S.
Coast
Guard­
approved,
independent
laboratories
as
to
the
current
state
of
MSD
technology,
we
do
not
believe
that
this
survey
will
accurately
reflect
the
actual
performance
of
installed
MSDs
on
the
water.
We
are
concerned
that
MSDs
are
not
inspected
on
a
regular
basis
and
are
only
required
to
meet
performance
specifications
before
a
retailer
can
sell
them.
It
would
be
more
beneficial
to
ascertain
the
performance
of
MSDs
that
are
already
installed
on
boats,
even
if
they
are
older
and
not
as
well
maintained
as
the
MSDs
used
at
the
independent
laboratories.

Response
#
19­
3:
EPA
concurs
with
the
assessment
stated
above.
The
surveys
contain
questions
about
the
long­
term
performance
capabilities
of
Coast
Guardcertified
MSDs.
The
Agency
may,
in
future
efforts,
address
the
issue
of
continuing
performance
of
MSDs.

Additionally,
in
order
to
get
the
most
accurate
assessment
of
boater
experiences
in
NDZs,
CZM
suggests
surveying
boaters
representing
a
wide
variety
of
NDZs
from
small
embayments
such
as
Nantucket
Harbor,
to
large
NDZs
such
as
Buzzards
Bay
and
Rhode
Island.
CZM
also
suggests
including
NDZs
that
have
been
established
for
a
number
of
years
versus
those
only
recently
established.
Consideration
of
both
these
criteria
in
the
survey
design
will
allow
for
a
more
accurate
assessment
of
boater's
experience.

Response
#
19­
4:
The
surveys
will
be
administered
at
15
NDZs
in
the
United
States.
These
15
NDZs
will
be
chosen
randomly
from
the
North
Atlantic,
Mid­
Atlantic,
South
Atlantic,
and
Great
Lakes
regions.
NDZs
will
also
be
selected
for
study
from
the
State
of
California.
The
survey
design
includes
characterizing
NDZs
established
ten
or
more
years
ago,
as
well
as
those
established
within
the
last
ten
years.
While
we
will
not
be
differentiating
between
the
size
of
NDZs
chosen,
we
will
have
information
on
the
size
of
each
NDZ
where
surveys
were
administered,
so
that
differences
between
different­
sized
NDZs
can
be
evaluated.

Again,
we
are
pleased
that
EPA
is
undertaking
this
survey
and
would
like
to
assist
in
any
way
possible.
Please
do
not
hesitate
to
call
Todd
Callaghan,
our
No
Discharge
Area
Coordinator
at
132
617/
626­
1233
or
Robin
Lacey,
our
Marine
and
Boating
Specialist
at
617/
626­
1220
of
you
have
any
questions.

Sincerely,

Tom
Skinner
Director
Comment
#
20:
Virginia
Clean
Marina
Program
Memo
to:
EPA
Office
of
Water,
Environmental
Protection
Agency
From:
Harrison
P.
Bresee
III,
Marina
Technical
Advisory
Specialist,
Virginia
Sea
Grant,
Virginia
Institute
of
Marine
Science
Date:
April
28,
2003
Re:
Surveys
to
Determine
the
Effectiveness
of
No­
Discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices
The
Virginia
Clean
Marina
Program
submits
the
following
comments
on
the
proposed
EPA
ICR
to
the
Office
of
OMB
regarding
the
Surveys
to
Determine
the
Effectiveness
of
No­
discharge
Zones
for
Vessel
Sewage
and
Marine
Sanitation
Devices,
EPA
ICR
N.
2107.01.

VCMP
suggests
that
the
survey
include
some
emphasis
on
the
following
topics,
issues
and
questions:

For
marina
operators:

I.
Marina
operators
need
information
regarding
the
best
MSD
equipment.
Questions
that
may
assist
in
determining
the
best
equipment
available
to
them
to
consider
are:


What
types
of
repairs
are
most
frequent
or
common
on
your
pumpout
system?


How
many
times
is
the
pumpout
out
of
service
per
year?


How
many
hours
of
pumpout
operation
per
year?


What
are
the
reasons
the
pumpout
was
out
of
order
with
a
ranking
of
mechanical
error
possibilities?

Response
#
20­
1:
The
first
question
is
outside
the
scope
of
this
survey.
Your
last
three
suggested
questions
have
been
incorporated.

II.
Ascertain
amount
the
waste
collected
by
calculating
gallons
of
waste
pumped
out
on
a
yearly
basis
to
determine
benefit
of
pumpout
to
water
body.

Response
#
20­
2:
Your
suggestion
has
been
incorporated
into
the
surveys.

III.
To
determine
the
amount
of
training
the
marina
staff
is
given
on
pumpout
use
and
application.
1)
What
type
of
training
is
marina
staff
given
for
pumpout
collection?
2)
Who
trained
the
staff?
3)
How
many
hours
of
training
were
staff
given?
4)
What
are
the
marina's
Best
Management
Practices
of
its
MSD
use,
if
available?
133
5)
What
type
of
training
does
MSD
retailer
give
to
the
marina
operator?

Response
#
20­
3:
Your
suggestions
(
1
­
4)
have
been
incorporated
into
the
surveys.
Regarding
question
5,
surveys
have
questions
regarding
training
the
marina
staff
may
be
given
associated
with
operation
of
the
pump­
out
facilities
in
an
environmentally
protective
manner.
However,
best
management
practices
training
associated
with
MSDs
are
not
within
the
scope
of
the
surveys.

III.
The
coordination
or
system
a
marina
may
use
to
accommodate
sailboat
vs.
motor
boat
pumpout
use
at
dock
to
accommodate
fuel
dispensing
vs.
pumpout
only.

Response
#
20­
4:
The
surveys
address
boat
type
(
e.
g.,
sailboat
or
motorboat).
They
also
contain
questions
regarding
the
services
the
marina
offers.

IV.
What
is
the
location
(
on
a
bulkhead,
T­
head,
or
gas
dock)
of
the
pumpout
at
the
marina?
What
is
the
mean
water
depth
at
pumpout,
ease
of
access
to
pumpout
and
size
of
boat
able
to
access
pumpout?

Response
#
20­
5:
The
exact
location
of
the
pump­
out
facility
is
not
within
the
scope
of
the
survey;
however,
the
surveys
do
address
the
maximum
draft
vessel
that
the
marinas'
pump­
out
facilities
can
accommodate
as
well
as
pump­
out
accessability.

For
Boaters:

I.
The
length
or
time
of
training
boaters/
slipholders
is
given
on
MSD
use
from
the
boat
supplier
or
marina
operator.

Response
#
20­
6:
The
surveys
contain
questions
regarding
the
general
knowledge
of
boaters
about
the
operation
of
their
MSDs
and
the
use
of
their
MSDs
within
the
NDZ.
EPA
believes
that
the
specific
training
boaters
receive
regarding
their
MSDs
is
not
within
the
scope
of
the
surveys.

II.
Are
pumpouts
readily
available,
reasonably
priced,
and
convenient?

Response
#
20­
7:
The
surveys
contain
questions
regarding
pump­
out
availability,
cost,
and
location.
These
pump­
out
topics
will
be
addressed
in
the
study.
134
Appendix
F
Survey
Text
135
Boaters'
experiences
operating
in
this
area.

#
This
survey
is
anonymous;
respondents
will
not
be
identified
in
the
analysis.

#
Please
only
complete
this
survey
if
you
operate
a
boat.

#
The
survey
is
not
intended
to
take
much
of
your
time
to
complete;
we
estimate
it
should
take
no
more
than
15
minutes
to
answer
all
the
questions.
Please
make
estimates
for
any
questions
you
don't
know
the
precise
answer
to.

Please
describe
the
boat
you
operate:

1.
Do
you
own
the
boat
that
you
operate?
G
Yes
G
No
2.
What
is
the
length
of
the
boat
you
operate?
___________
feet
3.
What
is
the
draft
of
the
boat
you
operate?
___________
feet
4.
Is
the
boat
you
operate
a.
commercial?
G
Yes
G
No
b.
recreational?
G
Yes
G
No
c.
a
live­
aboard?
G
Yes
G
No
5.
Is
the
boat
you
operate
a
a.
powerboat?
G
Yes
G
No
b.
sailboat?
G
Yes
G
No
6.
Does
the
boat
you
operate
have
a.
a
portable
toilet
(
e.
g.,
a
Porta­
PottyTM)?
G
Yes
G
No
b.
an
installed
toilet
(
head)?
G
Yes
G
No
If
you
answered
"
No"
to
both
parts
of
question
6,
please
skip
to
question
21.
If
you
answered
"
No"
to
question
6.
b.
please
skip
to
question
please
skip
to
question
10.

7.
If
the
boat
you
operate
has
an
installed
toilet,
is
it
a
a.
flow­
through
device?
G
Yes
G
No
b.
holding
tank?
G
Yes
G
No
8.
If
the
boat
you
operate
has
an
installed
toilet,
do
you
a.
regularly
service
it?
G
Yes
G
No
b.
know
if
you
need
to
add
chemicals?
G
Yes
G
No
c.
regularly
add
chemicals?
G
Yes
G
No
d.
believe
that
it
is
performing
adequately?
G
Yes
G
No
9.
If
the
boat
you
operate
has
an
installed
toilet,
how
do
you
operate
it
in
the
area
designated
on
the
attached
map?

G
I
close
the
Y
valve
G
The
waste
is
sent
to
a
holding
tank
G
I
don't
use
it.

Please
describe
your
boating
activity
so
far
this
season
(
2003):

10.
How
many
days
have
you
boated
this
season?
__________
days
136
11.
How
many
days
have
you
boated
in
the
area
designated
on
the
attached
map
this
season?
__________
days
12.
This
season
have
you
used
a
a.
stationary
pump­
out
facility
(
e.
g.,
on
piers
or
bulkhead)?
G
Yes
G
No
b.
mobile
pump­
out
facility
onboard
a
boat?
G
Yes
G
No
c.
shore­
based,
portable
pump­
out
facility?
G
Yes
G
No
d.
portable
toilet
dump
station?
G
Yes
G
No
13.
Do
you
have
an
arrangement
to
notify
marina
staff
(
by
flag,
for
example)
to
pump
out
the
holding
tank
during
your
absence?
G
Yes
G
No
14.
Have
you
used
a
pump­
out
facility
or
toilet
dump
this
season
in
the
area
designated
on
the
attached
map?
G
Yes
G
No
a.
How
many
times?
__________
times
(
If
none,
enter
"
0")

15.
Have
you
had
trouble
using
a
pump­
out
facility
or
toilet
dump
this
season
in
the
area
designated
on
the
attached
map?
G
Yes
G
No
G
I
have
not
attempted
to
pump
out
in
this
area
a.
How
many
times?________
times
(
If
none,
enter
"
0")

16.
Did
you
have
trouble
using
a
pump­
out
or
toilet
dump
on
your
last
trip
in
the
area
designated
on
the
attached
map?
G
Yes
G
No
G
I
have
not
attempted
to
pump
out
in
this
area
17.
Have
you
had
occasions
this
season
where
you
looked
for
but
could
not
find
a
working
pump­
out
or
toilet
dump
facilities
in
the
area
designated
on
the
attached
map?
G
Yes
G
No
18.
Have
you
discharged
sewage
outside
the
area
designated
on
the
attached
map
this
season?

G
Yes
G
No
a.
How
many
times?________
times
(
If
none,
enter
"
0")

19.
Have
you
found
any
of
the
following
conditions
at
any
pump­
out
or
toilet
dump
facilities
in
the
area
designated
on
the
attached
map
this
season?
a.
Marina
closed
G
Yes
G
No
b.
No
pump­
out
or
toilet
dump
facilities
at
marina
G
Yes
G
No
c.
Marina
open,
pump­
out
or
toilet
dump
facilities
not
functional
G
Yes
G
No
d.
Marina
open,
no
staff
available
at
pump­
out
or
toilet
dump
facilities
G
Yes
G
No
e.
Marina
open,
I
didn't
know
how
to
use
pump­
out
or
toilet
dump
facilitiesG
Yes
G
No
f.
Pump­
out
inaccessible
(
e.
g.,
water
not
deep
enough
or
hose
too
short)
G
Yes
G
No
g.
Mobile
pump­
out
boat
not
available
G
Yes
G
No
h.
Waiting
time
too
long
G
Yes
G
No
i.
Pump­
out
cost
too
high
G
Yes
G
No
j.
Pump­
out
facility
too
far
away
G
Yes
G
No
l.
I
have
not
had
any
problems
G
Yes
G
No
20.
Have
any
of
the
above
conditions
or
problems
deterred
you
from
using
pump­
out
facilities?

G
Yes
G
No
a.
How
many
times________
times
(
If
none,
enter
"
0")

Facts
About
No­
Discharge
Zones
21.
Do
you
know
that
the
area
designated
on
the
attached
map
is
a
no­
discharge
zone?
137
G
Yes
G
No
22.
Do
you
know
that
the
discharge
of
treated
and
untreated
vessel
sewage
is
prohibited
in
no­
discharge
zones?
G
Yes
G
No
23.
Have
you
seen
or
heard
information
about
no­
discharge
zones
from
any
of
the
following
sources?
a.
Television
G
Yes
G
No
b.
Radio
G
Yes
G
No
c.
Boat
Show
G
Yes
G
No
d.
Signs
at
this
marina
G
Yes
G
No
e.
Brochures
or
handouts
at
this
marina
G
Yes
G
No
f.
Verbal
instruction
by
staff
at
this
marina
G
Yes
G
No
g.
Signs
somewhere
else
G
Yes
G
No
h.
Brochures
or
handouts
somewhere
else
G
Yes
G
No
i.
Verbal
instruction
somewhere
else
G
Yes
G
No
j.
Told
by
someone
who
stopped
me
while
I
was
boating
G
Yes
G
No
k.
Heard
it
first
in
this
survey
G
Yes
G
No
l.
Nautical
maps
G
Yes
G
No
m.
Other,
please
describe
_______________________________________________________________________

24.
To
your
knowledge,
who
enforces
no­
discharge
zone
requirements
in
the
area
designated
on
the
attached
map?
a.
U.
S.
Coast
Guard
G
Yes
G
No
G
Don't
Know
b.
State
G
Yes
G
No
G
Don't
Know
c.
Local
government
G
Yes
G
No
G
Don't
Know
d.
Harbormaster
G
Yes
G
No
G
Don't
Know
e.
Marina(
s)
within
the
no­
discharge
zone
G
Yes
G
No
G
Don't
Know
g.
EPA
G
Yes
G
No
G
Don't
Know
25.
Are
you
aware
of
anyone
receiving
a
citation
for
discharging
sewage
in
the
area
designated
on
the
attached
map?
G
Yes
G
No
26.
The
area
designated
on
the
attached
map
was
designated
as
a
no­
discharge
zone
on
the
date
indicted
on
the
attached
map.
Have
you
noticed
a
change
in
water
quality
since
the
designation?

G
Yes,
the
water
seems
cleaner
G
Yes,
the
water
seems
dirtier
G
No,
the
water
seems
the
same
G
Don't
know
THANK
YOU
FOR
COMPLETING
THIS
SURVEY!
ENJOY
BOATING
ON
CLEAN
WATERS!
138
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
2003
No­
Discharge
Zone
Effectiveness
Survey
Marina
Owner/
Operator
EPA
is
asking
your
help
to
understand
marina
owners'
and
operators'
experiences
with
no­
discharge
zones
(
NDZs).
No
respondents
will
be
identified
in
the
analysis.
The
survey
is
not
intended
to
be
difficult
to
complete;
we
estimate
that
it
should
take
no
more
than
15
minutes
to
answer
all
the
questions.
Please
use
estimates
for
any
question
you
don't
know
the
precise
answer
to.
Thank
you
for
your
participation.

Marina
Description
1.
How
many
boat
slips
does
this
marina
have?
_________
slips
2.
Please
estimate
the
number
of
boats
currently
at
this
marina
________
boats
3.
Does
this
marina
have
a.
Onshore
pump­
out
facilities?
G
Yes,
how
many?
____
G
No
b.
Mobile
pump­
out
boat(
s)?
G
Yes,
how
many?
____
G
No
c.
Toilet
dump
station(
s)?
G
Yes,
how
many?
____
G
No
d.
Portable
pump­
out
facilities?
G
Yes,
how
many?
____
G
No
4.
What
other
services
does
this
marina
offer?
(
Please
check
all
that
apply)
a.
Fuel
G
Yes
G
No
b.
Boat
service
and
repair
G
Yes
G
No
c.
Boat
sales
G
Yes
G
No
d.
Equipment
and
parts
sales
G
Yes
G
No
e.
Bait
and
tackle
G
Yes
G
No
f.
High
and
dry
boat
storage
G
Yes
G
No
g.
Food
and
beverage
sales
G
Yes
G
No
If
you
answered
no
to
all
parts
of
question
3,
please
skip
to
question
21.

5.
If
this
marina
has
pump­
out
facilities
or
toilet
dump
stations,
(
use
the
back
of
this
page
if
more
space
is
needed)
a.
List
the
equipment
brand
name(
s)
________________________________
b.
List
the
year(
s)
the
pump­
out
equipment
was
installed
________________________________

6.
What
is
the
maximum
vessel
draft
this
marina's
pump­
out
facilities
can
service?
___________
feet
7.
Has
this
marina
received
any
Clean
Vessel
Act
monies
to
assist
with
no­
discharge
zone
requirements?
G
Yes
G
No
8.
How
much
does
this
marina
charge
per
pump­
out
or
toilet
dump?
$______________

9.
How
much
does
it
cost
annually
to
operate
and
maintain
this
marina's
pump­
out
facilities
and/
or
toilet
dump?
$____________

Pump­
out
Operations
139
10.
Who
performs
the
pump­
out
or
toilet
dump
operation?
G
Marina
staff
G
Boaters
11.
Do
you
require
the
marina
staff
who
operate
and/
or
maintain
the
pump­
out
facilities
and/
or
toilet
dumps
to
be
trained?

G
Yes
G
No
12.
If
the
marina
staff
are
trained
on
the
operation
or
maintenance
of
pump­
out
facilities
and/
or
toilet
dumps,
how
many
hours
of
training
is
each
person
given?
G
Less
than
30
minutes
G
30
minutes
­
1
hour
G
1­
5
hours
G
5­
10
hours
G
More
than
10
hours
13.
If
the
marina
staff
are
trained
on
the
operation
or
maintenance
of
pump­
out
facilities
and/
or
toilet
dumps,
describe
the
nature
of
the
(
formal
or
self­
directed)
pump­
out
operations
training.
Check
all
that
apply.
G
Staff
members
review
instructions
or
manuals
from
the
vendor
or
marina
G
Basic
hands­
on
training
on
operation,
maintenance,
and
safety
conducted
by
the
marina
G
Basic
hands­
on
training
on
operation,
maintenance,
and
safety
conducted
by
the
vendor
G
Off
site
training
on
operation,
maintenance,
safety,
and
environmental
protection
14.
What
are
the
marina's
hours
of
operation?

_____________________________________________________________________

15.
What
are
the
pump­
out
facilities'
and/
or
toilet
dumps'
scheduled
hours
of
operation?

______________________________________________________________________

16.
During
the
2003
season,
approximately
what
percentage
of
time
have
the
pump­
out
facilities
and/
or
toilet
dumps
been
functional?

G
100%
the
time
G
75%
to
99%
of
the
time
G
50%
to
74%
of
the
time
G
26%
to
49%
of
the
time
G
0%
to
25%
of
the
time
17.
If
the
pump­
out
facilities
and/
or
toilet
dumps
have
not
been
functional
during
operating
hours
in
the
2003
season,
what
were
the
causes?
a.
Not
applicable,
100%
availability
G
Yes
G
No
b.
Equipment
failure
G
Yes
G
No
c.
Waiting
for
equipment
parts/
repairs
G
Yes
G
No
d.
Boater
misoperation
of
equipment
G
Yes
G
No
e.
Insufficient
sewage
disposal
capacity
(
For
example,
sewer
pipe
backups
or
capacity
reached
before
septage
pickup
occurs)
G
Yes
G
No
f.
No
staff
available
G
Yes
G
No
g.
Other,
please
describe:
________________________________________________________________

18.
During
the
2003
season,
has
a
boater
needed
to
wait
more
than
15
minutes
to
use
the
pump­
out
facilities
or
toilet
dump
at
this
marina?
G
Yes
G
No
140
19.
If
boaters
have
needed
to
wait
more
than
15
minutes
to
use
a
pump­
out
facility
or
toilet
dump
at
this
marina
so
far
during
the
2003
season,
how
often
has
this
occurred?

G
Never
G
Rarely
G
Occasionally
G
At
certain
times
(
e.
g.,
weekends
at
sunset)

G
Frequently
20.
Please
estimate
the
number
of
pump­
out
and
toilet
dump
operations
or
the
total
volume
of
sewage
collected
at
this
marina
so
far
during
the
2003
season.
Use
whichever
measure
is
simpler
to
provide.

_________________
number
of
pump­
outs
and
toilet
dumps
operations
or
_________________
gallons
of
pumped
and
dumped
material
Roles
and
Responsibilities
21.
Does
this
marina
use
any
of
the
methods
listed
below
to
inform
boaters
that
they
are
in
a
nodischarge
zone?
a.
Signs
G
Yes
G
No
b.
Brochures/
handouts
G
Yes
G
No
c.
We
tell
people
G
Yes
G
No
22.
To
your
knowledge,
who
enforces
no­
discharge
zone
requirements
in
this
no­
discharge
zone
(
the
area
designated
on
the
attached
map)?
You
may
identify
more
than
one
organization.
a.
U.
S.
Coast
Guard
G
Yes
G
No
G
Don't
Know
b.
State
G
Yes
G
No
G
Don't
Know
c.
Local
government
G
Yes
G
No
G
Don't
Know
d.
Harbormaster
G
Yes
G
No
G
Don't
Know
e.
Marina(
s)
within
the
no­
discharge
zone
G
Yes
G
No
G
Don't
Know
f.
EPA
G
Yes
G
No
G
Don't
Know
23.
Are
you
aware
of
anyone
receiving
a
citation
for
discharging
sewage
within
this
no­
discharge
zone?

G
Yes
G
No
24.
To
your
knowledge,
does
the
State
do
any
of
the
following?
a.
Designate
no­
discharge
zones
G
Yes
G
No
G
Don't
Know
b.
Answer
marina
operators
questions
about
no­
discharge
zone
responsibilities
G
Yes
G
No
G
Don't
Know
c.
Answer
boat
operators'
questions
about
their
responsibilities
in
no­
discharge
zones
G
Yes
G
No
G
Don't
Know
d.
Provide
information
about
no­
discharge
zones
on
TV
or
radio
G
Yes
G
No
G
Don't
Know
e.
Provide
written
information
to
marina
operators
to
G
Yes
G
No
G
Don't
Know
inform
them
of
no­
discharge
zone
requirements.
G
Yes
G
No
G
Don't
Know
f.
Provide
signs
and
posters
to
marinas
to
inform
G
Yes
G
No
G
Don't
Know
boat
owners
and
operators
of
their
responsibilities
in
a
no­
discharge
zone
G
Yes
G
No
G
Don't
Know
g.
Provide
written
information
to
boat
owner
and
operators
about
no­
discharge
zone
requirements
G
Yes
G
No
G
Don't
Know
h.
Track
complaints
about
lack
of
pump­
out
availability
G
Yes
G
No
G
Don't
Know
141
iii.
Other
no­
discharge
zone
activities
(
Please
describe)______________________________________________

25.
This
marina
is
in
a
harbor
that
was
designated
as
a
no­
discharge
zone
in
(
date:
varies
with
marina).
Have
you
noticed
a
change
in
water
quality
since
the
designation?

G
Yes,
the
water
seems
cleaner
G
Yes,
the
water
seems
dirtier
G
No,
the
water
seems
the
same
G
Don't
know
142
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
2003
No­
Discharge
Zone
Effectiveness
Survey
State/
Local
Government
EPA
is
asking
your
help
to
understand
State/
Local
government
experience
with
no­
discharge
zones
(
NDZs).
ERG
is
assisting
EPA
in
this
effort.
We
would
like
to
ask
what
type
of
information
your
office
keeps
on
no­
discharge
zones
and
to
request
a
copy
of
the
available
information
for
this
study.
We
are
providing
you
a
list
of
the
specific
no­
discharge
zones
within
your
State
that
were
randomly
chosen
for
this
study.

Contact
Information
Please
provide
contact
information
for
the
person
who
is
filling
out
this
survey.

Name:
____________________________
Organization:
_________________________
Telephone:
____________________________
Date:
_____________________
____

E­
mail:
____________________________
Fax:
_________________________
Location
Identification
The
following
no­
discharge
zones
were
randomly
selected
for
analysis:

a.
(
Name
of
1st
NDZ;
designation
year)

Data
Availability
Instructions
to
Interviewer:
For
every
box
marked
"
Yes"
in
Questions
1­
5,
request
that
the
information
to
be
sent
to
you.
Ask
if
there
is
a
user
fee
or
other
charge
to
obtain
the
data.
If
so,
check
to
whom
the
request
and
check
are
sent.
Offer
to
provide
a
Federal
Express
number
to
expedite
the
transfer.

1.
Does
your
office
have
the
following
type
of
information
for
2000,
2001,
or
2002
for
these
nodischarge
zones?

2000
2001
2002
a.
Beach
closures
G
Yes
G
No
G
Yes
G
No
G
Yes
G
No
b.
Shellfish
bed
health
G
Yes
G
No
G
Yes
G
No
G
Yes
G
No
c.
Water
quality
data
G
Yes
G
No
G
Yes
G
No
G
Yes
G
No
2.
Does
your
office
have
the
following
type
of
information
for
these
areas
prior
to
them
being
designated
as
no­
discharge
zones?

a.
Beach
closures
G
Yes
G
No
b.
Shellfish
bed
health
G
Yes
G
No
c.
Other
water
quality
data
G
Yes
G
No
3.
Does
your
office
have
any
of
the
following
information
for
these
no­
discharge
zones?

a.
Anecdotal
data
on
no­
discharge
zone
effectiveness
G
Yes
G
No
b.
Other
no­
Discharge
zone
information
G
Yes
G
No
143
Available
Reports
4.
Does
your
office
have
any
reports
that
use
the
2000,
2001,
or
2002
data
to
assess
water
quality
or
the
effectiveness
of
this
(
these)
no­
discharge
zone(
s)?
G
Yes
G
No
5.
Does
your
office
have
any
reports
that
assess
water
quality
in
this
(
these)
area(
s)
prior
to
them
being
designated
as
no­
discharge
zone(
s)?
G
Yes
G
No
State/
Local
Government
Understanding
of
Roles
and
Responsibilities
6.
Which
organization
enforces
no­
discharge
zone
requirements?

t.
U.
S.
Coast
Guard
G
Yes
G
No
u.
State
G
Yes
G
No
v.
Local
government
G
Yes
G
No
w.
Harbormaster
G
Yes
G
No
x.
Marina(
s)
within
the
no­
discharge
zone
G
Yes
G
No
y.
EPA
G
Yes
G
No
7.
What
is
your
organization's
responsibility
regarding
no­
discharge
zones?

a.
Designation
of
this
area
as
a
no­
discharge
zone
G
Yes
G
No
b.
Enforcement
of
no­
discharge
zone
requirements
G
Yes
G
No
c.
Answering
marina
operator
questions
about
their
no­
discharge
zone
responsibilities
G
Yes
G
No
d.
Answering
boat
owner
and
operator
questions
about
their
no­
discharge
zone
responsibilities
G
Yes
G
No
e.
Providing
informational
advertising
on
TV
or
radio
G
Yes
G
No
f.
Providing
written
information
to
marina
operators
G
Yes
G
No
g.
Providing
signs
and
posters
to
marinas
to
inform
boat
owners
and
operators
of
their
responsibilities
in
a
no­
discharge
zone
G
Yes
G
No
h.
Providing
written
information
to
boat
owner
and
operators
G
Yes
G
No
i.
Tracking
complaints
about
pump­
out
facility
operations
G
Yes
G
No
If
yes,
please
provide
any
information
on
the
actions
taken
or
results.
j.
Seeking
Clean
Vessel
Act
funding
G
Yes
G
No
k.
Other
______________________________________________

Further
Contact
8.
If
you
do
not
know
the
answer
to
any
of
the
questions,
please
identify
someone
who
might
have
the
information.

Name:
____________________________
Organization:
_________________________
Telephone:
____________________________
E­
mail:
_________________________
144
U.
S.
Environmental
Protection
Agency
2003
Performance
of
Marine
Sanitation
Devices
(
MSD)
Survey
(
MSD
Manufacturers)

This
survey
is
designed
to
gather
information
regarding
the
performance
of
marine
sanitation
devices
(
MSDs).
This
information
may
be
used
in
future
decisions
associated
with
the
implementation
of
the
vessel
sewage
discharge
program.
It
is
understood
that
this
information
may
be
gathered
during
the
Coast
Guard
certification
process,
however,
we
would
like
you
to
provide
any
of
this
information
that
you
have.

1.
Do
you
manufacture
MSDs?

G
Yes
Please
continue
with
next
page.

G
No
Thank
you.
You
have
completed
the
survey.
Please
return
it
to
EPA.

Basic
Information
2.
Device
model
name:
________________________________________________

3.
Device
model
number:
_______________________________________________

4.
Has
this
device
been
issued
a
letter
of
certification
from
the
United
States
Coast
Guard
indicating
compliance
with
the
design
and
testing
criteria
of
Title
33,
Code
of
Federal
Regulations,
Part
159?
G
Yes
G
No
If
yes,
when
was
the
letter
of
certification
issued?
___/___/______
(
mm/
dd/
yyyy)

5.
Model
type
(
check
one)

G
Type
I
(
flow­
thru
device
that
can
be
installed
on
vessels
less
than
65
feet)

G
Type
II
(
flow­
thru
device
that
can
be
installed
on
any
size
vessel)

G
Type
III
(
holding
tank)

6.
Has
this
device
been
issued
an
IMO
Certificate
of
Type
Test
indicating
compliance
with
IMO
resolution
MEPC.
2(
VI)
Recommendation
on
International
Effluent
Standards
and
Guidelines
for
Performance
Tests
for
Sewage
Treatment
Plants?
G
Yes
G
No
a.
If
yes,
when
was
Certificate
of
Type
Test
issued?
___/___/______
(
mm/
dd/
yyyy)

7.
Is
this
device
designed
to
meet
the
effluent
requirements
for
cruise
ships
in
Alaska
(
33
CFR
159.309)?
G
Yes
G
No
8.
Is
this
device
designed
to
treat
gray
water,
which
is
defined
as
galley,
dishwasher,
bath,
shower
and/
or
laundry
wastewater?
G
Yes
G
No
9.
Is
this
device
designed
to
treat
drainage
from
medical
premises
(
dispensary,
sick
bay,
etc.)
via
wash
basins,
wash
tubs
and
scuppers
located
in
such
premises?
G
Yes
G
No
10.
Was
the
device
tested
for
certification:
(
Check
one)
Questions
2
through
46
ask
for
information
for
each
MSD
model
with
U.
S.
Coast
Guard
certification
or
IMO
Certificate
of
Type
Test
that
you
manufacture.
Please
fill
out
one
of
the
surveys
enclosed
for
each
MSD
you
manufacture.
Copies
of
the
survey
are
provided
for
additional
devices.
If
any
of
this
information
has
been
identified
as
confidential
business
information
(
CBI),
please
indicate
by
checking
the
CBI
box
or
write
CBI
beside
the
question.
145
G
This
specific
model
G
Another
model
relying
on
the
same
treatment
process.
(
Please
provide
the
model
name
_______
and
model
number
______
for
the
device
that
was
tested)

11.
What
are
the
space
requirements
for
this
device?
a.
Width
____________
units_______
b.
Length
____________
units_______
c.
Height
____________
units_______

12.
What
is
the
design
capacity
of
this
device?
a.
Average
daily
capacity
____________
units_______
b.
Peak
capacity
____________
units_______

13.
What
is
the
average
daily
energy
use
of
this
device?
____________
units_______

14.
What
is
the
average
volume
of
effluent
discharged
per
flush?
_____________
units______

15.
When
you
return
this
survey,
please
enclose
a
copy
of
the
instruction
manual.

Treatment
Process
16.
What
treatment
process
does
this
device
use?
(
Check
all
that
apply.)

G
Biological
G
Filtration
G
Chlorination
G
Ozone
treatment
G
Ultraviolet
irradiation
G
Heat
G
Other
(
please
describe:
______________________________________________)

17.
If
this
device
uses
biological
treatment,
is
the
wastewater
aerated
during
treatment?
CBI
G
G
Yes
(
wastewater
is
aerated)

G
No
(
wastewater
is
not
aerated)

G
This
device
does
not
use
biological
treatment.

18.
If
this
device
uses
filtration,
please
provide
the
following
information
on
the
filtration
process.
CBI
G
a.
Filter
material
_______________________
b.
Pore
size
____________
units_______
c.
Expected
filter
life
____________
units_______
d.
This
device
does
not
use
filtration.
G
19.
If
this
device
uses
chlorination,
please
provide
the
following
information
for
chlorination
processes.
CBI
G
a.
Mechanism
for
adding
chlorine
_______________________
b.
Chlorine
dose
added
to
wastewater
____________
units_______
c.
Chlorine
concentration
achieved
____________
units_______
in
wastewater
d.
Residence
time
at
this
chlorine
concentration
____________
units_______
e.
Is
there
a
dechlorination
step?
G
Yes
G
No
If
yes,
146
please
describe:
____________________________________________________
f.
This
device
does
not
use
chlorination.
G
20.
If
this
device
uses
ultraviolet
irradiation,
please
provide
the
following
information
for
ultraviolet
irradiation
processes.
CBI
G
a.
Ultraviolet
intensity
____________
units_______
b.
This
device
does
not
use
ultraviolet
irradiation.
G
21.
If
this
device
uses
heat,
please
provide
the
following
information
for
this
process.
CBI
G
a.
Identify
the
heat
source
_______________________
b.
Temperature
during
treatment
____________
units_______
c.
Residence
time
at
treatment
temperature
____________
units_______
d.
Average
temperature
of
the
effluent
____________
units_______
e.
This
device
does
not
use
heat.
G
22.
Does
this
device
use
chemical
additives
to
reduce
odors?
G
Yes
G
No
CBI
G
23.
If
this
device
uses
chemical
additives
to
reduce
odors,
please
identify
the
additive(
s)?
(
Check
all
that
apply.)
CBI
G
G
Glutaraldehyde
G
Formaldehyde
G
Enzymes
(
please
identify:________________________________________)

G
Perfume(
s)
(
please
identify:________________________________________)

G
Other(
s)
(
please
identify:________________________________________)

24.
Does
this
device
use
chemical
additives
to
reduce
G
Yes
G
No
offensive
colors?
CBI
G
25.
If
this
device
uses
chemical
additives
to
reduce
offensive
colors,
please
identify
the
additive(
s)?
(
Check
all
that
apply.)
CBI
G
G
Dyes
(
please
identify:________________________________________)

G
Other
(
please
identify:________________________________________)

Cost
Data
26.
Please
provide
the
following
cost
information
for
this
device
as
of
January
1,
2003.
a.
Equipment
price
(
wholesale,
f.
o.
b.)
$
US______________.
00
b.
Annual
operating
and
maintenance
cost
$
US______________.
00
c.
Installation
cost
­
new
vessel
$
US______________.
00
d.
Installation
cost
­
retrofit
on
existing
vessel
$
US______________.
00
Performance
Data
147
27.
Please
complete
the
following
table
on
performance
data
for
the
model.
Specify
actual
test
results,
e.
g.,
183
fecal
coliform
bacteria
per
100
milliliters;
do
not
report
effluent
concentration
as
a
range,
e.
g.
"
below
200
fecal
coliform
bacteria
per
100
milliliters."
CBI
G
Constituent
Test
(
Y/
N)
Test
Method
(
e.
g.,
USCS
#
or
EPA#)
Concentration
Influent
Effluent
Units
Fecal
Coliform
Y
Total
Suspended
Solids
(
TSS)
Y
Enterococci
E.
coli
5
day
Biochemical
Oxygen
Demand
(
BOD)

Chemical
Oxygen
Demand
(
COD)

Residual
Chlorine
pH
Additives
for
odors
and
color
Hepatitis
A
Other,
please
specify
_____________

28.
Please
attach
a
copy
of
the
raw
data
collected
or
any
additional
performance
data
on
this
model.
CBI
G
29.
Test
location
G
Laboratory
G
On
vessel
30.
Device
age
at
time
of
test
G
New
G
Used,
months
in
operation:
_____________

31.
Test
duration
_______________
days
32.
Test
temperature
______________
units
_____

33.
Flow
rate
______________
units
_____

34.
Influent
source
___________________________________________________________
148
35.
Has
the
performance
of
this
device
at
treating
gray
water
been
tested?
G
Yes
G
No
36.
If
yes,
please
attach
a
copy
of
all
testing
data
that
you
have
on
the
performance
of
this
device
at
treating
gray
water.

37.
Has
the
performance
of
this
device
at
treating
drainage
from
medical
premises
(
dispensary,
sick
bay,
etc.)
via
wash
basins,
wash
tubs
and
scuppers
located
in
such
premises
been
tested?

G
Yes
G
No
38.
If
yes,
please
attach
a
copy
of
all
testing
data
that
you
have
on
the
performance
of
this
device
at
treating
drainage
from
medical
premises.

39.
Has
the
performance
of
this
device
been
tested
for
any
period
longer
than
required
for
certification?
G
Yes
G
No
40.
If
yes,
please
provide
all
testing
data
that
you
have.

Sewage
Sludge
Management
41.
Does
this
device
produce
sewage
sludge?
CBI
G
G
Yes
Please
complete
questions
42
­
46.

G
No
You
have
completed
the
survey.
Please
return
it
to
EPA
42.
How
much
sewage
sludge
is
produced
daily
when
the
unit
is
operated
at
average
capacity?
____________
pounds/
day
43.
Does
this
device
treat
or
manage
sewage
sludge?
G
Yes
G
No
44.
Identify
all
sewage
sludge
treatment
processes
this
device
uses.
(
Check
all
that
apply.)

G
No
sewage
sludge
treatment
G
Concentration
G
De­
watering
G
Drying
G
Incineration
G
Other
(
please
identify:
___________________________________________)

45.
Please
provide
the
following
data
on
sewage
sludge
quality
if
available.

G
No
data
on
sludge
quality
available
Constituent
Concentration
Units
Percent
solids
Metals
Nutrients
Fecal
Coliforms
5
day
Biochemical
Oxygen
Demand
(
BOD)

Enterococci
E.
coli
149
Chemical
Oxygen
Demand
(
COD)

Other,
please
specify
_____________

46.
Please
attach
any
additional
information
on
the
quantity
and/
or
quality
of
the
sewage
sludge
produced
by
this
device.
Device
Model
Name:
_________________________
Page
150
Copy
#
____
of
____

150
U.
S.
Environmental
Protection
Agency
2003
Performance
of
Marine
Sanitation
Devices
(
MSD)
Survey
(
US
Coast
Guard
Independent
Accepted
Labs)

This
survey
is
designed
to
gather
information
regarding
the
performance
of
marine
sanitation
devices
(
MSDs).
This
information
may
be
used
in
future
decisions
associated
with
the
implementation
of
the
vessel
sewage
discharge
program.
It
is
understood
that
this
information
may
be
gathered
during
the
Coast
Guard
certification
process,
however,
we
would
like
for
you
to
provide
any
of
this
information
that
you
have.

1.
Do
you
test
the
performance
of
MSDs?

G
Yes
Please
continue
the
survey.

G
No
Thank
you.
You
have
completed
the
survey.
Please
return
it
to
EPA.

Basic
Information
ii.
Device
model
name:
________________________________________________

iii.
Device
model
number:
_______________________________________________

iv.
Has
this
device
been
issued
a
letter
of
certification
from
the
United
States
Coast
Guard
(
indicating
compliance
with
the
design
and
testing
criteria
of
Title
33,
Code
of
Federal
Regulations,
Part
159)?
G
Yes
G
No
If
yes,
when
was
the
letter
of
certification
issued?
___/___/______
(
mm/
dd/
yyyy)

v.
MSD
model
type
(
check
one)

G
Type
I
(
flow­
thru
device
that
can
be
installed
on
vessels
less
than
65
feet)

G
Type
II
(
flow­
thru
device
that
can
be
installed
on
any
size
vessel)

G
Type
III
(
holding
tank)

6.
Has
this
device
been
issued
an
IMO
Certificate
of
Type
Test
(
indicating
compliance
with
IMO
resolution
MEPC.
2(
VI),
Recommendation
on
International
Effluent
Standards
and
Guidelines
for
Performance
Tests
for
Sewage
Treatment
Plants)?
G
Yes
G
No
a.
If
yes,
when
was
Certificate
of
Type
Test
issued?
___/___/______
(
mm/
dd/
yyyy)

vi.
What
are
the
space
requirements
for
this
device?
a.
Width
____________
units_______
Questions
2
through
40
ask
for
information
for
each
MSD
model
with
U.
S.
Coast
Guard
certification
or
IMO
Certificate
of
Type
Test
that
this
lab
has
tested.
Please
fill
out
one
of
the
copies
of
the
survey
enclosed
for
each
MSD
this
lab
has
tested.
We
are
enclosing
10
copies.
If
you
have
certified
more
than
10
devices,
please
make
additional
copies
of
the
survey
as
needed.
If
any
of
this
information
is
confidential
business
information
(
CBI),
please
indicate
by
checking
the
CBI
box
or
write
CBI
beside
the
question.
Device
Model
Name:
_________________________
Page
151
Copy
#
____
of
____

151
b.
Length
____________
units_______
c.
Height
____________
units_______

vii.
What
is
the
design
capacity
of
this
device?
a.
Average
daily
capacity
____________
units_______
b.
Peak
capacity
____________
units_______

viii.
What
is
the
average
daily
energy
use
of
this
device?
____________
units_______

ix.
What
is
the
average
volume
of
effluent
discharged
from
the
treatment
device
per
flush?
____________
units_______

Treatment
Process
x.
What
treatment
process
does
this
device
use?
(
Check
all
that
apply.)

G
Biological
G
Filtration
G
Chlorination
G
Ozone
treatment
G
Ultraviolet
irradiation
G
Heat
G
Other
(
please
describe:
______________________________________________)
Please
use
the
back
of
the
page
if
you
need
more
space.

xi.
If
this
device
uses
biological
treatment,
is
the
wastewater
aerated
during
treatment?
CBI
G
G
Yes
(
wastewater
is
aerated)

G
No
(
wastewater
is
not
aerated)

G
This
device
does
not
use
biological
treatment.

xii.
If
this
device
uses
filtration,
please
provide
the
following
information
on
its
filtration
process.
CBI
G
a.
Filter
material
_______________________
b.
Pore
size
____________
units_______
c.
Expected
filter
life
____________
units_______
d.
This
device
does
not
use
filtration.
G
xiii.
If
this
device
uses
chlorination,
please
provide
the
following
information
for
the
chlorination
process.
CBI
G
a.
Mechanism
for
adding
chlorine
_______________________
b.
Chlorine
dose
added
to
wastewater
____________
units_______
c.
Chlorine
concentration
achieved
____________
units_______
in
wastewater
d.
Residence
time
at
this
chlorine
concentration
____________
units_______
e.
Is
there
a
dechlorination
step?
G
Yes
G
No
If
yes,
please
describe:
____________________________________________________

______________________________________________________________________
Device
Model
Name:
_________________________
Page
152
Copy
#
____
of
____

152
f.
This
device
does
not
use
chlorination.
G
15.
If
this
device
uses
ultraviolet
irradiation,
please
provide
the
following
information
for
ultraviolet
irradiation
processes.
CBI
G
a.
Ultraviolet
intensity
____________
units_______
b.
This
device
does
not
use
ultraviolet
irradiation.
G
16.
If
this
device
uses
heat,
please
provide
the
following
information
for
this
process.
CBI
G
a.
Identify
the
heat
source
_______________________
b.
Temperature
during
treatment
____________
units_______
c.
Residence
time
at
treatment
temperature
____________
units_______
d.
Average
temperature
of
the
effluent
____________
units_______
e.
This
device
does
not
use
heat.
G
17.
Does
this
device
use
chemical
additives
to
reduce
odors?
G
Yes
G
No
CBI
G
18.
If
this
device
uses
chemical
additives
to
reduce
odors,
please
identify
the
additive(
s)?
(
Check
all
that
apply.)
CBI
G
G
Glutaraldehyde
G
Formaldehyde
G
Enzymes
(
please
identify:________________________________________)

G
Perfume(
s)
(
please
identify:________________________________________)

G
Other(
s)
(
please
identify:________________________________________)

19.
Does
this
device
use
chemical
additives
to
reduce
G
Yes
G
No
offensive
colors?
CBI
G
20.
If
this
device
uses
chemical
additives
to
reduce
offensive
colors,
please
identify
the
additive(
s)?
(
Check
all
that
apply.)
CBI
G
G
Dyes
(
please
identify:________________________________________)

G
Other
(
please
identify:________________________________________)

Performance
Data
21.
Please
complete
the
following
table
on
performance
data
for
the
model.
Specify
actual
test
results,
e.
g.,
183
fecal
coliform
bacteria
per
100
milliliters;
do
not
report
effluent
concentration
as
a
range,
e.
g.
"
below
200
fecal
coliform
bacteria
per
100
milliliters."
CBI
G
Device
Model
Name:
_________________________
Page
153
Copy
#
____
of
____

153
Constituent
Test
(
Y/
N)
Test
Method
(
e.
g.,
USCS
#
or
EPA#)
Concentration
Influent
Effluent
Units
Fecal
Coliform
Y
Total
Suspended
Solids
(
TSS)
Y
Enterococci
E.
coli
5
day
Biochemical
Oxygen
Demand
(
BOD)

Chemical
Oxygen
Demand
(
COD)

Residual
Chlorine
pH
Additives
for
odors
and
color
Hepatitis
A
Other,
please
specify
_____________

22.
Please
attach
a
copy
of
the
raw
data
collected
or
any
additional
performance
data
on
this
model.
CBI
G
23.
Test
location
G
Laboratory
G
On
vessel
24.
Device
age
at
time
of
test
G
New
G
Used,
months
in
operation:_____________

25.
Test
duration
_______________
days
26.
Test
temperature
______________
units
______

27.
Flow
rate
______________
units
______

28.
Influent
source
___________________________________________________________
Device
Model
Name:
_________________________
Page
154
Copy
#
____
of
____

154
29.
Was
the
performance
of
this
device
at
treating
gray
water
been
tested
at
this
lab?

G
Yes
G
No
30.
If
yes,
please
include
attach
a
copy
of
all
testing
data
that
you
have
on
the
performance
of
this
device
at
treating
gray
water.
CBI
G
31.
Was
the
performance
of
this
device
at
treating
drainage
from
medical
premises
(
dispensary,
sick
bay,
etc.)
via
wash
basins,
wash
tubs
and
scuppers
located
in
such
premises
been
tested
at
this
lab?
G
Yes
G
No
32.
If
yes,
please
attach
a
copy
of
all
testing
data
that
you
have
on
the
performance
of
this
device
at
treating
drainage
from
medical
premises.
CBI
G
33.
Was
the
performance
of
this
device
beyond
the
required
test
period
been
tested
at
this
lab?
G
Yes
G
No
34.
If
yes,
please
attach
a
copy
of
any
testing
data
that
you
have
on
the
performance
of
this
device
beyond
the
required
test
period.

Sewage
Sludge
Management
35.
Does
this
device
produce
sewage
sludge?
CBI
G
G
Yes
Please
complete
questions
36­
40
G
No
Thank
you,
you
have
completed
the
survey.
Please
return
it
to
EPA.

36.
How
much
sewage
sludge
is
produced
daily
when
the
unit
is
operated
at
average
capacity?
____________
pounds/
day
37.
Does
this
device
treat
or
manage
sewage
sludge?
G
Yes
G
No
38.
Identify
all
sewage
sludge
treatment
processes
this
devices
uses.
(
Check
all
that
apply.)

G
No
sewage
sludge
treatment
G
Concentration
G
De­
watering
G
Drying
G
Incineration
G
Other
(
please
identify:
___________________________________________)

39.
Please
provide
the
following
data
on
sewage
sludge
quality
if
available.

G
No
data
on
sludge
quality
available
Constituent
Concentration
Units
Percent
solids
Metals
Device
Model
Name:
_________________________
Page
155
Copy
#
____
of
____

155
Nutrients
Fecal
Coliforms
5
day
Biochemical
Oxygen
Demand
(
BOD)

Enterococci
E.
coli
Chemical
Oxygen
Demand
(
COD)

Other,
please
specify
_____________

40.
Please
attach
any
additional
information
on
the
quantity
and/
or
quality
of
the
sewage
sludge
produced
by
this
device.
