I agree with your post other than this....
Here in Puget Sound, there was a connection made in much of the (mis)information given to the public, WA DOE, and legislators between requesting the EPA for a NDZ and the increase in available pump-out facilities. While I appreciate that there are more, and better serviced pump-outs than there were a couple decades ago, there really is no relation between the two.
The NDZ only affected a very small percentage of recreational boaters in Puget Sound. As such, placing this burden on such a small number of boaters won’t improve water quality. Even so, since the EPA requires evidence that there are adequate pump-out facilities in an area before they approve the NDZ designation, WA state implemented programs and grants to ensure that there would be enough pump-out facilities to satisfy the EPA.
So the EPA agrees with you even though creating an NDZ in Puget Sound puts no significant additional pressure on the pump-out facilities that recreational boaters use.