# 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 PR OTECTION AGENCY REGISTRATION REVIEW FOR COPPERS (DOCK ET IDENTIFICATION NUMBER EPA–HQ–OPP–2010-0212)

Please accept the following comments from th e 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 backgr ound 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 ha ve 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 f act, a number of California stakeholders have submitted extensive comments on these products. Ho wever, the pollution related to copper AFP use is the most pressing copper issue to DPR sin ce we regulate the sale and use of antifouling paints in California and due to the level of c oncern that stakeholders and water quality control agencies have expressed to us. DPR hopes that our input through Registra tion 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, a nd 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 Environmenta l 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 Reregistratio n Eligibility Decision as there were no opportunities to comment once the document wa s released. U.S. EPA chose the commercial harbor scenario for MAM-PEC modeling of copp er oxide antifoulant us e. This is not theMs. 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 environmenta l and use conditions wh en we evaluate new antifoulant active ingredients for California registration. This practice is a result of our observations that high dissolved copper con centrations tend to o ccur in large and poorly-flushed pleasure craft ma rinas along the California Coas t. Note that the default emission settings for the poorly-flushed marina s scenario still require adjustments to better reflect California conditions. For example, so me 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 le ss conservative scenario that U.S. EPA used, the predicted Estimated Envir onmental Concentrations (EEC) were 1.57 μg/L for the average dissolved copper concentra tion and 4.76 μg/L for the maximum dissolved copper

concentration. The maximum EEC value exc eeds the chronic salt water ambient water quality standard for copper (California Toxics Rule standard s 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 pr oximity of the EECs to these standards. If the poorly-flushed marina scenario under Ca lifornia conditions would have been modeled, the resulting EECs would have easily surpassed the acute standards. CT R standards are being vigorously imposed in California by the State’ s water quality regulator y 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 abou t five percent of all

recreational and commercial vessels in th e State’s coastal marinas use noncopper AFPs. Moreover, the leach rate of 50 μg/L/cm 2 /day is not the “highest possible” leach rate. Leach rate estimates submitted to DPR from copper AFP registrants show that environmentally-relevant leach rates (represe nting 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 fact or in these sources in generating EECs. This hull maintenance activity is very common in Calif ornia’s coastal marinas. Moreover, certain water bodies in California have relatively high background copper concen trations that could significantly contribute to a mari na’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 Regist ration Review need to consider all of these points. DPR is willing to assist Agency modelers in fine-t uning MAM-PEC inputs to give a more accurate picture of exposure scenarios.

2. Effect Assessment Endpoints : The current risk-quotient base d determination of harm or endpoints only serves to address Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) based mandates, which imply th at 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 considera tion the protective mandates that are established under the Clean Water Act (CWA). We encourag e that protective endpoints such as the CTR and the Biotic Ligand Model (BLM)-bas ed 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 cl ear whether this approach is be ing considered as part of the Office of Pesticide Programs and Office of Wa ter harmonization efforts that U.S. EPA has been undertaking.

3. DPR Supports the Use of the BLM : DPR has evaluated the scien tific basis of the BLM and we support its use for both fresh and salt wate r 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 mari na environment, we encourage U.S. EPA to finalize the salt water BLM. Note, however, th at a revision of the ambient national water quality criteria for copper does not translate to a revision of th e existing CTR standards in our State. SWRCB and its RWQCBs will need to enga ge in dialogue with U.S. EPA to make an update of the CTR standards for copper possible.

Our evaluation of marina water samples usi ng 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 te st organisms. In other words, the use of copper AFPs, which we believe are the most significant source of c opper 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 Ecologi cal Risk, Environmental Fate, and EndangeredMs. Rebecca von dem Hagen December 16, 2010 Page 4

Species Assessments for Coppers,” there appe ars 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 ar eas, 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 stat us 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 welcom e any near-term guidance from U.S. EPA. We have conducted and coordinated many assessm ent and mitigation rela ted activities. We have also recently initiated our formal reevaluation process on copper AFPs to initiate more

direct discussions with registrants and to gather data th at could be used to address high copper concentrations in our marinas. Th e 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 rela ted 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 orga nisms. 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 ingredient s currently used in AFPs ar e 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 gr oups to initiate a closer in vestigation 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 disso lved copper concentrati ons (to be referred to as copper concentrations in the rest of this document) there exceeded the CTR standards of

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

12.0 μ g/L. The U.S. EPA established these water quali ty 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 th e 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 contri buted 5%. All other sources in SIYB only accounted for 2% of the total copper load (SDRWQ CB 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 pr ecise 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 concentr ations at SIYB also threaten sediment quality and may potentially adversely impact benthi c life. Sediment concentrations of copper at SIYB have been shown to regularly ex ceed sediment quality guidelines developed by the National Oceanic and Atmospheric Admi nistration. However, unlike WQOs and CTR standards, sediment quality guidelines are not enforceable.

The TMDL implementation plan outlined strate gies and management practices available to dischargers and potential regula tory actions available to SDRW QCB. The Port of San Diego, SIYB marinas, boat owners, underw ater hull cleaners, and the City of San Diego are responsible as dischargers to meet this goal. Between 2007 and 2022, the implementation plan requiresMs. Rebecca von dem Hagen December 16, 2010 Page 6

dischargers to demonstrate incremental reductio ns of copper loads. Dischargers must first achieve a 10% reduction in coppe r loading by the end of 2012. By 2022, copper loading must be reduced by 76% from 2005 base le vels. Note that seven more Sa n 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 ha ve 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 suspect ed of being signific ant 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 impl ementation 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 activ e 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 id entify 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 pe rformance, longevity, and cost. The initial phase of the project involved tests of coatings painted on uniformly-si zed 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 wi ll 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 st atewide transition to copper alternatives.

In anticipation of the result of th e “Safer Alternatives Project,” the Port has initiated another U.S. EPA grant-funded project to subsidize the conversion of copper-AFP co ated boat hulls into those using noncopper AFPs. Approximately 200 to 250 recreational boats ar e being targeted for conversion under this project. Long -term tracking of AFP conversi on is also being developed by

the Port.

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

underwater hull cleaners in marinas that it has under its jurisdic tion. The Port maintains that it has the authority under Po rt 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 statew ide strategy in address c opper 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 addre ss this issue on a local scale, many other agencies, industry, academia, and stak eholder groups have been active in addressing the marina copper problem. These groups have colle ctively worked to make early water quality assessment work possible. In recent years, th eir attention has turned toward (1) evaluating environmentally-friendlier alternatives to coppe r AFPs, (2) finding other ways to mitigate the water quality problem, and (3) condu cting 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 to pics 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 Intera gency 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 e nvironmental fate and toxicological effects of copper in aquatic systems, but c opper monitoring data (especially those collected in California) were scarce. In order to fill this data gap, DP R spearheaded a multi-regional monitoring study to assess indicators of AFP pollution. With signi ficant 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 th e environmental impacts of copper AFP use, it also explored AFP-related policy, regulatory, and m itigation 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 fo r AFP-related issues in California. In 2008, the workgroup changed its name to the Antifouling St rategies 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 A FP 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 con centrations in marinas throughout the State (particularly those in salt and brackish water areas) frequently exceed federal water quality sta ndards. 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 μ g/L, respectively. Copper levels were consistently higher in marina samples than in background samples.

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

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

acute CTR standard of 4.8 μ g/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 μ g/L of total dissolved copper. Samples from Marina del Rey front and basins exhibited the highest levels of total dissolved coppe r in the study. The total dissolved copper averages for Marina del Rey front and back basins were 12.7 and 13.9 μ g/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 likel y 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, DP R 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 in formation 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 exceed ed 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 Calif ornia Coastal Water Research Project collected water samples from 30 marina sites in Dana Point Ha rbor, Oceanside Harbor, Mission Bay, and San Diego Bay (Schiff et al. 20 07). Concentration of copper in marina samples ranged from below detection to 21.0 μ g/L with a mean concentration of 7.0 μ g/L. Samples were occasionally toxic to the development of musse l embryos. Toxicity identification evaluations determined that trace metals (likely copper) were responsible for the majority of the observed toxicity. A strong relationship ex ists between the degr ee of toxicity and th e concentration of copper in the samples.

Shelter Island Yacht Basi n 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 c oncentrations toward the back of the basin and

lower concentrations toward the entrance. Se diment sampling also showed elevated copper concentrations (Neira et al. 2009) . A paper that evaluates the be nthic community is currently in

press.

Department of Pesticide Regulation Copper Antifouling Paint Reevaluation

In June 2010, DPR initiated a reevaluation for copper AFPs products (t hose with the active ingredient: copper oxide, coppe r thiocyanate, and copper hydr oxide) citing environmental

contamination in California coas tal 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. DP R is, however, in the process of amending data requirements. Ultimately, leach rate data, th e 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 predic t 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 stake holders are already exploring some of these approaches. DPR is involved in two projects that involve th e evaluation of various alternative AFPs. DPR is also soliciting m itigation 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 ea ch of them. Further exploration of th e issues associated with each option needs to be done before they can be succe ssfully implemented on a large scale.

Improve Underwater Hu ll Cleaning Techniques – The application of less abrasive techniques on hulls and less frequent cleaning events could resu lt in the reduction of copper loading. Before large scale implementation can take place, the eff ectiveness of this management practice needs to

be demonstrated.

Use of Non-AFP Control Strategies – Nonchemical solutions to bat tle hull fouling exist. Boat owners could use slip liners to surround their vessel’s hu ll during nonoperation periods. Boat

owners could also store their ve ssels out of the water during n onoperational 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 subs titutes for copper-based biocides . An evaluation of the few noncopper AFPs that are currently available show s 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 expectati on for efficacy. However, research on more environmentally-friendly biocides has in creased 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 ar e already available to boaters. Although these nonpesticide coatings are ge nerally considered en vironmentally friendly, they share some of the shortcomings of their alternative AFP pesticide analogs. Boaters are less comfortable in adopting less-prov en products. Commercial applica tion 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 reformul ation to lower the leaching rates (e.g., 40 μ g/cm 2 /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 Ag ency Agreement Coordinator, SWRCBMs. Rebecca von dem Hagen December 16, 2010 Page 12

References

Blossom N, Anderson C (2007) Review of S CCWRP 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 Californi a NonPoint Source Interagency Coordinating

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

Neira C, Delgadillo-Hinojosa F, Zirino A, Me ndoza G, Levin L, Porrachia M, Deheyn D (2009) Spatial distribution of coppe r in relation to recreational boating in a California shallow-water basin. Chemistry and Ecology 25(6):417-433.

SARWQCB (Regional Water Qualit y Control Board) (2007). Calif ornia Environmental Agency. Lower Newport Bay copper/metals marina study. Final report. Santa Ana, California. URL:

< http://www.swrcb.ca.gov/rwqcb8/water_issues/pr ograms/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, Gr eenstein D (2007) Extent and magn itude of copper contamination in marinas of the San Diego Region, Califor nia, 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 Envi ronmental Protection Agency, Department of Pesticide Regulation, Environmenta l Monitoring Branch, EH08-05. URL:

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