CALIFORNIA STATE LANDS COMMISSION REPORT ON 

COMMERCIAL VESSEL FOULING IN 

CALIFORNIA: 

ANALYSIS, EVALUATION, AND RECOMMENDATIONS TO REDUCE 

NONINDIGENOUS SPECIES RELEASE FROM THE 

NON-BALLAST WATER VECTOR 

Produced for the 

California State Legislature 

 By 

L. Takata, M. Falkner and S. Gilmore 

California State Lands Commission 

Marine Facilities Division 

April 2006 
EXECUTIVE SUMMARY 

Fouling community organisms attach or associate with submerged portions of 

structures. When associated with mobile structures such as vessels, nonindigenous 

fouling organisms can be moved from port to port and region to region, presenting the 

potential for a new invasion. Fouling has thus been considered an important 

mechanism for the introduction of nonindigenous species (NIS) in the marine and 

estuarine environments. 

The Marine Invasive Species Act of 2003 (Act) directs the California State Lands 

Commission (Commission) to analyze and evaluate the risk of nonindigenous species 

release from commercial vessel mechanisms other than ballast water (essentially 

vessel fouling), in consultation with a Technical Advisory Group (TAG). This report 

summarizes the analysis, evaluation, and consultations conducted by the Commission 

in accordance with the Act, and offers recommendations to reduce the discharge of NIS 

from vessel fouling. 

Considerations of the Commission and the TAG included the hull husbandry practices 

of the commercial vessel fleet, environmental conditions and vessel behaviors that 

influence fouling, and the fouling management frameworks that have been adopted or 

considered by other regions. The most difficult challenge for evaluating the risk of 

fouling for species introductions to the state was the limited amount of baseline 

information on vessel fouling and NIS across the types of vessels that regularly operate 

in California. A small minority of vessels or platforms that travel at very slow speeds, 

spend extended periods immobile, and rarely clean or paint hulls could be presumed to 

pose an elevated NIS risk. However, there was little information on the potential posed 

by a majority of the fleet that conducts regular vessel maintenance, spends relatively 

little time in port, and travels at normal speeds. There was also little information on how 

well the current hull maintenance practices of the majority of the fleet limit the transport 

and release of NIS. 

i
The Commission believes, however, that these difficulties should not prevent California 

from moving forward with actions at this time. Some actions can be implemented 

immediately based on available knowledge, and others may be implemented to build 

the information and tools to refine management in the future. The Commission 

therefore recommends that legislation be adopted to: 

1. Broaden the State program to include the control and prevention of NIS via 

commercial vessel fouling. Current legislation authorizes the Commission to 

adopt regulations to prevent NIS introduction only through ballast water. The 

authorization should be expanded to include vessel fouling. 

2. Broaden the reporting requirements to include mandatory reporting on 

maintenance practices and other anti-fouling related behaviors of 

qualifying vessels operating in California waters. Information on those 

factors that tend to exacerbate fouling, coupled with biological surveys of fouling 

on those vessels, will supply data needed to better characterize the fouling NIS 

risk for California. 

3. Expand enforcement components of the Act to address mandatory 

reporting in Recommendation 2. In order for the information collected in 

Recommendation 2 to yield meaningful results, a high proportion of reports must 

be submitted. Programs with unenforced reporting requirements experience low 

reporting rates, making any representative analysis impossible. 

4. Authorize the Commission to develop and adopt regulations that prevent or 

minimize the introduction of NIS via vessel fouling. Regulations to define 

regular vessel maintenance practices for the control of NIS fouling on commercial 

vessels, and requirements or restrictions for vessels that do not adhere to 

defined practices are needed. 

5. Expand and coordinate biological research directed towards characterizing 

the NIS risk posed by commercial vessel fouling with other Federal and 

State agencies. Baseline information on fouling and NIS that arrive on 

ii
commercial vessels will be critical for the formulation of future management 

actions. 

6. Support continued long-term NIS monitoring in California waters. Longterm biological monitoring is necessary to evaluate the effectiveness of 

management efforts to prevent NIS introductions; particularly as new 

management actions are implemented. 

7. Support research promoting technology development. A technology that 

can collect and contain in-water cleaning debris would be a desirable tool to 

prevent NIS release during in-water cleaning, while also providing commercial 

operators an avenue to clean hulls without placing a vessel in dry dock. 

Additionally, the advancement of antifouling coatings that are effective for 

preventing fouling accumulation and cause little or no water quality impact, will 

be critical for NIS prevention as regions implement bans on biocidal paints.

8. Direct the State and Regional Water Quality Control Boards, in cooperation 

with the U. S. Environmental Protection Agency, to evaluate the effects of 

biocidal antifouling coatings from vessels on water quality. As authorized 

by the Clean Water Act, the State and Regional Water Quality Control Boards 

should conduct a full review to determine if biocidal antifouling coatings 

contribute to water quality impairments or to the exceedance of water quality 

criteria in California. Water quality plans and/or Total Maximum Daily Loads 

should be adopted or amended accordingly.

9. Expand the existing Marine Invasive Species Program’s outreach and 

education program to include the fouling vector. Nonindigenous species 

transport and introduction through vessel fouling is a relatively new issue, and 

there is little to no awareness of its importance amongst key stakeholder groups. 

iii
10. Direct an appropriate agency to address the risk of fouling NIS 

introduction and spread in California through vessels under 300 gross 

registered tons. Any vessel or structure of any size may accumulate fouling 

and may be important mechanisms for the transport of NIS. The release and 

transfer of NIS through vessel types not included in the Act, including 

recreational and fishing vessels, should be examined by the agency(ies) with the 

appropriate authority, and recommendations to reduce NIS introductions from 

these mechanisms should be provided to the Legislature. 

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ABBREVIATIONS AND TERMS 

Act Marine Invasive Species Act (Also Assembly Bill 433 of 2003) 

ANZECC Australian and New Zealand Environment Conservation Council 

CA California 

CDFG California Department of Fish and Game 

CFR Code of Federal Regulations 

Commission California State Lands Commission 

IACS International Association of Classification Societies 

IMO International Maritime Organization 

KT Knot 

KTS Knots 

LCR Lower Columbia River 

m Meters 

MPH Miles per hour 

NIS Nonindigenous species 

PRC Public Resource Code 

Staff Staff of the California State Lands Commission 

TAG Technical Advisory Group 

TBT Tributyltin 

WSA Wetted Surface Area 

v
TABLE OF CONTENTS 

EXECUTIVE SUMMARY.............................................................................. i 

ABBREVIATIONS AND TERMS.................................................................... v 

I. PURPOSE........................................................................................ 1 

II. INTRODUCTION: NONINDIGENOUS SPECIES AND VESSEL FOULING... 1 

III. TECHNICAL ADVISORY GROUP PROCESS.......................................... 5 

IV. MERCHANT FLEET EFFORTS TO KEEP VESSELS CLEAN.......................... 9 

V. REVIEW OF CURRENT KNOWLEDGE ON VESSEL FOULING AND NIS..... 12

VI. EXISTING FRAMEWORKS FOR THE MANAGEMENT OF VESSEL 

FOULING.......................................................................................... 23

VII. CONCLUSIONS AND RECOMMENDATIONS.......................................... 31

VIII. LITERATURE CITED........................................................................... 41

IX. APPENDICIES................................................................................... 46

APPENDIX A: HULL-BORNE INVASIVE SPECIES WORKSHOP 

LIST OF ATTENDEES 47

APPENDIX B: CALIFORNIA STATE LANDS COMMISSION 

TECHNICAL ADVISORY GROUP PARTICIPANTS 50

APPENDIX C: SUMMARY OF THE HULL-BORNE INVASIVE 

SPECIES WORKSHOP (MAY 11, 2006) 53

APPENDIX D: SUMMARY OF THE CALIFORNIA STATE LANDS 

COMMISSION TECHNICAL ADVISORY GROUP MEETING 

(AUGUST 3, 2005) 60

APPENDIX E: SUMMARY OF THE CALIFORNIA STATE LANDS 

COMMISSION TECHNICAL ADVISORY GROUP MEETING 

(OCTOBER 13, 2005) 65

APPENDIX F: SUMMARY OF THE CALIFORNIA STATE LANDS 

COMMISSION TECHNICAL ADVISORY GROUP MEETING 

(DECEMBER 19, 2005) 71

X. ACKNOWLEDGEMENTS...................................................................... 76 

vi
I. PURPOSE 

This report was prepared for the California Legislature pursuant to the Marine Invasive 

Species Act of 2003 (Act), codified as California Public Resources Code (PRC) 

Sections 71203-71210.5. The Act enhanced and reauthorized the original law, the 

Ballast Water Management and Control for Nonindigenous Species Act of 1999. In 

accordance with the Act, the California State Lands Commission (Commission) was 

charged with preparing an analysis of vectors (i.e., mechanism or pathway) other than 

ballast water, and relative risks of those vectors, for the introduction of nonindigenous 

species (NIS) from commercial vessels (Section 71210.5 of the PRC). Per the law, the 

analysis shall include the release of NIS from vessel hulls, sea chests (recessed boxes 

where water may be pumped aboard for engine cooling or for ballast), sea suction grids 

(grates that cover water intakes), other hull apertures, in-water propellers, chains, 

anchors, piping, and tanks, and shall be conducted in consultation with a Technical 

Advisory Group (TAG). This report summarizes the results of this analysis and offers 

recommendations to reduce the discharge of NIS from vessel vectors other than ballast 

water. 

II. INTRODUCTION: NONINDIGENOUS SPECIES AND VESSEL FOULING 

Also known as “introduced”, “invasive”, “exotic”, “alien”, or “aquatic nuisance species”, 

NIS in marine, estuarine and freshwater environments may be transported to new 

regions through numerous human activities. Intentional and unintentional releases of 

fish and shellfish, aquaculture escapes, releases from the aquarium and pet industries, 

floating marine debris, bait shipping, and accidental release by research institutions are 

some of the mechanisms, or “vectors”, by which organisms are transferred (U.S. 

Commission on Ocean Policy, 2004). However, in coastal environments, commercial 

shipping is the most important vector for the introduction of NIS (Ruiz et al., 2000; 

Hewitt et al., 2004) in one study accounting for one half to three-quarters of NIS 

introductions to North America (Fofonoff et al., 2003). 

1
Once established, NIS can have severe ecological, economic and human health 

impacts to the receiving environment. Pimental et al. (2005) estimated approximately 

$120 billion worth of losses annually in the United States due to NIS. The most 

infamous NIS example is the zebra mussel (Dreissena polymorpha) introduced to the 

Great Lakes from the Black Sea. They attach to hard surfaces in dense populations 

that clog intakes of municipal water systems and electric generating plants, resulting in 

costs of approximately a billion dollars a year (Pimentel et al., 2005). The Asian clam 

(Potamocorbula amurensis) spread throughout the San Francisco Bay and its tributaries 

two years after its introduction, and accounts for up to 95% of living biomass in some 

shallow portions of the bay floor (Nichols et al., 1990). 

Attempts to eradicate NIS after they have become widely distributed are typically 

unsuccessful and costly (Carlton, 2001; McEnnulty et al., 2001; Meyerson and Reaser, 

2002). Control is likewise extremely expensive. Prevention is therefore considered the 

most desirable way to address the issue. For managers, policy makers, and 

researchers dedicated to the prevention of marine and estuarine NIS introductions, 

ballast water has been the major focus during the last decade. However, vessel fouling, 

which is a less understood mechanism, has been gaining attention as another important 

vehicle for introductions. 

Fouling organisms attach to submerged hard surfaces of both naturally occurring and 

man-made structures (Railkin, 2004). Fouling organisms such as mussels, seaweed, 

anemones, and sea squirts have been found on pier pilings, tide pool rocks, and oil 

platforms (Figure II.1). Barnacles, other seaweeds, and the plant-like limbs of 

bryozoans may be attached to mussel shells. Mobile organisms such as shrimp, 

worms, and sea snails may be tucked in nooks created by the larger animals. These 

associated mobile organisms are also part of this “fouling community”. 

2
Figure II.1: Mussel and Algae 

Fouling on a Vessel Propeller. 

Mariners have long been aware of fouling as a nuisance to vessel operations as it 

relates to vessel performance, fuel efficiency, and antifouling efficiencies. Fouling on 

the hull can create drag, increasing fuel consumption and potentially causing engine 

strain. In pipes, fouling can block inflowing seawater meant to cool machinery. To 

prevent such problems, vessel operators periodically clean underwater vessel parts, 

and utilize antifouling paints and antifouling systems. 

Though much of the outer surface of vessel hulls are treated with paints designed to 

discourage fouling growth, certain locations have been found to be more prone to 

fouling: dry docking support strips, waterlines, propellers, rudders, sea chests, and worn 

or unpainted areas (Coutts et al., 2003; Minchin and Gollasch, 2003; Coutts and Taylor, 

2004; Ruiz et al., 2005) (See Section V, “Review of Current Knowledge on Vessel 

Fouling and Nonindigenous Species”). 

Despite efforts by the maritime industry to minimize vessel fouling, recent studies 

indicate that fouling is still an important mechanism by which nonindigenous organisms 

can be transported to new regions. Vessels that move at slow speeds, spend long 

periods in port, or are repainted infrequently, tend to accumulate more fouling (e.g. 

Coutts, 1999). Unlike the laminar areas of the hull that experience strong water motion, 

sheltered recesses of vessels appear to be more hospitable for fouling organisms. 

3
Thus, studies have documented extensive fouling communities on towed vessels, in sea 

chests, and on recreational vessels. In Hawaii, fouling is believed to be responsible for 

more successful marine introductions than any other mechanism (Eldredge and Carlton, 

2002). For North America, one study estimated that at least 36% invertebrates and 

algae introduced through the shipping vector arrived via fouling (Fofonoff et al., 2003). 

In addition, the nature of fouling observed on vessels may change as restrictions on 

biocidal antifouling paints are adopted. Biocidal antifouling coatings deter the 

attachment of fouling organisms by leaching toxic compounds, such as those that 

contain tributyltin (TBT), copper, and zinc. Because these compounds are also 

detrimental to non-target organisms, many regions have adopted or are considering 

restrictions on their use. Tributyltin (TBT) is a highly effective antifouling agent that has 

been restricted by many nations in line with the 2001 International Maritime 

Organization (IMO) Convention on the Control of Antifouling Systems on Ships. Most 

non-TBT coatings available utilize copper compounds as biocides, though they are 

generally less effective and their longevity is shorter than TBT (Lewis, 2002). In 

addition, bans and restrictions on copper-based paints are being considered in a 

number of places, including the San Diego region. Biocide-free silicon-based coatings 

are available, but are more costly to apply and are currently only practically effective for 

active, swift vessels (those that cruise over 15 knots [KTS]) (Lewis, 2002; International 

Marine Coatings, 2006). As new coatings are developed and vessels shift to different 

antifouling coatings with potentially lower efficacies, there are concerns that the risk 

posed by fouling as a transport mechanism for NIS may increase (Nerhing, 2001). 

Since 2000, the Commission has administered California’s ballast water management 

program. In 2003, the Act expanded these responsibilities, directing the agency to 

formulate recommendations to prevent introductions through non-ballast, commercial 

vessel vectors – essentially vessel fouling. As required by the legislation (PRC Section 

71210.5), Commission Staff (Staff) assembled a Technical Advisory Group (TAG) 

composed of representatives from state and federal resource agencies, the commercial 

shipping industry, and the scientific research community. 

4
III. TECHNICAL ADVISORY GROUP PROCESS 

The Act (PRC Section 71210.5) requires Staff to consult with a TAG to prepare an 

analysis of non-ballast commercial vessel vectors for NIS introductions. Staff convened 

and facilitated a multidisciplinary TAG made up of representatives from the shipping 

industry (Chevron Shipping Company LLC, Pacific Merchant Shipping Association, 

Matson Navigation), academia (Portland State University, University of California at 

Davis), research institutes (Cawthron Institute, Smithsonian Environmental Research

Center, San Francisco Estuary Project), government agencies (California State Water 

Resources Control Board, U.S. Fish and Wildlife Service), and other interested parties 

(See Appendix B for a list of Commission TAG participants). Input was received during 

facilitated meetings that began with a collaborative workshop, followed by three TAG 

meetings. Discussions and areas of agreement were then considered by Staff to help 

guide recommendations put forward in this report. 

Discussions began in May 2005 with a cross interest one-day workshop co-sponsored 

and conducted by the Staff and the California Sea Grant Extension Program. The 

workshop objective was to share information and evaluate hull borne transport of 

invasive species for both the commercial maritime industry and recreational boating 

community. Attendees included scientists, and representatives from California ports 

and harbors, state and federal Agencies, environmental organizations, universities, hull 

coating companies, the commercial maritime industry, and the recreational boating 

community (See Appendix A for a list of workshop participants). 

The workshop began with informational presentations from several experts on fouling 

issues to inform attendees prior to their participation in afternoon break-out discussions. 

Speakers included vessel coating and maintenance professionals, a legal expert from 

the Sea Grant Law Center, and scientific experts from Hawaii, New Zealand, and the 

Smithsonian Environmental Research Center (See Appendix C for a workshop 

summary). Topics presented included: 

5
• Overviews of hull borne aquatic invasive species in North America, Hawaii and 

New Zealand 

• Management strategies that have been adopted or considered for fouling NIS in 

New Zealand and Hawaii 

• Information on how various antifouling coatings prevent fouling growth, and the 

water quality problems presented by some coatings 

• Hull husbandry practices of commercial vessels 

• International, federal and state policies related to vessel fouling and antifouling 

coatings 

Speakers participated in a panel-style question and answer session following the formal 

presentations. During the afternoon session, attendees were placed into break-out 

groups and asked to provide input on potential management considerations. These 

group sessions identified data gaps and outreach needs related to vessel fouling and 

NIS. 

Three additional TAG meetings were convened by Staff between August and December 

of 2005, which focused on commercial vessel fouling. These meetings included 

representatives from the shipping industry, scientists, government agencies, and other 

interested parties (See Appendix B for a list of Commission TAG participants). 

The objective of the August TAG meeting was to continue information sharing begun 

during the May workshop, but focused exclusively on commercial vessels. TAG 

members discussed the definition of “Non-ballast vessel-based vectors,” as stated in the 

Act. Further discussions addressed how environmental characteristics, and vessel 

behaviors and maintenance practices may influence vessel fouling (See Appendix D for 

summary of August TAG meeting). 

The October and December TAG meetings focused on the development of potential 

management frameworks to prevent NIS introductions via vessel fouling. During the 

October meeting, the TAG reviewed fouling management frameworks of other regions 

6
including codes of practice, regulations, informational surveys, and risk assessment 

techniques, and began to discuss their potential for application in California. The TAG 

additionally began discussing and prioritizing information and research needs (See 

Appendices E and F for meeting summaries). 

At the final meeting in December, the TAG considered the pros and cons of hypothetical 

management options that ranged from industry education and outreach to potential 

regulations. This final meeting culminated in an informal list of areas where more 

information would be beneficial for the development of future management actions (See 

Figure III.1). 

TAG Meeting Framework TAG Meeting Framework

Information Sharing Information Sharing

Workshop

May 11, 2005

Meeting #2

August 3

Meeting #3

October 13

Meeting #4 

December 19

Discussion:

focus on 

commercial 

vessels

Fouling risk 

factors

Commercial 

vessel 

maintenance

frameworks

Initial 

information

sharing 

inclusive 

of recreational 

fouling

Preliminary 

scoping of

potential

management

frameworks

Potential

Management 

Frameworks for

CA: Research?

Regulations?

Best Management 

Practices?

Potential

Management 

Framework

Areas of Agreement

Recommendation Development Recommendation Development

Figure III.1: Overview of major discussion areas and timing during Vessel Fouling Technical 

Advisory Group meetings.

Staff compiled and organized meeting notes to assist in the analysis of non-ballast 

commercial vessel vectors (See Appendices C-F for meeting summaries). The 

7
following list summarizes the major points that emerged during TAG discussions, and 

that framed the development of priority information gaps and action items. (These items 

are listed in the next portion of this section): 

• Vessel fouling poses an NIS risk that needs to be addressed. 

• Much of the merchant fleet is well maintained, and likely poses lower risk. 

• There is generalized knowledge on factors that facilitate fouling accumulation on 

vessels. 

• The extent of fouling risk in North America is unclear. There has been limited 

modern research conducted primarily in other regions, and it may be difficult to 

apply this data directly to California. 

• Dry dock facilities are in high demand and booked well in advance. There is little 

flexibility for unplanned dry docking events for the purposes of out-of-water hull 

cleaning. 

• Biocidal antifouling paints pose water quality concerns. 

 

As a result of the considerations listed above, several items were identified during the 

TAG process that members believed deserved priority attention. These are listed 

below and discussed further in focused sections of this report: 

• Compile additional data and research to develop a comprehensive and effective 

framework to prevent NIS introductions via vessel fouling in California. Specific 

data and research needs identified by the TAG were: 

3⁄4 How the periodicity and type of commercial vessel maintenance relates to 

the accumulation and composition of fouling communities (e.g. dry dock 

vs. in-water cleaning frequency, type of antifouling paint). 

3⁄4 The quantity of fouling and characterization of species found on vessels 

that call to California. 

3⁄4 Specific conditions that constitute a high risk vessel (e.g. vessel speed, 

husbandry, route, sedentary time, etc...). 

• Develop protocols that may be used to flag a high risk vessel arrival to California. 

8
• Develop response measures to prevent NIS release. 

• Develop technologies that contain and collect fouling effluent during in-water 

cleaning. 

• Develop standardized data collection protocols and procedures for diver or ROV 

surveys. 

• Increase outreach and education regarding vessel fouling as a vector for NIS 

introductions. 

Areas of agreement from the collaborative workshop and TAG meetings provided 

valuable multi-disciplinary input to Staff during its evaluation of vessel fouling. TAG 

discussions confirmed that many questions remain regarding vessel fouling as an NIS 

vector, although discussions did offer some guidance for where future efforts should be 

focused. The information and suggestions provided by the TAG were considered and 

incorporated into this report by Staff. 

IV. MERCHANT FLEET EFFORTS TO KEEP VESSELS CLEAN 

Vessels travel faster through water when their hulls are clean and smooth, free from 

fouling organisms such as barnacles, algae, or mollusks. Fouling control is important to 

protect the hull from corrosion, reduce drag, and save fuel. Vessel owners and 

operators have long understood these relationships, utilizing various mechanisms to 

prevent or reduce fouling, including regular dry docking where hulls are mechanically 

cleaned and antifouling compounds are applied, and periodic in-water hull cleaning. 

Antifouling compounds such as lime, arsenic, mercury, and pesticides (e.g. DDT) were 

used to coat vessel hulls prior to the 1960’s (IMO, 2002). Unfortunately, frequent 

reapplication of these compounds was necessary, increasing operating costs, and 

arsenic and DDT have since been shown to have significant negative impacts on the 

environment. In the 1960’s, the chemical industry developed biologically effective and 

cost-efficient organotin-based antifouling paints (e.g. tributyltin), that were believed to be 

less harmful than the biocides used at the time. These antifouling paints were designed 

9
to slowly release biocide, allowing vessels to go for as long as five years before 

reapplication. 

By the mid-1970’s, most oceangoing vessels had tributyltin (TBT)-based antifouling 

paints applied to their hulls. Tributyltin was found to be highly effective at keeping the 

hull smooth and clean, however, subsequent studies have shown TBT to have 

significant environmental impacts. Tributyltin and other organotin compounds leach into 

the water, persist in waters and sediments, and contaminate a range of non-target 

aquatic organisms. Tributyltin causes shell deformation in sea oysters, reduces 

resistance to infection in fish, is absorbed throughout the food chain, and has been 

found to be highly toxic to humans. As a result, several countries imposed rules to limit 

the use of TBT in antifouling paints. In 1999, the IMO adopted Resolution A.895 (21) 

“Antifouling Systems Used on Ships”. The Resolution prohibited the application of 

organotin compounds on ships after January 2003 with a complete prohibition by 

January 2008. With the impending TBT-ban, paint manufactures have been developing 

TBT-free antifouling and fouling-release (non-biocidal) coatings. Many vessels currently 

utilize coatings with copper or zinc as the active biocide in place of TBT. Some use 

slippery silicon-based coatings which contain no biocides but make it difficult for 

organisms to adhere, or remain attached to the vessel. 

The application of antifouling compounds is generally conducted in conjunction with 

regularly scheduled hull maintenance operations required by classification societies, 

though hull coating and cleaning is not explicitly required. Classification societies, such 

as American Bureau of Shipping, Det Norske Veritas, and Lloyd’s Register, are 

organizations that establish and apply technical standards related to the design, 

construction, and survey of vessels. The majority of vessels are built and surveyed 

based on classification society standards, which are published as rules. Ninety four 

percent of all commercial vessels operating in international trade belong to one of 

several societies that are part of the International Association of Classification Societies 

(IACS) (IACS, 2004). 

10
Vessels built in accordance with IACS rules are assigned a class designation and are 

subject to regular surveys to ensure that ships remain in compliance with those rules. 

Classification society rules include requirements for periodic hull surveys. While these 

rules are directed at ensuring safety and structural integrity rather than NIS prevention, 

they incidentally serve to control vessel fouling to a certain degree. The frequency that 

most vessels routinely clean hulls and reapply antifouling paints is associated with the 

hull maintenance rules of their classification. In general, each classed vessel is subject 

to a specified program of periodic surveys. These specific programs are based on a 

five-year cycle that consists of annual surveys (in-water), intermediate surveys (in-water 

or dry dock), and class renewal special surveys (dry dock) that take place every fifth 

year. As a vessel ages, the rigor of each survey increases. For example, older vessels 

generally require more frequent out-of-water surveys and some vessels operating in 

certain areas, such as Alaska’s Prince William Sound, are subject to more frequent 

inspections (see Appendix D). Additionally, an incident that may have compromised the 

integrity of the hull (e.g. collision, grounding or allision) generally requires an out of 

water dry dock survey. 

Vessels generally dry dock only as frequently as needed or required because dry 

docking facilities are limited, making scheduling difficult and costly. While reapplication 

of antifouling compounds is normally not required by societies, vessel owners 

commonly take advantage of required dry dockings and elect to clean and reapply 

antifouling compounds at the same time. Because fouling continues to accumulate 

between required dry dockings and can reduce fuel efficiency, most companies also 

conduct interim in-water cleanings. These are conducted as needed, according to the 

results of frequent fuel consumption and speed performance tests (see Appendix E). 

Most commercial vessel owners operating in California waters conduct regular hull 

maintenance for structural and economic reasons, not for NIS prevention. Therefore, 

while we may speculate that frequently dry docked and cleaned vessels pose “less” risk 

than those that are not maintained according to classification society rules, there is still 

11
a great deal of information needed on how much NIS prevention is achieved through 

adherence to these practices. 

V. REVIEW OF CURRENT KNOWLEDGE ON VESSEL FOULING AND NIS 

Staff and TAG members reviewed existing scientific information in order to evaluate the 

risk posed by commercial vessel fouling for NIS introductions in California, and to 

provide informed considerations for potential management recommendations. 

Information examined included peer reviewed and gray literature studies and 

discussions with scientists on the TAG with research expertise on NIS and commercial 

vessel fouling. Unfortunately, little research has been conducted on vessel fouling and 

its role as an NIS transport mechanism, particularly for North America. In the U.S., one 

limited study was conducted in the Port of Oakland, two are underway for the Pacific 

Coast, and a handful of studies have been completed in the Hawaiian Islands. The 

majority of research consists of smaller studies conducted on a combination of 

commercial and recreational vessels in Australia and New Zealand. In light of the 

limited amount of information, the TAG and the Commission examined generalized 

factors that affect fouling accumulation on vessels, the relative risk posed by vessels 

exhibiting those factors, and how factors may or may not apply to merchant traffic in 

California. Emphasis was placed on topics that could guide the development of shipbased management strategies that may help prevent NIS introductions via vessel 

fouling to the State. 

Vessel Movement and Maintenance Effects on Fouling 

Certain vessel movement patterns and maintenance practices have been observed to 

affect the diversity (variety of species) and quantity of fouling observed on commercial 

vessels. These factors influence the ability of free swimming or floating organisms to 

attach to a vessel, the ability of fouling organisms to remain affixed, or affect the ability 

of the organism to survive voyages. 

Immobile Periods: The amount of time a vessel spends in port or at anchor has a 

notable influence on fouling. Many floating or free swimming organisms are better able 

12
to attach or “settle” on surfaces while vessels are immobile, and vessels that spend long 

stationary periods have been observed to have heavier fouling communities (Skerman, 

1960; Rainer, 1995; Coutts, 1999). One study also indicated that fouling accumulates 

more quickly and more heavily in enclosed basins (e.g. marinas) likely because water 

and organisms are flushed out less frequently in comparison to inshore coastal areas 

(Floerl and Inglis, 2003). 

Vessel Speed: Vessel speed influences the quantity and diversity of fouling species 

observed on vessels. At high speeds, many organisms are unable to remain attached 

to vessels, or are less able to endure forceful water moving past the surface. Less 

robust organisms may be dislodged or may be unable to survive. Slow speeds are less 

stressful, allowing many fouling organisms to remain attached or continue settling on 

the vessel surface (Foster and Willan, 1979; Carlton and Hodder, 1995). Thus, slower 

moving vessels have been observed to accumulate thicker fouling than do faster 

vessels that travel over 18-20 KTS (Michin and Gollasch, 2003; Coutts and Taylor, 

2004). 

Voyage Duration: Shorter voyages have been observed to be more advantageous for 

the survival of fouling communities than longer voyages. The prolonged exposure to 

harsh physical conditions of the open ocean during a long voyage may be detrimental to 

fouling organisms, or they may be deprived of food for an untenable length of time 

(Coutts, 1999). 

Age of Antifouling Paint: As discussed in Section IV, “Merchant Fleet Efforts to Keep 

Vessels Clean”, commercial vessels regularly utilize antifouling coatings to discourage 

hull growth that can create drag. The majority of coatings in use today function by 

slowly releasing biocidal toxic agents (e.g. copper or zinc compounds) that kill fouling 

organisms or affect their ability to attach to the treated surface. The age of antifouling 

paint is strongly related to the diversity and amount of fouling organisms on both 

commercial vessels and recreational boats (Coutts, 1999; Floerl and Inglis, 2005). 

Older coatings have been observed to be less effective, presumably because the 

activity of the biocidal toxins decreases with time. 

13
In-water cleaning: In addition to periodic application of antifouling paints, vessel 

operators and owners may also have fouling growth removed through scrubbing while 

the vessel remains in the water, in between paint applications. While in-water cleaning 

is effective for removing fouling organisms in the short term, research on recreational 

vessels suggests that it may increase the amount of fouling in the long term. It is 

suspected that this may occur because the mechanical removal of fouling leaves traces 

of scraped organisms, including shell or tissue (Floerl, 2005; Floerl et al., 2005). For 

some fouling species, these remnants act as a signal for unattached fouling organisms 

in the water column to settle (Railkin, 2004). Additionally, in-water cleaning can 

dislodge viable organisms at a destination port which may facilitate introductions of NIS 

(see discussion in this section, “Transfer from Vessel to Port”). 

Environmental Factors that Influence Fouling – Salinity and Temperature 

As vessels transit from one port to another, they typically pass through changing salinity 

and temperature conditions, and these factors are believed to be important 

determinants of the survival of fouling organisms. While some organisms are able to 

survive a wide range of environmental conditions, many are not. Dramatic or rapid 

changes in either salinity or temperature are stressful for many organisms. In one case, 

this attribute was utilized to treat a heavily fouled vessel that had been moored for five 

years at a high salinity location (33-35 parts per thousand) in Washington State. 

Freshwater immersion resulted in approximately 90% removal of the original fouling 

growth (Brock et al., 1999). Organism intolerance to wide salinity and temperature 

fluctuations may also partially explain why higher levels of fouling are observed on 

vessels traveling on short voyages at similar latitudes where salinity and temperature 

levels tend to be more consistent (Coutts and Taylor, 2004). 

In addition to voyage route, temperature and salinity also vary depending on other 

interacting variables. Season, amount of precipitation, and depth of a vessel’s 

submerged surfaces are some of the major components that influence both temperature 

and salinity levels in any given location, and thus may affect vessel fouling. 

14
Location on a Vessel 

Fouling is not uniformly distributed on submerged portions of vessels. Some areas are 

particularly prone to fouling even on vessels with behaviors not generally conducive to 

fouling (e.g. travel at high speeds, spend little time in port). Areas sheltered from strong 

water forces, where antifouling coatings are less frequently renewed, or where 

antifouling systems may be irregularly utilized tend to exhibit higher levels of fouling 

(Coutts and Taylor, 2004). The Act specifically directs that the Commission include an 

analysis of specific vessel components. These “...shall include but not be limited 

to...hulls, sea chests, sea suction grids, other hull apertures, in-water propellers, chains, 

anchors, piping and tanks,” (Public Resources Code (PRC) Section 71210.5). The 

TAG and Staff therefore considered and prioritized the relative fouling risk associated 

with specific vessel areas. 

Areas on a vessel that are shielded from strong water flow have been noted to foul even 

in cases where main portions of the hull are clean. Studies have noted higher numbers 

and/or diversity of fouling organisms in sheltered areas and in crevices around rudders 

or propellers, intake pipes, gratings, and bow thrusters (Figure V.1) (Ranier, 1995; 

Coutts and Taylor, 2004). In particular, recent research has documented extensive 

fouling communities in the sea chests of some vessels (Dodgson and Coutts, 2002, 

Figure V.1: Intake opening on a 

vessel hull. 

Note that fouling is visible, though 

surrounding exposed areas are 

clean. 

15
Coutts et al., 2003). Larger mobile organisms, such as crabs, snails, and shrimp have 

been found in sea chests, in addition to immobile, attached fouling organisms. 

For vessels that are well maintained (cleaned and painted frequently) lowest risk areas 

are portions that are exposed to strong water movement such as the main hull, and 

areas of the rudder exposed to the intense flows generated by the propeller. There was 

no information available regarding fouling of propellers and anchors, which were 

explicitly listed in the Act. 

As noted earlier in this section, older antifouling coatings appear to be less effective at 

preventing fouling accumulation. Portions of a vessel that are coated less frequently 

may thus pose a higher risk, even if they are subjected to strong water motion. Studies 

in Tasmania and New Zealand have found high diversities of organisms on localized 

parts of the hull where support blocks prevented cleaning and/or painting during the 

most recent dry dock service (Coutts, 1999; Coutts and Taylor, 2004). These “dry dock 

support blocks” are placed at intervals under the length of the hull to suspend a vessel 

when it is brought into dry dock for repairs, maintenance, cleaning, or painting (Figure 

V.2). Though many dry dock operations alternate the location of the blocks so hull 

Figure V. 2: Vessel on dry 

dock blocks. The rectangular 

blocks suspend the vessel for 

maintenance, repair, and paint 

re-application. 

16
areas beneath them are serviced during every other docking, the antifouling coating is 

older at those locations in comparison to the rest of the hull. 

Transfer from a Vessel to Port 

Because fouling communities consist of organisms that are either physically attached or 

that associate with vessel surfaces, NIS must be transferred from the vessel to a 

recipient port for possibility of introduction. This may occur through: 

• Spawning or Egg Release 

• Detachment (drop off a vessel) 

• Mechanical removal (dislodged from a vessel) 

Spawning or egg release can expose a recipient site to the young of fouling organisms 

even if the adults are otherwise unable to detach from a vessel. For example, eggbearing crabs too large to escape sea chests have been found in vessels arriving to 

New Zealand and Tasmania (Dodgshun and Coutts, 2002; Coutts et al., 2003). For 

many marine invertebrates, certain environmental events such as changes in salinity or 

temperature can trigger spawning. In particular, rises in sea temperature can cause 

spawning for many temperate species (Michin and Gollasch, 2003), and likely triggered 

spawning of an NIS mussel species found attached to a vessel that had been towed 

from the Washington-Oregon area to Hawaii (Apte et al., 2000). 

For mobile organisms in particular, transfer to a recipient port may be accomplished by 

simply dropping off a vessel. Organisms capable of independent detachment 

associated with fouling communities include crabs, fishes, sea stars, shrimp, snails and 

plankton (Foster and Willan, 1979; Carlton and Hodder, 1995, Dodgshun and Coutts, 

2002; Coutts et al., 2003). Even in some documented cases involving the introduction 

of immobile fouling organisms, detachment is suspected as the only mode of transfer 

(Michin and Gollasch 2003). 

Organisms can be dislodged if the vessel is bumped or during the process of in-water or 

dry dock cleanings. In-water cleaning is typically conducted between dry dock 

maintenance intervals to ensure that drag caused by fouling is kept to a minimum, and 

17
to meet classification society maintenance requirements (See Section IV, Merchant 

Fleet Efforts to Keep Vessels Clean). During in-water cleaning, fouling material is 

scraped or scrubbed from the underwater portions of the vessel, and can result in 

organisms dropping to the seafloor (Michin and Gollasch, 2003). A study in New 

Zealand on in-water scraping of smaller vessels (less than 49 meters [m]) indicated that 

72% of the discarded organisms remained alive (Floerl et al., 2004), though it is not 

clear if other cleaning techniques (e.g. brushing) on larger commercial vessels would 

yield similar results. 

During cleaning in a dry dock, fouling is often removed via abrasive blasting or 

hydroblasting. Though organisms dislodged during dry dock pose a theoretical NIS 

threat, increasing concerns over toxic substances entering the water have resulted in 

strict disposal requirements for effluent from dry docks. For example, the National Point 

Source Discharge Permit issued to the commercial dry dock in San Francisco prohibits 

the direct discharge of particulates and effluent into waters of the State (California 

Regional Water Quality Control Board, San Francisco Bay Region, 1999). Fouling 

material along with other waste particulates are generally placed in holding tanks and/or 

discharged to municipal wastewater systems or to a landfill. Thus, the potential for 

fouling introductions from dry docks theoretically presents limited risk (Godwin et al., 

2004; Davidson et al., 2005). 

Studies Conducted on U.S. Pacific Coast 

Because fouling appears to be affected by factors that vary in relation to the type of 

commerce and environmental conditions of a specific region, it is important to consider 

field research conducted locally. A summary of studies conducted in the U.S. Pacific 

region are reviewed here. 

Port of Oakland, 2004 

A pilot study on nine containerships arriving to the Port of Oakland in 2004 found 

patterns of fouling that varied in some aspects from studies conducted in other regions. 

As in other studies, the most fouling was observed in sheltered, non-hull locations on 

each ship. In contrast, the overall amount of fouling was much lower than had been 

18
observed on vessels in New Zealand (Coutts and Taylor, 2004; Ruiz et al., 2005). This 

is likely partially due to the high average speed of the vessels in the study (24-28 MPH, 

or 21-24 KTS) and their short port residency time (less than 24 hours). In contrast to 

other studies, little fouling was found in dry dock support strip areas though the 

condition of antifouling paint there was poor. The authors suggest that containerships 

arriving to Oakland may have lower levels of fouling in comparison to other vessel types 

with differing movement patterns. However, they caution that the limited number of 

vessels examined and the focus on only one ship type make any generalizations 

premature. 

Wetted Surface Area (WSA) of Commercial Vessels Arriving to California Ports 

Any submerged portion of a vessel represents a potential for fouling accumulation. 

Thus, an estimate of total amount of submerged surface area from all vessels that arrive 

to a region can provide some indication of the rate and pattern with which individual 

organisms may arrive (propagule pressure), and how they may contribute to NIS 

establishment. As part of a larger study to investigate fouling NIS potential on vessels 

arriving to the West Coast, the Aquatic Bioinvasions Research and Policy Institute 

provided preliminary data on hull “wetted surface area” (WSA) of vessels arriving to 

California for this report. This analysis was based on vessel arrivals from the ballast 

water reporting forms submitted to California between July 2003 and June 2005. 

For the two years analyzed, 189.5 million square meters (m2

) of hull surface area has 

arrived to ports in the State (≈ 95 million m2 per year). Forty-one percent arrived from 

Pacific Coast ports of North America (California, Oregon, Washington, British Columbia 

and Alaska). The remaining 59% (111.8 million m2

) arrived from overseas ports in 71 

countries throughout the Pacific, Atlantic and Indian Oceans, highlighting the global 

scale of possible introduction via this mechanism. Containerships dominated California 

arrivals, accounting for 55% of the total WSA for the state, and were the most frequent 

visitor and one of the largest ship types on average (second only to tankers in terms of 

average WSA) (Figure V.3). 

19
0

20

40

60

80

100

120

Auto

Barge

Bulk

Container

General

Passenger

Tanker

Other

Vessel type

WSA (x 1 million)

Figure V.3: Total wetted surface area (WSA) arriving to ports from July 2003 - June 2005 in California by 

vessel type. 

The magnitude of the threat of invasion to California’s coastal waters from hull fouling is 

significant. The two-year total of WSA entering California waters equates to 11⁄2 times 

the area of San Francisco County. However, without reliable data on biofouling 

densities across different vessel types, the ability to determine the full extent of 

propagule pressure to the State from commercial hull fouling is limited. A first effort at 

gathering this data will be made later in 2006, with the longer term aim to determine 

how different vessel types, voyage routes, hull husbandry regimes, and recipient port 

conditions influence hull fouling transfers and species establishment. 

Wetted Surface Analysis and Vessel Fouling Surveys in the Lower Columbia River 

In a preliminary study, vessel fouling and its potential for introductions in the Lower 

Columbia River (LCR) was evaluated through: WSA calculations for vessels arriving 

between July 2002 and June 2005, a biological analysis of fouling on 10 vessels 

surveyed in dry dock and on 7 vessels surveyed on video, and an evaluation of the 

suitability of the Lower Columbia River for invasion. 

Over 40.5 million m2

 of WSA arrived in the region between July 2002 and June 2005. 

The scale of potential introductions was global – vessels arrived from 377 different ports 

20
in 66 countries. The vast majority (85%) of overseas arrivals came from Asian ports of 

the Northwest Pacific. Vessel WSA was dominated by bulk carriers (>50%). Fouling on 

vessels examined on dry dock was highly variable; it ranged between >90% and <1% of 

the WSA. High levels of fouling tended toward vessels that remained within either 

marine or freshwater conditions and had not been cleaned within the last two years. 

Minimal fouling levels were associated with vessels that commonly traversed a range of 

salinity conditions, such as barges that frequent the LCR. Two vessels with the highest 

number of species had traveled to the LCR from overseas and had not spent much time 

in freshwater. Many of the taxa on these vessels were probably nonindigenous to the 

Pacific Northwest region. Finally, the authors conjecture that the dramatically varying 

salinity and highly variable flow rates in the LCR may serve to limit some invasions 

(Davidson et al., 2005). 

Implications of Current Knowledge 

The review of current research provided in this section allows for broad generalizations 

regarding NIS invasion risk posed by fouling on commercial vessels. However, the 

extent to which these principals apply to the U.S. West Coast and California are unclear 

due to the limited amount of information available. Fouling and associated NIS 

introductions are highly dependent on environmental conditions, vessel maintenance 

practices, type of shipping traffic, and vessel movement patterns, which can be 

regionally unique. Fouling factors also interact. A single vessel may exhibit behaviors 

that fall into both higher and lower risk categories, resulting in fouling NIS risk that can 

be complex and difficult to evaluate. This is especially the case for North America and 

California, where very little locally based research has been conducted on vessel fouling 

and its relationship to NIS introductions. 

In a minority of instances where vessels or maritime structures exhibit exaggerated 

characteristics that contribute to fouling accumulation, the NIS risk has been observed 

to be high. For example, the decommissioned USS Missouri was observed to have 

accumulated at least 116 fouling species during its five-year residency in Bremerton, 

Washington (Brock et al., 1999), before it was to be relocated to Hawaii. Towed vessels 

21
or maritime structures that move extremely slowly and spend very long periods 

immobile have been observed to be problematic in New Zealand and Hawaii (Rainer, 

1995; Godwin, 2003; Coutts, 2005 (a)). In 2001, a barge that had arrived in New 

Zealand from the Philippines before 1991 and which had not been dry docked since its 

arrival, was observed to have accumulated over 28 tons of fouling organisms (Coutts, 

2005(b)). A heavily fouled floating dry dock that was towed to Hawaii in 1992 from the 

Philippines is thought to be responsible for the establishment of several NIS to Pearl 

Harbor (Coles et al., 1999). An oil platform towed for 68 days at an average of 3.7 MPH 

(3 KTS) from Japan to New Zealand arrived with over a ton of fouling (Foster and 

Willan, 1979). A floating dry dock towed to Hawaii from San Diego in 1999 had high 

levels of fouling the included 34 NIS, and an algal species became established as a 

result (Godwin, 2003). 

The majority of vessels in regular operation, however, do not exhibit similarly extreme 

characteristics. As noted in Section IV, most companies clean and paint hulls regularly 

for operational safety, to reduce maintenance costs, and to minimize drag-related fuel 

costs. Many minimize time in port and maximize transit speed in order to move cargo 

quickly for maximal profit. Because there have been no fouling studies across a broad 

range of vessel types, vessel movement patterns, and maintenance practices, it is not 

known what kinds of fouling patterns result on vessels that exhibit more common 

behaviors or that engage in a combination of behaviors with differing fouling effects (e.g. 

a swift vessel that typically spends three days in port; a freshly painted vessel that has 

been moored for two weeks). Thus, while it may be possible to identify irregular 

situations that likely pose a high risk, it is not clear what level of risk is presented under 

more typical commercial vessel behaviors. 

It is also notable that any vessel or structure of any size may accumulate fouling, and if 

mobile, can serve to transport NIS. Factors that influence fouling on commercial 

vessels also apply to other structures, including private boats or yachts, fishing vessels, 

and navigational buoys (Railkin, 2004). For example, the historical replica ship of the 

Golden Hinde transported over 64 species at various legs of its voyage from Yaquina 

22
Bay, Oregon to San Francisco Bay, California in 1987. The vessel spent 30-day 

layovers at three ports prior to and during its 4-4.5 MPH (3.5-4 KT) trip (Carlton and 

Hodder, 1995). In a Hawaii study, 21 NIS were found on 12 overseas personal craft, 

though all but one of the NIS had already become established in the state (Godwin et 

al., 2004). In New Zealand, recreational yachts have been suspected as a probable 

introduction vector for several problematic NIS (Floerl and Inglis, 2005). Though the Act 

explicitly directs the Commission to evaluate the NIS risk posed by vessels over 300 

gross registered tones able to carry ballast, it is important to note that a complete 

picture of the fouling NIS vector extends beyond commercial vessels. 

VI. EXISTING FRAMEWORKS FOR THE MANAGEMENT OF VESSEL FOULING 

A range of strategies for minimizing NIS introductions through commercial vessel fouling 

have been proposed or adopted by various countries, states/territories and regions. To 

date, no country has adopted national regulations for commercial vessels explicitly for 

the prevention of NIS introductions through vessel fouling. The types of management 

frameworks vary widely because there is little information on the efficacy of 

management strategies for the vector. In some cases, the primary impetus for 

management is not fouling NIS prevention, but the minimization of toxic antifouling paint 

release into the water as residues are scraped off during hull cleaning. The TAG and 

Staff examined the benefits and drawbacks of these strategies, and their potential for 

the prevention of fouling NIS in California. 

Federal and California Codes and Statutes 

The Federal code (Code of Federal Regulations [CFR] Section 151.2035 (5) and (6)) 

and the California statue (California Public Resources Code Section 71204 (e) and (f)) 

contain nearly identical language prescribing minimum maintenance actions to control 

fouling. However, both are limited in scope and specificity. They require that anchors 

and anchor chains be rinsed upon retrieval at their place of origin, and that fouling 

organisms be regularly removed from hulls, piping and tanks and be disposed of 

according to local, State or Federal regulations. Parameters are not defined regarding 

the “regular” removal of fouling. Despite this, the U.S. Coast Guard was able to use the 

23
federal regulation to intervene when decommissioned Suisun Bay Reserve Fleet 

vessels were moved from one Captain of the Port Zone to another for dismantling. 

Much of the Suisun Bay fleet has been immobile for years, if not decades, with little or 

no hull maintenance. 

Hawaii

In Hawaii, a draft information framework for the management of fouling NIS was 

developed by the Alien Aquatic Organism Task Force, a stakeholder group formed by 

the Hawaii Division of Aquatic Resources. The framework has not yet been officially 

adopted, and the State currently monitors maritime arrivals for high risk vessels through 

an informal network of state, federal, academic and private groups. Response is 

conducted through this informal network as much as possible. 

The draft framework separates fouling NIS management into three components. “Proactive measures” are geared towards minimizing high risk arrivals to Hawaii, and 

include education and outreach, maritime activity monitoring, and the evaluation of 

arrivals for potential high risk vessels. The second component addresses the response 

to a high risk event, and these “reactive measures” may involve an investigation of the 

identified vessel, and/or a determination of actions to minimize the potential for NIS 

introduction. The third component, “post-event measures”, involves the development of 

long term management measures once it is determined that they are needed (Godwin, 

2005). 

In order to assist with the identification of potentially high risk vessel arrivals during the 

pro-active stage, an evaluative risk matrix was developed (See Figure VI.1). Its 

components are based on vessel movement and maintenance patterns that influence 

fouling, though some of its specific parameters have not yet been defined (Godwin et 

al., 2004) (see Section V, “Review of Current Knowledge on Vessel Fouling and 

Nonindigenous Species”). In the proposed matrix, vessels arriving from outside of the 

state that do not adhere to international maintenance codes of practice, and spend long 

periods immobile would be flagged. In addition, certain vessel types are designated as 

24
high risk, based on prior NIS fouling surveys conducted in Hawaii. These would include 

vessel types that often travel at slow speeds and spend long periods inactive (e.g. 

barges, platforms, floating dry docks). Potential reactive measures for high risk vessels 

include restricting time in port to essential operations, quarantine, or out of water 

cleaning for those intent on an extended stay. 

Priority Vessels

• Towed Barges & Work Platforms

• Floating Drydocks

• Unique Arrivals

? Last port of call 

outside Hawaii

No Yes

Stop ? Compliance Standards

• ISM Code

• Local codes of practice

Yes

Stop

No

? Lay-up or inactive period

< Time X > Time X

Stop Investigate

Ranking System

Acceptable

Stop

Unacceptable

Response & Action

Figure VI.1: Preliminary “risk matrix” developed in Hawaii to assist with the identification of arrivals that 

pose a high fouling NIS risk to the state. From: Godwin, 2005. 

New Zealand 

The Biosecurity New Zealand (formerly New Zealand Ministry of Fisheries) is the 

primary agency responsible for the prevention and management of marine NIS in New 

Zealand. There are currently no regulations in place related to the prevention of fouling 

NIS, however information gathering efforts are conducted through a survey. The survey 

is included on the ballast water declaration form required of all arriving vessels, and 

asks three questions relating to vessel maintenance and activity: 

• When was the vessel last dry-docked and cleaned? 

25
• Has the vessel been laid up for three months or more since it was last dry 

docked and cleaned? If yes, state when and where. 

• Do you intend to clean the hull in New Zealand? If yes, state when and where.

In addition, New Zealand’s fishing industry adopted voluntary codes of practice in 

December 1996, following the highly publicized arrival of a fishing vessel in 1994 with 

approximately 90 tons of fouling (Hay and Dodgshun, 1997; Coutts, 2005(a)). The code 

requests that foreign owned or sourced vessels be free from growth prior to entering 

New Zealand’s Exclusive Economic Zone. If this cannot be assured, the vessel should 

be inspected, and either cleaned before departure or have fouling removed in a manner 

that does not allow organisms to enter the marine environment. 

Biosecurity New Zealand is currently considering several options for the regulation of 

hull cleaning practices. Proposed rules may require that out-of-water cleaning facilities 

contain, collect and dispose of or treat fouling material in a manner that prevents 

discharge of organisms to the marine environment. Additionally, proposed rules may 

include a ban on in-water cleaning, regulations targeting high risk vessels only, or the 

adoption of codes of practice for in-water cleaning operations (Coutts, 2005 (a); New 

Zealand Ministry of Fisheries, 2006). 

Australia 

Though Australia has not implemented nationwide regulations related to fouling on 

vessels larger than 25 m, all states and territories prohibit in-water cleaning on 

commercial-sized vessels (Hirst, 2006; New Zealand Ministry of Fisheries, 2006). Most 

of these prohibitions are variants of the Australian and New Zealand Environment 

Conservation Council (ANZECC) codes of practice (See discussion that follows on 

ANEZCC codes of practice), and in some cases have been adopted primarily to prevent 

biocidal antifouling paint flakes from entering the water or dropping to the sea floor. 

Currently, protocols tailored to specifically address fouling NIS are in very early stages 

of development (Hirst, 2006). 

26
In late 2005, Australia announced the implementation of national regulations to prevent 

fouling NIS introductions on internationally traveling vessels under 25 m. Though the 

regulation does not apply to commercial vessels, it is reviewed in this report because it 

represents the first legal regime specifically aimed towards the prevention of NIS 

introductions through the hull fouling vector in the marine environment (Australian 

Quarantine and Inspection Service, 2005). The rule will become mandatory in October 

of 2006 after a one year voluntary period, and requires that vessel gear and seawater 

systems are clean of marine pests and growths. In addition, operators must perform 

one of three antifouling measures: 

• Clean the hull one month prior to arrival 

• Apply antifouling paint within one year before arrival 

• Book the vessel to be slipped and cleaned within one week of arrival 

The Australian and New Zealand Environment Conservation Council (ANZECC) 

The Australian and New Zealand Environment Conservation Council (ANZECC) was a 

Ministerial Council that operated from 1991 to 2001 to develop coordinated policies 

between member nations. The Council produced codes of practice to minimize 

pollution problems caused by toxic antifouling paints and to reduce the release of 

fouling NIS. In-water cleaning is prohibited, except in extraordinary circumstances. The 

codes do allow the cleaning of sea chests, grids, and hull apertures under permit if 

debris was not allowed into the water or onto the seafloor, and also allow propeller 

polishing under permit (ANEZCC, 1997). 

Merchant Classification Society Requirements 

As discussed earlier, classification societies require periodic hull inspections and dry 

docking of commercial vessels (See Section IV, “Merchant Fleet Efforts to Keep 

Vessels Clean”). Though requirements vary slightly depending on the age of a vessel 

and classification, they generally require vessels to be dry docked at least once every 

five years. None of the societies requires the hull to be cleaned while dry docked. 

Nevertheless, because of the increased fuel consumption that can result from fouling, 

27
28

and because the dry docking process is costly and difficult to schedule, most companies 

take the opportunity to clean and paint vessel hulls during these periods. Most 

companies also conduct interim in-water cleanings according to fuel performance tests, 

in order to maintain cost effective fuel efficiency. 

Due to the lack of scientific knowledge on the most effective and practicable options for 

the prevention of NIS from commercial vessel fouling, no national policies have been 

adopted. For similar reasons, strategies that have been implemented in select regions 

range widely (See Table VI.1.). Clearly, more research will be needed to evaluate 

where the highest risks of NIS introduction lie and which preventative actions might be 

most protective. 
Country/State/

Port 

Management 

Strategy Details 

U.S. Federal California 

Embedded in ballast water regulation Embedded in ballast water statute

Rinse anchor chains and anchors at place of origin Remove fouling from hull, piping and tanks on a regular basis. Dispose wastes in accordanfederal law. 

Hawaii 

Information Framework Targeting High Risk Vessels (Proposed) 

Pro-active measures: Education/outreach, vessel arrival monitoring, evaluation for high-risk Re-active measures: Rapid response/investigation of high risk event Post-event measures: Long term regulations for high-risk events 

• Limit time in port • Vessel quarantine • Out of water cleaning 

Survey (On Ballast Water Declaration Form) 

1. When and where was the vessel last dry-docked and cleaned? 2. Has the vessel been laid-up for 3 months or more since it was last dry-docked and cleanand where. (Also requests start and end date laid up) 3. Do you intend to clean the hull of the vessel in New Zealand? If YES, state when and wh

New Zealand 

Voluntary Codes of Practice (Fishing Industry) 

Chartered foreign owned or sourced fishing vessels must be substantially free from plant or entering New Zealand’s EEZ. If no assurance, vessel inspected and cleaned before departure. Otherwise inspected in NZ and if necessary, fouling removed so no foreign organisms enter 

Table VI.1: Summary of Current Management Frameworks for Vessel Fouling. Various regulations, proposed managrecommendations, guidelines, and codes of practice aimed towards preventing NIS introductions through fouling are summ
Country/State/

Port 

Management 

Strategy Details 

Prohibition (States/Territories/ Ports) 

States& territories prohibit in-water cleaning. Many require containment and disposal regulations of fouling debris removed during out-of-w

Australia 

Regulation (Vessels less than  25 m) 

Keep ancillary gear and internal seawater systems clean of marine pests and growths, and Before departing your last port for Australia... 

o Clean hull within one month before arrival OR o Apply antifouling paint within one year before arrival OR o Book vessel for slipping and cleaning within one week of arrival (cleaning should be 

material removed can be collected and disposed of away from the sea) 

Australia and New Zealand Environmental Conservation Council (ANZECC) 

Codes of Practice 

In-water hull cleaning prohibited, except under extraordinary circumstances. Sea-chests, sea suction grids, other hull apertures may be allowed under permit, if debris nocolumn or sea bed. Polishing propellers may be allowed under permit. 

Merchant Classification Societies 

Requirements (Applies to majority of merchant fleet) 

Dry dock requirements vary somewhat depending on classification society. Generally: 

o Dry dock every 5 years. Cleaning and painting is usually conducted, but is at the do Interim in-water cleanings: Periodicity at the discretion of the company. Typically d

consumption tests. 

Table VI.1 (Continued): Summary of Current Management Frameworks for Vessel Fouling
VII. CONCLUSIONS AND RECOMMENDATIONS 

The most difficult challenge to developing recommendations that reduce the introduction 

of NIS from fouling is the limited amount of direct research that has been conducted on 

the vector. While studies in a number of regions indicate that fouling is an important 

mechanism through which modern invasions occur, few modern baseline studies have 

been conducted to characterize the vector, particularly in North America. Although 

generalizations can be made on factors that influence the degree of vessel fouling 

based on studies in regions outside of the mainland U.S., the information is not 

adequate to evaluate the specific NIS potential of the majority of vessels calling to 

California. While vessels with extreme characteristics that exacerbate fouling likely 

pose a risk, there is little information on the potential risk posed by the majority of the 

fleet that conducts regular vessel maintenance and exhibits more common behaviors. 

The Commission believes, however, that these difficulties should not prevent the State 

from moving forward with actions at this time. Staff approached the development of 

recommendations by considering which actions can be implemented now to reduce NIS 

introduction via fouling based on the knowledge currently available, and what actions 

are needed to build information and the tools needed to refine management measures 

in the future. 

Legislation should be adopted to: 

1. Broaden the State Program to include the control and prevention of NIS 

release via commercial vessel fouling. 

The Act currently focuses on the prevention of NIS introduction through ballast water 

discharges, and does not authorize the Commission to adopt regulations to prevent NIS 

introduction through vessel fouling. This lack of explicit authority prevents the 

Commission from implementing regulatory actions related to the vessel fouling vector.

31
2. Broaden the reporting requirements to include mandatory reporting on 

maintenance practices and other fouling-related behaviors of qualifying vessels 

operating in California waters. 

Both vessel movement patterns and maintenance practices are factors that strongly 

influence the degree of fouling found on vessels. Long mooring periods, slow transit 

speeds, and infrequent use of antifouling paint and systems have been found to 

facilitate fouling accumulation. However, there is currently no information on which 

characteristics are representative of the vessels that arrive to and/or operate in 

California, and how many of these vessels exhibit potentially higher risk characteristics. 

 

 It is known that the vast majority of vessel operators clean and paint hulls every five 

years, and perform periodic in-water cleaning during the interim. Most strive to 

minimize fouling due to operational dangers and increased fuel costs. Most also aim to 

maximize transit speeds and minimize time in port. However, case studies outside of 

California have observed that a small minority of vessels do not follow these 

maintenance schedules and/or do not exhibit these transit behaviors, and some have 

been found with excessive fouling. For example, a decommissioned military vessel that 

had been moored in Washington State for 5 years was observed to have accumulated 

over 112 species prior to its relocation to Hawaii (Brock et al. 1999). With such 

contrasting profiles, it will be critical to characterize vessels in California waters to better 

evaluate the nature of the risk posed by commercial vessels. Coupled with biological 

surveys of NIS fouling on vessels that operate in the State, vessel maintenance and 

behavior information will provide a better understanding of the actual NIS risk posed by 

fouling, and will be key for identifying appropriate management solutions that minimize 

the risk of NIS introductions via this pathway. The adoption of this recommendation 

would lead to an increase in the cost of the Commission Program associated with 

increased staff requirements for data entry, compilation, and analysis; as well as 

additional vessel inspections and monitoring. 

32
3. Expand enforcement components of the Act to address mandatory reporting in 

Recommendation 2. 

The California Marine Invasive Species program is supported by active reporting 

compliance monitoring, outreach to the shipping community, and the authority to apply 

penalties for non-compliance, which has yielded reporting rates that have exceeded 

90% since 2000 (Falkner, 2003; Falkner, et al. 2005). In contrast, mandatory reporting 

for the federal ballast water program is not similarly reinforced, and reporting rates were 

approximately 30% during 1999-2001 (Ruiz et al., 2001), making a sound assessment 

of the data impossible. The Commission therefore believes that the authority to apply 

penalties for non-reporting coupled with outreach to and monitoring of the shipping 

community, will ensure higher reporting rates. This authority will help assure that 

information collected through the survey provides representative information on the 

vessels operating in California ports or places. The adoption of this recommendation is 

not expected to increase the cost of the Commission Program above those anticipated 

with the adoption of Recommendation 2. 

4. Authorize the Commission to develop and adopt regulations that prevent or 

minimize the introduction of NIS via vessel fouling. 

Regulations to define regular vessel maintenance practices for the control of NIS fouling 

on commercial vessels are needed. These should place requirements or restrictions on 

vessels that do not adhere to the defined practices. Though there is a limited amount of 

scientific knowledge on the quantity and NIS risk presented by fouling that may be 

present on well maintained vessels operating in California, case studies show that a 

minority of vessels do not follow minimal “good housekeeping” practices. For example, 

a barge that had not been dry docked for at least 10 years was found in New Zealand 

with over 28 tons of fouling (Coutts, 2005(b)). Such vessels have been found with 

extensive amounts of fouling and present high risk scenarios for NIS introduction (See 

Section V, “Review of Current Knowledge on Vessel Fouling and NIS” for further 

discussion). 

33
Both the Act and the federal ballast water regulation (33 CFR 151.2035(a)(6)) require 

that vessels remove fouling on a regular basis, however, no definition or criteria is 

provided for the term “regular”. Given the high NIS risk posed by vessels that are not 

adequately maintained, the intent of the Act would be better served if criteria were 

placed on a definition for regular inspections and cleaning, and if vessels that do not 

adhere to defined criteria are subject to further examination. 

The Commission should therefore be authorized to adopt regulations that define 

parameters for regular husbandry practices for fouling control, and should be authorized 

to place requirements on vessels that do not follow such practices. Vessels that are not 

regularly maintained should be compelled to notify the Commission prior to their entry 

into or movement within California waters. Such a framework would serve to flag 

potential high risk vessels, providing an opportunity for the Commission to gather 

information on the frequency of arrivals of potentially high-risk vessels to California 

ports, and to work with vessel operators on actions that can minimize the adverse 

impacts of a highly fouled vessel. Adoption of this recommendation is not expected to 

increase the cost of the Commission Program above those anticipated with the adoption 

of Recommendation 2. 

5. Expand and coordinate biological research directed towards characterizing the 

NIS risk posed by commercial vessel fouling with other federal and state 

agencies.

The limited amount of scientific research on vessel fouling and NIS in California and the 

West Coast is the most prominent obstacle to a clear evaluation of the overall risk faced 

by the State. Existing studies have been conducted on limited numbers and types of 

vessels, in regions largely outside of North America. Though relative generalizations 

from these studies regarding factors that influence fouling likely apply to vessels 

operating in California waters, the magnitude of the NIS risk cannot be extrapolated to 

the State. For example, while it may be presumed that a vessel that travels at an 

average of 7 KTS likely has more fouling than one that travels at 17 KTS, it is not known 

34
how much fouling, how many NIS, or the level of NIS risk that may be presented on 

each. 

A number of questions critical for the development of effective, scientifically grounded 

management remain. At a minimum, information is needed to address the most basic, 

but most important question: How many fouling organisms and how many NIS arrive to 

and move within California via vessel fouling? Such information is critical for a 

characterization of the NIS risk faced by California. When coupled with vessel 

maintenance and movement patterns linked to fouling accumulation, research would lay 

the foundation to fill additional information gaps such as which kinds of vessels harbor 

notably more fouling than others, what criteria can be used to flag a potentially high risk 

vessel, and which vessels pose a negligible amount of risk. Answers to these kinds of 

management-based research questions can guide the formulation of preventative 

management actions in the future. Funds necessary to support such a research 

program could be obtained through three mechanisms: general funds, grants, or 

through the existing fees assessed on ships. The cost to adopt this recommendation to 

the Commission Program could be as much as $500,000 annually. 

6. Support continued long-term NIS monitoring in California waters. 

Long-term biological monitoring is necessary to evaluate the effectiveness of 

management efforts to prevent NIS introductions; particularly as new management 

actions are implemented. Surveys are also crucial for determining how to modify or 

enhance management actions so they are optimally effective for reducing invasions. As 

mandated by the Act, the California Department of Fish and Game (CDFG) administers 

a statewide monitoring program for NIS within California’s estuaries and along its coast. 

Legislation should support the CDFG’s continued long-term survey efforts so data may 

be used to evaluate the effectiveness of management measures implemented to 

prevent NIS introductions via vessel fouling. Adoption of this recommendation is 

expected to increase the cost of the CDFG Program. 

35
7. Support research promoting technology development. 

Vessel owners and operators strive to maintain clean hulls in order to minimize fuel 

costs, maximize vessel speed, meet classification society requirements, and to help 

ensure the structural integrity of their vessels. Available information indicates that hull 

cleaning at dry docks in California presents a lowered NIS risk because these facilities 

are required to prevent fouling debris from entering the water column. Complete 

cleaning and re-coating with antifouling paint may provide better long-term antifouling 

protection than does in-water cleaning. However, dry dock facilities capable of 

accommodating commercial class vessels are limited, expensive, and scheduled well in 

advance. Most owners and operators therefore conduct in-water cleaning between 

required dry dockings. 

In-water cleaning is one of several ways through which fouling NIS can be transferred 

from a vessel to a recipient port, and the activity poses some NIS introduction risk. 

Because of the potential for in-water cleaning to release NIS and toxic antifouling paint 

debris, Australian territories and states have banned the practice. However, in the 

absence of in-water cleaning, fouling organisms are still capable of transfer through 

spawning or by detachment from a vessel, and it has been contended that spawning or 

brood release may be the most important release mechanism (Michin and Gollasch, 

2003; Davidson et al, 2005). There has been no direct research to indicate if the fouling 

NIS risk is lower if in-water cleaning is banned or if it is allowed it to proceed. Clearly, 

NIS release can occur under either situation, and neither is optimal. 

A technology that collects and contains in-water cleaning debris would be a desirable 

avenue to prevent NIS release during in-water cleaning, while also providing 

commercial operators an avenue to clean hulls without placing a vessel in dry dock. In 

addition, a containment-based in-water cleaning technology could provide at tool to 

handle cases where a heavily fouled, high NIS risk vessel arrives to the State, and dry 

docks are not available. Prototype technologies have been under development to 

36
contain both fouling debris and toxic antifouling paint residuals: however, none are 

currently available for commercial application. 

As a result of current and impending bans on toxic antifouling coatings, many 

commercial vessel paint manufacturers are developing non-toxic antifouling coatings. 

However, currently available products are only effective for a minority of vessels that 

travel at very high speeds. As more regions adopt bans on coatings that release 

biocides, it will be important that alternative antifouling tools are available to prevent the 

accumulation of fouling and minimize NIS introductions. 

Legislation should therefore facilitate the advancement of in-water cleaning 

technologies that collect and contain fouling debris. The long-term goal of these 

technologies would be to phase out in-water cleaning activities in California that are not 

contained. Legislation should also facilitate the advancement of antifouling coatings 

that create little or no water quality impacts, and which are effective for preventing 

fouling accumulation on vessels. The advancement of both of these technologies would 

fulfill the intent of the Act to move the state towards the elimination of NIS discharge into 

waters of the State in a manner that also addresses water quality issues that may be 

generated by the antifouling practices of vessels. Funds necessary to support such a 

research program could be obtained through three mechanisms: general funds, grants, 

or through the existing fees assessed on ships. The cost to the Commission Program 

could be as much as $500,000 annually. 

8. Direct the State and Regional Water Quality Control Boards, in cooperation 

with the U. S. Environmental Protection Agency, to evaluate the effects of biocidal 

antifouling coatings from vessels on water quality. 

Copper enters California’s freshwater, estuarine, and marine environments from a 

variety of sources, including copper-based antifouling paints on vessels. Due to copper 

contamination, California’s major ports are included on California’s 2002 list of impaired 

waters as defined by the Clean Water Act Section 303(d). 

37
Though outside of the intent and scope of the Act to “...move the state expeditiously 

towards the elimination of the discharge of nonindigenous species into the waters of the 

state...,” the Commission feels that water quality impairments that may be caused by 

vessel antifouling practices warrant attention. The Commission recommends that the 

State and/or Regional Water Quality Control Board(s) investigate the issue in 

cooperation with the United States Environmental Protection Agency, under the 

authority and jurisdiction granted to them by the Clean Water Act. Full chemical 

constituent identification and toxicological literature reviews should be conducted to 

assess the potential aquatic toxicities of all antifouling paints now in use in California’s 

waters, including their propensity for bioaccumulation, leaching potential, and general 

environmental fate. More specifically, it should be determined if copper leachate from 

antifouling practices is contributing to: 

• The impairments in the 2002 California list developed pursuant to the federal 

Clean Water Act Section 303(d). 

• An exceedance of water quality criteria as provided under the California Toxics 

Rule (40 CFR Part 131) for inland surface waters, enclosed bays, and estuaries. 

• An exceedance of criteria for priority pollutants as provided in the 2005 California 

Ocean Plan for near coastal ocean waters. 

If it is determined that antifouling practices of vessels do contribute to water body 

impairment or exceedance of water quality criteria, the boards should adopt or amend 

water quality plans and or Total Maximum Daily Loads accordingly, as directed by the 

federal Clean Water Act. SWRCB Program costs may increase and the appropriate 

funding source needs to be identified. 

 

9. Expand the Marine Invasive Species Program’s existing outreach and 

education program to include the fouling vector. 

The goal of expanding the Program’s existing outreach and education program would 

be to inform ports, the merchant shipping industry, the military, resource agencies and 

policy makers about vessel fouling and its role as an NIS vector. Nonindigenous 

38
species transport and introduction through vessel fouling is a relatively new issue for 

many of these entities, and there is little to no awareness of its importance amongst 

these groups. The problem was underscored during the TAG meetings by a 

coincidental controversy over the proposed establishment of a ship breaking operation 

in Oregon, and the associated transfer of vessels from the Suisun Bay Reserve Fleet to 

the proposed operation or to an established operation in Texas. Though vessels in the 

reserve fleet exhibit exaggerated, high risk characteristics for fouling accumulation, 

there had been no consideration for the potential for NIS transfer prior to the public 

opposition and media attention that emerged over the controversy. 

Outreach to the stakeholder community should clearly be part of the early steps in any 

NIS prevention program. Such efforts allow affected parties to come up to speed on an 

issue, to become educated participants in the search for preventative strategies, and 

provide the opportunity to take voluntary action to prevent NIS introductions and spread. 

There was strong agreement amongst TAG members that outreach should be a high 

priority, particularly in light of the limited knowledge of fouling and NIS on the majority of 

the fleet that operates in California waters. Operations engaged in theoretically high 

fouling risk operations should be high priority targets of outreach. These would include 

(but are not limited to) the military, the Maritime Administration, salvage operators, 

companies operating oil platforms, and vessel towing companies. Awareness should 

also be raised amongst those involved with policy development, so well informed 

decisions can be made as emerging science provides a better understanding of the 

problem, and effective solutions for it. Adoption of this recommendation is not expected 

to increase the cost of the Commission Program. 

10. Direct appropriate agencies to address the risk of fouling related NIS 

introduction and spread in California waters by vessels under 300 gross 

registered tons. 

The Act explicitly directs the Commission to evaluate the risk of NIS introductions by 

vessels over 300 gross registered tones, able to carry ballast. However, it is important 

to recognize that any vessel or structure of any size, with or without ballast water tanks, 

39
may accumulate fouling and subsequently transport NIS. Factors that influence fouling 

on commercial vessels described in this report also apply to other structures, including 

private boats or yachts, fishing vessels, and navigational buoys (Railkin, 2004). 

Though vessels and structures under 300 gross registered tones are not encompassed 

by the Act, the Commission and the TAG believe that they are likely an important 

means for the introduction and spread of marine, estuarine and freshwater invasive 

species within California waters. The Commission recommends that the release and 

transfer of NIS through vessel types not included in the Act, including recreational and 

fishing vessels, be examined by the agency(ies) with the appropriate authority and 

jurisdiction. Recommendations for the reduction of NIS introductions from noncommercial shipping, non-ballast water vectors should be provided to the Legislature. 

40
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45
IX. APPENDICIES 

46
APPENDIX A 

 Hull-Borne Invasive Species Workshop 

 List of Attendees 

May 11, 2005 ● San Francisco, CA 

Marian Ashe 

California Department of Fish and Game 

Susan Ellis 

California Department of Fish and Game, Habitat 

Conservation Division 

John Berge 

Pacific Merchant Shipping Association 

Terri Ely 

California Department of Boating and Waterways, 

Aquatic Weed Control Unit 

David Breninger 

Recreational Boaters of California 

Carl Ernst 

Marina Recreation Association 

Margot Brown 

National Boating Federation 

Maurya Falkner 

California State Lands Commission 

Chris Brown 

Smithsonian Environmental Research Center 

Sylvain Fillion 

International Paint Company 

Brad Chapman 

Chevron Shipping Company LLC 

Reinhard E.Flick 

Scripps Institution of Oceanography, Center for 

Coastal Studies 

Amy Chastain 

San Francisco BayKeeper 

Paul Gates 

International Paint Company 

Ashley Coutts 

Cawthron Institute, Marine Biosecurity 

Suzanne Gilmore 

California State Lands Commission 

Jeff Crooks 

Tijuana River National Estuary Research Reserve 

Scott Godwin 

Bernice Pauahai Bishop Museum, Hawaii 

Holly Crosson 

University of California, Davis, Department 

Environmental Science and Policy 

Jamie Gonzalez 

University of California Sea Grant Extension Program 

Ian Davidson 

Portland State University 

Allison Gordon 

Pacific Coast Federation of Fishermen's Associations 

Larry Draper 

Recreational Boaters of California 

Ted Grosholz 

University of California, Davis 

Diane Edwards 

California State Water Resources Control Board, 

Division of Water Quality 

Brad Gross 

California Association of Harbor Masters and Port 

Captains 

47
Jon Gurish 

California Coastal Conservancy 

Greg Ruiz 

Smithsonian Environmental Research Center 

Marla Harrison 

Port of Portland 

Dragan Samardzic 

Matson Navigation 

Jeffrey Herod 

U.S. Fish and Wildlife Service, Sacramento/San 

Joaquin Estuary Fishery Resources Office 

Jason Savarese 

National Sea Grant Law Center 

Andrew Jirik 

Port of Los Angeles 

Guy Seabrook 

Magellan Companies, Inc 

Leigh Johnson 

University of California Sea Grant Extension Program 

Nan Singhasemanon 

California Department of Pesticide Regulation 

Jo-Anne Kushima 

State of Hawaii, Dept. of Land & Natural Resources, 

Division of Aquatic Resources 

Lisa Sniderman 

California Coastal Commission 

Tim Leathers 

MRA/Cabrillo Isle Marina 

Ernie Soeterik 

Sherwin Williams 

Mari Lou Livingood 

Association of Marina Industries 

Mike Sowby 

California Department of Fish and Game 

Vivian Matuk 

California Coastal Commission 

Cindy Squires 

National Marine Manufacturers Association 

Karen McDowell 

San Francisco Estuary Project 

Jay Stachowicz 

University of California, Davis, Section of Evolution 

and Ecology 

Sarah Mongano 

California State Lands Commission 

Nancy Stein 

Contra Costa County Department of Public Works 

Paul Murakawa 

State of Hawaii, Dept. of Land & Natural Resources, 

Division of Aquatic Resources 

David Stephens 

California State Lands Commission 

William Needham 

Harbor Safety Committee of the SF Bay Region 

Sean Svendsens 

Svendsen's Boat Yard 

Peter Ode 

California Department of Fish and Game 

Lynn Takata 

California State Lands Commission 

Deborah Pennell 

Shelter Island Marina, Board of Directors MRA 

Drew Talley 

San Francisco Bay National Estuary Research 

Reserve 

Russ Robinson 

Recreational Boaters of California 

Mariann Timms 

Marina Recreation Association 

48
Raynor Tsuneyoshi 

California Department of Boating and Waterways 

Kim Ward 

State Water Resources Control Board: Division of 

Water Quality 

Valerie Van Way 

California State Lands Commission 

Chela Zabin 

University of Hawaii, Manoa 

M K Veloz 

Northern California Marine Association 

Jody Zaitlin 

Port of Oakland 

Ted Warburton 

California Association of Harbor Masters and Port 

Captains 

 

49
APPENDIX B 

California State Lands Commission 

Technical Advisory Group Participants 

** Denotes participants that attended at least one Commission TAG meeting 

Cesar Alvarez** 

California Sea Grant Extension 

Abe Doherty 

California Coastal Conservancy 

Marian Ashe** 

California Department of Fish and Game 

Diane Edwards 

California State Water Resources Control Board 

John Berge** 

Pacific Merchant Shipping Association 

Susan Ellis 

California Department of Fish and Game 

Chris Brown 

Smithsonian Environmental Research Center 

Richard Everett 

United States Coast Guard 

Marina Cazorla 

California Coastal Conservancy 

Schauadi Falamaki 

California Association of Port Authorities 

Brad Chapman** 

Chevron Shipping Company LLC 

Maurya Falkner** 

California State Lands Commission 

Ashley Coutts** 

Cawthron Institute, Marine Biosecurity 

Sylvain Fillion 

International Paint Company 

Jeff Crooks** 

Tijuana River National Estuarine Research 

Reserve 

Oliver Floerl 

National Centre for Aquatic Biodiversity and 

Biosecurity, New Zealand 

Holly Crosson** 

West Coast Ballast Outreach Project 

Paul Gates** 

International Paint Company 

Ian Davidson** 

Portland State University 

Suzanne Gilmore** 

California State Lands Commission 

Nicole Dobroski** 

West Coast Ballast Outreach Project 

Scott Godwin 

Bernice Pauahai Bishop Museum, Hawaii 

50
Jamie Gonzalez** 

University of California Sea Grant Extension 

Program 

Steve Moore 

San Francisco Bay Regional Water Quality Control 

Board 

Ted Grosholz 

University of California, Davis 

Paul Murakawa 

State of Hawaii, Dept. of Land & Natural 

Resources, Division of Aquatic Resources 

Jon Gurish 

California Coastal Conservancy 

Sarah Newkirk 

The Ocean Conservancy 

Jeffrey Herod** 

U.S. Fish and Wildlife Service, Sacramento/San 

Joaquin Estuary Fishery Resources Office 

Peter Ode 

California Department of Fish and Game 

Eric Holm 

Naval Surface Warfare Center, Carderock Division 

Henry Olsen 

Matson Navigation 

Andrew Jirik 

Port of Los Angeles 

Stephen Philips 

Pacific States Marine Fisheries Commission 

Leigh Johnson 

University of California Sea Grant Extension 

Program 

Deborah Ruddock 

California Coastal Conservancy 

Giselle Johnston** 

California State Lands Commission 

Greg Ruiz** 

Smithsonian Environmental Research Center 

Dalia Keroles** 

California State Lands Commission 

Dragan Samardzic** 

Matson Navigation 

Jo-Anne Kushima** 

State of Hawaii, Dept. of Land & Natural 

Resources, Division of Aquatic Resources 

Tim Schott 

California Association of Port Authorities 

Jackie Mackay** 

California State Lands Commission 

Linda Sheehan 

California CoastKeeper 

Vivian Matuk 

California Coastal Commission 

Lisa Sniderman 

California Coastal Commission 

Karen McDowell** 

San Francisco Estuary Project 

Mike Sowby 

California Department of Fish and Game 

Whitman Miller** 

Smithsonian Environmental Research Center 

Jay Stachowicz 

University of California, Davis 

51
Lisa Swanson** 

Matson Navigation 

Steve Weisberg 

Southern California Coastal Research Project 

Mark Sytsma** 

Portland State University 

Rodney Young** 

Hawaii Dept. of Land and Natural Resources 

Lynn Takata** 

California State Lands Commission 

Chela Zabin 

University of Hawaii, Manoa 

Drew Talley** 

San Francisco National Estuarine Research 

Reserve 

Jody Zaitlin 

Port of Oakland 

Kim Ward** 

California State Water Resources Control Board 

52
APPENDIX C 

Summary of the Hull-Borne Invasive Species Workshop 

May 11, 2005 

San Francisco, CA 

Though the full workshop presentations and discussions examined the issue of introductions through 

fouling on both recreational and commercial vessels, the summary here focuses on topics that apply to 

the commercial industry. This text was prepared by staff of the California State Lands Commission so the 

agency may move forward with additional discussions regarding management recommendations for 

commercial vessels, as mandated by state legislation. A more complete proceedings document will be 

produced, to be collaboratively developed with the California Sea Grant Extension Program. 

Morning Presentations

Greg Ruiz, Smithsonian Environmental Research Center: 

Hull-Borne Aquatic Invasive Species Overview: 

Dr. Greg Ruiz provided an overview on aquatic/marine/estuarine invasions, and specifically provided 

information on the relative importance of hull fouling and ballast water as vehicles for the introduction of 

alien species. Commercial shipping is the largest means by which species are introduced to North 

America. The rate of invasion due to this “vector” has increased exponentially in North America since 

1790. These increases have been largest on the Pacific Coast. Ballast water and fouling are, in turn, the 

dominant shipping sub-vectors responsible for the largest number of invasions. The number of invasions 

likely due to fouling is growing in North America, and the rate of invasions through this vector may be 

increasing as well. 

The Smithsonian has been conducting additional studies on the importance of the commercial vessel 

fouling vector. A preliminary estimate was conducted on the amount of vessel surface area arriving to the 

United States that may be colonized by fouling organisms. The estimate, based on vessel arrival data 

and vessel particulars from Lloyd’s Registry, suggested that some 130-150 million m2

 of colonizable 

surface arrived to U.S. ports annually between 1999 and 2001. The Smithsonian is also conducting 

fouling plate surveys at sites throughout the coastal United States, British Columbia, and Alaska. Plates 

made of PVC, plastic and wood are deployed at sites to collect fouling organisms, later retrieved, and 

attached organisms are identified. Such studies will allow researchers to better understand the 

relationship between the number of organisms transported to North America via shipping (propagule 

supply), and the number of organisms that successfully establish reproductive populations (invasion 

success). 

Scott Godwin, P.B. Bishop Museum: 

Marine Invasive Species Transported by Vessel Hull Fouling: Potential Management Approaches

Hawaii has been highly impacted by invasive species, with approximately 343 introduced through human 

mechanisms, and approximately 212 are believed to have been introduced via vessel fouling. In 2003, 

the state began formulating an information framework to minimize introductions through the fouling 

vector. Prior to stakeholder discussions, studies were conducted on the dynamics of Hawaii port arrivals, 

and field surveys of fouling communities to inform the stakeholder meetings. High risk vessels fell into 

those with regular, predictable arrivals, and those that do not behave regularly (stochastic): 

53
Stochastic, High Risk: 

• Towed Vessel Platforms (i.e. floating dry docks, barges, drilling platforms) 

• Derelict vessels 

• Decommissioned Military 

• Personal Craft 

Predictable, High Risk: 

• Towed Vessel Platforms 

The stakeholder input effort began with a 2-day workshop in February 2003, and continued during 

meetings held through July 2003. The overarching goal adopted was, “Minimize marine alien species 

introductions by hull fouling,” since absolute prevention (no introductions) was deemed less realistic. The 

management strategies ultimately recommended by the task force to achieve this goal fell into three 

categories: proactive, reactive, and post-event. 

• Proactive Measures: 

o Vessel traffic monitoring – to identify and respond to high risk situations 

o Strong inter-agency communication, particularly to assist with the monitoring 

effort of recreational vessel arrivals 

o Creation of a risk matrix (see notes below) to identify high risk situations that may 

warrant investigation 

o Education and outreach component to increase awareness of the issue with the 

maritime public 

• Reactive Measure: 

o Rapid response investigation of high risk events/vessels identified during the 

proactive stage 

• Post-event Measures: 

o Quarantine 

o Cleaning requirement & procedures for proper cleaning 

A very preliminary risk matrix was drafted to prioritize high risk events that may warrant investigation. 

Factors that lead to a high risk determination were: 

• Priority (high risk) vessels 

• Last port of call was outside of Hawaii 

• Vessel does not observe compliance standards, such as local codes of practice, or IMO 

International Safety Management codes 

• Length of time vessel was inactive or laid up (long time = higher risk) 

Ashley Coutts, Cawthron Institute (New Zealand): 

An Overview of the Management of Biofouling on Vessels in New Zealand. 

Vessel fouling is considered to be a very important vector for New Zealand invasives. Known invasives 

have originated from all over the world, with the top 3 source regions being the 

Europe/U.K./Mediterranean (48%), the United States (13%), and Asia/Japan (11%). 

Management of the vector was initiated due to a Russian fishing vessel that arrived in 1993, remaining in 

New Zealand for 18 months with 90 tones of fouling. Pre-border management controls that have been 

put in place since then are: 

54
Fishing Industry Codes of Practice: 

• All chartered foreign owned or sourced fishing vessels must be substantially free from plant 

or animal growth prior to entering New Zealand’s Exclusive Economic Zone (EEZ). 

• If it is not free of fouling, the vessel must be inspected and cleaned prior to departure. 

• If it arrives to New Zealand and inspections reveal the vessel to be significantly fouled, the 

vessel is cleaned in a manner that doesn’t release organisms to the environment. 

Outreach (primarily geared towards recreational boaters) 

• Distribute information packs in the Pacific Islands (where personal vessels often originate), 

and at popular ports of entry to New Zealand.

• Distribute materials in yachting magazines.

Hull fouling questionnaire on ballast water reporting form (commercial vessels) 

• When and where was the vessel last dry-docked and cleaned? 

• Has the vessel been laid-up for 3 months or more since it was last dry-docked and cleaned? 

If yes, state when and where? 

• Do you intend to clean the hull of the vessel in New Zealand? If yes, state when and where? 

Current Knowledge of Fouling: 

• Merchant vessels have been observed to carry a substantial diversity of fouling exotics. 

• Fouling extent is related to the age of paint, vessel speed, and voyage duration.

• Fouling is higher in sheltered areas or those lacking good antifouling paint coverage (i.e. recesses, 

dry dock support strips, sea chest gratings).

Current Research 

• En route survival of fouling organisms 

• Evaluation of organism viability after various cleaning methods are used 

• Fouling type and extent across various vessel types arriving to New Zealand 

• Efficacy of hull cleaning methods. 

Dragan Samardzic, Matson Navigation: 

Commercial Vessel Fouling Control 

Dragan Samardzic provided an overview of Matson’s corporate history, and characteristics of their regular 

trade routes to Hawaii and Guam from California. Fouling control is important to commercial shippers in 

order to protect the environment, reduce drag and save fuel, deliver goods more swiftly, and to protect the 

hull. Factors that affect fouling appear to be the type and condition of antifouling paint, locations where a 

vessel travels, the seabed type at ports and anchorages, and the speed of the vessel. U.S. flagged 

vessels typically go into dry dock approximately every 5 years for repairs, hull cleaning, and re-application 

of antifouling paint. As with Matson, hulls may be inspected more frequently by divers, and in-water 

cleaning occurs as needed. 

Sylvain Fillion, International Paint Company: 

Antifouling and Foul-Release Technologies 

Sylvain Fillion provided an overview of the major antifouling (biocidal) and fouling-release (non-biocidal) 

coatings and their ability to reduce fouling on commercial vessels. 

Biocidal coatings involve a “soluble binder” which is slowly released into the water and prevents 

organisms from attaching. The three main biocidal coatings are rosin-based, self polishing co-polymer 

(SPC), and a hybrid type (rosin/SPC combination). The best performing but most expensive are the SPC 

types, followed by the hybrid which is less expensive but less effective. The least expensive, but least 

55
effective biocidal coating is the rosin type, with an effective life of approximately 36 months on exposed 

portions of the hull. 

Fouling-release coatings (non-biocidal) do not contain soluble binders, and are ultra smooth coatings that 

offer lower frictional resistance, and require less coatings on a vessel when compared to their biocidal 

counterparts. With such coatings, organisms may attach, but are easily knocked off with vessel 

movement or gentle removal. Vessels show little fouling after 25 months (primarily slime). After 25 

months, vessels exhibit low amounts of fouling. 

Jason Savarese, National Sea Grant Law Center: 

Legal Overview 

 

Jason provided an overview of local, national and international regulations related to vessel fouling 

control, antifouling paints, and government bodies involved with invasive species policy development. 

Though regulations related to both commercial and recreational vessels were covered, the summary here 

highlights those policies that relate to commercial vessels. 

Regulations for Vessel Fouling: 

• Victoria, Australia: Vessels of less than 200 tons must discard fouled organisms on land. 

• New Zealand: Fishing industry has adopted codes of practice to clean vessels before leaving port, 

and require vessel maintenance and movement information from vessels in conjunction with ballast 

water reporting form (also see summary of presentation by Ashley Coutts). 

• Australian and New Zealand Environment and Conservation Council (ANZECC): Adopted codes 

of practice for commercial vessels that discourage in-water hull cleaning wherever possible (also see 

talk by Ashley Coutts). 

• United States: U.S. Code of Federal Regulation 33, and California law AB 433 requires rinsing of 

anchor chains of organisms at their place of origin, and regular cleaning of hulls, piping and tanks. 

Hawaii has formulated a management framework for the issue that may be lead to the 

implementation of policies in the future (see presentation by Scott Godwin). 

Antifouling Coating Policies 

• The International Maritime Organization: The convention on the Control of Harmful Antifouling 

Systems on Ships bans the use of organotins on vessels, or requires vessels to cover such coatings 

so they do not leach after January 1, 2008. However, ratification had not been achieved by the 2003 

implementation date, and the convention is not yet in force. 

• Other Countries have adopted regulations banning or restricting biocidal antifoulant use. Australia

banned Tributyl tin (TBT) in 2006. The Netherlands banned TBT for recreational vessels in 1999, 

but allowed its use on commercial vessels. After 2000, antifoulants many be used in the European

Union only after evaluation and approval. 

• In the United States, the EPA has adopted recommended TBT discharge values for application with 

the Clean Water Act and other EPA regulations. California, Washington and Alaska restrict the use of 

TBT on commercial vessels. 

Alternative Fouling Control and Water Quality Considerations: 

Jamie Gonzalez, UC Sea Grant Extension Program 

Though there is an international convention for the eventual phase out of TBT, biocidal copper-based 

paints will remain legal in many areas, and will likely be used quite commonly to prevent fouling. Due to 

56
the low circulation of enclosed basins and harbors, the leached metals build up in the water and 

sediments, causing various problems for organisms residing in them. A non-toxic bottom paint 

demonstration project was conducted by Sea Grant in San Diego on a small number of (recreational) 

boats, to test the efficacy of non-biocidal coatings. The results indicate that epoxy and ceramic-epoxy 

coatings may potentially last longer than copper paints, but require more frequent cleaning. In the long 

term they may be more cost effective under certain use conditions, though they are more expensive 

initially. 

Speaker Question and Answer Session

A brief question and answer session was held for participants to pose questions to speakers. 

In response to a question on their opinion with regard to the balance between water quality (especially 

with relation to biocidal paints) and the prevention of fouling, speakers suggested that; 1) the goals of the 

society should drive the management priorities, and 2) In the case of Hawaii, the management 

recommendations aimed towards minimizing fouling introductions did not conflict with the water quality 

regulations in place, but tended to compliment each other. The water quality issues were entrusted to the 

regulatory agencies that had more expertise and experience dealing with them. 

In response to a question about the typical hull husbandry practices of the whole commercial fleet, it was 

noted that international standards for the cleaning of vessels exist depending on vessel class. The U.S. 

fleet follows these standards. In the case of Hawaii, it was not the U.S. flagged vessels that typically 

posed the most risk. The “flags of convenience” vessels and foreign fishing vessels typically pose the 

most severe risk, though these comprise a small percentage of the entire fleet that arrive to Hawaii. 

Afternoon: Breakout Discussion Session 

During the afternoon, participants were separated into three discussion groups, each consisting of a mix 

of scientists, regulators, recreational vessel stakeholders, and commercial shipping stakeholders. Groups 

were asked to address five questions: 

1. Does vessel/boat fouling pose an invasive species risk that needs to be addressed? 

2. What needs to be considered in solving the problem of hull transport of invasive species by 

recreational and commercial vessels? 

3. Where, how, and when should vessels be maintained to prevent fouling ANS introductions? 

4. What information gaps need to be closed? 

5. What are the outreach and educational needs for AIS prevention in California for recreational and 

commercial boats? 

Following the breakout discussions, all participants were reconvened, and representatives from each 

presented a synopsis of their respective discussions. Points of general (but not necessarily unanimous) 

agreement or discussion are included in this summary. 

Question 1. Does vessel/boat fouling pose an invasive species risk that needs to be addressed? 

The majority of members in 2 of the 3 groups believed that fouling posed a risk that should be addressed. 

One group felt that fouling posed a risk, but the severity of that risk, and where the majority of the risk fell 

with respect to recreational or commercial vessels was unclear. 

57
Question 2. What needs to be considered in solving the problem of hull transport of invasive 

species by recreational and commercial vessels? 

• Because it is not possible to predict what the next problematic invader might be, because control is 

generally much more costly than prevention, and because eradication is not typically successful, 

consider a vector-based management approach that minimizes introductions via the fouling vector as 

a whole.

• Consider incorporating a risk-based system that prioritizes high risk vessels or situations. Factors 

that may be used to evaluate the risk of a vessel or situation to consider are:

o Vessel behavior (speed, sitting time)

o Vessel type

o Hull husbandry practices

o Season

o Age of antifouling paint

o Vessel voyage route

o Port region/location

• Consider a management framework based on the hull husbandry practices of vessels and boats (see 

question 3 below). 

• Examine existing program models (i.e. Australia, New Zealand, Hawaii) to observe lessons learned 

and to avoid pitfalls.

• Consider water quality issues and regulations with respect to biocidal coatings.

• Any management measures proposed should incorporate a level of simplicity.

Question 3. Where, how, and when should vessels be maintained to prevent fouling ANS 

introductions? 

Though there was no general consensus on what type of hull maintenance procedures should be 

adopted, discussions generated several potential practices that could be adopted, and the advantages 

and disadvantages of each. The points summarized below were topics that were raised by at least 2 

groups. 

• Periodically maintain antifouling coatings, with a preference for foul-release coatings (non-biocidal). 

One group suggested that coating application or cleaning periodicity could be certified to verify that a 

vessel has been maintained properly. At this time, however, it is recognized that non-toxic coatings 

are initially very costly, and are still currently undergoing testing and further development. 

• Remove fouling organisms regularly from hulls as well as from other areas such as sea chests, 

anchors, etc. Ideally for ANS prevention, this would be done out of the water, however, this process is 

expensive and time consuming. In-water cleaning is more common and less costly, but current 

methods generally result in the release of fouling organisms into harbors or ports. 

• One group suggested that a code for “Best Management Practices” could be adopted for fouling 

maintenance. 

• Another group suggested that vessels could be cleaned upon departure from California and inspected 

upon return. 

58
Question 4. What information gaps need to be closed? 

• The relative risk posed by vessels based on vessel type, vessel behavior, and port conditions that 

increase potential risk (i.e. location, temperature). 

• Current maintenance practices of vessels. One group suggested that this could be advanced through 

a survey that asks vessel operators or owners: 

o How long was the vessel at the last port of call? 

o When was paint last applied to the vessel hull?

o When was the vessel last in dry dock for hull cleaning?

• Extent of biofouling as it is affected by factors such as:

o Vessel type

o Hull maintenance practices

o Vessel activity

Question 5. What are the outreach and educational needs for AIS prevention in California for 

recreational and commercial boats? 

• In general, outreach and education was deemed to be very important, and was particularly advocated 

for and by the recreational boating community. Potential vehicles for outreach discussed, therefore, 

applied largely to the recreational community. Suggestions that could be applied to the commercial 

industry included: 

o Advertisements/articles in industry publications (magazines) 

o Distribution of posters and brochures to commercial community 

o Internet/email distribution of information 

• Communication between agencies involved with the shipping industry should be facilitated. In 

Hawaii, this is the major vehicle by which many high risk vessel movements are tracked (i.e. fishing 

vessels, barges, etc...). 

• Increased communication between scientists and commercial/recreational stakeholders regarding 

magnitude of the invasive species problem. 

59
APPENDIX D 

Summary of the California State Lands Commission 

Technical Advisory Group Meeting 

August 3, 2005 

Sacramento, CA 

Overview: Advisory Group Goals and Process

Following the welcome and participant introductions, a presentation was given of the technical advisory 

group goals (TAG), anticipated advisory group meeting process, and the information that will likely be 

considered for the final legislative report. 

TAG Function: As outlined in Assembly Bill 433 passed in 2003 (AKA “The Marine Invasive 

Species Act”), the function of this TAG is to serve as consultant to the CSLC in its analysis of the 

relative risk of non-ballast, commercial vessel based vectors for the release of nonindigenous 

species to California waters. Further consultation with the U.S. Coast Guard and the State 

Water Quality Control Board is also mandated by the legislation. The CSLC will then submit a 

report summarizing an analysis and recommendations to the state Legislature by March 1, 2006. 

Source of Report Input: The CSLC anticipates several sources of input for the final legislative 

report. In addition to TAG discussions, these will include: 

• Review of scientific and grey literature on vessel fouling. 

• Marine Bioinvasions Conference Discussions: The U.S. Coast Guard and Biosecurity New 

Zealand organized an informal discussion on the risk and management of vessel fouling for 

species introductions at the 4th Biennial Marine Bioinvasions Conference in New Zealand. 

The CSLC will participate, share information with the TAG, and incorporate applicable 

information into the report. 

• Analyses of existing California vessel arrivals data. Additional analyses may also be 

completed and/or considered, but will be dependent on data availability, information needs 

uncovered, and time constraints. 

Anticipated Framework for TAG Meetings

Though this framework is subject to modification, it is anticipated that a total of 4-5 TAG meetings 

will be held through December 2005 or January 2006. The first few meetings are or were 

intended to mutually inform all TAG participants, so discussions may proceed from a base 

knowledge of the issue. The current meeting continues the information sharing process begun 

during the joint workshop held on May 11, 2005 (see attached summary). The 3rd meeting will be 

scheduled for late September or early October, during which discussions will begin on 

recommendation frameworks. The 4th meeting is anticipated for November or December 2005, 

and will likely continue discussions around potential recommendations. If consensus or majority 

recommendations are not reached, a final 5th meeting will be held in early January. 

Review of May 11th Workshop

An overview was given of speaker presentations and break-out group discussions from the May 11th 

workshop. Major points presented by speakers that applied to the commercial vessel side of the issue 

were reviewed (see attached workshop summary, and power point presentation from the August 3rd

meeting). 

60
 “Non-Ballast, Vessel-Based Vectors”: What should this include? Can the list be prioritized?

AB 433 lists several explicit areas on a vessel that shall be considered during the risk analysis of fouling 

introductions. These, “...include, but [will] not be limited to, hulls, sea chests, sea suction grids, other hull 

apertures, in-water propellers, chains, anchors, piping and tanks.” The group was asked to discuss the 

list, if any area of importance should be added to the list, and if the items could be prioritized. 

 “Non-Ballast, Vessel-Based Vectors”

Two additional vessel areas/categories were suggested as a component to consider with the AB 

433 list: rudders, and “non-hull protected areas”. Non-hull protected areas would include 

regions of a vessel that are sheltered from water shear forces when a vessel is underway, such 

as bow thruster tunnels, rope guards, intakes or grills. Ashley Coutts noted that he has observed 

organisms in these anomaly areas during the course of his research. It was suggested that an 

alternative method for organizing vessel regions according to risk could be to split items into 

“laminar areas” (lower risk, i.e. exposed hulls) and “protected areas” (areas protected from shear 

forces – higher risk). 

It was asked if the mandate was intended to include NIS transport connected to the transfer of 

goods, for example, those that may be moved with pallets or in packing material. 

It was also noted that organisms which do not attach to the vessel surface and are thus not 

technically “fouling” organisms, may also pose a risk for introductions (Miller). These may be 

located on interstitial areas of the vessel or within sea chests, and are associated more frequently 

with slow moving vessels. For example, Ashley Coutts found large mature organisms, including 

decapod crustaceans (i.e. crabs) in sea chests. 

Prioritizing Parts of a Vessel: 

In many cases, the categorization of parts of a vessel into higher or lower risk categories was 

complex, as several factors interact with each other. A risk determination, therefore, will often 

depend on a number of variables acting in concert (i.e. location on a vessel, maintenance 

practices, vessel behavior, vessel location, etc.). In general, highest priority vessel parts could be 

considered a higher risk on all vessels, regardless of other factors. Lower priority areas on are 

likely low for many vessels, but could be considered a high risk on some depending on other 

factors. For example, the laminar hull of a fast moving vessel (low risk factors) that hasn’t been 

repainted in some time and has spent substantial time in its last port of call could pose a 

significant risk. 

Given these complications, areas that are likely of higher risk would include: 

• Hulls: Laminar areas where antifouling paint coating is thin or old (i.e. dry dock support 

strips). Portions sheltered from shear forces. 

• Sea Chests: Extensive fouling communities including large mobile organisms have been 

observed to inhabit sea chests. 

• Sea Suction Grids: Intake grids have been observed to accumulate fouling.

• Non-Hull Protected Areas: described above.

• Rudders: Areas sheltered from shear forces, such as the stem, can accumulate fouling.

Though the designation of risk could depend on other interacting variables, lower risk areas may 

include: 

• Laminar Hull areas that are well maintained (cleaned and painted). 

• Rudder areas that are well maintained (cleaned and painted) and subject to the shear forces 

of the propeller. 

61
Several of the items listed in AB 433 required clarification, and more information will be obtained 

prior to the next meeting in October. 

• Tanks: It was unclear what type of tank this refers to (i.e. ballast, grey water?) 

• Piping: It was unclear if this referred to the areas around intakes and outtakes or all piping. 

For some vessel regions, the relative risk for fouling accumulation was unclear due to lack of 

knowledge or research: 

• In-Water Propellers: Could be a lower priority due to the movement of the propeller, and 

safety issues associated with a fouled propeller. Chevron noted that they coat propellers with 

self-polishing antifouling paints (Chapman).

• Anchors: Some companies, such as Chevron, equip vessels with automatic mechanisms 

that rinse anchors with ambient port water as they are brought aboard (Chapman). 

• Rudders: It is suspected that main portions exposed to shear forces may pose a lower risk, 

while protected areas may accumulate fouling (Coutts). 

Environmental Characteristics That Influence Fouling

A pre-prepared list of characteristics was created based on the May 11th workshop, and the TAG was 

asked if there were environmental factors that would result in more or less fouling on a vessel, and if 

these could be prioritized. As with the prioritization of locations on a vessel, the relationship between 

level of fouling and environmental factors can be complex. Numerous variables likely interact and result 

in varying amounts of fouling, and varying rates of species survival. 

Osmotic (salinity) and temperature stresses may be an important driver for the survival of 

organisms associated with vessels, and should be considered. It was noted that the relationship 

between survival and these variables is very complex, and more research needs to be conducted 

to better understand them. Several points for consideration were discussed. 

• Rapid and dramatic changes in salinity or temperature are stressful for many organisms. 

In a management context, vessels arriving to the Great Lakes from high salinity ports, for 

example, may be a lower concern than those from other freshwater ports. Conversely, it was 

noted that voyages within the same latitude (similar temperatures) have been found to be 

especially problematic in New Zealand (Coutts). 

• Some organisms are adapted to tolerate wide fluctuations in temperature and salinity. 

The issue was raised that, in theory, transits to and from high and low salinity organisms may 

serve to select for the hardiest NIS. Widely fluctuating conditions could possibly result in 

vessels arriving to port with organisms that are the most tolerant and thus more likely to 

invade. 

• The frequency and duration of freshwater exposure is important for seagoing vessels 

(and organisms). Vessels that arrive to Portland, then sail to freshwater portions of the 

Columbia River, and thereafter return to Portland, are observed to be less fouled than when 

they initially arrived (Davidson). Also, observations from international voyages to and from 

Alaska, suggest that trips shorter than 12 hours are related to better survival (Coutts). 

In addition to the physical tolerances of potential NIS, the variability of environmental salinity and 

temperature can be complex, and can be influenced by a number of factors that are not as 

straightforward as season or latitude. Several considerations were discussed. 

• Salinity will generally decrease in port areas during periods of high rain or snowmelt. 

This occurs, for example, in Alaskan harbors. Conversely, periods of little freshwater input 

will generally result in higher salinities. 

62
• Depth of vessel keel: A deeper keel would expose an organism to higher salinities, relative 

to shallower portions. Even if a vessel enters an estuary with a fresh surface salinity, deeper 

portions of the estuary and the vessel may experience higher salinities. Temperature, 

likewise, will vary with depth. 

• The sea chest environment may experience wide temperature and salinity fluctuations, 

as ambient water is taken into a vessel through it for vessel operations. Nonetheless, they 

have been observed to have significant fouling communities. 

Bottom Type

During the May 11th workshop, invited speaker Dragan Samardzic of Matson Navigation indicated 

that the harbor seafloor type is a factor that influences fouling, but the TAG was unfamiliar with 

this relationship. Lisa Swanson will touch base with Dragan and clarify. 

Vessel Behavior and Maintenance Practices That Influence Fouling

As with environmental characteristics, the TAG was asked to discuss and prioritize vessel behaviors and 

maintenance practices that influence fouling. Research by Ashley Coutts revealed a striking relationship 

between the age of antifouling paint, voyage speed and voyage duration. Again, fouling levels can be 

influenced by several factors acting together, and consideration of any one alone would not be adequate 

to evaluate risk. In general the priority factors were considered to be: 

• Vessel Inactive/Layover Time: The more frequently a vessel is sedentary, the more fouling 

it accumulates. 

• Vessel Speed: 

o “Fast” vessels traveling approximately 15 KTS or faster may be considered a 

lower risk. Vessels traveling at 22 KTS or above for at least 3 hours has very 

little fouling (Coutts). 

o “Slow” vessels traveling approximately 10 KTS or slower are a high risk. 

Vessels that typically travel at 3 knots or less will have extensive fouling. 

• Age of Paint: The older the antifouling paint, the higher the fouling. Studies in Tasmania 

indicate that copper based antifouling coatings less than 663 days old had the lowest levels 

of fouling (Coutts). Thereafter, fouling increased dramatically. 

• Voyage Duration: Shorter voyages pose a higher risk. 

• Age of Vessel/Vessel Flag: This factor is often correlated with the maintenance practices of 

the vessel owners. Companies that can afford new vessels, are also more able to keep them 

well maintained, and less fouled. These are also often correlated with the vessel’s country of 

registry (Coutts). The maintenance of vessels are very dependent on operators, and poorly 

managed vessels/companies (i.e. irregularly scheduled, irregularly routed tramp vessels) 

should be a priority (Chapman).

• Last Port of Call: In New Zealand, a last port of call with a similar latitude is considered a 

higher risk.

Hull Maintenance and Vessel Classification Societies

John Berge of PMSA provided the TAG with information on classification societies, and their relationship 

to vessel hull maintenance. Classification societies are private (non-governmental) organizations that 

establish and apply vessel design and maintenance standards for vessels. Societies certify vessels that 

are maintained according to rules established by that society for a particular vessel type. The vast 

majority of the world fleet belongs to one of the 10 major societies, as current certification is important for 

insurance purposes. 

63
Classification society rules include requirements for periodic hull maintenance. Though these are 

directed towards ensuring safety and structural integrity rather than NIS prevention, the frequency with 

which most vessels routinely clean hulls are dependent on the requirements of their classification. Prior 

to this meeting, John Berge conducted an informal survey of PMSA members on their hull cleaning 

practices, and those that responded (5) indicated that they typically follow the requirements of their 

classification society. In general these are: 

• Dry dock every 5 years with extensions possible with favorable interim in-water inspections. 

• Interim in-water inspections and cleanings (diver): 

o Self polishing coatings: 24-36 months after dry dock 

o Other Coatings: Every 6 months. 

Dry docking occurs more frequently under certain circumstances: 

• As a vessel ages, societies generally require more frequent out-of-water inspections 

• In the event of an emergency, or an incident that raises concerns for hull integrity (i.e. significant 

scraping or bumping) 

Due to the scarcity of dry docks available scheduling is very difficult, so vessels are generally not dry 

docked more frequently than needed or required. Dry docking is also expensive. Brad Chapman 

indicated that for Chevron, each day in dry dock costs approximately one million dollars for the docking, 

cleaning, and vessel repairs. 

There is generally not a requirement to recoat antifouling paint during required dry docking intervals, 

however, most operators take advantage of the opportunity to clean, and paint or touch up their hulls. 

Cleaning and repainting during these periods is also in the best interest of the operators, due to safety 

concerns and costs associated with reduced fuel efficiency from fouled laminar hull areas. Many vessels 

conduct frequent performance tests to evaluate fuel efficiency, and conduct in-water (diver) cleaning 

accordingly (Berge). In-water cleaning takes approximately 1 day (Chapman). 

Special Area Requirements: Vessels operating in certain areas or routes may also be required to 

maintain vessels more frequently. For example, all vessels operating in Alaska’s Prince William Sound 

are inspected annually, and are taken out of the water every two years (Chapman). 

Sea Chest Maintenance: Sea chests are coated and/or cleaned less frequently than laminar areas, as 

they are generally of less concern for fuel efficiency, and can only be accessed during dry dock. 

Cleaning may occur once every 10-15 years as needed, and the sea chest of a vessel nearing the end of 

its operational life may not be cleaned or painted. 

Action Items

• Clarify definition of items from AB 433 list of parts of a vessel that should be considered: 

“tanks” and “piping” 

• Determine if AB 433 applies to NIS introductions related to vessel cargo. 

• Locate upcoming paper by J. Crooks that observed that NIS had a survival advantage over 

natives in harbor environments with relatively high contaminant concentrations. (Tally) 

• Locate paper by Michin on the temperature and salinity conditions that trigger fouling 

community spawning events. 

• Lisa Swanson will clarify with Dragan Samardzic regarding the relationship between sea 

bottom type and fouling. 

• Contact Keith Hayes who has been studying risk assessment models for NIS based on 

environmental factors. 

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APPENDIX E 

Summary of the California State Lands Commission 

Technical Advisory Group Meeting 

October 13, 2005 

Sacramento, CA 

West Coast Ballast Outreach Project Update

Following welcome and introductions, Holly Crosson, Project Coordinator for the West Coast Ballast 

Outreach Project (Sea Grant Extension) provided a program update. The project has received funding for 

3 additional years, during which Holly and Program Representative Nicole Dobroski will continue the 

outreach mission of the project. Planned activities include: 

o Updated reprint of the “Stop Ballast Water Invasions” poster and associated brochure 

o Re-initiation of the Ballast Exchange newsletter with expanded distribution 

o Coordination with the California Maritime Academy on the development of a ballast related 

seminar series 

o Creation of a new project website 

Though the program’s grant directs that the Project’s efforts be focused on ballast water, there is the 

potential for other NIS issues, such as vessel fouling, to be addressed to a lesser extent. 

TAG Input Framework – Meeting Goals

The overall framework for the TAG input process was reviewed. The goals of this third meeting were to 

examine existing management frameworks in other countries/states for vessel fouling and to discuss 

options for the California to consider. Staff intends to utilize discussions from today’s meeting to 

construct “straw-men” management scenarios for discussion, criticism, deconstruction and/or revision at 

the next (4th) meeting, planned for November or early December. 

The TAG’s final input to the CSLC is not required to be in any specific format. Considerations put forward 

may be explicit or general (i.e. guideline-like), and the final format will be up to the TAG. It does not 

necessarily need to be presented in a written document. AB 433 states only that the CSLC must consult 

with an advisory group (the TAG), and consider this input during the formulation of recommendations for 

the report to the state Legislature. 

Action Items from Prior Meeting (August 3, 2005)

Non-Ballast Vessel Based Vectors List: Linda Sheehan (California Coast Keeper) was 

contacted for clarification on intent of AB 433 with regard to the type(s) of piping and tanks that 

were meant for consideration by this TAG, and if cargo-related NIS (such as those associated 

with packing material) were intended for consideration. She indicated that the terms were meant 

to have broad application towards anything that may involve NIS. 

The Animal and Plant Health Inspection Service (USDA) announced that as of September 16, 

2005 wood packing material (i.e. wooden pallets, boxes, crates, etc.) must be heat treated or 

fumigated prior to entering the United States to reduce the risk of pest introductions. The APHIS 

regulation would presumably address the issue of introductions via packing materials. 

A question was raised weather recreational boats carried on commercial vessels might be subject 

to consideration by the TAG, for example, if they were fouled and later placed in a California 

65
harbor. Dragan Samardzic noted that during his years working on commercial vessels, he had 

never witnessed such a situation. 

Fouling NIS Survival and Copper Contamination: Jeff Crooks summarized the findings of his 

recent study that compared the diversity of nonindigenous, and native fouling organisms in the 

San Francisco Bay Area (Tiburon) when exposed to varying concentrations of copper 

contamination. The results indicated that the diversity of natives declined with increasing 

contamination, while the diversity of NIS did not. These results suggest that contamination may 

have some bearing on the vulnerability of a system to invasion, in addition to traditional factors 

such as propagule pressure (number of organisms). The results are currently being drafted into a 

manuscript for publication. 

NIS Transfer from Vessel to Port (Michin and Gollasch 2003): Ian Davidson provided a copy 

of a paper suggested during the last meeting, which described the effects of temperature on 

fouling introductions. Four mechanisms by which organisms attached to vessels can be 

transferred to a recipient port were also described: 

1. A rise in sea temperature less than 3.6 oF can trigger a wide range of species to spawn 

2. Mobile species associated with fouling communities, such as crabs, can simply drop off 

3. In-water cleaning releases viable organisms from a vessel to the water column or sea floor 

4. The waste disposal practices of dry dock facilities may result in NIS discharge with effluent to 

a port. 

The waste disposal practices of commercial dry docks in California are governed by National 

Pollutant Discharge Elimination System (NPDES) permits issued by the Regional Water Quality 

Control Boards under the authority of the Clean Water Act. The San Francisco dry dock is 

prohibited from discharging effluent directly into the waters of the state. Following repair 

operations, wash-down water is collected in holding tanks and discharged into the City of San 

Francisco’s Treatment plant. Since the Regional Boards may have varying requirements for such 

discharges, Staff will investigate disposal practices of commercial dry docks located in Southern 

California. 

Sandy Sea Bottoms and Fouling Accumulation 

Dragan Samardzic clarified that the information shared during the May 11th workshop (vessels 

moored in sandy bottom areas tend to accumulate fouling faster than in other areas) was based 

on personal observation from his years working in the merchant shipping industry. 

Styela Clava (a Sea Squirt) Invasion in New Zealand

Ashley Coutts shared news on a recently discovered invasion of a sea squirt to New Zealand. In August, 

the presence of Styela clava in Auckland (North Island) was confirmed by a scientist visiting from the 

United Kingdom for the Marine Bioinvasions Conference. Since then, it has also been observed in 

Lyttleton Harbor (South Island). 

The species devastated the Canadian mussel aquaculture industry by smothering mussel lines and 

competing for food, resulting in a ~40% loss of production. There are concerns that it may cause similar 

impacts to New Zealand’s mussel farming industry. Originally from Korea and introduced to Australia in 

the 1970’s, the New Zealand invasion likely originated from Australia via vessel fouling. Larvae are only 

viable for 24 hours, and are thus not likely to have been transported via ballast water. A survey is 

currently underway to ascertain the geographic extent of the invasion, and to decide what management 

measures might be taken. 

Existing Vessel Fouling Management Practices (See appended Table, pg. 8)

A table of management practices considered or adopted in other states/nations was distributed to the 

group prior to the meeting, and quickly reviewed. Strategies included: 

66
• Codes of practice (antifouling paint application, cleaning periodicity, in-water cleaning 

restrictions/bans) 

• Survey (New Zealand): vessel behavior/maintenance 

• Risk-Assessment 

• Regulations (Australia, vessels <25 m): Requirements for hull condition prior to entering 

Australian waters 

Clarification of Merchant Classification Society Requirements: (See amended table, pg. 8). 

(Samardzic) The periodicity of interim in-water cleanings are not mandated, but are generally 

completed as noted in the table (every 2-3 years for self-polishing coatings), and are typically 

dictated by fuel consumption performance. Frequency of diver inspections is typically dependent on 

company requirements (Matson performs these quarterly). 

Companies strive to control levels of fouling, as heavy fouling can only be removed through scraping, 

often down to exposed metal. Hard scraping removes antifouling coatings, eliminating protection 

from future attachment, and vessel operators prefer to avoid it. For example, Dragan Samardzic 

once observed vessels that had been stationary for 3-9 months in the tropics that had accumulated 

incredibly large and thick fouling organisms (esp. barnacles). Such fouling can only be remedied via 

scraping. It is uncommon to observe operators that continue running vessels without regard to 

fouling control. (Samardzic) 

Effectiveness Codes of Practice and Surveys (Coutts, New Zealand): It was asked whether 

there was some sense for how widely applied and how effective non-mandatory codes of practice 

where. Initially, compliance was limited; however, compliance appears to have increased even 

without government enforcement for several reasons: 

• Growing public awareness and support for biosecurity – education and outreach are very 

important 

• Industry/company desire to avoid the hassle and embarrassment of being responsible for a 

new introduction (i.e. 1993 Russian trawler) 

• The point above appears to have resulted in some level of industry self-policing 

The vast majority of commercial vessels are clean, with the exception of the difficult to reach 

nooks and crannies on any individual vessel. The majority of ocean-going recreational boats (i.e. 

yachts) are also clean, as most owners have the incentive and financial ability to maintain them. 

It is the exceptional, stochastic vessel types/events that pose the most risk, such as vessels that 

travel at slow speeds, military vessels that are sold or moved after being laid up, the small 

minority of vessels/owners uninterested in maintenance, etc. It was this logic that led to the 

development of the Hawaii risk matrix. 

The survey included on the ballast water declaration appears to serve mainly as an information 

gathering tool, rather than for targeted investigation or enforcement. By the time a form is 

received and processed, the vessel has typically departed. 

Can it be assumed that risk factors observed in New Zealand apply to California? 

(Ruiz) With the caveat that direct studies are lacking the Northern Hemisphere, it is likely that, in 

general the characteristics of highest risk vessels for California will be very similar to those in 

New Zealand (slow movers, long lay-up). Also as in the Southern Hemisphere, the expectation is 

that fouling on any given vessel will be generally low with small “hot-spots” of heavier fouling (the 

“nooks and crannies”). However, the specific magnitude of risk for North America is not clear. 

Even for the Southern Hemisphere where the majority of recent research has been conducted, 

studies are limited, covering small sample sizes, a limited number of vessel types, vessel 

behaviors, cleaning practices, and routes. How the diversity of fouling organisms on vessels in 

North America will stack up is unknown. 

67
Priority Research Questions and Information Needs

Given the lack of research/information on vessel fouling as a NIS vector in North America and California, 

CSLC anticipates that further data gathering will likely be included as a recommendation. The TAG was 

asked which questions might be the most important for directing future management options and for 

furthering the basic science of the field. 

Surveys on the species and extent of biota arriving to California ports via commercial 

vessel fouling were considered one of the highest priorities. Discussion indicated that such 

studies should be coupled with information on several vessel variables to elucidate relationships 

with NIS introduction risk: 

• Vessel type – include a broad cross section of vessel types 

• Vessel behavior - voyage speed, lay over time, etc. 

• Maintenance practices - frequency of in-water cleaning and out of water cleaning 

• Transit route(s) – prior ports of call. Supplemental information could be obtained from the 

USCG for the last 3 ports of call. 

• Antifouling coating age and type - (Coutts) As the phase out of TBT-based coatings 

proceeds, invasion patterns may shift in response to increased use of Copper-based 

coatings. (Samardzic) Many companies have already moved away from TBT coatings. 

(Gates) As of 2005, TBT paints could not be sold in the U.S., and all vessels must have 

sealed (covered) or removed such paints by 2008. 

Aquatic Bioinvasion Research and Policy Institute (ABRPI), a partnership between the 

Smithsonian Environmental Research Center and Portland State University, are currently 

initiating a study with funding from CSLC, which intends to address many of the above priority 

research. Current research aims to: 

• Estimate “wetted surface area”, or vessel surface area that may be colonized by fouling 

organisms, that moves into and out of U.S. West Coast ports. 

• Investigate pilot methods for biological surveys of fouling organisms across vessel types 

coming into and out of these same ports. 

Future components of the research would include a characterization of fouling communities 

across vessel types, source ports (transit route), and vessel behaviors (maintenance, residence 

time, etc). Together, these data sets would then enable an analysis of the overall magnitude of 

NIS moving through West Coast Ports. 

Information on vessel operations and maintenance factors tied to fouling: Information on 

vessel activities that might influence fouling extent and accumulation was considered a high 

priority, and would be extremely useful if combined with biotic surveys of fouling (described 

above). Such information could be collected via a vessel survey, with questions related to dry 

docking, cleaning, painting, and/or laid-up periods, etc. 

Potential survey in conjunction with CA SB 771: California Senate Bill 771 passed in 

September (2005) requires the CSLC to conduct a 1 year survey of arriving vessels for 

greywater/blackwater discharge issues. The CLSC could devise 2-4 targeted fouling 

related questions in consultation with the scientific community, and add them to this 

survey. This approach would minimize the number of forms required of arriving vessels, 

and would collect information that could compliment the biotic surveys. 

Information could also be gathered through shipping agents, CSLC inspectors, and 

coordinated communication with USCG. 

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Fouling on military vessels: Virtually nothing is known about the fouling levels on military 

vessels, though some likely exhibit high risk behaviors. For example, vessels in the “Mothball” 

fleet (out-of-service military vessels) have been moored in Suisun Bay (San Francisco Bay 

Region) for extended periods, and likely contain substantial fouling communities. Transport of 

such vessels would constitute a high risk event. Unfortunately, research access to military 

vessels is extremely difficult to obtain. In addition, AB 433 specifically exempts military vessels 

from its authority, and they are instead subject to the Uniform National Discharge Standards for 

Vessels of the Armed Forces. 

Cruise/passenger vessels have been observed to have substantial communities in sea chests, 

and their voyage patterns may be of particular importance. Such vessels tend to visit pristine 

areas (marine parks, wilderness areas) that may require higher levels of protection. They make 

frequent trips on regular routes to international locations (i.e. California to Mexico, California to 

Canada), increasing NIS exposure from specific regions (repetitious inoculations). 

Stochastic, theoretically high risk vessels, such as slow moving towed structures, foreign 

fishing vessels, derelict vessels, should be examined or monitored in California, due to the 

disproportionately high risk they present in Hawaii and New Zealand. For California, towed 

drilling platforms may be of particular interest as these may occasionally be moved to other 

regions in the U.S. and Canada. 

Role of route and freshwater exposure: There is evidence that freshwater exposure 

dislodges/inactivates many organisms attached to vessels, suggesting that seagoing vessels that 

spend some period in freshwater may pose a lower risk in some situations. This effect, and its 

implications for NIS introduction potential, should be investigated. 

Colonization from vessel to port: The mechanisms by which organisms may transfer from a 

visiting vessel to a recipient port, through spawning or in-water cleaning for example (Michin and 

Gollasch 2003), are important research areas, however, may be of less immediacy given 

information gaps in more critical areas. In the meantime, it would be good to assume that high 

levels of fouling on a vessel equate to high risk for introduction to a port. 

Long term monitoring of NIS, such as the CDFG coordinated monitoring, should clearly be 

continued. Long term monitoring will be key to evaluate how invasion patterns change with 

ballast water management, ballast water treatment, and the phase out of TBT. This will also be 

the primary information needed to attempt to evaluate the effectiveness of management activities. 

Potential Management Strategies for California

The TAG was asked to discuss the following question, “Considering what’s known/not known about 

fouling and other non-ballast water vessel vectors, what management strategies should or could 

California consider?” 

Further research and vessel operational/maintenance information collection via surveys 

(as discussed in the prior section): 

o Clear priority 

o Some members felt that more information and/or research was needed before 

regulations or restrictions should be implemented. 

Codes of Practice: 

o At a minimum, these should be developed rather than postponing action until more 

information is gathered. These could be particularly important if it is decided that it is 

premature to implement restrictions or regulations. 

o Could expand upon the maintenance requirements of merchant classification societies. 

69
Requirements for regular sea chest painting and cleaning 

o It was noted that most vessels currently paint sea chests every 5 years. 

o Water used to cool a vessel’s engine is brought in through sea chest openings. 

Chlorination systems typically operate to keep cooling system components unobstructed 

by growth, and sea chests are exposed at some level to the de-fouling action of these 

systems. 

o However, researchers have observed that some sea chests are very clean while others 

are not. Since many vessels have multiple sea chests, it may be that the operational 

condition of chlorination/cleaning systems varies in each one, or that the exposure of sea 

chests to these systems varies. 

Support or incentives for the development of in-water cleaning technologies that eliminate 

or reduce organism release into the water. There are a small number of technologies in 

developmental stages that reduce particle release during in-water cleaning; however, none are 

known to be ready for commercial distribution: 

o U.S. Navy (Jerry Bohlander) – First presented the development of a technology some 

years back, but current status is unknown.

o 2 companies in NZ claim they have a technology developed that contains organisms as 

small as 60 microns. System testing will begin in November (2005), and the results may 

be available in approximately a year.

A major disadvantage of these prototype systems is that they have difficulty reaching the 

recesses & crevices where fouling is commonly highest. They perform best on exposed laminar 

surfaces, where fouling is generally the lowest. 

Though the ANZECC and some Australian ports promote codes of practice that prohibit in-water 

cleaning, it’s not clear that such prohibitions are beneficial in all situations (i.e. on heavily fouled 

vessels). In-water cleaning bans also do not a create win-win situation for environmental 

protection and commercial shippers. Support or incentives for the development of in-water 

cleaning technologies have the potential to create a mutually beneficial solution for all parties 

Define parameters for a risk matrix, and implement action on high risk vessels. Since the 

vast majority of the arriving fleet will likely present a low risk, it was suggested to focus attention 

on infrequent, high risk occasions (poorly maintained, slow movers, extended sitters). Some 

suggestions for action that could be taken were: 

o Inspection 

o Cleaning requirements/case-by-case permits for cleaning 

o Quarantine 

o Restrictions on port activities 

Outreach and Education: An outreach and education component to the merchant shipping 

industry should be included as part of any recommendations. 

 

70
APPENDIX F 

Summary of the California State Lands Commission 

Technical Advisory Group Meeting 

December 19, 2005 

Sacramento, CA 

Proposed Vessel Dismantling Operation in Oregon & Suisun Bay Mothball Fleet 

Ian Davidson provided a brief overview on the developments related to a proposal by Bay Bridge 

Enterprises to establish a ship dismantling operation in the Port of Newport, Oregon. Should the proposal 

move forward, the deactivated vessels from Suisun Bay (AKA the “Mothball Fleet”) may be moved to 

Oregon for deconstruction. Originally, relocation was planned for February, but has been postponed due 

to vocal opposition over the potential for contamination and NIS introductions. It is likely that an EIS will 

be prepared, and the TAG was asked monitor the federal register notice for the EIS and send comments. 

It is unclear which federal or state environmental regulations will have to be followed prior to relocation 

efforts since most, if not all of the fleet is composed of military vessels. Kim Ward indicated that if 

California state water quality issues come into play, jurisdiction and oversight would fall to the Regional 

Water Quality Control Board. Karen McDowell volunteered to find out if anyone from the RWQCB has 

been monitoring the issue. 

Several related newspaper articles from the Oregonian, Portland’s main newspaper, were distributed to 

the group. A December 18th article focused specifically on the issue of potential fouling NIS introductions 

through the relocation activities. Quoted representatives from the Maritime Administration (MarAd), and 

from the Texas Parks and Wildlife Department (where some vessels have already been moved) were 

unaware of the hull fouling issue. 

Hull Husbandry Survey for 2006 

As discussed during the last TAG meeting (October 13th), 4 questions related to the hull fouling 

husbandry/fouling control practices were formulated with input from members of the TAG from the 

scientific community. The questions are designed to supplement biological studies, and were distributed 

in conjunction with the 2006 California Clean Coast Act survey (see attached document). 

The distribution of the survey was targeted at vessels arriving to California, however, it was noted that it 

would be advantageous if the hull husbandry survey could be distributed more widely. The CSLC 

welcomes other states to utilize the survey if they are interested. It was noted that vessel identification 

was missing from form, and the IMO number and vessel name will be added to an amended form. It was 

also noted the specificity of the question about the type of antifouling treatment applied was unclear 

(Chapman). If the form is revised, the question and/or the instructions for this question may also be 

revised. 

 

Overview of TAG Discussions Thus Far 

Throughout the TAG discussions since May, several considerations have been identified that frame the 

development of recommendations 

• Vessel fouling poses an NIS risk that needs to be addressed 

• Specific knowledge on the nature of fouling risk factors for N. America and California is very 

limited 

• There is generalized knowledge on fouling risk factors, based on studies conducted in New 

Zealand and Hawaii 

71
• Dry docks are in high demand and booked well in advance. There is little flexibility for unplanned 

scheduling. 

• Biocidal antifouling paints pose water quality problems 

• Much of the merchant fleet is well maintained, and likely pose lower NIS risk 

• Occasional/stochastic vessels likely pose significant NIS risk 

During the last TAG meeting (October 13th) several potential management frameworks were discussed 

and prioritized in very broad terms. These were: Information gathering/research, codes of practice, sea 

chest maintenance requirements, incentives/support for in-water cleaning technology development, and 

regulatory action on stochastic high risk vessels. 

Straw-Person Management Options 

Based on discussions from the October TAG meeting, Staff formulated a set of straw-person 

management scenarios to generate discussion and constructive criticism during this meeting. TAG 

members were asked to provide feedback on why options were favorable or not, if or how an option might 

be improved, and to consider which management ideas might be appropriate both for now and for the 

future. Scenarios ranged from education and outreach to regulatory action, and were distributed on a 

handout (see attached document). These were then discussed systematically by the group. 

Discussion: Straw-Person Management Options – Outreach 

It was noted that a lack of knowledge on fouling and associated NIS risk was underscored by the Oregon 

ship dismantling operation controversy. It will therefore be important to increase awareness amongst 

agencies or companies that may be involved in activities that pose a high fouling risk, and with state and 

federal entities involved in policy development and decision making (Ruiz). 

Discussed entities that may warrant targeted outreach, and avenues for reaching them were: 

Commercial Shipping Industry

• Target Companies: salvage operations, dry dock facilities, oil platforms, vessel towing 

companies 

• Articles for industry publications such as Pacific Maritime, and maritime listservs 

• Commercial dive companies that clean and inspect vessels 

UC Sea Grant Extension/West Coast Ballast Outreach Project has several initiatives planned that 

may be potential avenues for outreach: 

• Seminar series in conjunction with the California Maritime Academy - the fouling issue could 

be a topic area covered. 

• Advisory Committee meeting January 17th for input on NIS issues and outreach 

recommendations 

• Regular mailings and/or distribution of pamphlets could include fouling education materials, 

for example, an insert in the ballast water brochure 

• Special workshop organization and coordination. 

• Inclusion of fouling information on their website 

• Articles in their newsletter 

State Resource Agency Networks:

• California Association of Professional Scientists (state scientist union) 

72
• Western Regional Panel of the ANS Task Force meetings are organized by Susan Ellis 

(California Department of Fish and Game) however, this group meets somewhat irregularly 

and informally

Federal Agency Priorities and Information Networks

• Maritime Administration: has an environmental officer for the western region. Dragan 

Samardzic will locate his contact information. 

• ANS Task Force is composed of a network of federal agencies for the purposes of 

coordination and communication. Scott Newsham (executive secretary, ANS Task Force) 

may be a good contact. 

• Additional agencies that should be priority outreach targets: U.S. Army Corps of 

Engineers, Military, Fish and Wildlife Service, Minerals Management Service 

• Outreach to legislators, such as Sununu and Boxer through letters or other avenues.

• Washington DC meetings/briefings geared towards informing Congressional staffers on 

relevant current issues and may be good networking/outreach opportunity. These occur 

throughout the year, and an option could be to sponsor an event through a program such as 

the Oceans Caucus, or participate/organize events that receive media attention such as the 

National Invasive Weeds Awareness Week held in DC. 

Discussion: Straw-Person Management Options – Vessel Surveys

The TAG was asked if a mandatory vessel survey would be beneficial. It was noted that a survey similar 

to New Zealand’s could be very useful, however, without an associated penalty for non-reporting, 

submission rates will be less effective (Davidson, Miller). It was suggested that fouling questions could 

also be asked by CSCL inspectors during boarding (Ruiz). If a mandatory survey is implemented, it was 

suggested that the industry be involved with the formulation of questions to ensure that they are clear and 

reasonable (Chapman). 

Discussion: Straw-Person Management Options – Hull Maintenance: Codes of Practice & 

Requirements 

Straw person scenarios outlining specific hull cleaning and coating practices for codes of practice (COP) 

and maintenance requirements were identical, however, the COP version would be optional whereas 

requirements would be mandatory. These options are summarized together here, because discussions 

generally applied to both. 

It was noted that promotion/distribution of any COP should be accompanied with information on their 

rationale and purpose, and with a contact for more information (Ruiz). 

Time periods specified in the cleaning requirements (clean within 6 months; coat within 3 years of arrival, 

2 week lay-up) generated notable discussion. It was noted that these place holder periods were 

somewhat arbitrary (Sytsma) and it was unclear if vessels that meet these criteria would constitute a high 

risk. The TAG was unable to suggest more appropriate time frames. A complicating factor is the 

variability of fouling rates due to environmental factors. In particular, fouling accumulates faster in warmer 

waters depending on geographic location. In addition, some antifouling paints are designed to last up to 

10 years, and are more effective if not scraped. Frequent cleaning on these coatings may not improve 

hull cleanliness, and could exacerbate fouling (Gates, Samardzic) 

Idea - Dive inspection rather than cleaning or coating: A suggestion was put forward to request (in 

the case of COP’s) or require (for regulations) dive inspections, rather than cleaning or coating, if certain 

criteria are not met by vessels prior to arriving in California (e.g. not cleaned within 6 months, not coated 

within 3 years, laid-up more than 2 weeks) (Falkner, Chapman). This could be coupled with a 

requirement to provide the inspection documentation to the CSLC. 

73
If an inspection requirement was implemented, standardized protocols for the survey and collection of 

specific types of data would need to be developed to ascertain relative fouling risk. Criteria would also 

need to be developed to discern acceptable versus unacceptable fouling condition (Samardzic). 

Currently, inspection procedures are performed according to the requirements of classification societies 

or owners, and focus on mechanical and structural aspects rather than on biological issues (Gates, 

Samardzic). Inspection reports are unstandardized and narrative in format, typically noting only 

problems. They are also not conducted in low visibility conditions (~30 ft or less), and are thus not often 

conducted on the U.S. west coast. (Chapman) 

Inspection videos are typically taken during diver inspections. If these or photographic images could be 

collected in a standardized manner, they could provide information for inspection purposes and also 

biological data for research. Images and video reduce error and are less subjective for data collection 

and evaluation. Vessel masters also seem to be extremely interested in this type of information, so they 

may monitor operational aspects of their vessel. (Ruiz) 

Fuel Consumption as an indicator for fouling: It was asked if fuel consumption is related to fouling 

accumulation (Berge). There is a relationship between higher levels of fouling and lowered fuel economy, 

though engine or mechanical problems can also cause increased fuel consumption (Chapman, 

Samardzic). Chevron has been investigating the relationship, and Brad Chapman will provide information 

that is available. 

Discussion: Straw-Person Management Options – Regulatory Action on High Risk Arrivals 

Identification of a high risk vessel will be critical for determining which will be subject to regulatory 

action (Berge). The TAG was thus asked to consider what criteria might be used. Some extraordinary 

cases, such as the Suisun Bay Mothball fleet movement, are very likely high risk situations (Davidson). 

However, though it is known which general factors constitute higher risk (slow speed, long lay-up, high 

temperature, etc.), in less extreme cases it is not clear where an acceptable delineation between high and 

low risk might lie for California. The concept of locating potential high risk vessels for closer investigation 

is good, but it is not clear if it would be most appropriately implemented as a data gathering activity, or as 

a regulatory action (Ruiz). At this point in time, it may be best to flush out the characteristics of a high 

risk vessel, and develop options for what may be done with high risk arrivals, both today and in a few 

years as new technologies are developed (Ruiz). 

Responsibility and resources: If inspections or investigations were implemented, it was asked which 

agency would be responsible for conducting them (Crosson). It will be important to make this 

determination, and to identify funding that would be needed for such personnel intensive efforts (Falkner). 

Actions on high risk arrivals: If a vessel was determined to be a high risk arrival, the TAG was asked 

to consider what actions might be taken. 

A requirement for out-of-water-cleaning would be difficult to implement due to dry dock 

demand and scheduling issues, particularly since vessels in this situation would likely be irregular 

and unplanned (McDowell). An in-water cleaning would not be protective (Chapman). 

Fine or fee: To be effective, any fine or fee should be higher than the cost of cleaning the 

vessel, however this would not be protective once a vessel has already arrived in port (Ashe). A 

fine could also be subjective, unless specific criteria were used to evaluate fouling accumulation 

(Berge). 

Quarantine: It was suggested that an area outside of a port, possibly a low current area 

offshore, could be dedicated towards inspections and in-water cleaning (Samardzic). 

Identification of such a site would be difficult, however (Ashe), as NIS spread to other areas 

would still be a potential problem. The state of Hawaii has been investigating potential quarantine 

sites which would be sacrificial in nature, but have not yet been successful (Kushima). 

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Require vessel remedy problem or deny return: An idea suggested was that if a high risk 

vessel arrives, require that they remedy the problem before their next visit, and provide 

documentation that they have done so (e.g. diver cleaning and inspection). If they do not comply, 

deny entry on the next visit to California (Chapman). A similar type of procedure is used by the 

Coast Guard. It was noted that though the CSLC’s has authority to deny entry, it has never been 

used and could be challenged (Berge, Falkner). 

Action on extreme risk arrivals: Though there is not enough knowledge at this point in time to discern 

between high and low risk vessels for California, it was noted that the state could attempt to define an 

extreme risk criteria. For example, a vessel laid up for 30-50 years such as those in the Suisun Bay 

Mothball Fleet would fall into an extreme risk category. Such vessels could be subject to meet certain 

criteria before entering California waters, or face penalties. 

Discussion: Straw-Person Management Options – In-Water Cleaning Restrictions 

In-water cleaning using a technology or technique where fouling material is contained and collected (not 

allowed to enter the water column or seafloor) was discussed both as an action that could be 

implemented on high risk arrivals, and as the only in-water cleaning method allowed in California on any 

vessel. Though vacuum type-technologies are under development by the Navy, and by companies in 

New Zealand and Hawaii, none are currently available for commercial application (Kushima, Samardzic). 

Biological evaluation will occur during 2006 on the New Zealand technology. Other technologies may 

warrant investigation, such as the limno-curtain used to contain biocides applied to freshwater plant 

pests. 

It was asked what size class fouling organisms typically fall under (Berge). Most research has been 

focused on larger organisms. There may still be an issue with smaller organisms such as algae spores 

and microbes, but little research has been done on organisms in these size classes (Ruiz). It was also 

asked what size filter might be appropriate, say, if a contained in-water cleaning technology utilized one to 

eliminate organisms prior to discharge in the water column (Falkner). It was suggested that a 50-80 

micron mesh might be appropriate, according to unevaluated, best scientific judgment (Ruiz). This would 

not, however, address microorganisms or algal spores (Ruiz). 

Points of General Agreement: 

• Outreach on vessel fouling as a vector for NIS introductions is a clear priority. Companies engaged 

in potentially high risk operations, resource agencies, and policy-making entities should be priority 

outreach targets. 

• Biological research on levels and type of fouling on vessels that arrive to California is important. 

• Vessel surveys on behavior and maintenance factors that influence fouling will be important to 

compliment biological research and for the development of risk evaluation. 

• The identification of conditions and criteria that constitute a high risk arrival to California/West Coast 

is needed for the development of regulatory management frameworks. 

• For vessels identified as high risk, the development of response measures that prevent NIS release is 

needed. 

• The development of technologies that contain and collect fouling effluent during in-water cleaning is 

needed. 

• If a requirement for diver inspections is implemented, standardized survey methods, data collection 

protocols, and video/image collection procedures will also need to be developed. 

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X. ACKNOWLEDGEMENTS 

Special thanks to Ian Davidson for providing preliminary data and text in Section V on 

the wetted surface area of commercial vessels arriving to California ports. 

Staff would also like to extend its sincere appreciation to the following people for 

contributing a substantial amount of their valuable time and expertise to the 

development of this report: 

Marian Ashe 

John Berge 

Brad Chapman 

Ashley Coutts 

Jeff Crooks 

Holly Crosson 

Nicole Dobroski 

Richard Everett 

Oliver Floerl 

Paul Gates 

Scott Godwin 

Jeffrey Herod 

Jo-Anne Kushima 

Karen McDowell 

Whitman Miller 

Greg Ruiz 

Dragan Samardzic 

Lisa Swanson 

Mark Sytsma 

Drew Talley 

Kim Ward 

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