Irrigation System and Aquatic Weed Control General Permit Reissuance Public Comment Period

19 Results

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Comment From: Washington State Department of... (George Tuttle)

3/20/23 @ 11:45 PM
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Comment From: East Columbia Basin Irrigation... (Jamie Balliet)

3/20/23 @ 3:33 PM
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Comment From: Washington State Water Resourc... (John Stuhlmiller)

3/20/23 @ 2:28 PM
The attached file embodies the comments from the Washington State Water Resources Association.
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Comment From: Roza Irrigation District (Roza Irrigation District )

3/20/23 @ 1:35 PM
This is a continuation of the other comment from Roza Irrigation district.
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Comment From: Roza Irrigation District (Roza Irrigation District )

3/20/23 @ 1:32 PM
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Comment From: Roza Irrigation District (Roza...

3/20/23 @ 1:05 PM
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Comment From: Sunnyside Valley Irrigation Di...

3/20/23 @ 1:02 PM
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Comment From: RSBOJC

3/20/23 @ 11:09 AM
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Comment From: SePRO

3/20/23 @ 10:54 AM
Please see attachment for full text.
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Comment From: Naches-Selah Irrigation Distri... (NSID )

3/20/23 @ 10:54 AM
March 17, 2023

Danielle Edelman
Washington State Department of Ecology
PO Box 47696
Olympia, WA 98504-7696

RE: Public Comments Draft Irrigation System and Aquatic Weed Control General Permit Reissuance

Dear Ms. Edelman,

Thank you for the opportunity to comm...↓

For more than 130 years the reliable flow of irrigation water has grown the area into the thriving communities that provide work and homes to over 13,000 people. Aquatic herbicides are one tool utilized to maintain this vital flow of irrigation water. These chemicals are cost effective, reducing labor and risk of higher impacts from powered equipment alternatives.

NSID supports comments being submitted by other irrigation districts, Washington State Water Resources Association and Yakima Basin Joint Board.

NSID and others have been covered by this General Permit since 2003. We look forward to continued success and partnering with the Department of Ecology for this permit cycle and the decades ahead.

Respectfully,
Naches-Selah Irrigation District

Justin Harter
District Manager
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Comment From: Wenatchee Reclamation District (Waylon Marshall)

3/20/23 @ 10:50 AM
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Comment From: RSBOJC

3/20/23 @ 10:39 AM
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Comment From: Yakima Basin Joint Board (YBJB... (Lori Brady)

3/20/23 @ 9:11 AM
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Comment From: Selah-Moxee Irrigation Distric... (Nathan Draper)

3/17/23 @ 6:13 PM
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Comment From: Naches-Selah Irrigation Distri... (Justin Harter)

3/17/23 @ 3:13 PM
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Comment From: Quincy-Columbia Basin Irrigati... (Roger Sonnichsen)

3/17/23 @ 2:58 PM
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Comment From: SePRO

3/17/23 @ 2:42 PM
Please refer to attached document for full text.
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Comment From: South Columbia Basin Irrigatio... (John O'Callaghan)

3/17/23 @ 9:56 AM
Attachments:

Comment From: SePRO

3/16/23 @ 12:28 PM
50 mg/l.

The draft General Permit reads, "to be eligible for reduced monitoring for copper sulfate use, permittees must have 5 years of water hardness results that are all over > 50 mg/l". In addition to the afore mentioned data demonstrating lower t...↓

The data supports a less stringent hardness level and monitoring period for when chelated copper is used compared with copper sulfate. We propose additional language stating, if chelated copper is being used, water hardness results for one year are needed and those results need to be > 25mg CaCO3/L.


References
Masuda, K., C..E Boyd (1993) Comparative evaluation of the solubility and algal toxicity of copper sulfate and chelated copper. Aquaculture 117:287-302.

Murray-Gulde, C. L., J. E. Heatley, A. L. Schwartzman and J. H. Rodgers Jr. 2002. Algicidal effectiveness of Clearigate, Cutrine-Plus, and Copper Sulfate and margins of safety associated with their use. Environ. Contam. Toxicol. 43:19-27.

Popp, A., Cope, W. G., McGregor, M. A., Kwak, T. J., Augspurger, T., Levine, J. F., & Koch, L. 2018. A Comparison of the chemical sensitivities between in vitro and in vivo propagated juvenile freshwater mussels: Implications for standard toxicity testing. Environmental Toxicology and Chemistry, 37(12), 3077–3085

Riley and Finlayson. 2004. Acute Toxicities of Herbicides Used To Control Water Hyacinth And Brazilian Elodea On Larval Delta Smelt And Sacramento Splittail By. California Department of Fish and Game. Office Of Spill Prevention and Response Administrative Report 04-003

Stauber, J. L. and T. M. Florence (1987) Mechanism of toxicity of ionic copper and copper complexes to algae. Marine Bio. 94:511-519.

Straus, D.L., C.S. Tucker (1993) Acute toxicity of copper sulfate and chelated copper to channel catfish Ictalarus punctatus. J World Aquacult Soc 24(3):390-395.

United States Environmental Protection Agency (2009) Reregistration Eligibility Decision for Coppers. 738-R-09-304. 176 p.

Virginia Cooperative Extension. 2009. Pesticides and Aquatic Animals: A Guide to Reducing Impacts on Aquatic Systems. Publication 420-013. http://hdl.handle.net/10919/48060

WA DOE Supplemental Environmental Impact Statement Assessments of Aquatic Herbicides volume 6: copper
Wagner JL, Townsend AK, Velzis AE, Paul EA. 2017. Temperature and toxicity of the copper herbicide (Nautique) to freshwater fish in field and laboratory trials. Cogent Environmental Science 3:1339386
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