Comment Submitted by D. Ross

EPAs proposal to include recreational vessels, simply based on vessel length, in Vessel General Permit (VGP) together with commercial vessels is unreasonable -- without some other defining criteria. Further, creating the Recreational General Permit (RGP) for vessels under 79 feet would constitute an unnecessary burden on the recreational vessel owner. The proposed permits do not appear to create any new regulations. From my reading of EPAs proposed regulations and the Federal Register it is unclear about the term of the proposed permits and any costs that might be incurred by the vessel owners to comply with the permitting requirements. Simply creating a new permit, together with associated application and processing requirements, does not appear to enhance EPAs ability to improve environmental conditions within U.S. waters. Further, the proposed Clean Boating Act of 2008 and U.S. Coast Guard regulations appear to have sufficient regulatory powers to enforce environmental regulations in recreational vessels. By themselves, the U.S. Coast Guard regulations appear sufficient to regulate recreational vessels. Should the Clean Boating Act of 2008 be passed, the permits proposed by EPA would be even more unnecessary. As a boat owner of a USCG documented vessel, operated entirely in foreign waters, it is unclear whether these EPA permits would be required for my vessel, simply because of the status of a documented vessel. If the permit was required, obtaining such a permit could be difficult, depending on the permit application requirements and processing procedures. Overall, the proposed discharge permits appear to be unnecessary and do not seem to do anything more to ensure compliance with existing regulations. Dennis Ross S/V Two Can Play USCG Doc. 641244