Comment submitted by Lake Carriers' Association (LCA)

Summary: The Lake Carriers’ Association, representing 13 members operating 43 U.S. flag Great Lakes vessels, is submitting comments to ensure that the EPA's process for establishing No-Discharge Zones (NDZs) accurately accounts for the specific needs of commercial shipping. They argue that the current draft guidance lacks sufficient detail regarding pumpout facility capacity, vessel-specific requirements (like draft and connections), and seasonal demand, and they advocate for making many "optional" data points mandatory to ensure a fact-based determination.