Charlie Costanzo, vice president for AWO’s Pacific region, has a spreadsheet listing 130 towing vessels that work in Puget Sound. Of these 130, 24 have Type III marine sanitation devices, meaning they have blackwater holding tanks. The other 106 have Type II MSDs, meaning they treat onboard sewage to the federal standard of 200-ppm fecal bacteria before discharging overboard.

Washington state’s Department of Ecology wants those 106 vessels to get holding tanks and stop discharging treated sewage in Puget Sound. In fact, it wants all vessels, commercial and recreational, to switch to holding tanks because it is preparing to petition the Environmental Protection Agency to declare all of Puget Sound from the Canadian border to Olympia a No Discharge Zone (NDZ).

From the tugboat operator’s perspective, this is a disaster. Converting to Type III holding tanks is not easy and it’s not inexpensive. Estimated costs per vessel are over $100,000, which includes engineering and drydocking. Dunlap Towing, which owns and operates 27 of those 106 towing vessels, says that converting these boats is simply impossible.

Costanzo said there’s no reason any of the boats with Type IIs should have to change. “If you look at [Department of] Ecology’s own maps showing areas of the highest concentration of impaired water quality, you’ll see that these aren’t areas where commercial mariners are navigating. So even Ecology’s own maps don’t provide any evidence that would say vessels with Type II MSDs are part of the problem. Actually, Ecology’s maps would suggest that we aren’t.”

So the state Department of Ecology doesn’t have to undertake a cost-benefit analysis of the NDZ proposal? “Ecology doesn’t even have to present any data,” said Costanzo. “Ecology just has to have an idea.”

Maybe the EPA will reject the state Ecology Department’s petition? “Never in NDZ history has the EPA told a state that it’s not a good idea.”

California’s coastal waters were recently declared an NDZ, too, but holding tanks are only required for large passenger vessels and other oceangoing ships larger than 300 tons. For tugs and other workboats, federally approved Type IIs are fine.

For what it’s worth, I agree. The proposed Puget Sound NDZ is a bad idea. It should be shot down. If you also agree, go to Ecology’s website, click on Amy Jankowiak’s email address and register your objections. You’ve got until April 21. 

With a degree in English literature from the University of Washington (Go Dawgs!), journalism experience at the once-upon-a-time Seattle P-I, and at-sea experience as a commercial fisherman in Washington and Alaska, Bruce Buls has forged a career in commercial marine trade journalism, including stints at Alaska Fishermen’s Journal and National Fisherman, WorkBoat’s sister publications. Bruce spent 16 years as WorkBoat's technical editor before retiring in May 2015. He lives on Puget Sound’s Whidbey Island, about 20 miles north of Seattle (go 'Hawks!).