b'InCalifornia,certainharborsandbaysareandMississippi.Thereseemstobeonlyadisposal of treated sewage effluent? If so, can designated as NDZs for both commercial andsoleNDZ(inMinnesota)alongtheentiresuch structural change be done in conjunction recreational vessels, while all California marineMississippi River system. Of course, nothingwith a scheduled visit to a drydock or shipyard? waters are NDZs for recreational craft. Theprevents states from putting into motion theWhat shoreside or mobile options to receive statewide marine waters designation was madeprocess for designating new NDZs. treated sewage effluent are available now or can pursuant to section 312(f)(4)(A) of the Cleanreasonably be installed in the near future?Water Act. This subsection requires a state toThe EPA has a web page with information (in-apply to EPA, which must determine that thecluding maps) on each No Discharge Zone; en- Finally, sometimes confusion arises as to the protection and enhancement of the water bodyter EPA and No Discharge Zone into yourClean Water Acts requirements for vessel dis-requires the establishment of an NDZ. Whensearch engine to locate it. chargeoftreatedsewageeffluent(including NDZs) and the Clean Water Act regulation Each PVA vessel member should become fa- of other discharges incidental to the operation No Discharge Zonesmiliar with the status of the waters on whichof a vessel (graywater, ballast water, deck wash, his or her vessels operates. If the vessel sails onetc.), controlled by the terms of the EPAs Ves-have spread acrosswaters not now covered by an NDZ, it couldsel General Permit (VGP). These are separate be only a matter of time before a designation isregulatory requirements. Eventually, the EPA the country. They canproposed. Planning ahead for an NDZ can savewill issue a new version of the existing 2013 a lot of agony and expense. Can the vessel beVGP to comply with the Vessel Incidental Dis-be found in 28 states. modified to eliminate the need for overboardcharge Act of 2018.this particular subsection is invoked, it is not necessary to find that adequate pump-out facilities are reasonably available. Because of the lack of discharge reception facilities in California for commercial vessels, it would not have been legally possible to base the statewide marine waters designation on the criteria of section 312(f)(3).The most contentious No Discharge Zone is the Washington State one, encompassing all of Puget Sound and its connecting waters. It went into effect for most vessels on May 10, 2018. While most PVA vessels in Puget Sounddonotdischargeoverboardtheir treated sewage effluent, the existence of ade-quate reception facilities to service all vessels is in dispute. Operators of commercial tow-ing vessels and small ship overnight vessels (some of whom are PVA members) maintain thatfacilitiesthatcanaccommodatethem simply do not exist, at least in the areas in whichtheycustomarilyoperate.Washing-ton State delayed enforcement of the Puget Sound NDZ for these particular vessels for five years until May 10, 2023. This seems to be a tacit admission that the reception facil-ities are lacking. The American Waterways OperatorssuedtheEPA,seekingtoover-turn the agencys section 312(f) certification, which took place in the waning hours of the Obama administration. This is the case that U.S. District Court judge Amit Mehta de-cided against AWO on February 14, as men-tioned earlier in this article.In reviewing EPAs list of states with NDZs, one sees that there are no or very few NDZs in Alaska, Hawaii, Oregon, Illinois, Ohio, Kentucky,Tennessee,Missouri,Alabama, 21 MARCH 2022'