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July 17, 2008

Water Docket

Environmental Protection Agency

Mail Code 2822T

1200 Pennsylvania Ave., NW

Washington, D.C. 20460

Re: Docket ID No. EPA-HQ-OW-2008---0055 for the VGP

Dear Sir/Madam:

We are writing on behalf of the members of the Marine Retailers
Association of America (MRAA) to comment on the **Draft National
Pollutant Discharge Elimination System (NPDES) General Permit for
Discharges Incidental to the Normal Operation of a Vessel** proposed
rule identified by the above Docket Number published in the *Federal
Register* on June 17, 2008.

MRAA is the national trade association of small businesses which sell
new and pre-owned recreational boats, operate public access to our
nation's waters by marinas or access ramps, and sell marine accessory
products. We have approximately 3,500 members.

MRAA believes the proposed rule would have a vast, unprecedented impact
on recreational boating, the nation's economy, and the clear choice of
family recreation of over 70 million Americans. This rule would place an
undue hardship on Americans over everyday water discharges and would
place them in a direct regulatory regime designed for land-based
industrial facilities, like sewage disposal plants, and commercial
shipping vessels.

As was described in the proposed rule, failure for 17 million Americans
who own recreational boats to comply with the proposed rule would result
in harsh \$32,000 per day fines per violation.

Our members strongly oppose this rule for several reasons:

-   The NPDES permit program for recreational boats would strongly
    discourage Americans from participating in boating in leisure time
    and would hurt the nation's economy with vast increases in
    unemployment. Our nation is facing the prospects of a recession that
    already is being felt in recreational boating with sales significant
    declines for new boats. We believe there are 19,000 small businesses
    in the USA devoted to recreational boating employing over 154,000
    people. This does not include ancillary businesses, such as bait
    shops, restaurants, etc., which have a significant amount of their
    business dependent on recreational boating.

-   States can establish their own permits and charge different fees. We
    understand states are free to implement different requirements and
    their own permit programs that vary by body of water in their own
    state. This uncertainty allows for the possibility of confusion
    among boaters on how to comply, increased bureaucratic paperwork and
    fees, and enforcement of yet undetermined permits.

-   If the boating American tries to comply but gets it wrong, look out
    for lawsuits and potential huge fines. American boaters are clearly
    the target and this government action will strongly encourage
    boaters not to go boating and for others not to get involved in
    boating for leisure time activities.

-   The proposed rule does not allow for education of boaters. Boaters
    will have to comply with the NPDES permit requirement after
    September 30, 2008, but the EPA will not be educating the boating
    public on what these new permits mean. There are a lot of people to
    educate in a very short amount of time.

This proposed rule is clearly the first installment of what could be
several new rules that may vary by fifty states. The EPA is even asking
for comments on what new best practices should be mandated on boaters
and if boaters should meet something called "numerical limits." It is
clear the permitting will get more and more complicated over time
further discouraging Americans from boating.

MRAA sees great fault with the proposed rule and the potential of it
causing great harm to the nation. We ask that the proposed rule be
reconsidered and returned to the current application of the Clean Water
Act to recreational boats.

Sincerely.

Phil Keeter Robert Soucy

President Chairman