Copper verses Clean in San Diego

[sarafina]

Anyone heard about this?

People can kvetch all they like about how useless the movement towards legislation against copper paint is.

Looks to me like it is here to stay...

I know I would be signing up for this in a heart beat! Maybe they will enlarge the program to the SF bay!.

Copper Reduction Program | Port of San Diego

[westwinds]

The State of California Water Resources Control Board in Sacramento (WRCB) is the parent organization for the San Diego Regional Water Quality Control Board (Regional Board). If you do not like a decision by the Regional Board, you can appeal it to the WRCB and if that fails, it can then go to a court of law, but you have to appeal to the WRCB first. If you do appeal you should have some scientific evidence that any harm to aquatic organism is ballanced against the economic hardship caused by not being able to paint the boat with copper bottom paint. I would think it would be very hard to prove harm to aquatic organisms except on the bottom of the boat as the copper leached from the paint is at such a low concentration that it cannot even be measured, let alone have it come to a level that would be harmful. By the way, you can ask for meetings with their staff and ask for the studies they baised their decision on and use that as a starting point. You can also go to the members of the legislature and explain how the Regional Board is being unreasonable if you want to try for a quick solution

[fstbttms]

This is old news and has nothing to do with the Regional Water Quality Control Board. This is the Port of San Diego's mishandled and toothless attempt to reduce the exposure the members of the San Diego Port Tenants Association have for any possible state or federally mandated copper remediation costs that may be meted out in the future. Since it is a program of the Port of San Diego, which has no authourity outside San Diego Bay, it is not possible for that organization expand the program. And since the state apparently kowtows to the paint manufacturing lobby (as evidenced by the recent declawing and ultimate shelving of copper elimination bill, SB623), it seems unlikely that this or similar programs will appear in other coastal areas anytime soon.

[westwinds]

The RWQCB has something to do with it:
http://www.waterboards.ca.gov/rwqcb9...hrpt020905.pdf
http://www.waterboards.ca.gov/rwqcb9.../2005_0019.pdf

What surprises me is how low the level for copper is in these documents and what studies have been done to justify setting such a low level

[fstbttms]

Originally Posted by westwinds

The RWQCB has something to do with it:
http://www.waterboards.ca.gov/rwqcb9...hrpt020905.pdf
http://www.waterboards.ca.gov/rwqcb9.../2005_0019.pdf

What surprises me is how low the level for copper is in these documents and what studies have been done to justify setting such a low level

The fact the RWQCB has funded copper loading studies has nothing to do with the Port's copper reduction "efforts." It has everything to do with the fact that Shelter Island Yacht Basin exceeds federally mandated copper loading levels and the state of California (and therefore the Cal EPA, State Water Quality Control Board and the regional boards) are required by law to bring that body of water, and all other impaired bodies (of which there are hundreds) into compliance. The acceptable copper levels are set by the USEPA, not by any agency at the state or regional level.

http://www.epa.gov/lawsregs/laws/cwa.html

The Port's program is stand-alone and is not sanctioned by any state agency.

[fstbttms]

Originally Posted by westwinds

I would think it would be very hard to prove harm to aquatic organisms except on the bottom of the boat as the copper leached from the paint is at such a low concentration that it cannot even be measured, let alone have it come to a level that would be harmful.

Of course copper emissions from anti fouling paint can be measured (both from passive leaching and yes, from in-water hull cleaning activities) and of course they have been found to be harmful. From the most widely accepted study (of at least three) on copper loading and its effects in Shelter Island Yacht Basin:

Perhaps the largest contaminant source to marinas is vessel antifouling paints. Antifouling paints are designed to slowly release biocides in order to prevent the growth of encrusting organisms and algae that will corrode fittings, decrease speed, and increase fuel consumption (WHOI 1952). Copper is currently among the most commonly used biocides in recreational vessel antifouling paints (Valkirs 2003). Schiff et al. (2004) demonstrated that these paints, which may contain between 20% and 76% copper content (as cuprous oxide), leach approximately 4.0 µg/cm2/day or roughly 25 g/month for a typical 9 m power boat.

A strong relationship between the concentration of dissolved copper in marina samples and the degree of toxicity was observed. Normal embryo development was negatively correlated with the concentration of dissolved copper in the surface water samples (r = -0.90, p < 0.01). Moreover, the amount of toxicity measured in the field samples (mean normal embryo development = 70%) was similar to the amount of toxicity predicted from the regression analysis of the concurrent copper reference toxicant tests, and the concentrations of copper in the surface water samples (mean normal embryo development = 69%).

http://www.environmental-expert.com/...sd_marinas.pdf

[westwinds]

But what about the economic hardship caused by not being able to harvest mussels in Shelter Island Yacht Basin? How does that balance agains the cost of not being able to use copper bottom paint? I am surprised that mussel embryo are sensitive to such low levels, although I should have realized that modern testing equipment can go that low on detection limits.

[westwinds]

Need to have a study done by a registered civil engineer. A report about an environmental problem legally has to be sighed by a registered engineer to have any legal standing with a RWQCB.

[fstbttms]

Originally Posted by westwinds

Need to have a study done by a registered civil engineer. A report about an environmental problem legally has to be sighed by a registered engineer to have any legal standing with a RWQCB.

Whatever. You're only 8 years behind on this issue.

This is how the RWQCB Region 9 (San Diego) is dealing with copper loading there:

http://www.waterboards.ca.gov/rwqcb9...hrpt020905.pdf

[westwinds]

Originally Posted by fstbttms

Whatever. You're only 8 years behind on this issue.

This is how the RWQCB Region 9 (San Diego) is dealing with copper loading there:

http://www.waterboards.ca.gov/rwqcb9...hrpt020905.pdf

It can still be challenged to the WRCB if it can be shown that a basic premise is incorrect, like a proper cost benefit analysis was not done.

[roverhi]

Any new word on the supposedly eco friendly bottom paints??? The positives from Latitude 38 don't seem to have been borne out by real world experience.

Talked with a boat yard manager in Port Townsend, Washington and he was expecting significant increase in income from the Washington anti copper legislation. They hadn't found an eco friendly bottom paint that came within 50% of the effectiveness and life of the copper variety.

[zeehag]

would be nice to have the requirements for commercial and military be same as for the recreational boater as this isnt caused by the recreational boating contingent. it is all forgotten that there is a heavy military and industrial contingent here. this counts for most of the heavy metals pollution of sd bay.
those i know who tried the new paints were greatly disappointed in the performance, or lack thereof.....

[fstbttms]

Originally Posted by roverhi

Any new word on the supposedly eco friendly bottom paints??? The positives from Latitude 38 don't seem to have been borne out by real world experience.

Same, same, all samie same. No magic bullet yet.

Originally Posted by roverhi

Talked with a boat yard manager in Port Townsend... they hadn't found an eco friendly bottom paint that came within 50% of the effectiveness and life of the copper variety.

Pretty much my experience as well. None of my clients that have ventured into the realm of non-copper anti fouling paints has been satisfied with the results.

[Thorpydo]

I'm need of new bottom paint and moored in the commercial basin. I'll have to look into he program!

[fstbttms]

Originally Posted by zeehag

this isnt caused by the recreational boating contingent. there is a heavy military and industrial contingent here. this counts for most of the heavy metals pollution of sd bay.

Merely your completely unsupported opinion. Please account for this- there is no heavy industry or military presence in Shelter Island Yacht Basin, which is the only body of water in San Diego currently under the TMDL.