Imidacloprid draft SEIS

Submitted By

418 Results

Search Type

Sort:

Sort Results By

Comment From: Kenichi Wiegardt

11/01/17 @ 2:47 AM

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 ...↓

No attachments

Comment From: Edgar Galvan

11/01/17 @ 1:57 AM

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 i...↓

No attachments

Comment From: Annie Herrold

11/01/17 @ 1:47 AM

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 popu...↓

No attachments

Comment From: Brady's Oysters Inc. (Mark Ballo)

11/01/17 @ 1:07 AM

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...↓

No attachments

Comment From: Ingrid Rasch

11/01/17 @ 1:07 AM

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.

No attachments

Comment From: Daniel Cheney

10/31/17 @ 1:11 PM

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. Th...↓e 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.

No attachments

Comment From: John Conley

10/31/17 @ 11:09 AM

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...↓

No attachments

Comment From: Caroline Armon

10/31/17 @ 9:07 AM

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...↓

No attachments

Comment From: Lisa Olsen

10/31/17 @ 7:01 AM

Attachments:

Download

Comment From: richard james

10/31/17 @ 5:12 AM

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 atta...↓

Attachments:

Download

Comment From: Beyond Pesticides (Nichelle Harriott)

10/31/17 @ 5:09 AM

see attached

Attachments:

Download

Comment From: Jessica Helsley

10/31/17 @ 4:25 AM

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 adip...↓

No attachments

Comment From: Robert Paradise

10/31/17 @ 3:55 AM

Please work for restoration of Willapa Bay and do not allow spraying of Imidacloprid.

No attachments

Comment From: Eric Bensch

10/31/17 @ 3:47 AM

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.

Attachments:

Download

Comment From: Eric Bensch

10/31/17 @ 1:50 AM

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. ...↓

No attachments

Comment From: Kim Figlar-Barnes

10/30/17 @ 12:53 PM

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 w...↓ildlife 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.

No attachments

Comment From: Dick Sheldon

10/30/17 @ 7:00 AM

Attachments:

Download

Comment From: Lynne Bannerman

10/30/17 @ 5:28 AM

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...↓

No attachments

Comment From: David Clark

10/30/17 @ 4:37 AM

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.

No attachments

Comment From: Michael Sullivan

10/30/17 @ 3:48 AM

support the comment letter from the Coastal Watershed Institute found here: https://commentinput.com/attachments/projectID_1001/10063/merged//12829.pdf)

No attachments

Comment From: Lynn Lloyd

10/30/17 @ 1:22 AM

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 ...↓

No attachments

Comment From: Julian Beattie

10/30/17 @ 1:22 AM

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...↓

No attachments

Comment From: Sam Jennings

10/29/17 @ 9:45 AM

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.

No attachments

Comment From: Orca Conservancy (Shari Tarantino)

10/29/17 @ 9:44 AM

Comments from Orca Conservancy are attached. -ST

Attachments:

Download

Comment From: Jon/Anna Aufderheide

10/28/17 @ 7:23 PM

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!

No attachments

Comment From: Martha Gray

10/28/17 @ 7:36 AM

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.

No attachments

Comment From: Janine Cohen

10/28/17 @ 5:47 AM

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 o...↓

No attachments

Comment From: Ann&Alan Musche&Richards

10/27/17 @ 3:38 AM

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, a...↓

No attachments

Comment From: Cristina McCutcheon

10/26/17 @ 2:36 PM

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.

No attachments

Comment From: Paul Gruver

10/26/17 @ 1:50 PM

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 t...↓

No attachments

Comment From: Martha Hall

10/26/17 @ 11:28 AM

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 summa...↓ry 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?

No attachments

Comment From: Bonnie Henwood

10/26/17 @ 11:16 AM

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 neonico...↓

No attachments

Comment From: Gina Massoni

10/26/17 @ 8:53 AM

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 C...↓

No attachments

Comment From: Tom Jensen

10/26/17 @ 8:41 AM

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 dec...↓

No attachments

Comment From: Heather McFarlane

10/26/17 @ 8:22 AM

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 fro...↓

No attachments

Comment From: Stan Marriott

10/26/17 @ 4:45 AM

What impact might this pesticide have on the migrating gray whales that feed on the ghost shrimp?

No attachments

Comment From: LLyn De Danaan

10/26/17 @ 4:35 AM

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 o...↓

No attachments

Comment From: Alda Siebrands

10/26/17 @ 3:23 AM

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 c...↓

No attachments

Comment From: Diane Boteler

10/26/17 @ 3:20 AM

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 ...↓

No attachments

Comment From: bill dixon

10/26/17 @ 3:20 AM

no!

No attachments

Comment From: Coastal Watershed Institute (Anne Shaffer)

10/26/17 @ 2:15 AM

Attachments:

Download

Comment From: Robert Rao

10/26/17 @ 12:05 AM

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...↓

No attachments

Comment From: Margaret Fillmore

10/25/17 @ 1:19 PM

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 an...↓

No attachments

Comment From: Karen Miller

10/25/17 @ 12:24 PM

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...↓

No attachments

Comment From: ROBERT WENMAN

10/25/17 @ 9:41 AM

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 Willap...↓a 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

No attachments

Comment From: Clayton Smith

10/25/17 @ 8:05 AM

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!

No attachments

Comment From: Melinda Mueller

10/25/17 @ 1:03 AM

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, how...↓

No attachments

Comment From: Edward Vaughn

10/24/17 @ 6:17 PM

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 chem...↓

No attachments

Comment From: Bill Abelson

10/24/17 @ 6:02 PM

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 specie...↓

No attachments

Comment From: Blythe Horman

10/24/17 @ 8:35 AM

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 ha...↓

No attachments

Comment From: Laura McGrath

10/24/17 @ 3:52 AM

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. ...↓

No attachments

Comment From: Anonymous Anonymous

10/22/17 @ 9:59 AM

No attachments

Comment From: Gloria Plaggemeier

10/21/17 @ 10:32 AM

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...↓

No attachments

Comment From: Dan Hogan

10/21/17 @ 3:49 AM

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 w...↓

No attachments

Comment From: Patrick Townsend

10/21/17 @ 3:19 AM

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. ...↓

No attachments

Comment From: Clayton Smith

10/20/17 @ 4:30 AM

Do not allow spraying or other application of neurotoxins in Willapa Bay!

No attachments

Comment From: Teresa Ferrari

10/20/17 @ 3:12 AM

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, o...↓

No attachments

Comment From: Teresa Ferrari

10/20/17 @ 3:12 AM

No attachments

Comment From: Larry Warnberg

10/19/17 @ 6:36 AM

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 Gr...↓owers' 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

No attachments

Comment From: Washington Farm Bureau (Tom Davis)

10/19/17 @ 3:38 AM

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 gra...↓

No attachments

Comment From: Jennie Lindberg

10/18/17 @ 11:58 AM

I have reviewed the EIS and believe this plan is understudied, inadequate and fails to protect community and environmental health.

No attachments

Comment From: Edward Kolodziej

10/18/17 @ 6:45 AM

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 ...↓

No attachments

Comment From: David Ryan

10/18/17 @ 6:24 AM

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 pr...↓oposal 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 dcryan28@gmail.com

No attachments

Comment From: Katie Gaut

10/18/17 @ 4:57 AM

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 ...↓

No attachments

Comment From: Lisa Belleveau

10/18/17 @ 4:36 AM

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...↓

No attachments

Comment From: Kathleen Sayce

10/16/17 @ 12:56 PM

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 ...↓

No attachments

Comment From: Ron Figlar-Barnes

10/15/17 @ 5:19 AM

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 o...↓

No attachments

Comment From: Sharron Coontz

10/13/17 @ 12:36 PM

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...↓

No attachments

Comment From: Anonymous Anonymous

10/12/17 @ 2:25 PM

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 c...↓

No attachments

Comment From: Michael Sullivan

10/12/17 @ 2:35 AM

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 aprove...↓

No attachments

Comment From: Bill Yake

10/12/17 @ 1:18 AM

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 reesta...↓

No attachments

Comment From: William Kelly Rupp

10/11/17 @ 4:17 AM

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 qu...↓

No attachments

Comment From: Jim Sayce

10/10/17 @ 12:43 PM

No attachments

Comment From: Nathan Donley

10/10/17 @ 12:43 PM

No attachments

Comment From: Laurie Pine

10/10/17 @ 12:43 PM

No attachments

Comment From: Jeff Nesbitt

10/10/17 @ 12:43 PM

No attachments

Comment From: Laura Hendricks

10/10/17 @ 12:43 PM

No attachments

Comment From: Dick Sheldon

10/10/17 @ 12:43 PM

No attachments

Comment From: Tim Hamilton

10/10/17 @ 12:43 PM

No attachments

Comment From: Ross Barkhurst

10/10/17 @ 12:43 PM

No attachments

Comment From: Mark Emrich

10/10/17 @ 12:43 PM

No attachments

Comment From: Lisa Olsen

10/10/17 @ 12:43 PM

No attachments

Comment From: Kathleen Moncy

10/10/17 @ 12:43 PM

No attachments

Comment From: Norman Olsen

10/10/17 @ 12:43 PM

No attachments

Comment From: Seth Book

10/10/17 @ 12:43 PM

No attachments

Comment From: Eric Anonymous

10/10/17 @ 12:43 PM

No attachments

Comment From: Ann Pelo

10/10/17 @ 12:20 PM

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. An...↓

No attachments

Comment From: Jim Walsh

10/10/17 @ 11:43 AM

No attachments

Comment From: Marilyn Sheldon

10/10/17 @ 11:43 AM

No attachments

Comment From: Daniel Dietrich

10/08/17 @ 2:17 PM

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.

No attachments

Comment From: Lacey Hughey

10/08/17 @ 4:54 AM

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.

No attachments

Comment From: George Clyde

10/08/17 @ 3:44 AM

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

No attachments

Comment From: Frank Wolfe

10/07/17 @ 6:42 AM

No attachments

Comment From: Ross Barkhurst

10/07/17 @ 6:42 AM

No attachments

Comment From: David Beugli

10/07/17 @ 6:42 AM

No attachments

Comment From: Norm Olsen

10/07/17 @ 6:42 AM

No attachments

Comment From: Dick Sheldon

10/07/17 @ 6:42 AM

No attachments

Comment From: Eric Petit

10/07/17 @ 6:42 AM

No attachments

Comment From: Gustave Wiegardt

10/07/17 @ 6:42 AM

No attachments

Comment From: Jim Sayce

10/07/17 @ 6:42 AM

No attachments

[ Previous Page / Next Page ]