. . . since in real life I am a lawyer who represents several of the Waterkeepers bringing Clean Water Act cases against water polluters.

As the Puget Soundkeeper correctly informed you, the Clean Water Act prohibits the discharge of any "pollutant" without a permit. The non-sewage discharges issue came up a couple of years ago when an environmental group sued to put limits on the "grey" water and bilge water discharges from cruise ships -- a huge water quality problem in small harbors -- which should have been subject to permit requirements and standards. The environmentalists won (it's an easy case under the Clean Water Act, which defines "vessels" as point sources that require permits, -- before 2008 the only exception was for sewage from vessels, which comes under the CG regulations).

EPA then proposed a general permit that would set standards and best practices for grey water, bilge water, and wash water from all vessels, including recreational vessels. Our good friends at BOAT US lobbied Congress to make an exemption for recreational boats, but the exemption left out wash water, so wash water is still covered by the permit requirement, but without the general permit. (A general permit is a "permit" that applies to everyone, without anyone having to apply for it individually).

Someone suggested, why not just prohibit discharges that cause water quality problems. We had a system like that in place for about 25 years before the 1972 amendments to the Clean Water Act. The result was no prosecutions for water pollution and the Cuyahoga River catching on fire. The problem with basing water quality regulation on "pollution impacts" is that it is very hard to prove that a particular polluter caused the impact -- impossible to prove it beyond a reasonable doubt for a criminal violation. Every polluter would just point the finger at the next polluter and say -- it wasn't MY discharge that cause the problem, it was THEIR discharge. Water bodies died the death of a thousand cuts.

In 1972 Congress correctly decided that the only way to control water pollution was to cut it off at the source, and have every industry in the nation meet uniform standards implemented by permits, without trying to figure out the scientifically (and politically) difficult questions of which discharges cause which water quality problems.

Incidentally, the Clean Water Act still includes a water-quality based regulatory scheme, which is nearly completely unenforced, still.

So, discharge of wash soap from a vessel is a technical violation of the clean water act. Not likely to see any major enforcement anytime soon, but if we can encourage better practices with the threat of legal action, so much the better.

And no, NACL and the dreaded DHMO would not be considered "pollutants" just because they are "chemicals." The Clean Water Act does not make all "chemicals" "pollutants." Only "chemical wastes" are pollutants, as are all "biological materials." So wash soap is a pollutant, as it's a chemical and a waste when it hits the water. Use non-toxic soaps that do not leave a trace in the water and no-one is going to bother you.

Oh, yes, corn husks are pollutants, too ("biological materials" and "solid wastes"). But don't worry about peeing while you are swimming -- a Court of Appeals ruled that human beings can't be point sources that require a permit.

Don't even think about gutting our Clean Water Act. The reason it works is because it is a strict statute with a zero discharge standard (zero discharge, or get a permit. period). It might make your life easier in the short run not to have to deal with the Clean Water Act as it applies to wash water -- but without the Clean Water Act zero discharge standards all the waters we enjoy would be really filthy. Like they were in the 60s and 70s.

Me, I use Murphy's Oil soap once a year on our teak decks, otherwise its just good ol Hudson River water, or whatever sea water I can find. Yes, I know the teak is unsustainable.

--Karl S/V Mabel Rose