Imidacloprid draft SEIS

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Comment from: olympic environmental council (JoeBreskin)
Comments on SEIS from Olympic Environmental Council We are a 501c3 organization in Washington State that is concerned with protection and preservation of natural systems. We serve as an umbrella organization for other organizations and groups dedicated to defending natural systems. Historically, we have been active in this arena for over 25 years since the dawn of GMA process and have had to appeal several bad agency decisions. I am sure we will not be alone in noting that absurdity of permitting non-lethal levels of insecticide, and the inevitability that this approach will predictably fail to address the deep systemic problems that the industry and the agencies have created over the past 50 years, by focusing in single issues w/o considering to potential scale or importance of the unintended consequences of the actions taken to protect an industry that is based on entirely unsustainable methods and on fundamental misunderstandings of ecosystems. First things first: if we look at this as an ecosystem, the burrowing shrimp have coexisted in balance with the oysters in Willapa Bay forever. They have been in the estuary at high population levels since before the ice age. If population of a single species appears to be increasing rapidly the first question that needs to be asked is "Where?" And the second question is of course "Why?" The answers to both of these questions point to a long history of gross negligence by the shellfish industry. At the turn of the century self-serving exploiters basically strip-mined the estuary and destroyed the shell reefs that had supported the oysters, kept the shrimp out of oyster territory, and kept aragonite levels in the water column ideal for oyster propagation. Since then, almost everything that has been tried has had the appearance of a macabre comedic sort of rolling catastrophe. Growers introduced numerous invasive species, each of which has complicated the situation. They introduced japanese oysters, whose means of reproduction is poorly suited to the chemical conditions in the estuary, manila clams, oyster drills, spartina, and japonica. And someone introduced the isopod parasite that is currently driving the mud shrimp to the verge of extinction on the west coast. Historically, mats of japonica rhizomes supported vast populations of migratory waterfowl. The stuff has been called 'duckgrass' for a very long time, because ducks and geese eat the blades, roots, or both. American Wigeon, Northern Pintail, and Mallard are the three main species of ducks that eat duckgrass on Willapa Bay. These ducks are dependent on duckgrass to survive; in fact the Wigeon's diet consists of more plant matter than any other dabbling duck. The Northern Pintail is considered a common bird in steep decline.[ii] The Dusky, a goose, eats both duckgrass and marina, and on paper, the Dusky is a protected goose, due to low a population.There are several species of migratory geese that are almost totally dependent on it being here and when they fly into Willapa Bay expecting to feed and fatten for their migration, they now find barren defoliation. This is genuinely life threatening: they simply cannot survive a mistake of this magnitude. But it is not the ducks' mistake, it is the mistake of Washington State that is permitting the destruction of duckgrass and marina with Imazamox. Since the 1980's scientists have consistently reported (see feldman 2000 review paper and excerpt below) that eelgrass keeps shrimp from burrowing in the areas where it grows. The eradication of japonica has now damaged or destroyed both species of eelgrass (marina and japonica) over vast areas of Willapa Bay and opened those areas to shrimp. The wholesale destruction of Eelgrass using the herbicide Imazamox not only reduced the shrimps' predators, who used it as habitat and hiding cover, it removed a key physical constraint - the mats of rhizomes were an obstacle to the shrimps' burrows and the destruction of the Eelgrass (to support another introduced invasive species: Manila Clams) has allowed the shrimp to move into vast areas where they could not live when the Eelgrass was there. "Field surveys have been consistent with Brenchley's (1982) findings, noting the abrupt decline and low densities of ghost shrimp burrows in Zostera rnarina beds compared to adjacent intertidal mudflats (Swinbanks and Murray 1981; Swinbanks and Luternauer 1987). Harrison (1987) reported that an expansion of Z. marina and Zostera japonica habitat was accompanied by a corresponding reduction in ghost shrimp density." So now the industry want to poison the sediments with a different neurotoxin in an effort to paralyze the shrimp so that they will suffocate in their burrows. A lawsuit brought against the state and industry by citizen activists to end the use of carbaryl resulted in a hard won settlement agreement with the Willapa Bay Grays Harbor Oyster Growers Association. This agreement called for the phase-out of carbaryl and gave the industry over a decade to develop and adopt an integrated pest management plan to replace their unsustainable pesticide-based shrimp control measure. This settlement agreement was based on a serious legal challenge from citizens -- not the state -- against ecosystem scale contamination. It is not what the industry PR machine is now pretending was a voluntary phase-out based on some sort of magic wand of enlightenment among the growers: they kept spraying year after year and spent hundreds of thousands of dollars (including public funds) exploring alternate chemical approaches rather than embracing non-chemical approaches to restore ecosystem balance. During that 10 year negotiated phase out, the National Marine Fisheries Services determine in 2009 that the application of carbaryl in both Willapa Bay and Grays Harbor jeopardized the continued existence of endangered salmon and adversely affected or destroyed their habitat. Also in 2009, the NMFS determined the application of carbaryl adversely affected ESA listed green sturgeon in these same bays. The spraying continued unabated. A great deal of public money was spent exploring chemical means to control a native animal species whose growth has been facilitated by destruction of a native plant species. As far as we can tell, the use of USDA's IPM funds to develop a pesticide based approach to destroy a native animal species in support of a non-native animal species is entirely unprecedented, and is especially disturbing in the face of the population collapse of the native mud shrimp that is currently underway. It is not clear if, when, or or how the required IPM was actually adopted, but it is very clear that almost none of the usual principles of IPM are involved in the latest pesticide permit proposal. The DEIS to which this EIS is attached is deeply flawed, because it fails to address the complex interactions between species. For example, the estimates for incidental take of non target organisms are just plain wrong, and the role of crabs as oyster predators is not discussed, but millions of <1 juvenile crabs are poisoned ans killed by pesticides, larger crabs are not destroyed and can be harvested and sold immediately after they are poisoned. Because the pacific oyster spawns into the water column, and the initial layer of shell is developed in the water column, rather than under controlled conditions inside the female oyster, as occurs in the olympia oysters that were native to these waters, water conditions are critical, if shell building is to proceed properly. In an effort to control this process, and to allow the propagation of sterile triploid oysters, the industry adopted a hatchery program to supply seed. Mismanagement of the hatcheries and misunderstanding of chemical processes involved in shell building led to the claim that ocean acidification was destroying oysters and that pacific oyster was the canary in the coalmine for ocean acidification. This was an interesting story and it played well in the press, and continues to be played by politicians, but it was based on both a serious misunderstanding of water chemistry and a willful convenient falsehood. The real problem is that unlike the native oyster, in the waters of the pacific northwest, the pacific oyster is near the edge of its natural range and its means of reproduction in the water column is only suited to chemical and temperature conditions found in these water some of the time. When those conditions are not present, shell-building in the first 48 hours is compromised. It is a very human trait to assume that every year is pretty much the same as the ones before it, but this assumption leads to human development along unstable slopes and riverbanks that move and so the development gets wiped away when weather conditions drift outside the normal range. Same with the oysters. Water conditions 80 years ago were perfect for them. Since that time, vast tracts of forest in the watersheds that feed the estuaries have been removed, potentially altering the pH of the water entering the estuary, the eelgrass in the bay has been eradicated, and the ecological balance has been drastically altered by ground culture methods that involve dragging the bottom of the bay with chain dredges and harrows, stirring up sediments. We also see a very serious issue emerging in that the primary proponent of the pesticide approach has been found to be in violation of the state's ethics rules. It appears to us that the ethics board may actually have failed to follow the rules set forth in the APA that appear to us to call for agency actions taken on the basis of ethically compromised testimony to be revisited. The key presenter and salesman for this new pesticide and its permit has been censured and fined by the ethics board for his involvement with the industry [] which should raise serious concerns for agencies who have relied on his testimony and sale pitches. What we find astonishing is that your agency and you as individuals know more than we do about what is going on. You know ALL of this and more, and many of you in the agency know that it is just plain wrong. This is willful blindness on your part and is not an acceptable defense. It is time for you to be asking hard questions, not us. Joe Breskin Olympic Environmental Council
11/01/17 4:59 PM   |  
Comment from: WSDA (GeorgeTuttle)
Please see attachment "WSDA Final Comments 11.1.2017"
11/01/17 4:56 PM   |  
Comment from: Center for Food Safety (Amyvan Saun)
Please see attached comments from Center for Food Safety, Center for Biological Diversity, and Western Environmental Law Center.
11/01/17 4:49 PM   |  
Comment from: Walter Jorgensen
Dear DOE, Commercial shellfish beds, specif. gooeyduck, have obliterated Totten Inlet in lower Puget Sound. In addition to pre-empting the beach from any other reasonable year-round recreational or natural appreciation use, mussel barges cover a good portion of the "non-open" waters. Leave nature alone and protect it from the greed of "about a dozen oyster farmers from the Willapa Grays Harbor Oyster Growers Association (WGHOGA)." These tide lands should be held in trust for the public, with easements if necessary, and not mis-treated with pesticides to support private their aquaculture practices. DOE should DENY the permit to apply the pesticide Imidacloprid IN ANY Amount to control burrowing shrimp on commercial shellfish beds in Willapa Bay and Grays Harbor. Here are the three major reasons: 1. Imidaclorprid is a neonicotinoid pesticide. It has deadly consequences for beneficial insects, including bees. Bees are already critically threatened from so-called colony collapse disorder. Colony collapse is thought to have more than one contributor, but among the most serious, and the most preventable, is from the use of neonicitinoids. The use of Imidacloprid is not safe to use at any strength. 2. There likely could be adverse consequences from using it in this situation which are not understood at this time that may only come to light after it is too late. 3. The Department of Ecology's mission is "protect, preserve, and enhance Washington's environment". No where in this mission statement does it say or even suggest that business interests should take priority above protecting the environment. I will presume that the reason business interests are not mentioned is that protecting our environment is more important than protecting business interests. I hope that is still the position of DOE. Please do not permit the use of this neonicitinoid pesticide on our fragile coastal waters just to benefit a few businesses.
11/01/17 4:49 PM
Comment from: Patrick Pressentin
Law Office of PATRICK E. PRESSENTIN 1001 Fourth Avenue Plaza, Suite 4400 Seattle, WA 98154-1065 Patrick E. Pressentin (206) 587-0066 [email protected] FAX: (206) 389-1708 November 1, 2017 By email only: Derek Rocket, Permit Writer Washington State DOE Water Quality Program P.O. Box 47775 Olympia, WA 98504-7775 Re: Imidacloprid use on Willapa Bay tideland Dear Sir: This is a public comment on the use of the toxin imidacloprid in areas of Willapa Bay. I assume the economic consequences of denying the permit, much as I would assume that there were economic consequences to the prohibition of DDT. Nevertheless I oppose all use of this product on Willapa based on the Draft Environmental Report: "There are still knowledge gaps about imidacloprid." Of utmost importance are the unknown cumulative effects of Imidacloprid and its breakdown products throughout the bay in areas whether applied or not. Neurotoxins are not specific and the report indicates that the benthic and invertebrate populations will be affected to an unknown extent, particularly on a cumulative basis which is a required finding. Measurements after a 4 hour window do not provide a scientific basis for approval. Rhetorically, would you ingest the chemical with such testing? Green Sturgeon, an endangered species, eat these shrimp and bio accumulate toxins. Will they become like the orca as the most contaminated tissue over time with a newer toxin than PCB, affecting birthrate and reducing the natural predation? My background is local and practical and includes the UW Wetland Certificate course, environmental law practice in the litigation and cleanup of hazardous waste sites in Washington and Alaska, and continuous voluntary work over 30 years in restoration of contaminated sites. I visit Willapa Bay annually, have for over 40 years. I eat oysters (I applaud Taylor Seafoods since they have decided NOT to use this chemical.). I enjoy Oysterville and purchasing oysters there. Who cleans up after this chemistry is used for 10 years? Not the small users, but the taxpayers. Are the breakdown products and cumulative effects of Carbaryl applications still in the watershed and flora and fauna? Is there not cumulative and synergistic effects to the populations affected aside from "immediate adverse, unavoidable impacts to juvenile worms, crustaceans, and shellfish to the areas treated". Pulp mills in Washington and Alaska left legacy sites that cannot be cleaned entirely, decimating benthic, invertebrate, and fish populations by cumulative effects ignored at the permit stage. The cleanups exceed the economic value conveyed in the long run and the environment will not fully recover for decades. And these pollutants were not neurotoxins, but effluent, sulfuric acid, industrial PAHs that will eventually break down naturally. There are "immediate adverse, unavoidable impacts to juvenile worms, crustaceans, and shellfish to the areas treated". This says nothing of cumulative impact. I must comment on the proponents website, where they defend the use of imidacloprid as "A Responsible, Ecologically-Conscious Integrated Pest Management Program" and an ecological necessity for the plan. "An ecosystem imbalance that's not natural that has caused proliferation of the shrimp and turned the bay into a wasteland, where nothing else can live or grow." This is their lawyer talking, an advocate without scientific basis. The "imbalance" is not historical, nor an imbalance. The shrimp are native unlike the Spartina grass. The Pacific oysters are the invaders, the result of Japanese natives introduced here and now the users are insisting on draconic change, much the way Atlantic salmon have edged their way into our environment and now the users place the taxpayers and owners (Public Trust ownership) of our waters at risk. The mud tidelands are not deserts of biology but simply an alternative ecology of the most natural kind. Wetlands were once regarded as wastelands because of lack of knowledge and are now protected because of their economic value; these mud flats are biologically diverse and have their own value and economic assets to the larger ecosystems that are not explored in the Draft EIS. The artificial reduction of these shrimp by the use of a neurotoxin is not reasonable. Unexplored options as alternatives exist (floating or hanging cultures like Penn Cove) but have not been proposed due to economic considerations. Toxins are not the answer if we are to look to a sustainable, healthy food source. Yours truly, /s/ Patrick E. Pressentin
11/01/17 4:49 PM
Comment from: Jules Michel
Thank you for considering the wealth of information provided on the importance of native burrowing shrimp, the important ecosystems which Willapa Bay and Grays Harbor make up, and the desire for shellfish growers to maximize their profits. This issue is no different than Seattle Shellfish and Taylor Shellfish believing the "only way" to grow-out geoduck seed was to use hundreds of "kiddie wading pools" in the tidelands. When that method's impact was shown to detrimental to the benthic and marine ecosystem, they easily came up with alternative growing methods. Taylor Shellfish modified mussel farm rafts and Seattle Shellfish built a floating dock to which grow-out rafts were attached. It was more expensive, but they adapted and accepted it as a cost of doing business. This current situation is no different. Accepting Alternative 1 (do nothing) will show that to be the case here, as it was there. Willapa Bay and Grays Harbor shellfish growers claim alternative growing methods are more expensive or not feasible, pointing to long lines "sinking" in the sediments and it being hard to walk in those sediments. While above sediment methods are more expensive, and in a few areas the sediments are soft, the current system pointed to is simply a poorly engineered system to grow oysters, and a poorly engineered system will always fail. But it does not mean alternatives are not available. Look at Drakes Bay Oyster Company's use of racks in Drakes Estero where above sediment structures were used for years, accessed by boat, as they have been in Japan for decades (and where the nonnative Pacific oyster originated from). Pilings are driven into firm sediments which, in the case of Willapa Bay (and likely Grays Harbor) are 3 feet below what the current growers are complaining about. In turn, those pilings had stringers attached to them, over which "hangars" were draped, holding oyster spat. When mature, workers traveled to the structures by boat/barge, lifted the hangers off of the stringers and onto the barge, and returned them to the processing plant. It is only one of the alternatives available to growers. While Drakes Bay Oyster Company is not longer operating in Drakes Estero, it was not because the method used was more expensive. In addition to providing the alternative growers testified at hearings they so dearly want, this also provides a permanent structure onto which marine organisms grow, and remain. The pilings and stringers become ecosystems in and of themselves. (While oysters suspended also provide "structure", they are removed at each harvest so cannot be truly called adding to the ecosystem.) Of course there is a risk of a boater running into them. But navigational hazards are easily marked and, if significant enough, lit. And unlike other areas, these have no eelgrass to shade. Growers state the wave energy is too strong for a robust structure such as what is described. If that is true, then there is no way on- bottom oyster growing will be able to take place, burrowing shrimp or not. As Taylor Shellfish noted in a deposition submitted when an encroachment onto state tidelands was being investigated, waves on that parcel caused oysters to be pushed to the upper tidelands, having to be retrieved by hand, and then placed back in the lower tidelands. If on bottom oyster growing may be done on these parcels after killing burrowing shrimp, then most certainly a well engineered structure may be used, avoiding the use of this pesticide, providing "ecosystem services" as well. Other growers claim above ground structures create such an impediment to tidal and sediment flow that they result in sediment deposition, putting other beds at risk. However, they site no studies to substantiate such a claim and merely provide conjecture on whether it is significant, let alone even happens. Further, Taylor Shellfish has been using above ground methods (flip bags in this case) for years and nobody complained to DOE about sediment transport issues. Dick Sheldon's comment expresses concerns that above ground methods result in micro-plastics in oysters. Yet testimony by "expert witnesses" for Taylor Shellfish in numerous hearings claim grow-bags are not the source of micro plastics. More importantly, the method described easily avoids the use of any plastics at all, instead, using hangers. While Mr. Sheldon should be concerned about plastic, he should be more concerned about the public's perception of his oysters, those of Willapa Bay, and those in Washington, being grown on beds and in waters where pesticide and herbicides are being applied. Another supporter of pesticide use is from Daniel Cheney who states the use of Carbayl (Sevin) by the shellfish industry (used since 1963, unknown to most consumers of Willapa Bay oysters) to kill burrowing shrimp resulted in an increase of eelgrass due to firmer sediments. Not noted is the species most common to grow in these areas where shrimp are killed in order to grow oysters is Japanese eelgrass, an eelgrass considered a "noxious weed" by shellfish growers who have been spraying the herbicide Imazamox on to eliminate. While there were areas where the native eelgrass increased, those were predominantly in tidal pools, where water never drained and lower in tidal elevation. In short, while applying a pesticide did result in an increase in eelgrass, it was predominantly Japanese eelgrass which shellfish growers would simply spray with Imazamox, adding more chemicals to Willapa Bay. As noted by many, Willapa Bay and Grays Harbor provide ecosystems which support a large number of native species. That support starts at the bottom of the food chain where burrowing shrimp exist. Imidacloprid is not "shrimp specific" - it will kill any marine invertebrate it comes in contact with. Derreck Rockett noted many "uncertainties" in this proposal at public hearings. There are, and those uncertainties - coupled with the very real certainty that this is a pesticide which kills marine invertebrates - should prevent this proposal from considering anything other than Alternative 1, the "do nothing" alternative. Like the timber industry who adapted to environmental constraints, like Taylor Shellfish and Seattle shellfish adapted to alternative growing methods for geoduck, so too can Willapa Bay and Grays Harbor shellfish growers adapt profitable alternative growing methods, avoiding the taint all shellfish grown in Washington would take on if pesticides are applied to shellfish beds.
11/01/17 4:31 PM
Comment from: Helen Wheatley
Deny the permit to apply Imidacloprid to control burrowing shrimp. Neonicotinoids should be illegal. To quote the Thurston County Democratic Party: Banning the Use of Neonicotinoid Pesticides (Adopted June 27, 2016) WHEREAS, Neonicotinoids, one of the most widely used classes of insecticides in the world, are systemic, persistent neurotoxins and spread throughout treated plants including to pollen/nectar gathered by pollinators; and WHEREAS, Neonicotinoid pesticides, widely used in Washington and US agriculture and horticulture, are a class of neuro-active, nicotine-based insecticides; and pollinators are critical to key Washington crops, such as tree fruit; over one-third of all agricultural production worldwide is dependent on pollinators; and WHEREAS, An independent review of more than 800 scientific studies concluded neonicotinoids are causing significant damage to a wide range of beneficial invertebrate species and are a key factor in the decline of bees; THEREFORE BE IT RESOLVED, That the Thurston County Democrats support and urge our State and Federal Elected officials to support a ban on the use of neonicotinoid pesticides; and urge the Environmental Protection Agency (EPA) to suspend the registration of all neonicotinoids pesticides.
11/01/17 4:27 PM
Comment from: As You Sow (AustinWilson)
As You Sow is a national 501c3 non-profit that has researched and promoted corporate responsibility for over 25 years. We advocate for long-term sustainability programs that benefit shareholders, companies, and the communities in which they do business. We work with major food companies to develop sustainable agriculture policies that meet current needs while securing future supply. Imidacloprid is a dangerous neurotoxin. It is well-established that invertebrates quickly develop resistance to neonicotinoid pesticides, including imidacloprid. The pesticide applications in this proposal will only kill 60-80 percent of the shrimp in a plot, which will accelerate imidacloprid resistance, rendering the program ineffective. This pesticide will wreak havoc on the local system for a few years of relief. We urge the Department to determine why burrowing shrimp are overgrowing in these regions and seek proposals that are sustainable for oyster farmers, local communities, and all other stakeholders. Austin Wilson Environmental Health Program Manager As You Sow
11/01/17 4:26 PM
Comment from: Debra Jaqua
Dear DOE, My comment is that DOE should DENY the permit to apply the pesticide Imidacloprid IN ANY Amount to control burrowing shrimp on commercial shellfish beds in Willapa Bay and Grays Harbor. My reasons are as follows: 1. Imidaclorprid is a neonicotinoid pesticide. It has deadly consequences for beneficial insects, including bees. Bees are already critically threatened from so-called colony collapse disorder. Colony collapse is thought to have more than one contributor, but among the most serious, and the most preventable, is from the use of neonicitinoids. The use of Imidacloprid is not safe to use at any strength. 2. There likely could be adverse consequences from using it in this situation which are not understood at this time that may only come to light after it is too late. 3. The Department of Ecology's mission is "protect, preserve, and enhance Washington's environment". No where in this mission statement does it say or even suggest that business interests should take priority above protecting the environment. I will presume that the reason business interests are not mentioned is that protecting our environment is more important than protecting business interests. I hope that is still the position of DOE. Please do not permit the use of this neonicitinoid pesticide on our fragile coastal waters just to benefit a few businesses.
11/01/17 4:05 PM
Comment from: Seth Book
11/01/17 3:38 PM   |  
Comment from: Northwest Center for Alternati... (AshleyChesser)
We, the undersigned, support efforts to protect this fragile ecosystem from a potentially dangerous pesticide application. This plan is understudied, inadequate and fails to protect community and environmental health! We support timely efforts to expand promising alternatives to neonicotinoids and to increase their feasibility and effectiveness. Investments should be made in educational, technical, financial, policy, and market support to accelerate adoption of alternatives rather than continuing to rely on highly toxic pesticides. Research and demonstration are needed to determine and improve the most effective alternatives and their respective potential and feasibility for farms of different sizes, locations, shrimp population density, and access to equipment. The state should invest its resources in these efforts prior to and instead of allowing toxic contamination of state estuaries. Department of Ecology must protect Washington's water, wildlife, public health, and local economies from the harmful impacts of toxic pesticides. The future of oyster farming in Washington State depends on the industry's ability to adopt sustainable cultural and management strategies.
11/01/17 3:28 PM   |  
Comment from: Pacific Coast Shellfishg Growe... (MargaretBarrette)
11/01/17 3:24 PM   |  
Comment from: Center for Food Safety (Center for Food SafetyAnonymous)
Please find attached comments urging Ecology NOT to move forward with a spray permit for imidacloprid on shellfish beds in Willapa Bay/Grays Harbor, signed by 446 Center for Food Safety members.
11/01/17 3:17 PM   |  
Comment from: Jennifer Finley
11/01/17 3:05 PM   |  
Comment from: Audubon Washington (TrinaBayard)
Please see attached file for Audubon WA comments
11/01/17 2:36 PM   |  
Comment from: U.S. Fish and Wildlife Service (JayDavis)
11/01/17 2:25 PM   |  
Comment from: Willapa/Grays Harbor Oyster Gr... (DouglasSteding)
11/01/17 2:12 PM   |  
Comment from: Nadiya Stipanovich
I am against the use of NEUROTOXIN by the oyster farmers. We are bombarded enough with toxins all over. I think we should be more conservative and careful in using those. Especially since little known direct risk to fish, birds, marine mammals, and human health and further research is needed.
11/01/17 1:36 PM
Comment from: Jana Wiley
I am writing again to strongly condemn this move to prop up the unsustainable oyster industry in Willapa Bay. These tidelands really do not support oysters without pesticides being applied. If feels wrong to poison the environment for all other lifeforms for this reason. It is time that they reconfigure their growing sites. It was in 2015 that I last wrote on this issue, and it is inconceivable to me that they can simply petition again and possibly get what they want by virtue of wearing down the public's response. Fortunately, I JUST found out about this comment period and am able to get something in under the deadline. I would hope if the public's response has been less this year, that DOE would allow a longer period for comments. Politically and socially the public has been overwhelmed by too many matters.
11/01/17 1:20 PM
Comment from: Ilene Le Vee
I recommend applying the Imidacloprid to 1000 acres of the burrowing-shrimp-affected area as 500 acres is not sufficient and doing nothing is not advisable. I also recommend that Taylor Shellfish partner with a local Tribe and harvest 1000 acres of shrimp infested beds. Attempt to develop a market for this shrimp by doing a study/cookout to determine customer satisfaction with the taste of these creatures. After application/harvest, if DOE determines there are no negative environmental impacts from Imidacloprid on the 1000 acres, continued use may be advisable depending on cost/outcomes. If the results of the shrimp study/cookout is favorable, we may have discovered a new, plentiful and popular food source. Good luck and thanks for the opportunity to comment.
11/01/17 1:09 PM
Comment from: Kari Peterson
I oppose the proposal to use pestcides. Please consider completing and publishing impact studies prior to taking steps to implement
11/01/17 11:24 AM
Comment from: U.S. Fish and Wildlife Service (JayDavis)
11/01/17 10:53 AM   |  
Comment from: Erika Buck
11/01/17 10:47 AM   |  
Comment from: Northwest Center for Alternati... (MeganDunn)
Please see the attached comment letter.
11/01/17 10:26 AM   |  
Comment from: Kenichi Wiegardt
11/1/2017 To: Derek Rocket I appreciate to opportunity to comment on the SEIS and the burrowing shrimp NPDES permit. I urge Dept. of Ecology to issue this permit. The option of "No action" in the SEIS is not an option at all. If this path is chosen the economic as well as ecological damage will be immense. The people who have applied for this permit are all long time residents on Willapa Bay, with many of them being multi generational. Unlike large companies who grow shellfish in many locations along the West coast of the United States Willapa Bay is all these growers have. Personally I have kept it this way for my company because this bay and surrounding community is my home, I'm proud of my family's history here. If this permit is not issued myself and many others will be forced to close our doors. Hundreds of full time employees along with their families will have to find employment elsewhere, most likely outside of Pacific County. Local school districts will be severely affected, as enrollment will drop as families once supported by shellfish will be forced to go elsewhere. Growing up on the tidelands of Willapa Bay I have first hand experience of what happens when an area is infested by burrowing shrimp. The ground becomes a barren wasteland, with nothing but burrowing shrimp present. Gone are all the other things that inhabit a healthy tideland. There are no crab, no eelgrass, no shellfish, no snails, no birds present. Nothing. For the people that have applied for this permit it is about much more than assuring we can grow shellfish on the ground. We care deeply about about the ground and want it to remain healthy and vibrant with a diverse amount of different animals and plants being able to utilize it. Again I urge Dept. of Ecology to issue the NPDES permit for burrowing shrimp control. Sincerely, Kenichi Wiegardt
11/01/17 9:47 AM
Comment from: Edgar Galvan
I am employed in the shellfish industry in Willapa Bay. It's the only job I've ever held and I am proud of what I do. I support the use of imidacloprid to reduce the out of control burrowing shrimp population. 16 of my family members, all residing in Pacific County, also work in this industry. We have seen firsthand how the shrimp are destroying the oyster and clam beds. It is very frustrating to see the crops that we work so hard to grow sinking into the mud because of the effect of the shrimp. The shellfish industry is the largest private employer in Pacific County providing around 2000 jobs between Willapa Bay and Grays Harbor. Without a permit, the effects will be devastating to the farms, my family and our local economy. Please issue the draft permit so that we can reduce the shrimp populations to a manageable level and continue providing shellfish to consumers all over the world.
11/01/17 8:57 AM
Comment from: Annie Herrold
I am a fourth generation oyster farmer in Willapa Bay and I strongly believe that the Draft SEIS supports the issuance of a Draft Permit. My family has been farming in Willapa Bay for over 100 years and we have worked to control burrowing shrimp populations since their explosion in the 1960's. Currently we are facing an infestation and without any tools to reduce the populations on our beds they are being destroyed and the estuary as a whole is beginning to see what will be devastating effects if burrowing shrimp are left unchecked. If you have taken the time to walk the beds, then you've seen the disastrous effects the shrimp are having. As a member of the local Chinook Indian tribe and a family that are long time Pacific County residents, I care deeply about the health and sustainability of Willapa Bay. Farming oysters is a way of life for us, and without a healthy balanced ecosystem our way of life would cease to exist. Oyster growers are constantly working to protect this beautiful bay that we call home. If the science didn't support the issuance of a permit, then we wouldn't support it either. We are proposing to use only up to 8 oz an acre of the next generation, EPA approved imidacloprid on less than 1% o the total acres in Willapa Bay. It is undetectable in the water within 24 hours and will not be applied to the oysters themselves but directly to the sediment during the lowest tides of the year. The long term result would be healthy vibrant beds with an abundant diversity of species present and oysters that won't contain even a trace of imidacloprid. I am proud to farm some of the same land that my great grandpa did and it is a tradition that I hope to be able to pass down to the next generation but to do so we need a way to protect our land. Please issue the Draft Permit so that we can save our farms and preserve the delicate ecology of Willapa Bay.
11/01/17 8:47 AM
Comment from: Brady's Oysters Inc. (MarkBallo)
Thank you for the opportunity to comment on this important issue. I am and have been the Oyster grower/farmer for Brady's Oysters Inc.for 24 years. Brady's Oyster's has been in business for 47 years and have never had the luxury of knowing there was going to be a tool for dealing with this problem at our disposal. This has been a constant question mark almost every year, even with a permit. I have witnessed the explosion of the burrowing shrimp populations on our oyster beds the past 2/3 years without any ability to do anything about it. We have spent huge amounts of money trying to work our way through the permitting process. The oyster growers are running out of time on this issue as crops and usable land are being lost to the shrimp. I have heard some say that you just need to use alternate culturing methods like long lines or suspended culture, but these are not solutions as these methods also will sink in a soupy substrate or can't be planted at all because is too hard to work in sinking mud. We need some tools in our tool box to deal with this problem. The Oyster growers have been done a dis-service by DOE by a constant moving of the bar. In the original Carbaryl agreement to stop using that product to treat the shrimp our counterparts agreed to help (not hinder)to find a new solution for the problem. I have never known this to be true, the more we have tried the more difficult it has become and you at DOE are a party to that behavior. I find it difficult to believe that DOE has less problem with the Army Corps of Engineers digging a giant channel through the middle of Grays Harbor that affects many more acres and disrupts bottom fish, kills Eel Grass and who knows what other detrimental impacts the dumping of dredge spoils has outside the bay. DOE owes the oyster growers of Washington a clearly defined path to a permit, please set the parameters of expectations and stick to them. The Oyster growers have approached this burrowing shrimp problem with the integrity of science and cooperation, help us get control of this problem by putting forth an achievable plan. Thank you, Mark Ballo, Farm Manager, Brady;s Oysters Inc.
11/01/17 8:07 AM
Comment from: Ingrid Rasch
I am absolutely OPPOSED to using any means of reducing the Burrowing Shrimp population. These shrimp are native to Puget Sound/Salish Sea and if anything, should be protected. Commercial shellfish farming should not eclipse native species.
11/01/17 8:07 AM
Comment from: Daniel Cheney
I've been involved with various aspects of shellfish farm management in Willapa Bay and elsewhere since the 1970's. The SEIS correctly observes the difficulties farmers face in growing oysters on grounds densely colonized with burrowing shrimp. The high shrimp densities observed since the 1960's have been described as reflecting both human disturbances and changing ocean-system dynamics. The current proposal to apply imidacloprid to reduce shrimp densities on the most productive grounds in Willapa Bay and Grays Harbor, is the result of concentrated efforts since the mid-1990's to: 1) examine alternative control and culture methods; 2) study the ecology and marine chemistry of the growing areas; 3) better understand the ecosystem services provided by shellfish culture; and 4) conduct laboratory and field experiments on the effects of a range of chemical, physical and electrical tools for shrimp control. I believe the SEIS adequately addresses the rationale and need for the application of imidacloprid, and cites current literature on this and other chemicals used or proposed for control of burrowing shrimp. The examination of the three alternatives fairly reviewed anticipated impacts for a range of treatment options; however, some readers may not have access to the more detailed available information on ecosystem changes that would result under Alternative 1 (no treatment). Aspects of these ecosystem changes were evaluated in greater detail in the 2015 FEIS, and are briefly quoted as follows: --From FEIS – p 3-4. Deposit-feeding polychaetes, bivalves, tube-dwelling tanaids and amphipods (e.g., Corophium spp.), and other sedentary species were reduced in numbers in areas where dense populations of ghost shrimp were present. --From FEIS – p 3-5. Burrowing shrimp act to limit eelgrass presence by disrupting the sediment and making it too soft for eelgrass roots and rhizomes (Dumbauld and Wyllie-Echeverria 2003; Hosack et al. 2006). Dumbauld and Wyllie-Echeverria found a strong increase in eelgrass abundance in areas where carbaryl was experimentally applied to burrowing shrimp. --From FEIS – p 3-5. Oyster beds provide important ecosystem services such as water filtration, resulting in decreased suspended solids, turbidity, and increased denitrification; habitat for epibenthic invertebrates such as crabs; carbon sequestration; and stabilization of adjacent habitats and the shoreline.... Oysters grow well on hard, rocky bottom or on semi-hard mud firm enough to support their weight. Shifting sand and soft mud are usually unsuitable for oysters. --From FEIS – p 3-28. The treatment of intertidal oysterbeds with carbaryl [a chemical treatment for shrimp control until 2013] clearly reduces abundance of shrimp in this zone and we documented the same pattern of seagrass colonization on a commercial oyster bed and lack of seagrass in an adjacent unsprayed area. Density of native seagrass Z. marina shoots was also enhanced in plots treated with carbaryl, but only at lower tidal elevations or in intertidal pools where it could survive (Dumbauld, B.R. and S. Wyllie-Echeverria. 2003. The influence of burrowing thalassinid shrimps on the distribution of intertidal seagrasses in Willapa Bay, Washington, USA. Aquatic Botany 77:27–42) --From FEIS – p 3-48. Increased densities of burrowing shrimp could result in decreased biodiversity and increased sedimentation (Dumbauld and Wyllie-Echeverria 1997; Colin et al. 1986). High densities of burrowing shrimp have been associated with lower numbers of Dungeness crab, oysters, and other shellfish due to competitive exclusion and habitat modification caused by the shrimp (Doty et al. 1990; Brooks 1995; Dumbauld and Wyllie-Echeverria 1997)." This information coupled with the uncertainly, production risks and high costs associated with the described alternative off-bottom oyster culture and non-chemical burrowing shrimp control methods, clearly indicate the no action Alternative 1 is not acceptable from both ecological and food production perspectives. I urge the Washington Department of Ecology to support and permit the more balanced approaches afforded by Alternatives 3 and 4.
10/31/17 8:11 PM
Comment from: John Conley
No, no, no! Don't tell us that a neurotoxin (Imidacloprid) will "only" affect the shrimp and "perhaps" (definitely!) some other invertebrates (crabs, snails, etc.). It will and does affect humans as well. I will never, never, knowingly purchase or consume an oyster that has been grown in an area treated with Imidacloprid. Never. I would not dine at a restaurant or buy from a fish-monger who carried such oysters. If this poisoning is allowed, I've had my last Willapa Bay/Gray's Harbor oyster. Forever. There are other ways to raise oysters --- in bags, or on racks --- that would avoid the "mud" problem (it's real, and I understand it) caused by the native shrimp (the oysters raised in Wilappa Bay are not natives (are any of them Olympia oysters?; don't think so), but the shrimp are natives). I cannot understand why this is not a solution to the problem, other than for financial concerns: sure, it's cheaper to just dump the oyster spat on the tidelands and then pick them up a couple of years later than it is to use racks or tethered bags. So, to make a buck, let's screw the environment, screw the Public, and just poison both the Public and the shrimp at the same time. In 2017, who thinks spraying neurotoxins into our environment (yes, we live here with the shrimp and oysters) is a good idea? Only someone who puts profit above all else. Please do not allow this. Aside from the very real risk to human health (for those who would consume these poisonous oysters, or those who live near the proposed spraying areas), there will be a significant economic cost to the State, as many will refuse to consume them, or do any business with restaurants and purveyors who carry them. This will not help the Washington oyster industry. It will harm it in a major way. Thank you for considering these comments, John Conley
10/31/17 6:09 PM
Comment from: Caroline Armon
As your own supplemental environmental review findings show numerous impacts to the entire ecosystem that cannot be mitigated. A short term solution that will leave long term devastation to endangered and threatened species and the entire ecosystem. Lets learn from our neighbors- this pesticide has been banned by most of the European Union and ban being considered in Canada because of it's scientifically proven severe impacts to aquatic species. We need to consider all the species in an ecosystem, including we humans, impacts made by us and impacts to us, by use of this pesticide. Native Olypmpic oysters are much more resilient and adaptive to this area- their natural habitat, and should be considered to replace the non-native Pacific oyster. Pacific oysters may grow faster in the short term, yet cannot withstand these environmental changes, whereas Olympic oysters can and do, becoming more abundant and profitable in the long term, beneficial to the entire ecosystem.
10/31/17 4:07 PM
Comment from: Lisa Olsen
10/31/17 2:01 PM   |  
Comment from: richard james
Please deny the permit to spray imidacloprid (or any pesticide) in Willapa Bay and Grays Harbor. I support the letters from the Coastal Watershed Institute and the letter from Northwest Center for Alternatives to Pesticides. both of which are attached. If one searches the internet, one can read and hear where growers or their allies use the term "pristine" to describe Willapa Bay & Grays Harbor. According to Websters this is the definition of pristine: 1 :belonging to the earliest period or state :original the hypothetical pristine lunar atmosphere 2 a :not spoiled, corrupted, or polluted (as by civilization) :pure a pristine forest b :fresh and clean as or as if new used books in pristine condition If Willapa Bay were pristine, it would NEVER have had carbaryl sprayed in it. Nor would it have EVER had imazamox sprayed in or near it. Pristine means it would not have had, nor will it again have imidacloprid sprayed into it. Spraying toxic chemicals into a bay to kill native shrimp in order to grow non-native oysters for profit is the last thing one would do to a place they call pristine. If growers can raise oysters without resorting to the use of toxic chemicals, without introducing uncountable pieces of PVC, HDPE and other toxic plastics into our ocean, without destroying habitat for native species, then do so. If Willapa Bay & Grays Harbor growers are unable to practice authentic stewardship in the making of their money, then they should cease their practice. Shellfish consumers worldwide must be made aware, and will be made aware of the practices used by growers in Willapa Bay & Grays Harbor in the state of Washington. Deny the permit to spray toxic pesticides into Willapa Bay & Grays Harbor. Richard James coastodian Tomales Bay, CA
10/31/17 12:12 PM   |  
Comment from: Beyond Pesticides (NichelleHarriott)
see attached
10/31/17 12:09 PM   |  
Comment from: Jessica Helsley
The Willapa/Grays Harbor Oyster Growers Association (WGHOGA), which grows non-native oysters on the Washington Coast, proposes to control native burrowing shrimp through the application of Imidacloprid. Imidacloprid has been found to enhance adipogenesis, resulting in insulin resistance in cell culture models (Sun et al. 2016, 2017). This provides a strong concern for human health. More direct impacts from insecticide application, including the application of Imidacloprid, have been observed in marine invertebrates which are a critical food source for juvenile salmon and forage fish (Westin et al. 2014, 2015). Wild fish species of salmon and the forage fish food structure that they depend upon are critical components of coastal resiliency- culturally, economically, and ecologically. Macneale et al. 2014 and Gibbons et al. 2015 provide thorough reviews of these concerns. Application of Imidacloprid to coastal areas in the shallow areas of Grays Harbor and Willapa Bay will detrimentally impact critical marine and nearshore ecosystems while also being a human health concern. Impacts to coastal juvenile salmon and forage fish when they are feeding, resting and migrating will have negative impacts to both local salmon populations as well as to salmon populations currently listed under the Endangered Species Act that utilize Washington's coastal waters for nourishment and refugia during their migrations (Shaffer et al. 2012). Additionally, application of Imidacloprid will have a cascading impact up the food chain- impacting marine mammals that include populations also listed under the Endangered Species Act. Washington's coastal ecosystems are complex and vital to our region. We should be working to restore and protect them, not further their demise to enhance the growth of a non-native shellfish species for commercial use. The state and federal agencies are required by law, to preserve Washington State's wild species and the ecosystems upon which they depend. Application of Imidacloprid and other insecticides in coastal zones contradict this mandate and should not be permitted.
10/31/17 11:25 AM
Comment from: Robert Paradise
Please work for restoration of Willapa Bay and do not allow spraying of Imidacloprid.
10/31/17 10:55 AM
Comment from: Eric Bensch
I support the two letters, comment letter from the Coastal Watershed Institute and the letter from Northwest Center for Alternatives to Pesticides, which I have attached to this file.
10/31/17 10:47 AM   |  
Comment from: Eric Bensch
As a citizen that lives on the water of Puget Sound, I find this proposal disconcerting. My understanding is that the affects of this pesticide are far reaching and will have an overall negative impact on the immediate area and larger Puget Sound. I am strongly opposed to the use of these chemicals in our waters. Please deny this request.
10/31/17 8:50 AM
Comment from: Kim Figlar-Barnes
Studies have shown (Morrissey, c, Mineau, P et al. 2015. Neonicotinoid contamination of global surface waters and associated risk of aquatic invertebrates: A review. Environment International 74: 291-303) The water soluble Imidacloprid is toxic to wildlife and highly toxic to aquatic invertebrates (listed on the label for Protector 0.5G and Protector 2F); it affects the survival, growth, emergence, mobility and behavior of many sensitive aquatic invertebrate taxa, even in low concentrations. Spraying or applying Imidacloprid in any manner will have a negative biological and ecological impacts on a wide range of non-targeted invertebrates in aquatic, marine and benthic habitats. Imidacloprid will damage the diverse and unique marine ecosystems of Willapa Bay and Grays Harbor causing a cascading trophic effect, harming a multitude of juvenile and adult fish species (federally endangered/threatened green sturgeon, bull trout, Columbia River Chinook, Columbia River Chum, Columbia River Coho and Steelhead, and Yelloweye Rockfish), birds (federally endangered snowy plover) and a host of other wildlife species that rely on these estuaries for sustenance. The proposed application of Imidacloprid during the month of May will have irrevocable consequences to the multitude of shore birds that migrate and feed in Willapa Bay and Grays Harbor on their way to artic breeding grounds. Imidacloprid would kill the aquatic invertebrates the shore birds rely for food to continue migration to breeding grounds. The lack of food could kill many shore bird species or prevent them from having enough energy to breed. The direct ingestion of Imidacloprid by shore birds could harm or kill them, thus drastically reducing the populations of many shore bird species along the Pacific Flyway. The proposed application of Imidacloprid during the month of May will also have irrevocable consequences to the multitude of fish species that utilize Willapa Bay and Grays Harbor as juvenile rearing habitats. All the Pacific Salmonid species, bottom fish, rock fish and forage fish rearing in these two water ways would be negatively impacted by the application of Imidacloprid, thus reducing the populations of these vitally important species. The proposed application of Imidacloprid would also kill other juvenile shellfish species in Willapa Bay and Grays Harbor; such as Dungeness crab, shore crabs, red crab and a host of other crab and shellfish species. Juvenile crab species are an important source of food for many species of fish, birds and other marine organisms. What will be the impacts be to the commercial and tribal Dungeness crab fishery when Imidacloprid is sprayed and kills juvenile Dungeness crab? What will the impacts of Imidacloprid application have on the commercial, tribal and recreational salmon fisheries in Willapa Bay and Grays Harbor when juvenile salmonid foraging prey are killed? These are questions that need to be answered. Considering pesticides are generally not allowed on shellfish beds in Puget Sound, this same practice needs to be applied in Willapa Bay and Grays Harbor. The use of Imidacloprid to control ghost shrimp will be detrimental to the marine and ecological environments of Willapa Bay and Grays Harbor. Other practices such as harrowing have shown great results in reducing the populations of ghost shrimp without the use of pesticides. Sacrificing the multitude of marine organisms and other commercial, tribal and recreational fisheries in Willapa Bay and Grays Harbor to benefit oyster growers is not acceptable.
10/30/17 7:53 PM
Comment from: Dick Sheldon
10/30/17 2:00 PM   |  
Comment from: Lynne Bannerman
As an environmental educator I strongly advise against granting the permit for pesticide application to deal with this problem. Humans have created conditions leading to warming temperatures and acidification of the waters. Pesticide application is a short term fix for a much longer term problem and will in the long run create further issues.
10/30/17 12:28 PM
Comment from: David Clark
I own property on the South Sound and want to oppose the use of Imidaclorid in the South Sound and support the comments made by the Coastal Watershed Institute in its October 24, 2017 letter opposing the use of the pesticide.
10/30/17 11:37 AM
Comment from: Michael Sullivan
support the comment letter from the Coastal Watershed Institute found here:
10/30/17 10:48 AM
Comment from: Lynn Lloyd
Hello, I would like to express my concern about the spraying of Willapa Bay with pesticides. I don't see how you can regulate the consequences of such actions. The consequence of spraying will find its way around that bay and up into the food chain and out into the ocean. The "farmers" should find a physical way to solve their problems. Thank you, Lynn Lloyd
10/30/17 8:22 AM
Comment from: Julian Beattie
I am opposed to the use of this pesticide as urge the Department to deny this application. The effects on the local ecosystem have not been adequately studied. The precautionary principle holds that we should not proceed until more is known. Also, my right to a healthy ecosystem outweighs others' right to grow and consume what is in essence a luxury item. Thank you for taking my comment.
10/30/17 8:22 AM
Comment from: Sam Jennings
If you decide to use pesticides on the oysters my family will not be eating oysters. If you do decide to use pesticides It should be labeled as such.
10/29/17 4:45 PM
Comment from: Orca Conservancy (ShariTarantino)
Comments from Orca Conservancy are attached. -ST
10/29/17 4:44 PM   |  
Comment from: Jon/Anna Aufderheide
Do not permit the use of imidacloprid to control the burrowing shrimp. We are straining gnats only to swallow the camel here. Our pollinators are dying en masse from neonicotinoid use! Do not grant permission, please!
10/29/17 2:23 AM
Comment from: Martha Gray
It would be very dangerous as well as totally irresponsible for the Department of Ecology to approve using pesticides in Willipa Bay And Grays Harbor as well as any waters in Puget Sound. This should not be allowed anywhere in our state.
10/28/17 2:36 PM
Comment from: Janine Cohen
Hello, I was a tourist that travelled through SW Wa. and was inadvertently educated about oyster farming. It was disturbing to know that beautiful tidelands are being sprayed with pesticides for the exclusive benefit of old-fashioned, destructive oyster farming practices. Plus, it is a hidden topic. No one who I spoke with about the spraying knew of it before I mentioned it and then they were very interested in finding out more. Yes, to stop spraying would be a big change for the farmers, but this is an enlightened era where people are acting sustainably and spraying pesticides that indiscriminately kill is not popular or healthy for the environment or us. There are other ways to farm oysters that don't require pesticides. I love to eat oysters and didn't eat any in SW Wa. because of the spraying. Janine Cohen
10/28/17 12:47 PM
Comment from: Ann&Alan Musche&Richards
10/27/2017 We agree with Gov Inslee's veto (July, 2017), of the use of imidacloprid in Willapa bay. It is a poison with important disastrous possible effects on the inhabitants of the Bay area, especially pollinating insects, on which we humans, among others, are dependent for survival (as those insects are essential to the growth of many of our fruits and vegetables). It took more than a dozen years, and the efforts of countless people, to finally get Carbaryl removed from Willapa Bay, in 2013, several years after it had been finally banned. Since then, some oyster growers in the Willapa Bay area want to begin using imidacloprid as another poison. Outrageously, and shockingly, public opinion reversed a DOE decision to go ahead with this poisoning, in May 2015. But instead of changing the way they grow oysters, the growers in Willapa Bay continue to want to change to another poison. We think that it is unwise and vastly unfair that their preferences for larger profit margin, with the less labor-intensive methods, should rule the rest of us who stand to lose. Alan Richards & Ann Musche' 250 Knappton Rd Naselle WA 98638 [Residents of PACIFIC COUNTY] Members of Northwest Center for Alternatives to Pesticides (NCAP) Members of Willapa Hills Audubon Society (WHAS)
10/27/17 10:38 AM
Comment from: Cristina McCutcheon
The potential for unintended, and irreversible, consequences is great. Please do not risk the long term health of this ecosystem for relatively short term financial considerations.
10/26/17 9:36 PM
Comment from: Paul Gruver
Stop the use of pesticides everywhere in Washington waters, and in particular, Willapa Bay. You and the shellfish industry are well aware that profitable alternate methods are immediately available to successfully grow shellfish without destroying the environment with poisons in our waters. Stop pesticides in Washington waters!
10/26/17 8:50 PM
Comment from: Martha Hall
Thank you for the opportunity to comment on the possible use of Imidacloprid to kill ghost shrimp. It isn't necessary to read very much of the file before deciding that this is a very bad idea. It seems like these items in the summary provide sufficient evidence that WDFW should not be spraying Imidacloprid into the waters of Washington State: 1. Immediate adverse, unavoidable impacts to juvenile worms, crustaceans, and shellfish to the areas treated with Imidacloprid and the nearby areas covered by incoming tides. 2. Limited impacts bay-wide, but that there is significant uncertainty about the cumulative impacts and other unknown impacts to other marine invertebrates and life cycles. Little known direct risk to fish, birds, marine mammals, and human health. 3. Potential indirect impacts to fish and birds if food sources are disrupted. 4. There are still knowledge gaps about Imidacloprid. Further research is needed. It is time for WDFW to take an ecosystem approach when managing our state's wildlife. Singling out and killing one species, this ghost shrimp, to help commercial oyster farms makes no sense, scientifically, when the impacts on most species is not understood. There is a chance that some endangered species, fish and birds, may be impacted. Some of the species that Imidacloprid spraying will kill are food for many other species, as are ghost shrimp. I can't believe WDFW is even considering this approach. Why not examine the cause of the huge increase in this species of ghost shrimp? What role in this increase can be attributed to the oyster farms, the species of oyster they raise, and/or their management practices? How has the chemistry of these bays/harbors changed over the years? What has happened to the natural food chains in these bays over the years? Probably oyster farming has also meant the loss of habitat and numbers of many native species. Is oyster farming worth it? Would these bays be more productive if oyster farming changed or did not exist? We keep discovering that chemicals are not the answer. They often end up destroying far more than we expect when they are approved. The spraying won't even get rid of the shrimp, and do we really want to get rid of this shrimp? Most likely the surviving shrimp will develop a resistance to this pesticide - or it will be found to be too dangerous and will be banned like the carbaryl that was previously used. We have too many ecosystems showing stress and collapsing already. We have too many endangered species. Yet WDFW is considering use of a new pesticide in some of the most ecosystems in our state? I wonder how productive these bays would be for all citizens of WA State if oyster farms were removed?
10/26/17 6:28 PM
Comment from: Bonnie Henwood
This proposal should not go through. The environmental impacts have not been studied enough and the pesticide is likely to have detrimental effects on other species. From my experience working in a lab with ghost shrimp and imidacloprid, this neonicotinoid is not even very effective against the species. Results suggested that ghost shrimp are easily immobilized (paralyzed) by IMI, but concentrations necessary to kill the shrimp exceed those for other marine invertebrates. Using it widespread would be ineffective and they would be likely to build up resistance over a short time. The more long term causes of the ghost shrimp problem need to be addressed instead. Oyster farm techniques as well as dams have affected the rise in ghost shrimp populations. Using a toxin that is likely to have severe impacts on aquatic species should not be the short or long term solution.
10/26/17 6:16 PM
Comment from: Gina Massoni
I support efforts to protect this fragile ecosystem from a potentially dangerous pesticide application. This plan is understudied, inadequate and fails to protect community and environmental health! Please take a look at the concerns the Northwest Center for Alternatives to Pesticides has identified. These also include suggestions for moving forward: -The presence of data gaps undermines Ecology's conclusion of no significant adverse effects. -Evidence for minimal impact to non-target invertebrates is lacking or contradictory. -Field trials left many questions unanswered. There is inadequate analysis of the effects to threatened and endangered species and no recognition of potential impact to two nearby National Wildlife Refuges. -There are impacts to Dungeness crab. -There is uncertainty regarding important indirect effects and Ecology understates imidacloprid properties (environmental fate) in predicting effects. -Buffers to protect against human consumption are inadequate. -We recognize the importance of the oyster industry to Pacific County and to the state of Washington, and we support efforts to improve Integrated Pest Management (IPM) practices and research and demonstration of non-chemical alternatives. I support timely efforts to expand promising alternatives to neonicotinoids and to increase their feasibility and effectiveness. Investments should be made in educational, technical, financial, policy, and market support to accelerate adoption of alternatives rather than continuing to rely on highly toxic pesticides. Research and demonstration are needed to determine and improve the most effective alternatives and their respective potential and feasibility for farms of different sizes, locations, shrimp population density, and access to equipment. The state should invest its resources in these efforts prior to and instead of allowing toxic contamination of state estuaries. Department of Ecology must protect Washington's water, wildlife, public health, and local economies from the harmful impacts of toxic pesticides. The future of oyster farming in Washington State depends on the industry's ability to adopt sustainable cultural and management strategies.
10/26/17 3:53 PM
Comment from: Tom Jensen
I urge Ecology to deny a permit for applying Imidacloprid to control burrowing shrimp. My sense is that this neonicotinoid chemical has too many unknowns to risk long term impact on the environment of Willapa Bay. As with beekeeping and serious decline in those pollinators, which probably came from a combination of issues (long-distance transport for pollination (exposing bees to new challenges faster than they can evolve defenses), fungi, mites, and more recently neonicotinoids), I worry that Imidacloprid could be one of a combination of issues causing problems in unanticipated ways with other species. I also question the abandoning of helicopter as a proposed application method to the tidal areas. Doesn't the proposed use of boats mean application would be when areas are flooded and prone to unintended dispersal when the tide goes out? (This might be akin to cropdusting drift when it's too windy.) The use of Imidacloprid would also seem to prevent the chance for marketing organic oysters? Here's a nearby example: Thank you for the opportunity to comment.
10/26/17 3:41 PM
Comment from: Heather McFarlane
Why are we discussing an outmoded and dangerous treatment when other areas use above sediment methods to protect their shellfish. I believe Drakes Estero, among others, plunged either wood or metal stakes into the sediment to support cross beams from which they hung/hang product to maturity. They then simply used skiffs/boats etc to harvest among the raised, hanging platforms. Depth of sediment should determine appropriate materials for the long and strong stakes. It is ludicrous to have Washington's Ecology having to expend monies to "control" ghost shrimp, while across State lines, Oregon is studying how ghost shrimp feed salmon, etc, etc.
10/26/17 3:22 PM
Comment from: Stan Marriott
What impact might this pesticide have on the migrating gray whales that feed on the ghost shrimp?
10/26/17 11:45 AM
Comment from: LLyn De Danaan
Oh, please. I can't even be sane in my response. Haven't we been here before....a thousand times...with the wishy washy assessment that there is "no known impact" or maybe some peripheral impact or .......this is simply a bad idea and ANY impact on our struggling native fish AND, btw, shellfish, is simply a bad idea. No, you must NOT issue a permit. There are unavoidable, unforeseen environmental impacts and you must deliver the sad news to proponents. Time and again, big money, big industry seeks to by pass or wiggle around our efforts in the state of Washington to have a clean environment. The coal suit is an example. People don't want it. We know the terminal on the Columbia is a bad idea. But big money will try to force it. Salmon pens rote and allow escapement. We, the people, and the state are trying VERY HARD to hold back and hold on. Please make the right decision on this and do not allow the permit.
10/26/17 11:35 AM
Comment from: Alda Siebrands
It is impossible to imagine any permitting of a substance to control (get rid of/kill) a native species in order to farm a non-native species. No application of a killing pesticide can have a happy ending, except for a very small entity - those who can make money off the elimination of their enemy, a creature that naturally has evolved to exist in those waters. And no way does the application of a pesticide kill selectively. How many studies need to be completed to provide enough information, over a long enough period of time, to finally put to rest the idea that we humans can safely and selectively apply a killer pesticide to an ecosystem with no consequences to everything else that lives in that ecosystem?
10/26/17 10:23 AM
Comment from: Diane Boteler
I am strongly opposed to any use of this dangerous neocontinoid pesticide in Puget Sound waters. The ghost shrimp population increase is clearly a symptom of an ecosystem that is not well. Adding a pesticide with known short term lethality to many collateral marine species and completely unknown long term effects is at best naïve and at worst potentially disastrous for the local ecosystem. Surely our scientists can come up with some alternative that is not so environmentally damaging..And for what gain, a short term economic benefit to a few oyster farmers. For me and I'm sure most other people in the state of Washington my sympathy goes out to these individuals, but their economics should not trump our duty to not inflict further harm to a critically ill ecosystem. I urge you not to approve the use of this, or any other pesticide, in the waters that belong to all Washingtonians.
10/26/17 10:20 AM
Comment from: bill dixon
10/26/17 10:20 AM
Comment from: Coastal Watershed Institute (AnneShaffer)
10/26/17 9:15 AM   |  
Comment from: Robert Rao
I have lived in WA. for 40 years and have lived in Grey's Harbor for 17 years. The previous use of herbicides for ghost shrimp had far lasting impacts on a native species which is critical for food for NUMEROUS species of animals and fish. We used to be able to gather a supply of ghost shrimp for bait at bottle beach and Roosevelt beach in Greys Harbor, but they have not been found in numbers for years now. The oyster growers are just looking to expand their operations and profit at the expense of one of our most important links in the food chain for our native resources. Surf perch, Grey Whales, salmon, and numerous bottomfish need this resource. And why is it that a dangerous pesticide with little research into effects on humans or the environment is even being considered? What officials (elected and otherwise appointed_) suggested such a radical attack on our eco-system? Folks in the pockets of shellfish growers? Look at the long picture, do you want our beaches to be sterile growing mediums for the select few to profit from? or a healthy example of multi-species thriving? Robert Rao
10/26/17 7:05 AM
Comment from: Margaret Fillmore
Our salmon runs are dwindling, orca numbers are declining so anymore pesticides in the water will continue to kill our aquaculture. Large companies like Taylor are abusing our Tide lands with over use without concern for other wildlife. The eagles and other foal feed in these areas putting them at risk also. Cancers are on the rise please don't let them spray our food and wildlife with poison
10/25/17 8:19 PM
Comment from: Karen Miller
It is insane that the state is even considering allowing a pesticide that is banned in other parts of the world to be sprayed on our precious and sensitive waterways simply to improve industrial level shellfish growing that is entirely out of control throughout Western Washington. They are looking to kill a native species in order to grow/sell a non-native species. Where is the sense in this? Perhaps the native species is doing exactly what it should be doing in order to take back it's natural habitat from the invaders placed by industrial level shellfish operations. I will check with any restaurant on their source of oysters and will never purchase from any grower who uses pesticides. DOE you must put a stop to sacrificing our ecological environment for the benefit of a few growers profit margin.
10/25/17 7:24 PM
Comment from: ROBERT WENMAN
Robert Wenman, Resident Gig Harbor, WA 98329 I am concerned that the Department of Ecology is catering to the shellfish industry for purposes that have nothing to do with the wishes of citizens of Washington State, the ecological health of Willapa Bay or human health. While others are banning the use of pesticides, such as Imidacloprid, our Department of Ecology is working closely with the aquaculture industry to expand the use of this dangerous chemical in our precious waters. The number of agencies and retailers who are implementing a ban on the use of the pesticide imidacloprid continues to grow. Most recently, most retailers have agreed to phase out neonicotinoid pesticides, of which imidacloprid is one. The City of Portland issued an immediate ban on its use. The Oregon Legislature has bills before it which would eliminate its use. The US Fish and Wildlife agency has banned their use on wildlife refuges across the United States. The European Commission, in 2013, banned the use of imidacloprid. The NY Times reported in a European Academies Science Advisory Council report stated imidacloprid "has severe effects on a range of organisms that provide ecosystem services like pollination and natural pest control, as well as on biodiversity. Additionally, in 2015 the general public across the state of Washington together with a large coalition of restaurant owners opposed the previous permit based on numerous concerns including ecological impact and impact upon human health . Seattle Times, April, 2015 The following chemicals have been used upon Willapa Bay and Grays Harbor, altering the ecology, and endangering the health of local species and humans that consume fish, shellfish, and waterfowl that utilize these waters: • Carbaryl—Eradicates native ghost shrimp and could harm other benthic species. Known to adversely effect salmon. • Imazapyr—Eradicates spartina. • Glysophate—Eradicates spartina. A recent study* on the effects of glysophate-based herbicides states: "Pesticides may be involved in oyster summer mortality events, not necessarily as a single causative agent but as an additional stressor." • Imazamox—Eradicates Zostera japonica eelgrass, but is known to also eliminate nearby native eelgrass. Adverse effects on other aquatic vegetation are not documented at this time. • Imidacloprid—Eradicates native ghost shrimp and could harm other benthic species. Linked to bee colony collapse disorder and subject of bans in other countries and states. Among the concerns is "...the significant risk Imidacloprid presents to aquatic invertebrates..." which, in turn, "...can also cause a cascading trophic effect, harming fish, birds, and other organisms that rely on them for sustenance." Of special concern noted is the fact that Willapa Bay and Grays Harbor "...are among the most important migratory bird stopover sites on the west coast." I have the following basic concerns with the SEIS: 1.The SEIS is inadequate, in that it ignores best available science; such as bay circulation patterns and sediment/plant capture of systemic poisons designed to kill invertebrates. 2.The SEIS does not consider the impact of the use of Imadacloprid on key species already in trouble. These include waterfowl, salmon, and forage fish. 3.The SEIS does not consider the cumulative impacts of this action and future permits that may further impact this water body or become a determinate on expanding this program to other waters. Request: 1.I request that Ecology declare the SEIS to be inadequate to support drafting an NPDES permit for Imidacloprid for burrowing shrimp removal in Willapa Bay and Grays Harbor. 2.I request that application of Imazamox to kill eelgrass in Willapa Bay be suspended. The Buffer Validation Test is unreliable with respect to how much chemical was actually applied, and suspect when the plan was abandoned to have final review of damage done by an independent WDFW contractor. The latter was removed and replaced with the same Extension Agent who applied the chemical and was at the time in violation of State Ethics codes. Damage was done in drainages outside the protective buffer and evaluated as acceptable by the same conflicted person who supervised the application improperly. 3.A public task force should be set up to advise WDFW on a plan to recover the ecological state of Willapa Bay and review the ecological state of Grays Harbor. Recommendations of this task force would be incorporated in any future plans to remove or restore habitat in Willapa Bay. 4.It is recommended that WDFW immediately restore plans, this year, to survey waterfowl stopping over in Willapa Bay, especially during historical peak periods. The cause of historic declines locally must be determined and corrected. This for example would include November peaks for ducks and geese and spring staging periods for Pacific Brant. Further, WDFW should commit to monitoring herring spawning mass annually in Willapa Bay going forward, and generating a recovery plan for these forage fish. The Willapa Salmon Management Policy should be supplemented with a more robust recovery plan for these fish under current conditions, and expanded to include recovery of both species of sturgeon historically present in large numbers. Sincerely, Robert Wenman
10/25/17 4:41 PM
Comment from: Clayton Smith
Please prohibit the use of pesticides and herbicides on Washington State shellfish beds. It will damage the health of the shellfish industry and of humans!
10/25/17 3:05 PM
Comment from: Melinda Mueller
I oppose the use of imidacloprid to control burrowing shrimp. This shrimp species is native, not invasive, and performs important ecosystem functions (such as bioturbation). Though they are a "pest" in regards oyster farming, "Their effects may, however, have knock-on effects across the entire ecosystem, and may buffer it from the hazards of nutrient enrichment and increase primary and secondary productivity by increasing the amount of dissolved inorganic nitrogen (1)." Furthermore, neoniconotinoid pesticides, such as imidacloprid, pose a significant threat to other species and to ecosystems as a whole. They are known to be toxic to birds, fish, and aquatic invertebrates other than shrimp (2, 3). "Of the neonicotinoids, imidacloprid is the most toxic to birds and fish (4)." These pesticides also pose significant threats to honeybees and other pollinators (5), whose productivity is crucial to Washington agriculture and ecosystems. Finally, near-shore spraying risks pesticide contamination of shellfish that are harvested commercially and by individuals. The use of this pesticide is not a safe or appropriate action. (1) R. James, A. Atkinson & Alan C. Taylor (2005). "Aspects of the physiology, biology and ecology of thalassinidean shrimps in relation to their burrow environment". In R. N. Gibson, R. J. A. Atkinson & J. D. M. Gordon. Oceanography and Marine Biology: An Annual Review. 43. CRC Press. pp. 173–210. ISBN 978-0-8493-3597-6. (2) Morrissey, Christy A., et al. "Neonicotinoid contamination of global surface waters and associated risk to aquatic invertebrates: a review." Environment International 74 (2015): 291-303. (3)Fishel, Frederick M. "Pesticide toxicity profile: neonicotinoid pesticides." University of Florida, IFAS (2005). "Of the neonicotinoids, imidacloprid is the most toxic to birds and fish." (4) Alaux, Cédric, et al. "Interactions between Nosema microspores and a neonicotinoid weaken honeybees (Apis mellifera)." Environmental microbiology 12.3 (2010): 774-782. (5) Henry, Mickaël, et al. "A common pesticide decreases foraging success and survival in honey bees." Science 336.6079 (2012): 348-350.
10/25/17 8:03 AM
Comment from: Edward Vaughn
A recent report has indicated a massive decline in necessary insect populations---bees, butterflies, etc. The cause in almost certainly the use of pesticides. And your response to the problem in Willapa Bay and Grays Harbor is to ... inject more chemicals, specifically Imidacloprid. Precisely how much poison can the earth's system support? AND, what will this poison do to other life forms in the area? Have you no other answer, none? Not very imaginative, folks. Try again!
10/25/17 1:17 AM
Comment from: Bill Abelson
I'm writing to urge you to deny the permit to allow the use of imidacloprid in Willapa Bay and Grays Harbor. Your agency has prudently declined this in the past, since Imidacloprid is a dangerous pesticide found to cause significant harm to species which form the basis of a healthy aquatic ecosystem. If used in Willapa Bay and Grays Harbor, the pesticide could cause serious negative impacts to these ecosystems. Instead of allowing this dangerous pesticide to be sprayed, I urge the Department of Ecology to work with growers to find creative, non-poisonous solutions that will be safe for our food chain and important ecosystems. Thank you for your consideration.
10/25/17 1:02 AM
Comment from: Blythe Horman
I'm writing to urge you to deny the permit to allow the use of imidacloprid in Willapa Bay and Grays Harbor. Your agency has prudently declined this before, due to the fact that Imidacloprid is a dangerous pesticide that many scientific studies have found to cause significant harm to target and non-target species, including aquatic invertebrates, which form the basis of a healthy aquatic ecosystem. The use of this pesticide in Willapa Bay and Grays Harbor could result in serious unanticipated negative impacts to these ecosystems, including imperiled fish and bird species. It seems unlikely that reducing the acreage involved, as the new request proposes, will mitigate the adverse impacts, since the pesticide will disperse unimpeded through the harbor and bay waters. Instead of allowing this dangerous pesticide to be sprayed, I urge the Department of Ecology to work with growers to find creative, non-poisonous alternatives that will not kill off important segments of the food chain and threaten important ecosystems. Thank you for your thoughtful consideration of these comments. Sincerely,
10/24/17 3:35 PM
Comment from: Laura McGrath
I understand that pesticides might be the most cost effective way to address this issue, but this does not consider the cost to ecosystem and human health. More effort needs to be placed on finding a more ecological friendly and less toxic solution.
10/24/17 10:52 AM
Comment from: Anonymous Anonymous
10/22/17 4:59 PM
Comment from: Gloria Plaggemeier
I recommend disapproval of this permit request for the following reasons: 1. Unknown environmental impact 2. Adding yet another toxin to the environment is undesirable. 3. The mud shrimp is an endangered species that generally benefits the aquatic ecosystem. 4. The oyster growers can use an alternative method to grow and harvest oysters that will be beneficial to them (no bad press and lost revenues due to backlash) and the environment. Please review this post: Thank you, Gloria V. Plaggemeier
10/21/17 5:32 PM
Comment from: Dan Hogan
Willapa Bay produces some of the finest oysters in the country. Spraying Imidaclorid would destroy other species and hurt the rest of the oyster farmers because customers would not want to buy contaminated oysters. Plus there are other ways to farm where it is not needed.
10/21/17 10:49 AM
Comment from: Patrick Townsend
This class of pesticide has been implicated in bee colony collapse and should never be used in marine waters. After the salmon net pen disaster the DOE should be implementing the precautionary principle for these types of impacts on the environment. Alternatives already exist that do not require the use of this type of pesticide. There should be no allowed use of imidacloprid in Willapa Bay and Grays Harbor, or in any waters of Washington State.
10/21/17 10:19 AM
Comment from: Clayton Smith
Do not allow spraying or other application of neurotoxins in Willapa Bay!
10/20/17 11:30 AM
Comment from: Teresa Ferrari
I am dismayed and shocked that we must still be fighting against companies & corporations who can only see the value in their 'products' and the profit to be made. This view is shortsighted and does not consider long term health of our waterways, oceans, soils and air. We must not continue to use poisons. One long term view is to consider and believe that the cure for anything we face (human disease, unbalanced ecosystems, pollution) is already present on the earth and we simply need to adopt a new way of thinking and new systemic models. There are other ways to work within a healthy ecosystem to sustainably grow and harvest oysters. I oppose the use of Imidacloprid and trust that the correct action will be taken, one that does the least harm to the masses of species. With faith, Teresa Ferrari CA resident Part time resident on Tomales Bay, another 'oyster waterway'.
10/20/17 10:12 AM
Comment from: Teresa Ferrari
I am dismayed and shocked that we must still be fighting against companies & corporations who can only see the value in their 'products' and the profit to be made. This view is shortsighted and does not consider long term health of our waterways, oceans, soils and air. We must not continue to use poisons. One long term view is to consider and believe that the cure for anything we face (human disease, unbalanced ecosystems, pollution) is already present on the earth and we simply need to adopt a new way of thinking and new systemic models. There are other ways to work within a healthy ecosystem to sustainably grow and harvest oysters. I oppose the use of Imidacloprid and trust that the correct action will be taken, one that does the least harm to the masses of species. With faith, Teresa Ferrari CA resident Part time resident on Tomales Bay, another 'oyster waterway'.
10/20/17 10:12 AM
Comment from: Larry Warnberg
Hello Derek: Thanks for the opportunity to comment on the Draft SEIS. It is encouraging that Ecology is raising serious questions about the adverse impacts of controlling burrowing shrimp with imidicloprid. I hope the application submitted by the Growers' Association will be denied. There should be several corrections to the Draft SEIS, if it is accepted. I found no mention in the document that the burrowing shrimp are a native, foundation, keystone species in the estuaries, while the shellfish are invasive exotic varieties. Shrimp populations have been declining for at least a decade, possibly due to an introduced parasite. Loss of shrimp will have a devastating impact on the ecosystem. Killing shrimp with a pesticide to protect a non-native crop makes no sense. If/when shrimp get listed as Threatened or Endangered the issue of pesticide use will be moot. Contrary to claims by Growers that shrimp continue to be a threat to their crops, evidence presented by scientist John Chapman refutes their claim. The Growers want to deliver granular imidicloprid by boat during high tide, which would lead to rapid dispersal through the estuary with adverse effects on many non-target organisms. There is no mention of dry times at low tide, buffer zones, or efforts to minimize drift off-site. The Growers have inflated the threat from burrowing shrimp, failed to comply with a Memorandum Of Agreement with Ecology to implement an IPM plan, failed for several years to conduct annual meetings on IPM strategies with Agency personnel and stakeholders, while insisting that pesticide control of shrimp is their only option. Their hired scientist Kim Patten defended this point: "In his conclusion, Dr. Patten states that no non-chemical approach is viable as a stand-alone treatment for burrowing shrimp due to logistics, cost, low efficacy, and/or impacts to non- target species. WGHOGA anticipates technical discussions with Ecology to evaluate whether and which non-chemical controls should be included as part of an IPM strategy approach to controlling burrowing shrimp. Within such an IPM approach, non-chemical methods might be proposed as stand-alone controls in particular locations or conditions, or as adjuncts to imidacloprid applications designed to improve the overall effectiveness of burrowing shrimp control." Patten's opinions should be taken with a grain or two of salt. He is not a shellfish farmer. His objectivity must be questioned after it was revealed recently that he accepted money from the Growers, and received Censure from the Washington State Ethics Commission. The Growers rely heavily on his research, which should be dismissed as biased and unreliable. I farmed oysters successfully in Willapa Bay for 25 years without using pesticide. There are many others growing shellfish with non-chemical methods, including the 2 largest companies operating in the 2 estuaries, Coast and Taylor, which opted out of the current permit application. Only a few small Growers on the entire West Coast persist with efforts to obtain a pesticide permit. If Ecology denies their application, viable alternatives exist, the industry will continue, and sustainable organic aquaculture may finally be possible. Naturally, Larry Warnberg
10/19/17 1:36 PM
Comment from: Washington Farm Bureau (TomDavis)
On behalf of the Washington Farm Bureau, we are providing comments on the Willapa-Grays Harbor Oyster Growers Association request for a permit to use the pesticide imidacloprid to control burrowing shrimp in Willapa Bay and Grays Harbor. As a grassroots organization with over 46,000 members, Washington Farm Bureau works to protect the interests of farm families across the state. Today, our members face unprecedented regulatory pressures that threaten the viability of their operations and their capacity to produce good local food on working lands. We understand that the current proposal is for the use of imidacloprid on only 490 acres in the two bays – substantially less than the 2,000 acres in the prior permit request. This represents a significant reduction and one that will greatly diminish any possible concerns that were expressed by a vocal minority last time. In addition, the growers have stated the control will be applied on the tidelands with hand or ground equipment and not by aerial sprayer. This is also a substantial change from the prior permit and shows the great lengths the growers are willing to commit to reduce any potential environmental impacts. The one thing that has not changed is the need to control burrowing shrimp. Without this essential tool, the continued viability of the shellfish industry in the Willapa Valley is at risk. Many of these beds have a history of requiring shrimp control to remain viable for cultivation. Without the use of imidacloprid, an effective and reliable tool, many valuable multi-generational family oyster farms in these two bays could be lost. Solid research demonstrates that shellfish beds become economically unviable once infested by significant populations of burrowing shrimp. This region relies on the economic stability of the shellfish industry, which provides hundreds of jobs, and many more indirect employment opportunities. These rural communities will be greatly impacted economically if a prohibition of imidacloprid was imposed. For these reasons, we encourage approval of the permit. Thank you for the opportunity to comment on this important issue.
10/19/17 10:38 AM
Comment from: Jennie Lindberg
I have reviewed the EIS and believe this plan is understudied, inadequate and fails to protect community and environmental health.
10/18/17 6:58 PM
Comment from: Edward Kolodziej
Dear Department of Ecology, Please note that I think this proposed pesticide action is a bad idea for humans and the environment. As a specialist who makes a career in the fate and transport of organic contaminants, this proposed action seems to pose an unacceptably high, and poorly understood, risk of adverse consequences for non-target organisms and humans. Please lets get past the point where spreading lethal concentrations of toxic compounds throughout our jointly owned environment is considered to b a good idea. There are other ways to address this problem that do not involve the use of toxic chemicals on our aquatic environment. This is a bad idea. Dr. Edward P. Kolodziej
10/18/17 1:45 PM
Comment from: David Ryan
My name is David Ryan. My wife and I live in Ocean Park. My education and experience is as a forester and a natural resource manager. I have experience in managing for habitat and I support the Willapa Grays Harbor Oyster Growers Association proposal to manage burrowing shrimp. I have spoken with representatives from the shellfish industry, scientists, community members, and I have read the reports. The more I learn, the more I know that the oyster growers have done their due diligence and are working to find the best path to a healthy bay. I understand what Imidicloprid is and what it does. I understand the concerns around its use. I have all those same concerns. And I know that the oyster growers have those concerns too. For many human illnesses doctors prescribe medicines that are, technically toxic, yet people ingest and inject these toxins with the understanding that, in the right doses and applied in the right way, the body will be better. My research indicates that the proposed formulations, application methods, concentrations, coverage areas, timing, and monitoring protocols are all adequate mitigation for the issues surrounding its use. And I believe that the result will be a healthy and balanced ecosystem. I believe a healthy oyster industry is indicative of a healthy bay. And when it comes to stewardship of the bay, the shellfish industry has proven themselves to be among the most conscientious and dedicated stewards this community could hope for. They are out there more than anyone and they are the best monitors of the bay, its condition, and changes to the environment. They are fine stewards using good science and I support their efforts. This issue goes beyond a matter of native vs. non-native. This issue is about ecosystem function, ecosystem balance, and ecosystem health. The current burrowing shrimp populations are symptomatic of an unbalanced ecosystem which, if left unchecked, will lead to a degraded and unhealthy bay. I want a healthy bay and I know the oyster growers do too. A "no-action" alternative is unacceptable. And we must find solutions that maintain on-bottom oyster growing as a viable sector of the county economy and ecology. The current proposal is our best chance right now, and we don't have time to delay any more. In the early half of the twentieth century, Aldo Leopold travelled through the west. He addressed the laissez faire attitude he encountered regarding cheatgrass. And although he writes of cheatgrass, I believe the same principle applies here. He says: "I listened for clues whether the West has accepted cheat as a necessary evil to be lived with until kingdom come, or whether it regards cheat as a challenge to rectify past land use. I found the hopeless attitude almost universal. There is, as yet, no sense of pride in the husbandry of wild plants and animals, no sense of shame in the proprietorship of a sick landscape. We tilt windmills in behalf of conservation in halls and editorial offices, but on the back forty we disclaim even owning a lance" I see the oyster growers fighting on the back forty, taking pride in their husbandry and I, for one, will not disclaim ownership of a lance. I take mine up and stand with the oyster growers as they fight for their livelihoods and a healthy bay ecosystem. I do not want to feel the shame of allowing a sick landscape to become our legacy. They have fought this fight before with spartina and I hope we will help them do it again with burrowing shrimp. It's the right thing to do and I urge everyone to support their proposal. Thank you. David Ryan PO Box 338, Ocean Park, WA, 98640 [email protected]
10/18/17 1:24 PM
Comment from: Katie Gaut
I do NOT support this new permit to use the pesticide imidacloprid to control burrowing shrimp on commercial shellfish beds in Willapa Bay and Grays Harbor. I agree with the Northwest Center for Alternatives to Pesticides that: 1) The Toxicity to Non-Target Aquatic Invertebrates is Addressed in SEIS, but Evidence for Minimal Impact is Lacking or Contradictory in the SEIS 2) There are significant Data Gaps that Undermines Ecology's Conclusion Of No Significant Adverse Effects 3) That there was No Recognition of Potential Impact to Two Nearby National Wildlife Refuges 4) Uncertainty Regarding Important Indirect Effect 5) Monitoring Required Under The Permit is Inadequately Described I recognize the importance of aquaculture to the state of Washington, but adequate research and evaluation must be performed to allow for pesticide use in our tidelands and waters. The consequences are far too great to allow operation with this amount of uncertainty. Thank you for your time and consideration and do not hesitate to contact me for additional comments or questions. Thank you, Katie Gaut
10/18/17 11:57 AM
Comment from: Lisa Belleveau
I do NOT support the use of pesticide in the estuaries of Willapa or Grays Harbor!! I commented against this a couple years ago and the permit was withdrawn just to have them try to push it through again! I do NOT approve of the killing of a native species, via poisoning the ecosystem, so that a non-native oyster can flourish! Imidacloprid will kill more than just the target invertebrate and cause damage to these delicate estuarine systems. Many species rely on these productive systems (specifically the benthic invertebrates) to survive; such as salmon, crab, and shorebirds. Salmon and Dungeness crab are NATIVE commercially valuable species and the use of this poison will adversely affect them. These 2 estuaries are incredibly important rest areas for shorebirds as they migrate and without productive benthos to feed on the impacts could prove to be catastrophic! This particular insecticide has been linked to declines in bee populations which could impact many other valuable crops in the near future. There is more to think about here than the decline of one non-native species farming operation. What about the decline in salmon and crab populations? They too are extremely valuable commodities. Perhaps there could be another solution, such as enhancement of oyster beds by the addition of gravels instead of poison. It could potentially cost a similar amount and have a MUCH less detrimental impact on the delicate ecosystem. There must be a way to work WITH the system rather than destroy it for the benefit of a non-native aquiculture operation. I STRONGLY oppose the approval of this permit and hope that the Department of Ecology denies this application.
10/18/17 11:36 AM
Comment from: Kathleen Sayce
It is critical to any decision-making by Ecology about pesticide usage in estuaries that science-based information be the basis for estuarine management decisions. The trend in this agency towards decisions led by public opinion is dismaying. Please get back to facts, back to science, and back to factual ecological outcomes for the shellfish industry. In that light, as an ecologist, I support science-based management of pest species in coastal estuaries, including the use of appropriate pesticides, properly applied. I also support better management of historic predatory fish species to provide control of burrowing shrimp species in the coastal estuaries of Washington.
10/16/17 7:56 PM
Comment from: Ron Figlar-Barnes
I am not supportive of the use of Imidacloprid for ghost shrimp! This is the use of a pesticide that has been found to impact bee populations, and birds. There have been studies ( Pesticide Information Project of Cooperative Extension Offices of Cornell University, Michigan State University, Oregon State University, and University of California at Davis) showing Imidacloprid is toxic to upland game birds--what about the ducks and other bird species associated with Willapa Bay and Grays Harbor? Imidacloprid may be very toxic to aquatic invertebrates besides ghost shrimp. In the same work mutagenic effects were noted as well as teratogenic effects on growth and skeletal structure of rats. Imidacloprid in water is a question mark. No one can point to certainty that this pesticide will not cause harm to the Willapa Bay and Grays Harbor ecosystems. It would be prudent to use a small plot area to test the spread and the effects of imidacloprid. My suggestions; Use harrowing instead of a pesticide. Use fresh water to reduce the ghost shrimp population. Grow your product in naturally rocky sub-straight areas. Specific Questions What is the effect of imidacloprid on Dungeness crab? What is the status of natural rocky sub-straight in Willapa Bay and Grays Harbor? Have investigation been undertaken regarding predators and ghost shimp? What direct investigations have been undertaken to understand the effects of pesticides use in the past in both bays? What is the effect on salmonid populations during out migration? What has been the effect of dredge-harvesting on ghost shrimp?
10/15/17 12:19 PM
Comment from: Sharron Coontz
Please do not allow them to apply a known neurotoxin to the oyster beds. You know the adverse impacts to the ecosystem. And even though further research is needed, there is already plenty of evidence telling us this isn't a good idea. Historically, we've spent a lot of time having to say, "Oops -- there were unintended consequences" and having to deal with those sometimes horrific consequences. Let's not make that mistake again on a popular food source, especially since other companies have found ways to still grow their oysters without resorting to using poison on them. Thanks! Sharron Coontz
10/13/17 7:36 PM
Comment from: Anonymous Anonymous
I own land in Willapa Bay and do not want a neurotoxin sprayed on the water or land that has the potential to pollute my property and to kill all life on it. We have laws against air pollution, second hand smoke, etc. and this is no different. This could have long-lasting impacts on the food chain and should not be permitted. Oyster farmers must change their growing methods instead of looking for a quick fix that could kill us all.
10/12/17 9:25 PM
Comment from: Michael Sullivan
The shellfish industry is expanding on Harstine Island. I am a property owner in which Seattle Shelfish has made an application to install oyster bed racks. This would occur in my front yard. I do not want the application of pesticides to be aproved!!! This will set a precedense that the industry will continuously reference and agenecies will then approve. Concerns: How would the sprayed application once atomized be prevented from spreading to my property and my family and animals from breathing it? What are the studies on the effects of pesticide on humans that will be in the effected area? Application can not be prevented from becoming airborne and impacting local residents and animals. What independent research has been done by DOE; not just data provided by the industry? Can you provide data?
10/12/17 9:35 AM
Comment from: Bill Yake
Without a fundamental change in approach, oyster culture in these areas -- Willapa Bay and Grays Harbor – they will forever remain "estuaries on drugs". 'Drugs' that indiscriminately kill native invertebrates. It's necessary to understand and reestablish the fundamental ecological structure of these waterbodies if we're ever going to have healthy aquaculture there. The EIS should advance this approach. There is a considerable body of knowledge that suggests that the bump in burrowing shrimp populations is largely due to the demise of eelgrass – and the influx of, and subsequent eradication efforts towards, Spartina. It's also likely that increases sedimentation in these watersheds – largely from poor forestry practices – plays an important role. Work should be focused on these sorts of fundamental disruptions in the ecological balance of the estuaries and their watersheds. This draft largely ignores this aspect of the problem – and, therefore, cannot solve the problem in a sound, integral, and ethical way.
10/12/17 8:18 AM
Comment from: William Kelly Rupp
Without question, the threat to our shellfish industry from burrowing shrimp is now critical. Imidacloprid applications have been proven to be effective in containing the shrimps' spread without long-term adverse impact either to habitat or water quality. I'm a property owner on Willapa Bay without business interests in shellfish, and a strong advocate for conservation and habitat preservation; I would not support the permit approval if I believed for an instant that Imidacloprid would compromise our Willapa Bay ecosystem. I urge Ecology to approve this permit application at its earliest convenience. Thank you.
10/11/17 11:17 AM
Comment from: Ann Pelo
We know that neonicotinoids are a disaster for pollinators. We think there's a good likelihood that imidacloprid adversely impacts marine invertabrates and life cycles, and probably also impacts fish and birds by wrecking their ecosystem's health. And the Department of Ecology is considering allowing it to be used on shellfish beds?!? What about the "ecology"part of the department? Beyond legal considerations, beyond commerce, beyond the " yuck" and "no way" from Seattle restauranteurs and consumers, there is an ethical obligation to the ecology of Willapa Bay. That's what you're charged with stewarding, right? Ecology. Ecosystem health. The flourishing of the lives of tiny marine invertebrates and whales, of bees and eagles. The flourishing of life. Not the flourishing of farmers who have disrupted the natural ecosystem by planting more shellfish than the ecosystem can sustain. The flourishing of life. There's such a lot more at stake than shellfish growers' commerical success right now. There's a whole lot of life and living ahead, years and decades and generations from now. The job of the Department of Ecology is to stand on the side of that life living forward. Do not issue a permit for imidacloprid. Sincerely, Ann Pelo
10/10/17 7:20 PM
Comment from: Daniel Dietrich
Seriously? Spray a toxin into our oceans to kill a NATIVE species so a few can profit from it? Please do not even CONSIDER this preposterous request.
10/08/17 9:17 PM
Comment from: Lacey Hughey
Poisoning the ocean to kill native species in order to profit from growing non-native species is unacceptable and unfair to the public citizens sharing these waterways.
10/08/17 11:54 AM
Comment from: George Clyde
I am a consumer of shellfish from Washington State, and I strongly object to use of imidacloprid, both for the environmental reasons and for the health and safety of my family and me as consumers. Best, George Clyde
10/08/17 10:44 AM

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