Comments from the Marine Industries Association of South Florida
regarding the Proposed Revisions to the Ozone and Particulate Matter
National Ambient Air Quality Standards
before the Senate Environmental and Public Works
Subcommittee on Clean Air
April 29, 1997

Mr. Chairman and subcommittee members, good afternoon my name is Frank Herhold. I am the Executive Director for the Marine Industries Association of South Florida, which represents over 640 marine businesses. I am also here today on behalf of the National Marine Manufacturers Association (NMMA), which is the national trade association representing over 1500 boat builders, marine engine and marine accessory manufacturers.

I am here today to explain why the EPA's proposed revision to the National Ambient Air Quality Standards (NAAQS) will be bad for recreational boating. What is bad for recreational boating is bad for the State of Florida and the nation. There are currently 750,000 registered boats in the State of Florida and the latest annual marine retail sales figures topped $11 billion in Florida. To put this into perspective, in Broward County alone, the marine industry represents a total economic output of $4.3 billion employing 88,390 people, with an average growth rate of 6.5%. Boating brings dollars and jobs to the State of Florida.

The Clean Air Act Amendments of 1990 have placed a significant technical and economic challenge on the recreational boating industry. The new marine engine emission regulation which was finalized in July 1996 will require that all new marine engines reduce hydrocarbon emissions by 75%. Economic impact estimates have this regulation costing the industry over $350 million, increasing the cost per boat engine by as much as 15 percent. The Clean Air Act will also regulate air emissions from boat manufacturing plants with a MACT (Maximum Achievable Control Technology) standard scheduled to be promulgated in the year 2000. This regulation will also be costly raising the price of boats, thus directly reducing the number of people who can afford to enjoy boating.

Needless to say, the proposed revised NAAQS will have a devastating effect on the recreational marine industry. Without drastically reengineering American society, states will be forced to press emission sources for further reductions, many of which like the recreational boating industry, have reached the point of diminishing returns.

Several years ago, when the NAAQS for ozone was initially set at .12 ppm, some state regulators in non-attainment areas considered bans on recreational boating as a method to meet the requirements of their State Implementation Plans. The Washington DC Council of Governments (COG) actually proposed a ban on recreational boating in 1993. This proposal raised immediate opposition from boaters, marinas, waterfront restaurants, and other effected groups. COG eventually reversed its decision after the affected parties spent considerable resources to educate COG as to the proposal's adverse effects. This EPA proposed revised standard will again force states to reconsider episodic bans and this time states may be pushed to implement episodic restrictions on recreational boating throughout the nation.

I am appealing to you to stop EPA's attempts to revise the standards at this time. It is my understanding that the scientific studies that EPA is using to defend this proposal do not take into account either the specific constituents in air pollution or other mitigating factors that effect human health. I feel that EPA would be premature to impose such a burdensome standard without first identifying the specific benefit and real cost of the proposal. Even if we fail to convince EPA that it is making a terrible mistake, at a minimum, let's somehow prevent states from using episodic bans as a means to attain compliance. Episodic bans will negatively effect a person's decision to purchase a boat, knowing that on the hottest days of the summer the government can take away his or her freedom to operate it. Not since Congress passed the luxury tax have boaters faced a more serious threat. If this standard is finalized in its current proposed form, consider the burden it will place on states, industry and its workers, and the million of people who just want to spend a summer afternoon on the water with their family.

In conclusion, everyone needs to realize that America's air is cleaner and will continue to improve, as the benefits from recently and soon to be initiated Clean Air Act regulations are realized. What we do not need now is more regulation. What we need now is the time and resources to implement those regulations that are already on the books. Boaters want clean air and clean water and the recreational marine industry is ready to assist both Congress and the EPA in this rulemaking process. Thank you for the opportunity to testify.