Imidacloprid draft SEIS

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Comment From: Felicity Devlin

12/15/17 @ 1:44 AM

Instead of allowing this dangerous pesticide to be sprayed, I urge the Department of Ecology to work with growers to find creative alternatives to imidacloprid that will not threaten important ecosystems. Marine animals already have enough challen...↓

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Comment From: Paula Mackrow

12/15/17 @ 1:43 AM

. We agreed years ago that eelgrass is of UTMOST importance to the nearshore environment. Critical stages of all marine life live in these nearshore habitats. Industrializing this precious ecosystem has been a catastrophe for the foodchain leading t...↓

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Comment From: Leone Newmark

12/15/17 @ 1:42 AM

This is insanity to use toxins to kill a native species so an introduced species can do better when you are ruining the water, air soil and the planet. This is shear stupidity at the least!

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Comment From: Karen Powers

12/14/17 @ 10:56 AM

Insects that pollinate our food are already in decline. I cannot emphasize enough the importance of not using Omidaclopride.

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Comment From: Richard Horner

12/14/17 @ 10:55 AM

I'm writing to urge you to reject the permit to allow the use of imidacloprid in Willapa Bay and Grays Harbor. If you do not do so, I will stop buying Washington shellfish.

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Comment From: Sego Jackson

12/14/17 @ 10:53 AM

I am an avid oyster eater, was formerly engaged in aquaculture in Penn Cove, and formerly owned Willapa Hills Hatchery. Even so, I am absolutely against use of these pesticides!

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Comment From: Katherine Spence

12/14/17 @ 10:52 AM

Imidacloprid is a dangerous pesticide that many scientific studies have found to cause significant harm to nontarget species, including aquatic invertebrates. The use of this pesticide in Willapa Bay and Grays Harbor could result in serious unanticip...↓

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Comment From: Deborah Rudnick

12/14/17 @ 10:50 AM

It is time to recognize that continued use of toxins in our aquatic environments is the antithesis of what we should be striving for in our relationship to these important natural resources. We have got to find a way of managing our shellfisheries th...↓

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Comment From: Linda Carroll

12/14/17 @ 10:49 AM

As a Washington voter and the daughter of a chemist and science teacher who values our state's environment, I'm writing to urge you to reject the permit to allow the use of imidacloprid in Willapa Bay and Grays Harbor.

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Comment From: Sherry Daniel

12/14/17 @ 10:35 AM

This chemical is also a carcinogen and classified as a Marine Pollutant, so using it near food sources and in proximity to water is doubly dangerous and should not even be considered under any circumstances. Check the product's Safety Data Sheet, pa...↓

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Comment From: Eileen McCabe

12/14/17 @ 10:32 AM

From an economic standpoint, this could also threaten the livelihoods of fisherman in the area.

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Comment From: Liz Frazer

12/14/17 @ 10:31 AM

Please, please, please don't allow this to happen--our environment is already struggling so please don't cause more issues with this toxic pesticide.

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Comment From: Erik Hagstrom

12/14/17 @ 10:30 AM

Yet another attempt by the current administration supporters to turn back the clock to a time when the health of its citizenry took a back seat to the profits of the businesses with a short term view of their resource.

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Comment From: Paula Rotondi

12/14/17 @ 10:27 AM

Enough. We can not allow any additional, new, or increased poisoning of our planet upon which all life including human life depends. Please reject the permit to allow the use of imidacloprid in Willapa Bay and Grays Harbor. We can no longer pursue p...↓

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Comment From: Ellen McKinley

12/14/17 @ 10:25 AM

I am alarmed by the blindness government has shown to the numerous poisons allowed to pollute our planet. Can't y'all see the effects?

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Comment From: Deborah Cruz

12/14/17 @ 10:13 AM

You would think that with all the problems we're having with our shellfish, we would be more careful with them.

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Comment From: Mike Shaughnessy

12/14/17 @ 10:12 AM

This is an absolutely crazy proposed action, with extremely dangerous environmental consequences to our NW coast and it's fish and wildlife populations. Thank you for your thoughtful consideration of these comments, and I look forward to the termi...↓

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Comment From: Mary Hanneman

12/14/17 @ 10:10 AM

I suffer from autoimmune issues caused or exacerbated by environmental toxins. It is crucial for our health to eliminated these toxins in our beautiful seafood.

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Comment From: Form Letter (Multiple) Do Not Allow Imidacloprid

12/14/17 @ 7:42 AM

I oppose the spraying of Willapa Bay and Grays Harbor with any quantity of imidacloprid. Although the "no action" alternative is acceptable, the only really effective and protective alternative is restoration of the bays' ecology. While the SEIS a...↓nd other studies identify "immediate adverse, unavoidable impacts to juvenile worms, crustaceans, and shellfish in the areas treated with imidacloprid and the nearby areas covered by incoming tides," the SEIS fails to give adequate weight to the "knowledge gaps" it identifies. In some cases, monitoring is proposed as a way of reducing uncertainty. In order to protect the bays, facts need to be established before permitting the use of another toxic chemical in Willapa Bay and Grays Harbor. Crucially, the SEIS identifies uncertainties regarding the efficacy of imidacloprid for controlling burrowing shrimp. These uncertainties include questions of the extent and duration of the effect of imidacloprid, the lack of a treatment threshold, lack of data regarding resistance, lack of field research regarding clams, and efficacy of treatment in low temperature. Certainly, no use of imidacloprid can be supported without demonstrating efficacy. The SEIS finds a number of knowledge gaps concerning the direct effects of spraying imidacloprid, including accumulation in sediments, long-term toxic impacts, impacts on zooplankton, sublethal effects, impacts on vegetation, impacts of degradation products, and the area that would be affected. These gaps must be filled before approving the use of the chemical. The SEIS does not adequately address synergistic effects, including impacts of imidacloprid combined with other chemicals ("inert" ingredients, other chemicals used in the bays, and other pollutants) or other stressors. Among the organisms known to be at risk is the commercially important Dungeness crab, which has been shown to be susceptible to the effects of imidacloprid, and whose populations experience large natural fluctuations, putting them at risk of extinction. Given the systemic mode of action of imidacloprid in crop plants, the failure to account for impacts on non-target animals consuming vegetation in treated areas is inexcusable. Willapa Bay and Grays Harbor have been affected by human activity over the past century that has contributed to problems experienced by all who use the bays. Of the three options proposed, the No Action alternative is the best. However, what is truly necessary to address these problems is an option that was not considered in the SEIS –a plan to restore the habitat by removing stressors from streams flowing into the bays. Thank you for your consideration. Sincerely,

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Comment From: Rich Moser

12/14/17 @ 4:44 AM

(Email Submission) Dear Dear Mr. Rockett: Please consider critical new information that should be included in the Supplemental Environmental Impact Statement for the proposal by the Willapa Grays Harbor Oyster Growers Association (WGHOGA) to a...↓pply imidacloprid to Willapa Bay and Grays Bay. Information in a new U.S. Environmental Protection Agency (EPA) aquatic risk assessment shows that imidacloprid cannot be safely used by oyster growers. (USEPA. 2017. Preliminary Aquatic Risk Assessment to Support the Registration Review of Imidacloprid. Office of Chemical Safety and Pollution Prevention. Washington DC) EPA found, "[C]oncentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates." The assessment also found chronic risk concerns with imidacloprid exposure to saltwater invertebrates. The agency evaluated an expanded universe of adverse effects data and found that acute (short-term) and chronic (long-term) toxicity endpoints are lower than previously established aquatic life benchmarks. EPA found risks from imidacloprid exposure to ecologically important organisms not previously evaluated as part of its regulatory review. A 2015 scientific review by Christy Morrissey, PhD, Pierre Mineau, PhD, and others, on the impacts of neonicotinoids in surface waters from 29 studies in nine countries finds that these chemicals adversely affect survival, growth, emergence, mobility, and behavior of many sensitive aquatic invertebrate taxa, even at low concentrations. (Morrissey, C, Mineau, P et al. 2015. Neonicotinoid contamination of global surface waters and associated risk to aquatic invertebrates: A review. Environment International 74: 291–303.) Neonicotinoids were also recently evaluated by a large panel of international experts chartered under the International Union for the Conservation of Nature (IUCN), which found that these chemicals have "wide ranging negative biological and ecological impacts on a wide range of non-target invertebrates in terrestrial, aquatic, marine and benthic habitats." (Van der Sluijs J.P., et al. 2014. Conclusions of the Worldwide Integrated Assessment on the risks of neonicotinoids and fipronil to biodiversity and ecosystem functioning. Environ Sci Pollut Res doi:10.1007/s11356-014-3229-5.) I urge you to consider this and other new scientific data in your review of the permit application by the WGHOGA. I believe that if you do so, you will find that imidacloprid cannot be used in the proposed way without harming the ecology of the bays. Sincerely,

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Comment From: Jane Beattie

12/14/17 @ 4:40 AM

(Email Submission) Dear Dear Mr. Rockett: Please consider new information that should be included in the Supplemental Environmental Impact Statement for the proposal by the Willapa Grays Harbor Oyster Growers Association to apply imidacloprid ...↓

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Comment From: Tom Douglas

12/14/17 @ 4:38 AM

(Email Submission) Please deny the spraying permit application for spraying Imidicloprid in our ocean. This stuff is not only toxic to the pest but to other wildlife in the area and those beds that refrain from spraying. I would also request a...↓

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Comment From: Jan Halliday

12/14/17 @ 4:37 AM

(Email Submission) If the oyster industry fails because of burrowing shrimp, so be it. Find another way to grow them. Spraying neurotoxin or insecticide on mudflats is irresponsible and has been a travesty for decades. I used to write for Na...↓

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Comment From: Linda Carroll

12/14/17 @ 4:34 AM

To the Department of Ecology: On the basis of recent research, neonics should not be used in Willapa Bay and Grays Harbor because of the harmful effect on numerous aquatic species whose benefits to the ecosystem have been demonstrated by research co...↓

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Comment From: W Asprey

12/14/17 @ 4:33 AM

(Email Submission) Sirs and maams, The past amateur pesticide uses and public notifications have been a sick joke. Applications in high winds, no boat launch notices, one blurry notice in a RAYMOND junk paper all lead me to amateur conclusions. ...↓

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Comment From: Ross Lockridge

12/14/17 @ 4:31 AM

(Email Submission) I too oppose the spraying of Willapa Bay and Grays Harbor with any quantity of imidacloprid. Take note of this recent study: Warning of 'ecological Armageddon' after dramatic plunge in insect numbers. https://www.theguar...↓dian.com/environment/2017/oct/18/warning-of-ecological-armageddon-after-dramatic-plunge-in-insect-numbers?CMP=share_btn_link "Three-quarters of flying insects in nature reserves across Germany have vanished in 25 years, with serious implications for all life on Earth, scientists say." Although the "no action" alternative is acceptable, the only effective and protective alternative is restoration of the bays' ecology. While the SEIS and other studies identify "immediate adverse, unavoidable impacts to juvenile worms, crustaceans, and shellfish in the areas treated with imidacloprid and the nearby areas covered by incoming tides," the SEIS fails to give adequate weight to the "knowledge gaps" it identifies. In some cases, monitoring is proposed as a way of reducing uncertainty. In order to protect the bays, facts need to be established before permitting the use of another toxic chemical in Willapa Bay and Grays Harbor. Crucially, the SEIS identifies uncertainties regarding the efficacy of imidacloprid for controlling burrowing shrimp. These uncertainties include questions of the extent and duration of the effect of imidacloprid, the lack of a treatment threshold, lack of data regarding resistance, lack of field research regarding clams, and efficacy of treatment in low temperature. Certainly, no use of imidacloprid can be supported without demonstrating efficacy. The SEIS finds a number of knowledge gaps concerning the direct effects of spraying imidacloprid, including accumulation in sediments, long-term toxic impacts, impacts on zooplankton, sublethal effects, impacts on vegetation, impacts of degradation products, and the area that would be affected. These gaps must be filled before approving the use of the chemical. The SEIS does not adequately address synergistic effects, including impacts of imidacloprid combined with other chemicals ("inert" ingredients, other chemicals used in the bays, and other pollutants) or other stressors. Among the organisms known to be at risk is the commercially important Dungeness crab, which has been shown to be susceptible to the effects of imidacloprid, and whose populations experience large natural fluctuations, putting them at risk of extinction. Given the systemic mode of action of imidacloprid in crop plants, the failure to account for impacts on non-target animals consuming vegetation in treated areas is inexcusable. Willapa Bay and Grays Harbor have been affected by human activity over the past century that has contributed to problems experienced by all who use the bays. Of the three options proposed, the No Action alternative is the best. However, what is truly necessary to address these problems is an option that was not considered in the SEIS –a plan to restore the habitat by removing stressors from streams flowing into the bays. Thank you for your consideration. Sincerely,

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Comment From: Jim Steitz

12/14/17 @ 4:28 AM

***Minimizing competition from native wildlife against an invasive, non-native oyster farming operation is not a legitimate use of an insecticide already shown to have a vast range of non-target damage.*** I oppose the spraying of Willapa Bay and ...↓Grays Harbor with any quantity of imidacloprid. Although the "no action" alternative is acceptable, the only really effective and protective alternative is restoration of the bays' ecology. While the SEIS and other studies identify "immediate adverse, unavoidable impacts to juvenile worms, crustaceans, and shellfish in the areas treated with imidacloprid and the nearby areas covered by incoming tides," the SEIS fails to give adequate weight to the "knowledge gaps" it identifies. In some cases, monitoring is proposed as a way of reducing uncertainty. In order to protect the bays, facts need to be established before permitting the use of another toxic chemical in Willapa Bay and Grays Harbor. Crucially, the SEIS identifies uncertainties regarding the efficacy of imidacloprid for controlling burrowing shrimp. These uncertainties include questions of the extent and duration of the effect of imidacloprid, the lack of a treatment threshold, lack of data regarding resistance, lack of field research regarding clams, and efficacy of treatment in low temperature. Certainly, no use of imidacloprid can be supported without demonstrating efficacy. The SEIS finds a number of knowledge gaps concerning the direct effects of spraying imidacloprid, including accumulation in sediments, long-term toxic impacts, impacts on zooplankton, sublethal effects, impacts on vegetation, impacts of degradation products, and the area that would be affected. These gaps must be filled before approving the use of the chemical. The SEIS does not adequately address synergistic effects, including impacts of imidacloprid combined with other chemicals ("inert" ingredients, other chemicals used in the bays, and other pollutants) or other stressors. Among the organisms known to be at risk is the commercially important Dungeness crab, which has been shown to be susceptible to the effects of imidacloprid, and whose populations experience large natural fluctuations, putting them at risk of extinction. Given the systemic mode of action of imidacloprid in crop plants, the failure to account for impacts on non-target animals consuming vegetation in treated areas is inexcusable. Willapa Bay and Grays Harbor have been affected by human activity over the past century that has contributed to problems experienced by all who use the bays. Of the three options proposed, the No Action alternative is the best. However, what is truly necessary to address these problems is an option that was not considered in the SEIS –a plan to restore the habitat by removing stressors from streams flowing into the bays. Thank you for your consideration. Sincerely,

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Comment From: Christine Hoepfner

12/14/17 @ 4:25 AM

(Email Submission) Spraying Willapa Bay and Grays Harbor with any quantity of imidacloprid is not a sound approach, as the "knowledge gaps" mentioned in the SEIS indicate. The best alternative the SEIS offers is "No Action;" however what is reall...↓

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Comment From: Sherril Futrell

12/14/17 @ 4:23 AM

The only really effective and protective alternative is restoration of the bays' ecology. In order to protect the bays, facts need to be established before permitting the use of another toxic chemical in Willapa Bay and Grays Harbor. The SEIS d...↓

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Comment From: Gayle Janzen

12/14/17 @ 4:18 AM

(Email Submission) It is shocking that your SEIS has so many unknowns about the affects of using Imidalcoprid in Willapa Bay and if it will even achieve the desired outcome. With questions like that, how can you in all good conscience even conside...↓r using this toxic chemical in this environmentally sensitive area? Don't you think it's time to really address the problems the Bay faces by stopping the flow of pollutants into the bay from surrounding areas? If you try to put an Imidalcoprid bandaid on the problem, you are going make the situation worse and will probably kill off a lot more vegetation and animals than you could have even imagined in your extremely flawed SEIS. Therefore, I oppose the spraying of Willapa Bay and Grays Harbor with any quantity of imidacloprid. Although the "no action" alternative is acceptable, the only really effective and protective alternative is restoration of the bays' ecology. While the SEIS and other studies identify "immediate adverse, unavoidable impacts to juvenile worms, crustaceans, and shellfish in the areas treated with imidacloprid and the nearby areas covered by incoming tides," the SEIS fails to give adequate weight to the "knowledge gaps" it identifies. In some cases, monitoring is proposed as a way of reducing uncertainty. In order to protect the bays, facts need to be established before permitting the use of another toxic chemical in Willapa Bay and Grays Harbor. Crucially, the SEIS identifies uncertainties regarding the efficacy of imidacloprid for controlling burrowing shrimp. These uncertainties include questions of the extent and duration of the effect of imidacloprid, the lack of a treatment threshold, lack of data regarding resistance, lack of field research regarding clams, and efficacy of treatment in low temperature. Certainly, no use of imidacloprid can be supported without demonstrating efficacy. The SEIS finds a number of knowledge gaps concerning the direct effects of spraying imidacloprid, including accumulation in sediments, long-term toxic impacts, impacts on zooplankton, sublethal effects, impacts on vegetation, impacts of degradation products, and the area that would be affected. These gaps must be filled before approving the use of the chemical. The SEIS does not adequately address synergistic effects, including impacts of imidacloprid combined with other chemicals ("inert" ingredients, other chemicals used in the bays, and other pollutants) or other stressors. Among the organisms known to be at risk is the commercially important Dungeness crab, which has been shown to be susceptible to the effects of imidacloprid, and whose populations experience large natural fluctuations, putting them at risk of extinction. Given the systemic mode of action of imidacloprid in crop plants, the failure to account for impacts on non-target animals consuming vegetation in treated areas is inexcusable. Willapa Bay and Grays Harbor have been affected by human activity over the past century that has contributed to problems experienced by all who use the bays. Of the three options proposed, the No Action alternative is the best. However, what is truly necessary to address these problems is an option that was not considered in the SEIS –a plan to restore the habitat by removing stressors from streams flowing into the bays. Thank you for your consideration. Sincerely,

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Comment From: EM Ryan

12/14/17 @ 4:16 AM

(Email Submission) Of the three alternatives, the "no action" is best. Nature can clean itself up if given the chance. It can't clean itself up (or a lot slower) if abused by pesticides, herbicides, and other toxins. Your own research shows unc...↓

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Comment From: Lorna Smith

12/14/17 @ 4:13 AM

(Email Submission) Hello, Derek Rockett, Please find attached a letter regarding intention to spray imidacloprid in Willapa Bay and Grays Harbor. I am strongly oppposed to the issuance of such a permit. Thank you Lorna Smith

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