Comment submitted by Neal Blossom, American Chemistry Council

Dear Members of OPP and OW, The attached file explains our request and information more thoroughly but in brief we are requesting that your two offices work together to consistently accept and apply the marine Biotic Ligand Model for copper to risk assessments for copper containg pesticides and for site speicific water quality standards. The validation of the marine BLM will greatly assist the states in regulating copper containing pesticides registered by OPP but then not regulated with the latest science by the lack of validation by OW of the marine BLM. Please complete the work to implement the marine BLM into accepted federal water quality standards. Thank you, Neal Blossom