Formal Public Comment Period -- Draft 2026 Aquatic Plant and Algae Management General Permit

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Comment From: Betsy Norton

10/24/25 @ 10:20 PM

I am a birder and hiker and concerned about biodiversity amid climate change. I am particularly concerned about accumulations of alum precipitate on lake bottoms and associated cumulative levels of metals, Sulfides and organic chemicals in our lakes ...↓

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Comment From: Snohomish County DCNR SWM (Jennifer Oden)

10/24/25 @ 5:25 PM

Comments on Draft Aquatic Plant and Algae Management General Permit

Jennifer Oden, Snohomish County SWM

Fact Sheet Comments
Pg 8 – missing explanation of 2025 EPA vs. SF ruling. Just one sentence in current draft, "Add explanation of 2025 EPA vs. ...↓

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Comment From: Ronda Larson Kramer

10/24/25 @ 4:20 PM

I appreciate the improvements to permitting over the past four years in terms of being science-based and protective of aquatic life. But I would urge you to add a requirement for Ecology limnology and biological experts to review site specific inform...↓

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Comment From: Esther Kronenberg

10/24/25 @ 11:50 AM

I write as a member of the Clean Black Lake Alliance , a citizens group which monitors the health of Black Lake in Thurston County. We advocate for treatment that uses herbicides as a last resort, not the first, in alignment with the 2012 IAMVP done...↓ for Black Lake.

I appreciate Ecology's intent to give greater flexibility to the use of aquatic herbicides, add lanthanum based control of phosphorus and to add requirements around testing the impacts of aluminum sulfate on water quality.

I urge Ecology to consider the following when issuing this permit.

1. Ecology states the application of pesticides must not cause or contribute to lower water quality standards. (S3.A.1) A technical memorandum done by Thurston County's hydrogeologist found strong evidence that contaminants from lakes were entering deeper aquifer layers that supply Olympia's drinking water. See uploaded file.

Does Ecology know the cumulative effects of annual herbicide use on the groundwater of each lake? Protecting the drinking water should be Ecology's Number 1 priority. I urge Ecology to study these cumulative impacts before issuing annual permits.

2. Ecology should have data on each lake's historic use of chemicals and their results on DO and on salmon predation in littoral vegetation zones in which herbicides were applied. Herbicide use reduces dense vegetation.
DO should also be measured at night when it is the lowest to get an accurate read on its actual presence.

More site specific data for each lake should also be provided.

3. Ecology should better describe surface waters to which landowners' "unreasonable interference" applies. There are ditches with low DO and dense vegetation which provide habitat to threatened species like the Olympic mudminnow in Western Washington.

Habitat should be an at least equal, if not more important, use criteria when setting water quality effluent limits.

4. Ecology states individual actions covered under a general permit need not go through independent Tier 2 review. That means there is no additional review of impacts of waters of higher quality from new projects. Ecology needs to be proactive to prevent the degradation of waters of higher quality BEFORE they are impacted.

5. I also note that according to Ecology's own documents, the Black Lake SUD is not authorized under State law to do this kind of work. It was formed under RCW 85.38 for diking, drainage and flood control, which is not an RCW listed as valid for obtaining an algae and herbicide permit. The BLSD should be reconfigured as an LMD with appropriate public input to be consistent with Ecology's rules.

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Comment From: Northwest Aquatic Management, ... (Kyle Steelhammer)

10/24/25 @ 11:36 AM

The attached files were submitted by Jeff Tepper earlier in 2025. We have been working with Jeff for several years in regard to ZV Iron and its effectiveness in Lakes and agree with his findings and supported documentation.

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Comment From: Anonymous Anonymous

10/24/25 @ 8:34 AM

Plese help out the groups trying to figure out how or whether they need to control phosphurs in Black lake. I am concerned over the amt of alum and sulfate that must be accumulating in there.

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Comment From: Washington Department of Fish ... (Rae Eaton)

10/23/25 @ 8:53 PM

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Comment From: Okanogan County Noxious Weed C... (Darla Dolph)

10/23/25 @ 10:47 AM

WDFW Timing Window Change
I would like to make a suggestion for an amendment to the timing window for lakes that only have restrictions for waterfowl? For instance, lakes that have planned treatments and will only be treated in residential/lakeside p...↓

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Comment From: Woodland Resource Services Inc... (Eric Meador)

10/23/25 @ 9:11 AM

I think having the list of approved adjuvants live on the website instead of the appendix of the permit is a great idea for the reason stated in your comments!

Great to have Triclopyr Choline added to the list of approved ingredients. The "Irrigatio...↓n Permit" is where we're having the most trouble with such a short list of approved products. We're now facing Glyphosate resistant Kochia here on the east side because in "orchard/vineyard" areas glyphosate is the only post-emergent product allowed on the inner banks of canals. (2,4d is too volatile for those areas)

On page 24, S5.E2.B there is a clause regarding posting signs that face both the water and the shore. From our 15 years of experience, the sign facing the water seems to be redundant and only contribute to more litter and wasted materials. If they were in the water when we posted the sign; they would see us doing it and realize a treatment was about to take place. If they entered the water after the sign was posted, they would see the sign facing the shore as they approached the water body anyway. I just can't think of a likely scenario where the sign facing the water would ever be used.

S6.A.1: This provision seems very challenging to the actual work-flow that typically occurs. Typically, treatments are scheduled weeks in advance (business/residential notice as well as Ecology pre-treatment notification requirements the week before) and the contracted applicator arrives the morning of the treatment. This provision appears to require the temperature to be taken, at a minimum, and possibly other parameters. Either the applicator would do it when they arrive (and possibly have to turn around and drive hours home) or the sponsor would need to do it the day before to make sure conditions were permissible for treatment. Can the permittee delegate the task to the sponsor who likely lives close to the site? Is there a relatively inexpensive device that can measure these parameters that sponsors could buy? I could see a potential for a real challenge if it's a shallow waterbody that is subject to the July 15th WDFW timing window restrictions forcing us to wait for the hottest time of year in order to be able to treat. The provision also doesn't state how long prior to treatment the measurements can be taken...1 day, 1 week, 1 month?? If the applicator is required to visit the site the day before (i.e. a special trip) to take the sample, it could add enough cost to smaller jobs that the treatment would no longer be financially viable. Maybe there have been issues with fish kills related to this, but I'm not aware of any.

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Comment From: Gloria Charland

10/20/25 @ 4:16 PM

I support the intent of your general proposal to:
1) revise monitoring requirements around DO and some types of treatment to reduce P,
2) clarify treatment timing windows,
3) increased flexibility on aquatic herbicides
4) add lanthanum=based cont...↓

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Comment From: Shannon Brattebo

10/20/25 @ 10:05 AM

Comments on Draft Aquatic Plant and Algae Management General Permit

1. General comment – phosphorus is spelled several different ways throughout permit document. Suggest searching document and ensuring that one spelling is used.

2. Section S2.A #2 ...↓

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Comment From: Esther Kronenberg

10/03/25 @ 2:44 PM

Hello,
I write as a member of the Clean Black Lake Alliance in Olympia WA. Our organization's mission is to advance lake management strategies that do not rely on herbicides and other toxic materials to control lake vegetation. Instead we advocate ...↓the use of mechanical harvesting, installation of effluent interceptor projects such as constructed marshes and wetlands, stormwater nutrient capture using biochar, upstream filtration and fertilizer runoff reduction to control algae and excess lake vegetation.

I am attaching a technical memo by Thurston County's hydrogeologist who studied 58 water wells around the Tri-Lakes area which is dominated by Type I CARAs and overlaps part of the area protecting Olympia's McAllister Wellfield, its primary drinking water source. The area is ringed with many on-site septic systems.

The study found that "significant groundwater contamination does exist, and is likely related to OSS, but that other sources probably contribute to nitrate loadings." (Page 1) It also found Chemicals of Emerging Concern (CECs), including pesticides and herbicides in an initial screening. (Page 10) There are hundreds, if not thousands, more of these CECs, all of which threaten to contaminate our drinking water. (See Figure 12, Page 11)

The study also found that the downward pull of hydraulic gradients, increased in part by heavy deeper groundwater pumping, is causing vertical movement of contaminants to deep aquifers below confining layers. (Page 14)

This should be deeply concerning to Ecology as it permits the use of herbicides in lakes. Ecology must assume that these herbicides, and other CECs will end up in our deepwater aquifers in areas that are populated, due to the presence of deep water wells causing a downward hydraulic gradient, and OSSs.

I urge Ecology to only permit the use of these dangerous chemicals to situations where the public health is threatened. Their use DOES result in the contamination of our drinking water aquifers in certain areas, like Thurston County. It is more important to protect our drinking water than to rid a lake of nuisance weeds.

Some other points - I am happy to see Ecology describing how much algae is beneficial, and though a nuisance, is not a public health threat.
I would urge Ecology to cite research as to whether the percentage of the littoral zone where herbicides may be applied will not increase predation risk and lower dissolved oxygen. Ecology should include text that herbicides may increase dissolved oxygen causing release of phosphorus from sediments, thereby exacerbating harmful algae blooms. Does Ecology know how many plants can be killed before dissolved oxygen levels rise?

I was concerned to read that Tier 2 analyses are not done for lakes with high water quality. How is it in the public interest to degrade high quality water? Does Ecology require that listed species be identified in these high quality lakes, and the effect of degrading the water quality would have on these listed species?

For example, the Olympic mudminnow requires dense vegetation to secure its eggs. Can Ecology ensure this threatened species' survival by adding language to protect the dense vegetation conditions needed by the Olympic mudminnow?

Thank you for this opportunity to comment and for your diligence in protecting the water resources of our State.

Uploaded Tech Memo 77 - Tri-lakes area

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Comment From: Bonnie Blessing

9/17/25 @ 9:13 AM

Salmon get preyed on by bass blugill and perch that tend to use different amounts of littoral aquatic vegetation. At some point, Ecology should consider reviewing the literature on how much littoral vegetation should be removed. Here's 3 articles rel...↓

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Comment From: Bonnie Blessing

9/15/25 @ 2:47 PM

Hello
I uploaded a file with some comments for the next draft algae and aquatic plant permit. Thank you

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