This debate could be constructive only if there was a shred of empirical or even anecdotal evidence to support the supposition hull cleaning in-situ does not significantly increase copper loading.
I can certainly anticipate that studies are always subject to bias from various directions but in this case, there is nothing except supposition to contradict three of them (and common sense).
If Fastbottoms or anyone else has any evidence to support a contrary opinion, it would go a long way toward supporting an alternative view about the effects of hull cleaning.
Parenthetically, Fastbottoms point about the distinction between point source and non-point source discharges is well-taken. I helped write the regs while at EPA decades ago. What he omits is that there is do pass given to contaminant discharges simply based on source. The distinction lies in how and why they are regulated.
I can certainly anticipate that studies are always subject to bias from various directions but in this case, there is nothing except supposition to contradict three of them (and common sense).
If Fastbottoms or anyone else has any evidence to support a contrary opinion, it would go a long way toward supporting an alternative view about the effects of hull cleaning.
Parenthetically, Fastbottoms point about the distinction between point source and non-point source discharges is well-taken. I helped write the regs while at EPA decades ago. What he omits is that there is do pass given to contaminant discharges simply based on source. The distinction lies in how and why they are regulated.