This process is outside the scope of their Vessel General Permit - Title 33 U.S.C. section 1412 (d) - and requires an individual permit or an exemption to be in compliance.  I urge the State Water Board to please be objective and consider this matter closely.  This is a chronic and cumulative problem in that the purse seine fleet is allowed to net 51 thousand metric tons annually.  The netted fish struggle, panic and release nutrients and pathogens into the surrounding water.  The water is discharged over the side of the boat and results in a large, persistent slick of sea foam.  Evidence that the water contains high levels of dissolved organic matter.  Floating organic matter is eaten by sea gulls.