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hie, this is my new paintin, concept was under water...used a reference for this painting.
software : photoshop
This is a nice piece, but I am not getting any sense of underwater. The loose hair could just as easily be blowing in the wind.
You could include bubbles, particulate matter, distortions caused by convection currents, god-rays, etc. to indicate a watery environment.
I am also not reading any distress in her expression. If she is supposed to be drowning, she is quite calm about it.
As the ego shrinks, so the spirit expands.
It's very well done the hair has a nice languid flow as if floating rather than blowing and the blue lighting (if a bit bright) gives a good effect, but I'd agree with the water based stuff stated above. She could maybe do with being a touch more cyanotic as well, although her lips and eyelids are blue her cheeks, nose tip and ears are still quite rosy.
I saw this reference on Corbis. I think one thing that takes away from the "underwaterness" is that it is a bit chalky. Maybe glaze it with a layer of blue and smoothe out some areas -