Chris T. Flaherty

While it does not directly affect my life, I feel pollution at any level affects us all. There is no more horrendous an act of pollution than the dumping of items in to bodies of water. It interrupts ecosystems, kills organisms, and soils one of our most precious resources. That is why I have chosen to comment on the defining of “marine debris” for the purpose of the Marine Debris Research, Prevention, and Pollution Act. While I believe the act a great step towards reducing marine pollution, I believe it stops short of truly protecting our water. The aim of this rule is to define what “marine debris” is for the purpose of forming the overall act. The proposed rule would define marine debris as such: “For the purposes of the Marine Debris Research, Prevention, and Pollution Act (33 U.S.C. 1951-1958 (2006) only, marine debris is defined as any persistent solid material that is manufactured or processed and directly or indirectly, intentionally or unintentionally, disposed of or abandoned into the marine environment or the Great Lakes.” While on its face this seems like a pretty good definition, I believe it lacks in a significant way. According to this definition only those items that are “manufactured or processed” qualifies as marine debris. This is not always the case as even items that are not technically “processed” could damage the environment if introduced. What if raw sewage is dumped in to the ocean, would this be considered manufactured or processed? How about agricultural products that have not yet been processed, would those be considered? What about minerals like asbestos or unprocessed mercury or lead? While I may not agree with all provisions it is a step forward, and other parts of the Act I am for. The Interagency Marine Debris Coordinating Committee was reactivated with the task of overseeing the program and meets quarterly to oversee progress. They are tasked to work with the National Oceanographic and Atmospheric Administration and the United States Coast Guard to help. The act also created the Marine Debris Prevention and Removal Program within the NOAA. Their task includes mapping, assessing, preventing, and removing marine debris. I strongly support this work and agree whole heartedly. I also agree with the Act requiring the Coast Guard to enforce the Convention for the Prevention of Pollution from Ships passed in 1973. They will monitor and ensure enforcement as well as reporting damage to vessels and navigation disruption caused by marine debris. I also strongly support the requirement that the Coast Guard report to congress about this issue. Overall I believe the administrative rule is very strong. It helps to highlight the problems facing our lakes and oceans. Failing to clean our water is a mistake and will probably lead to far more issues in the future. Other than slight changes to the definition this is a strong law that will hopefully bring some needed changes. I do admit I would like to have heard more about current efforts to clean our waters, that is not necessarily the aim of the rule. Thank you for considering my comment.