Department of Pesticide Regulation 

Mary-Ann Warmerdam 

Director 

Arnold Schwarzenegger 

Governor 

1001 I Street • P.O. Box 4015 • Sacramento, California 95812-4015 • www.cdpr.ca.gov

A Department of the California Environmental Protection Agency 

December 16, 2010 

Ms. Rebecca von dem Hagen 

U.S. Environmental Protection Agency 

Office of Pesticide Programs 

1200 Pennsylvania Avenue, N.W. 

Washington, District of Columbia 20460-0001 

SUBJECT: U.S. ENVIRONMENTAL PROTECTION AGENCY REGISTRATION 

REVIEW FOR COPPERS (DOCKET IDENTIFICATION NUMBER 

EPA–HQ–OPP–2010-0212) 

Please accept the following comments from the California Department of Pesticide 

Regulation (DPR). The purpose of this letter is to (1) provide feedback on the registration 

review work plan, (2) provide some background on copper antifouling paint (AFP) pollution in 

California, and (3) highlight the significant amount of activities relating to the assessment and 

mitigation of this pollution. When possible, we have provided links to referenced documents and 

web pages. 

DPR recognizes that there may be other water and sediment quality concerns associated with the 

use of copper in non-AFP pesticide products. In fact, a number of California stakeholders have 

submitted extensive comments on these products. However, the pollution related to copper AFP 

use is the most pressing copper issue to DPR since we regulate the sale and use of antifouling 

paints in California and due to the level of concern that stakeholders and water quality control 

agencies have expressed to us. DPR hopes that our input through Registration Review will help 

the U.S. Environmental Protection Agency (U.S. EPA) develop its final work plan that is 

expected to be completed in February 2011, and the environmental risk assessment that is 

expected to be completed in 2015. DPR also hope that our input will ultimately allow U.S. EPA 

to make the most informed risk management decisions on copper AFP products. 

WORK PLAN RELATED COMMENTS: 

DPR generally agrees with the approach that is proposed in the work plan for coppers. However, 

we do offer the following comments, which we hope will strengthen the basis for the risk 

assessment and eventual risk management decisions for antifoulant use of copper. 

1. Reregistration Screening-Level Environmental Risk Assessments (ERAs) for Antifoulant 

Exposure: DPR would like to address the ERA contained in the August 10, 2010 Revised 

Addendum to the Revised Coppers Reregistration Eligibility Decision as there were no 

opportunities to comment once the document was released. U.S. EPA chose the commercial 

harbor scenario for MAM-PEC modeling of copper oxide antifoulant use. This is not the 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 2 

worst-case modeling scenario that should have been used. DPR has been requesting that 

antifoulant registrants produce MAM-PEC simulations for the poorly-flushed salt water 

marina scenario under California environmental and use conditions when we evaluate new 

antifoulant active ingredients for California registration. This practice is a result of our 

observations that high dissolved copper concentrations tend to occur in large and 

poorly-flushed pleasure craft marinas along the California Coast. Note that the default 

emission settings for the poorly-flushed marinas scenario still require adjustments to better 

reflect California conditions. For example, some of our larger coastal marinas harbor 

thousands of pleasure crafts. The default marina scenario assumes that there are only 

299 boats. 

Furthermore, please note that even with the less conservative scenario that U.S. EPA used, 

the predicted Estimated Environmental Concentrations (EEC) were 1.57 μg/L for the average 

dissolved copper concentration and 4.76 μg/L for the maximum dissolved copper 

concentration. The maximum EEC value exceeds the chronic salt water ambient water 

quality standard for copper (California Toxics Rule standards promulgated by U.S. EPA for 

California) that is set at 3.1 μg/L. The acute standard of 4.8 μg/L is also very close to the 

maximum EEC. The ERA failed to point out the proximity of the EECs to these standards. If 

the poorly-flushed marina scenario under California conditions would have been modeled, 

the resulting EECs would have easily surpassed the acute standards. CTR standards are being 

vigorously imposed in California by the State’s water quality regulatory agencies–the State 

Water Resources Control Board (SWRCB) and its nine Regional Water Quality Control 

Boards (RWQCBs). 

Also, please note that the ERA’s conservative assumption that all the ships are painted with 

copper oxide AFPs is not that conservative. DPR estimates that only about five percent of all 

recreational and commercial vessels in the State’s coastal marinas use noncopper AFPs. 

Moreover, the leach rate of 50 μg/L/cm2

/day is not the “highest possible” leach rate. 

Leach rate estimates submitted to DPR from copper AFP registrants show that 

environmentally-relevant leach rates (representing long-term not maximum rates) from a 

number of copper oxide products exceeded this threshold. 

Future ERAs should also take into account the larger water body’s background copper levels 

and the impacts of underwater hull cleaning on biocide leaching from boat hulls. The 

MAM-PEC model does not factor in these sources in generating EECs. This hull 

maintenance activity is very common in California’s coastal marinas. Moreover, certain 

water bodies in California have relatively high background copper concentrations that could 

significantly contribute to a marina’s copper load. Brackish water areas, in particular, tend to 

have high background copper levels. 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 3 

Subsequent ERAs under this Registration Review need to consider all of these points. DPR is 

willing to assist Agency modelers in fine-tuning MAM-PEC inputs to give a more accurate 

picture of exposure scenarios. 

2. Effect Assessment Endpoints: The current risk-quotient based determination of harm or 

endpoints only serves to address Federal Insecticide, Fungicide, and Rodenticide 

Act (FIFRA) based mandates, which imply that some level of biological impacts is 

acceptable. While this may be scientifically and legally defensible under FIFRA, these 

 types of endpoints do not take into consideration the protective mandates that are established 

under the Clean Water Act (CWA). We encourage that protective endpoints such as the 

 CTR and the Biotic Ligand Model (BLM)-based fresh water quality criteria for copper 

somehow be considered by U.S. EPA as part of the risk management decision making under 

Registration Review. It is not clear whether this approach is being considered as part of the 

Office of Pesticide Programs and Office of Water harmonization efforts that U.S. EPA has 

been undertaking. 

3. DPR Supports the Use of the BLM: DPR has evaluated the scientific basis of the BLM and 

we support its use for both fresh and salt water exposure and effects assessments. Since our 

work on copper AFP pollution has shown that the greatest risk to aquatic life from exposure 

to copper is in the salt water or marine marina environment, we encourage U.S. EPA to 

finalize the salt water BLM. Note, however, that a revision of the ambient national water 

quality criteria for copper does not translate to a revision of the existing CTR standards in our 

State. SWRCB and its RWQCBs will need to engage in dialogue with U.S. EPA to make an 

update of the CTR standards for copper possible. 

Our evaluation of marina water samples using the BLM under California-specific conditions 

suggests that the biological impacts of dissolved copper concentrations in California marinas 

tend to be over stated (Singhasemanon et al. 2009). At the same time, even with 

bioavailability accounted for, there are many instances where the BLM still predicted 

toxicity to sensitive aquatic test organisms. In other words, the use of copper AFPs, which we 

believe are the most significant source of copper in salt water marinas during dry-weather 

periods, may still threaten aquatic life in these waters. 

4. Copper Oxide Environmental Fate: DPR scientists recently completed a manuscript on the 

environmental fate of copper oxide. It is currently in press and will be printed in an 

upcoming volume of the Reviews of Environmental Contamination and Toxicology. DPR 

would like to share this review with U.S. EPA once it is published. It may be of use to 

Registration Review staff. 

5. Description of Ecosystems at Risk for Antifoulant Use: In the Registration Review document, 

“Preliminary Problem Formulation for Ecological Risk, Environmental Fate, and Endangered 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 4 

Species Assessments for Coppers,” there appears to be a error in the linkage of the 

antifoulant use of copper to the ecosystems at risk (page 25 of 106). U.S. EPA staff may be 

referring to the sites of use for the various antimicrobial uses of copper rather than the 

ecosystems at risk. With antifoulant use of copper, the ecosystems that are most at risk are 

those that are associated with marina areas, as these locations tend to exhibit high 

concentrations of copper as a result of pesticide use. 

6. Registration Review’s Risk Management Decision Timeline: DPR is concerned with the point 

at which risk management decisions (e.g., label changes, registration status changes) could be 

made under the currently established U.S. EPA timeline. Since the ERA is not expected until 

2015, it is unlikely that any U.S. EPA action would occur prior to that event. 

DPR has been engaged in evaluating copper AFP pollution for more than a decade (see 

background section below) and we would welcome any near-term guidance from U.S. EPA. 

We have conducted and coordinated many assessment and mitigation related activities. We 

have also recently initiated our formal reevaluation process on copper AFPs to initiate more 

direct discussions with registrants and to gather data that could be used to address high 

copper concentrations in our marinas. The reregistration process concluded without 

recognition of this issue, and subsequently no actions were taken as a result. Depending on 

the outcome of our ongoing evaluations, DPR may need to take California-specific 

regulatory or registration related measures independent of federal actions. Although DPR is 

not a CWA agency, we strive to work collaboratively with our sister agencies (i.e., SWRCB 

and RWQCBs) to assist them with the implementation of their CWA mandates. 

ISSUE BACKGROUND: 

Antifouling Paint Products in California 

In 1988, U.S. EPA and DPR established regulations to limit the use of tributyltin AFPs because 

of documented adverse affects to aquatic organisms. Copper-based AFPs, which were also 

popular at the time, became the dominant class of AFPs used. Today, cuprous oxide is the most 

utilized active ingredient in AFP products with about 180 products registered in California. The 

other two copper active ingredients currently used in AFPs are copper thiocyanate and copper 

hydroxide; however, these are only formulated into about 15 products. 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 5 

Shelter Island Yacht Basin TMDL and Implementation Plan 

In 1996, the San Diego Regional Water Quality Control Board (SDRWQCB) placed the Shelter 

Island Yacht Basin (SIYB) on the CWA Section 303(d) list and soon began development of a 

Total Maximum Daily Load (TMDL) for copper. This regulatory development prompted DPR, 

other agencies, and stakeholder groups to initiate a closer investigation into copper pollution 

stemming from the use of AFPs. 

SIYB is a large recreational boat basin that contains ten popular marinas and yacht clubs that 

harbor approximately 2,200 boats. Marina sampling conducted by SDRWQCB and others at 

SIYB over many years demonstrated that total dissolved copper concentrations (to be referred to 

as copper concentrations in the rest of this document) there exceeded the CTR standards of 

3.1 μg/L (chronic) and 4.8 μg/L (acute) by two to threefold, with concentrations as high as 

12.0 μg/L. The U.S. EPA established these water quality standards in California in 2000 for the 

protection of aquatic life. Copper concentrations at SIYB also violated the enforceable narrative 

water quality objectives (WQOs) for toxicity and pesticides as defined in the SDRWQCB Basin 

Plan. 

SDRWQCB determined that at SIYB, 93% of the copper in the basin was attributed to the 

passive leaching of copper-based AFP pesticides that have been applied to boat hulls. Copper 

released from underwater hull cleaning contributed 5%. All other sources in SIYB only 

accounted for 2% of the total copper load (SDRWQCB 2005). Note that an alternate analysis of 

the same data used in the TMDL by copper AFP registrants in 2007 showed that relative 

contributions may be closer to 55% passive leaching and 45% underwater hull cleaning 

(Blossom and Anderson 2007). Regardless of the precise allocation, it is clear that copper 

AFPs are the major source of copper in this basin. 

Toxicity to copper sensitive test species and endpoints has also been documented 

(SDRWQCB 2005). Moreover, high copper concentrations at SIYB also threaten sediment 

quality and may potentially adversely impact benthic life. Sediment concentrations of copper 

at SIYB have been shown to regularly exceed sediment quality guidelines developed 

by the National Oceanic and Atmospheric Administration. However, unlike WQOs and CTR 

standards, sediment quality guidelines are not enforceable. 

The TMDL implementation plan outlined strategies and management practices available to 

dischargers and potential regulatory actions available to SDRWQCB. The Port of San Diego, 

SIYB marinas, boat owners, underwater hull cleaners, and the City of San Diego are responsible 

as dischargers to meet this goal. Between 2007 and 2022, the implementation plan requires 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 6 

dischargers to demonstrate incremental reductions of copper loads. Dischargers must first 

achieve a 10% reduction in copper loading by the end of 2012. By 2022, copper loading must be 

reduced by 76% from 2005 base levels. Note that seven more San Diego Bay marinas have been 

added to the 2006 CWA Section 303(d) list for beneficial use impairments due to elevated 

copper levels. 

TMDLs that deal with copper from AFP sources have also been established for Marina del Rey 

(harboring approximately 6,000 to 8,000 boats) and Lower Newport Bay (harboring 

approximately 10,000 boats). Copper AFPs are suspected of being significant copper sources in 

these basins as well based on the large presence of boats and the projected loadings. As new data 

become available, these TMDLs and their implementation plans will undoubtedly focus in on the 

sources of copper from AFP use and the methods for pollution control. 

Stakeholder Activities 

In response to the SIYB TMDL and CWA Section 303(d) list designations of additional marinas, 

the Port of San Diego has taken on very active role in spearheading and coordinating local 

mitigation efforts with the goal of meeting TMDL reduction goals. In recent years, the Port 

conducted a U.S. EPA grant-funded project to identify safer antifouling alternatives to copper 

(i.e., the Safer Alternatives Project). Dozens of noncopper AFPs, including some that are 

considered “biocide free” were evaluated for performance, longevity, and cost. The initial phase 

of the project involved tests of coatings painted on uniformly-sized panels that were submerged 

for exposure to fouling pressures and periodically cleaned when needed. The second phase of the 

project involved selecting the most promising noncopper AFPs from phase one and testing them 

on recreational boat hulls. The Port recently released a draft project document soliciting 

comments from stakeholders with expectations that a final report will be completed and 

submitted to U.S. EPA by February 2011. DPR believes that findings from this project could 

potentially be used to assist boaters statewide transition to copper alternatives. 

In anticipation of the result of the “Safer Alternatives Project,” the Port has initiated another 

U.S. EPA grant-funded project to subsidize the conversion of copper-AFP coated boat hulls into 

those using noncopper AFPs. Approximately 200 to 250 recreational boats are being targeted for 

conversion under this project. Long-term tracking of AFP conversion is also being developed by 

the Port. 

The Port is concurrently engaged in developing a permit to help control the activities of 

underwater hull cleaners in marinas that it has under its jurisdiction. The Port maintains that it 

has the authority under Port Code Section 8.05. A draft permit is being circulated for review to 

interested stakeholder in December 2010. The resulting permit is being watched closely by DPR 

as it may allow us to better construct a statewide strategy in address copper pollution that is 

generated by underwater hull cleaners. 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 7 

Although the Port of San Diego has conducted a lot of work to address this issue on a local scale, 

many other agencies, industry, academia, and stakeholder groups have been active in addressing 

the marina copper problem. These groups have collectively worked to make early water quality 

assessment work possible. In recent years, their attention has turned toward (1) evaluating 

environmentally-friendlier alternatives to copper AFPs, (2) finding other ways to mitigate the 

water quality problem, and (3) conducting outreach to various user groups to raise awareness of 

the problem and potential solutions. The major forum for this type of coordination and for 

general information sharing on antifouling topics is discussed in the next section. 

Copper Antifouling Paint Sub-Workgroup/Antifouling Strategies Workgroup 

In March 2004, DPR formed the Copper AFP Sub-Workgroup, which is a workgroup of the 

SWRCB NonPoint Source Interagency Coordinating Committee’s Marina and Recreational 

Workgroup. The objective of the Copper AFP Sub-Workgroup is to investigate copper AFP 

pollution across the State to help facilitate the evaluation of mitigation options by DPR, 

SWRCB, and its RWQCBs. 

Initially, the workgroup focused its efforts to identify and gather existing AFP-related 

information. There was extensive information on environmental fate and toxicological effects of 

copper in aquatic systems, but copper monitoring data (especially those collected in California) 

were scarce. In order to fill this data gap, DPR spearheaded a multi-regional monitoring study to 

assess indicators of AFP pollution. With significant assistance from workgroup agencies, DPR 

completed the study in late 2006. Findings from this and other monitoring studies in California 

are summarized in the next section. 

Even though the workgroup’s primary focus was on the environmental impacts of copper AFP use, it 

also explored AFP-related policy, regulatory, and mitigation issues. With its expansion to include 

participation of non-governmental stakeholder groups (i.e., marina, boating, and pesticide industries), 

the workgroup became the central discussion forum for AFP-related issues in California. In 2008, the 

workgroup changed its name to the Antifouling Strategies Workgroup to reflect the workgroup’s 

broader interests beyond copper AFPs. The workgroup’s past meeting agendas, notes, and associated 

materials can be found at: <http://www.cdpr.ca.gov/docs/emon/surfwtr/caps.htm>. 

Monitoring Findings from California 

Four major monitoring studies for copper and other indicators of AFP pollution have been 

conducted in California in the last several years. These may be of interest to U.S. EPA. These 

studies indicate that copper concentrations in marinas throughout the State (particularly those in 

salt and brackish water areas) frequently exceed federal water quality standards. Details on these 

studies are presented below. 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 8 

Multi-Regional Marina Monitoring Study – DPR conducted a monitoring study of 23 marinas in 

the summer of 2006 (Singhasemanon et al. 2009). High levels of copper were detected in the 

South and Central Coast marinas. Moderately high levels of copper were detected in several 

San Francisco Bay Area marinas. The mean copper concentrations for salt water, brackish, and 

fresh water marinas were 5.0, 3.1, and 2.0 μg/L, respectively. Copper levels were consistently 

higher in marina samples than in background samples. 

In salt and brackish water areas, copper concentrations in 15 of 17 marinas exceeded the chronic 

CTR standard of 3.1 μg/L. Copper concentrations in 10 of these 15 marinas also exceeded the 

acute CTR standard of 4.8 μg/L. CTR standards for fresh water were never exceeded in any of 

the six fresh water marinas. This is likely a result of lower AFP use in fresh water areas and 

higher fresh water CTR standards. Very few background samples, regardless of water type, 

exceeded CTR standards. 

The highest copper level documented in the study was detected in two samples from Marina del 

Rey. Both samples contained 18.4 μg/L of total dissolved copper. Samples from Marina del Rey 

front and basins exhibited the highest levels of total dissolved copper in the study. The total 

dissolved copper averages for Marina del Rey front and back basins were 12.7 and 13.9 μg/L, 

respectively. 

Eight of the 47 water samples were toxic to mussel embryo development bioassays. Seven of 

these eight toxic samples were collected from Marina del Rey. A toxicant identification 

evaluation determined that a trace metal (most likely copper) was the likely cause of toxicity. 

The study report has previously been sent to U.S. EPA for consideration under the federal 

reregistration for copper oxide. However, DPR will resubmit the document under Registration 

Review in hope that it will be of use in the impending risk assessment. The report is quite 

detailed and contains a significant amount of information that will be relevant to U.S. EPA 

including extensive monitoring data, toxicity results, and copper bioavailability results based on 

the BLM for both fresh and salt water systems. 

Lower Newport Bay Metals Study – In September 2006, the Santa Ana RWQCB conducted a 

monitoring study (in collaboration with DPR) for metals in Lower Newport Bay (SARWQCB 

2007). The study indicated that the majority of the 72 Lower Newport Bay samples from boat 

mooring areas (marinas, yacht basins, and boat anchorages) exceeded the chronic salt water CTR 

standard. Some of these samples also exceeded the acute salt water CTR standard. 

Toxicity was not observed in mussel embryo development tests. Although several sediment 

samples were toxic to the amphipod Eohaustorius estuarius, a combination of metals and organic 

chemicals (possibly pyrethroids) was the likely cause of toxicity. 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 9 

South Coast Copper Study – In August 2005, the Southern California Coastal Water Research 

Project collected water samples from 30 marina sites in Dana Point Harbor, Oceanside Harbor, 

Mission Bay, and San Diego Bay (Schiff et al. 2007). Concentration of copper in marina samples 

ranged from below detection to 21.0 μg/L with a mean concentration of 7.0 μg/L. Samples were 

occasionally toxic to the development of mussel embryos. Toxicity identification evaluations 

determined that trace metals (likely copper) were responsible for the majority of the observed 

toxicity. A strong relationship exists between the degree of toxicity and the concentration of 

copper in the samples. 

Shelter Island Yacht Basin Biological Impact Study – In 2006, the California Department of 

Boating and Waterways initiated a study of the benthic community in SIYB to better understand 

the impact of elevated copper levels. Water column sampling results showed that copper 

concentrations regularly exceeded salt water CTR standards. Moreover, a concentration gradient 

exists in the basin with higher dissolved copper concentrations toward the back of the basin and 

lower concentrations toward the entrance. Sediment sampling also showed elevated copper 

concentrations (Neira et al. 2009). A paper that evaluates the benthic community is currently in 

press. 

Department of Pesticide Regulation Copper Antifouling Paint Reevaluation 

In June 2010, DPR initiated a reevaluation for copper AFPs products (those with the active 

ingredient: copper oxide, copper thiocyanate, and copper hydroxide) citing environmental 

contamination in California coastal marinas as the rationale. DPR established a number of data 

requirements from the registrants. The Web site that provides background on this reevaluation 

and the data requirements is at: 

<http://www.cdpr.ca.gov/docs/registration/reevaluation/chemicals/antifoulant_paints.htm>. 

Registrants have been tremendously cooperative so far in working with DPR. At this point, a 

large registrant Task Force has been formed. DPR is, however, in the process of amending data 

requirements. Ultimately, leach rate data, the MAM-PEC exposure model, and the BLM (when 

necessary) will be used as the foundation of our analysis to estimate the dissolved copper 

concentrations in marinas and to help predict the effectiveness of mitigation measures. 

Mitigation Approaches 

There are several nonregulatory mitigation approaches that DPR staff have considered to reduce 

the loading of copper from AFP sources. Researchers and stakeholders are already exploring 

some of these approaches. DPR is involved in two projects that involve the evaluation of various 

alternative AFPs. DPR is also soliciting mitigation ideas from AFP registrants through 

reevaluation. 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 10 

Although all of the options below are promising, they also have technical and implementation 

issues associated with each of them. Further exploration of the issues associated with each option 

needs to be done before they can be successfully implemented on a large scale. 

Improve Underwater Hull Cleaning Techniques – The application of less abrasive techniques on 

hulls and less frequent cleaning events could result in the reduction of copper loading. Before 

large scale implementation can take place, the effectiveness of this management practice needs to 

be demonstrated. 

Use of Non-AFP Control Strategies – Nonchemical solutions to battle hull fouling exist. Boat 

owners could use slip liners to surround their vessel’s hull during nonoperation periods. Boat 

owners could also store their vessels out of the water during nonoperational periods away from 

the fouling environment. These solutions are not practical for larger boats and yachts. 

 

Use of Alternative AFP Pesticide Products – At first glance this may appear to be the simplest 

solution, but there are few substitutes for copper-based biocides. An evaluation of the few 

noncopper AFPs that are currently available shows that they (1) are difficult to find, (2) are 

relatively expensive to purchase and apply, (3) require more frequent cleaning, and (4) do not 

meet the consumer’s level of expectation for efficacy. However, research on more 

environmentally-friendly biocides has increased in the last couple of years. 

Use of Non-Pesticide Coatings – Some alternative coatings (epoxy and silicone-based products) 

are not considered to be pesticide products and therefore do not need to go through federal and 

California pesticide registration processes. Some of these coatings are already available to 

boaters. Although these nonpesticide coatings are generally considered environmentally friendly, 

they share some of the shortcomings of their alternative AFP pesticide analogs. Boaters are less 

comfortable in adopting less-proven products. Commercial application and handling issues also 

exist. 

Reformulation of Copper AFPs – Most copper AFPs employ copper leaching rates that are high 

to help ensure product efficacy. A reformulation to lower the leaching rates (e.g., 40 μg/cm2

/day 

as implemented in Canada) could greatly reduce the amount of copper released through passive 

leaching. However, reformulated products may not be as effective resulting in an increase the 

frequency of underwater hull cleaning. 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 11 

We appreciate the opportunity to comment in this Registration Review. If you have any 

questions, please contact me by phone or e-mail at <nsinghasemanon@cdpr.ca.gov>. 

Sincerely, 

Original signed by 

Nan Singhasemanon 

Staff Environmental Scientist/ 

Management Agency Agreement Coordinator 

Environmental Monitoring Branch 

916-324-4122 

cc: Syed Ali, Ph.D., Management Agency Agreement Coordinator, SWRCB 
Ms. Rebecca von dem Hagen 

December 16, 2010 

Page 12 

References 

Blossom N, Anderson C (2007) Review of SCCWRP Report on Copper Input from In-water 

Hull Cleaning. PowerPoint presentation by Neal Blossom and Colin Anderson to the Copper 

Antifouling Paint Sub-Workgroup of the California NonPoint Source Interagency Coordinating 

Committee’s Marina and Recreational Boating Workgroup. May 17, 2007. 9 pp. 

Neira C, Delgadillo-Hinojosa F, Zirino A, Mendoza G, Levin L, Porrachia M, Deheyn D (2009) 

Spatial distribution of copper in relation to recreational boating in a California 

shallow-water basin. Chemistry and Ecology 25(6):417-433. 

SARWQCB (Regional Water Quality Control Board) (2007). California Environmental Agency. 

Lower Newport Bay copper/metals marina study. Final report. Santa Ana, California. URL: 

<http://www.swrcb.ca.gov/rwqcb8/water_issues/programs/tmdl/docs/newport/finalcufinal_report

.pdf> (accessed: 12/14/10). 

SDRWQCB (San Diego Regional Water Quality Control Board) (2005) Total maximum daily 

load for dissolved copper in Shelter Island Yacht Basin, San Diego Bay. Resolution No. R9-

2005-0019, Basin Plan Amendment and Technical Report. San Diego, California. URL: 

<http://www.waterboards.ca.gov/sandiego/water_issues/programs/watershed/docs/swu/shelter_is

land/techrpt020905.pdf> (accessed: 12/14/2010). 

Schiff K, Brown J, Diehl D, Greenstein D (2007) Extent and magnitude of copper contamination 

in marinas of the San Diego Region, California, USA. Marine Pollution Bulletin 54:322-328. 

Singhasemanon N, Pyatt E, Bacey J (2009) Monitoring for indicators of antifouling paint 

pollution in California marinas. California Environmental Protection Agency, Department of 

Pesticide Regulation, Environmental Monitoring Branch, EH08-05. URL: 

<http://www.cdpr.ca.gov/docs/emon/pubs/ehapreps/eh0805.pdf> (accessed: 12/14/2010).