Comment from Patrick Rooks

I am writing to convey my support of the Olympic Coast National Marine Sanctuary Regulations Revisions. The proposed rule is effective in remedying vagueness in the current definitions and balances the needs of interested parties. However, I would also urge the ONMS to continue pursuing data on the actual impact of the graywater discharges on the waters and ecosystem of the Olympic Coast National Marine Sanctuary. As elucidated in the Supplementary Information, “[v]ery little research has been done on the impacts of graywater on the marine environment....” A typical cruise ship can produce 1,000,000 gallons of graywater in a single week, in addition to all of the other materials generated. In support of the proposition that graywater contains materials detrimental to the environment, a comparison to Alaska is made, where studies have shown large amounts of suspended solids and fecal coliform. Alaska requires that many ships utilize Advanced Wastewater Treatment (AWT), which is effective in removing many substances including such suspended solids and fecal coliform. However, it is only moderately effective in removing dissolved nutrients. The proposed regulation accurately points out that “naturally occurring harmful algal blooms...often occur during the summer months off the coast of Washington....” As such, if the dissolved nutrients do in fact exacerbate these existing conditions, then prohibition of graywater emissions is warranted. It is necessary to understand whether the algal blooms and other occurrences are related to emitted nutrients and metals. If not, then requiring the use of AWT systems on cruise ships would perhaps be a more effective solution than an outright prohibition of graywater discharge. My concern is that such a prohibition is difficult to enforce since claims that cruise ships avoid discharge have not been verified.