Formal Draft of the Zostera japonica Management on Commercial Clam Beds in Willapa Bay General Permit

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Comment From: WSDA (George Tuttle)

11/05/19 @ 5:00 PM

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Comment From: Lisa Belleveau

11/05/19 @ 2:26 AM

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Comment From: Olympic Environmental Council (joe breskin)

11/04/19 @ 4:38 PM

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Comment From: Annie Herrold

11/04/19 @ 12:53 PM

My family and I farm Manila clams along with Pacific oysters on Willapa Bay. Having the ability to control Zostera japonica, a noxious invasive weed, has been a valuable tool for our clam farm. A few weeks ago we were looking through some old photogr...↓

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Comment From: Center for Food Safety (Amy van Saun)

11/04/19 @ 12:51 PM

Please see attached comments.

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Comment From: Center for Food Safety (Joey Lee)

11/04/19 @ 10:12 AM

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Comment From: Larry Phillips

11/04/19 @ 10:01 AM

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Comment From: Kathleen Moncy

11/04/19 @ 8:42 AM

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Comment From: Richard Wilson

11/04/19 @ 8:36 AM

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Comment From: David Beugli

11/04/19 @ 5:35 AM

Jon, Please find the attached comments from the Willapa-Gray Harbor Oyster Growers Association on the renewal of the Zostera japonica Management on Commercial Clam Beds in Willapa Bay General Permit draft. Thanks, David

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Comment From: Pacific Coast Shellfish Grower... (Margaret Pilaro)

11/04/19 @ 4:47 AM

(copy of attached documents) November 4, 2019 Mr. Jon Jennings Washington State Department of Ecology PO Box 47696 Olympia, WA 98504 7696 Dear Mr. Jennings, The Pacific Coast Shellfish Growers Association (PCSGA) appreciates the oppo...↓rtunity to comment on the consideration to reissue the Zostera japonica (Z. japonica) Management on Commercial Clam Beds in Willapa Bay National Pollutant Discharge Elimination System (NPDES) and State Waste Discharge General Permit. PCSGA was founded in 1930 to represent the interests of shellfish growers in the states of Washington, Alaska, Oregon, California, and Hawaii. PCSGA works on behalf of its members on a broad spectrum of issues, including environmental protection, shellfish safety, regulations, and technology. Our Washington members grow a wide variety of healthy, sustainable shellfish including oysters, clams, mussels, and geoduck, and they are very concerned about the negative impacts of the Z. japonica infestation on their farms. As a highly invasive species, Z. japonica is classified as a Class C noxious weed in Washington State. Shellfish farming along the Pacific Coast has a rich history and is critical to coastal counties such as Pacific County as it provides much needed family-wage jobs and local tax revenue. There are many challenges to farming shellfish including water quality, conflicting uses, and the growing presence of noxious weeds. The presence of Z. japonica is increasing rapidly, particularly along the Washington Coast. The infestation of Z. japonica is negatively affecting natural tidelands, natural setting and recruitment of seed. In addition, the presence of Z. japonica is known to alter benthic invertebrates, affect water and sediment temperatures, and reduce shellfish meat yield and increases predation of crops. Imazamox has proved to be a crucial tool in controlling the spread of Z. japonica and has allowed shellfish farmers to reclaim lands for clam production for years. Demonstrating success of the intent of the issuance of the original permit in 2014, less than 40% of the 1,200 acres currently under permit coverage is in need of annual treatment and protection in order for native seagrass remain in place. There have been multiple studies that demonstrate Imazamox to be a targeted chemical and as authorized under the NPDES permit, it impacts the invasive Z. japonica without effecting water quality or harming other aquatic organisms. Imazamox has been a valuable tool for clam farming in Willapa Bay, and has allowed many acres of valuable marine lands to be restored in working with the Conservation District. PCSGA strongly supports the reissuance of the permit. In absence of the permit to use Imazamox, much of the progress that has was made since the permit was issued will be reversed, and puts the economic and environmental health of Willapa Bay and Pacific County in jeopardy. Again, thank you for considering comments on the proposed General Permit for Z. japonica Management on Commercial Clam Beds in Willapa Bay. Please don't hesitate to contact me if you need additional information. Respectfully, Margaret P. Barrette Executive Director

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Comment From: Kim Patten

11/04/19 @ 4:33 AM

There have been no new changes in the science since this permit was issued the first and second time to warrant making any changes in the new permit. The monitoring and reporting system are also working fine, also suggesting that changes to the perm...↓

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Comment From: Brian Sheldon

11/04/19 @ 3:08 AM

November 4, 2019 To: Washington State Department of Ecology Re: Zostera japonica Management on Commercial Clam Beds in Willapa Bay General Permit Hello and thank you for accepting these comments in regard to the re-issuance of the permit t...↓o control the invasive noxious weed Zostera japonica in Washington State. These comments are in addition to the many I have submitted to Ecology on this important invasive species issues over the last 18 years. I am requesting that WDOE reissue the Imazamox/japonica permit in an expeditious fashion, and consider amendments as requested below. The noxious invasive weed Zostera japonica has destroyed tens of thousands of acres of natural habitat along the west coast of the US. It's listed as an invasive noxious weed in all of Washington State's waters, as well as in California. It's displacing native Eel grass Zostera Marina in the lower tideland areas. I have witnessed this in all the areas I visit in Willapa Bay. Its geographic scope has increased from a narrow band in the upper inter tidal range ( 4') in the 1990's, to the lowest reaches of the inter tidal area (-3.5'). While this has occurred, state and federal agencies have taken little if any action to protect natural critical areas from its infestation. In reality, most effort around this issue by engaged agency science and other staff has been to mislead and misrepresent the issue to the public so as to insinuate that this invasive species is a net positive in regard to overall ecological impact. In my 20 plus years of onsite experience with this invasive, nothing is further from the truth. The position of net positive impact is in clear conflict with the documented and real-world impacts this invasive are causing. The end result is that agencies have mismanaged this massive infestation, where if it had been addressed responsibly in the first place it could have been eradicated in the same fashion and location as invasive Spartina has been. At long last some responsible public land managers are stepping up and accepting the facts around the negative impacts this invasive is causing to our estuaries. Displacement of native Eel grass, loss of recreational and commercial shellfish harvest areas, loss of shore and migratory bird forage habitat, loss of sturgeon forage habitat, massive tide flat areas eco-engineered into anaerobic muck supporting other invasive species, etc. While the ability to eradicate this invasive species has likely been lost due to mismanagement, a safe and effective control program has been developed thanks to responsible action of shellfish growers in Willapa Bay. Since 2014 when the permit was initially issued, shellfish growers have conducted a small control program to control this weed. This program has been limited by DOE to only commercial clam beds in Willapa Bay. My understanding is that it's unprecedented to limit permit coverage to only one infinitesimal area of the state for an aggressive invasive species listed on the State weed list as a noxious weed. Through great effort it has been demonstrated that the only effective control is the use of imazamox. By limiting permit coverage as DOE has chosen to do, it has essentially eliminated the ability of all other public and private land managers to implement any control action for this aggressive noxious weed. I request that WDOE remove this restriction from the permit and treat japonica like any other listed weed in regard to coverage under the State's General Permit so other land managers can manage this invasive as necessary, and per state law related to listed noxious weed control requirements. For 6 years now the use of imazamox has been demonstrated to be a safe and effective management tool. It has negligible impacts on other species, and results in a good level of efficacy. It is very effective at returning areas to their more natural high aerobic function so other native species can utilize these areas for foraging, travel, etc. State and public lands left uncontrolled are acting to re-infest controlled areas causing great economic damages to agriculture, and there is no reason for this to be continuing given the proven safety of selectively controlling this aggressive invasive species. The Washington State Department of Agriculture (WSDA) is charged with managing agricultural and other pests that are harming the State's agricultural interests. Japonica has destroyed thousands of acres of agricultural lands and continues to threaten other lands. WSDA manages the state General Permit for the control of aquatic weeds such as Spartina. It's extremely duplicative and unusual for WDOE to be managing an invasive agricultural pest species, and this duplicity and lack of expertise in agricultural pest management is resulting in millions in wasted tax dollars, confusion in the application of weed law, lost agricultural lands, etc. To remedy this, I request that the management of the Zostera japonica NPDES permit be turned over to WSDA to be managed like any of the other 100s of weed species already managed by WSDA under the state General Permit. WSDA has the expertise to manage this weed now that the program has been proven to be safe and effective using imidacloprid. Thank You, Brian Sheldon Northern Oyster Company Ocean Park, Washington

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Comment From: Ross Barkhurst

11/03/19 @ 5:00 PM

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Comment From: Lawren Pulse

11/03/19 @ 5:00 PM

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Comment From: Lyn Z Page

11/03/19 @ 5:00 PM

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Comment From: Donna Harlan

11/03/19 @ 5:00 PM

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Comment From: Barbara Wight

11/03/19 @ 5:00 PM

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Comment From: Lynne Oulman

11/03/19 @ 5:00 PM

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Comment From: Atiah Azhar

11/03/19 @ 5:00 PM

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Comment From: Kate O'Brien

11/03/19 @ 5:00 PM

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Comment From: Alexandria Falcon

11/03/19 @ 5:00 PM

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Comment From: Phyllis Villeneuve

11/03/19 @ 5:00 PM

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Comment From: Allen Elliott

11/03/19 @ 5:00 PM

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Comment From: David Jessup

11/03/19 @ 5:00 PM

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Comment From: Audrey Farrelly

11/03/19 @ 5:00 PM

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Comment From: Pete Compton

11/03/19 @ 5:00 PM

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Comment From: Margery Barlow

11/03/19 @ 5:00 PM

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Comment From: Sara Kaul

11/03/19 @ 5:00 PM

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Comment From: Robert Jensen

11/03/19 @ 5:00 PM

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Comment From: James Ploger

11/03/19 @ 5:00 PM

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Comment From: Phyllis Rapport

11/03/19 @ 5:00 PM

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Comment From: Silvia De Los Santos

11/03/19 @ 5:00 PM

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Comment From: Roger Hardi

11/03/19 @ 5:00 PM

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Comment From: T Reading

11/03/19 @ 5:00 PM

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Comment From: Sherry Petersen

11/03/19 @ 5:00 PM

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Comment From: Ben Rall

11/03/19 @ 5:00 PM

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Comment From: Sally Goodson

11/03/19 @ 5:00 PM

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Comment From: Ann Cobban

11/03/19 @ 5:00 PM

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Comment From: Jennifer Purcell

11/03/19 @ 5:00 PM

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Comment From: Denny Duncan

11/03/19 @ 5:00 PM

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Comment From: Rafael Robles

11/03/19 @ 5:00 PM

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Comment From: Paul Krippner

11/03/19 @ 5:00 PM

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Comment From: Eileene Gillson

11/03/19 @ 5:00 PM

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Comment From: Rene Ray

11/03/19 @ 5:00 PM

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Comment From: Amy Valdez

11/03/19 @ 5:00 PM

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Comment From: Susan Shouse

11/03/19 @ 5:00 PM

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Comment From: Michele Walters

11/03/19 @ 5:00 PM

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Comment From: Diane Weinstein

11/03/19 @ 5:00 PM

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Comment From: Clyde Williams II

11/03/19 @ 5:00 PM

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Comment From: Tika Bordelon

11/03/19 @ 5:00 PM

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Comment From: Lorraine Kristoferson

11/03/19 @ 5:00 PM

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Comment From: Julie Glover

11/03/19 @ 5:00 PM

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Comment From: Kacey A Donston

11/03/19 @ 5:00 PM

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Comment From: Tana Cahill

11/03/19 @ 5:00 PM

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Comment From: Harrie Kessler

11/03/19 @ 5:00 PM

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Comment From: Nancy White

11/03/19 @ 5:00 PM

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Comment From: Yonit Yogev

11/03/19 @ 5:00 PM

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Comment From: Linda Graham

11/03/19 @ 5:00 PM

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Comment From: Janet H.

11/03/19 @ 5:00 PM

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Comment From: Luwana Wanaisie

11/03/19 @ 5:00 PM

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Comment From: Matt Freedman

11/03/19 @ 5:00 PM

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Comment From: Francisco Gadea

11/03/19 @ 5:00 PM

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Comment From: Nancy Hh

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Comment From: Tara Spires

11/03/19 @ 5:00 PM

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Comment From: Brad Kalita

11/03/19 @ 5:00 PM

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Comment From: Greeley Wells

11/03/19 @ 5:00 PM

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Comment From: Nannette Taylor

11/03/19 @ 5:00 PM

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Comment From: Michael Burmester

11/03/19 @ 5:00 PM

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Comment From: Lisa Brienen

11/03/19 @ 5:00 PM

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Comment From: Linda Alstad

11/03/19 @ 5:00 PM

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Comment From: David Laws

11/03/19 @ 5:00 PM

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Comment From: Steve V.

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Comment From: Stephanie West

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Comment From: Philip Chanen

11/03/19 @ 5:00 PM

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Comment From: Ruth Weedman

11/03/19 @ 5:00 PM

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Comment From: Donna Leavitt

11/03/19 @ 5:00 PM

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Comment From: Adam McDuff

11/03/19 @ 5:00 PM

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Comment From: Amanda Caster

11/03/19 @ 5:00 PM

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Comment From: Howard Donaghy

11/03/19 @ 5:00 PM

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Comment From: Lynn And Roger Stapes

11/03/19 @ 5:00 PM

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Comment From: Nina French

11/03/19 @ 5:00 PM

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Comment From: Lorraine Hartmann

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Comment From: Linda Sears

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Comment From: Anne Mosness

11/03/19 @ 5:00 PM

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Comment From: Tracy Richards

11/03/19 @ 5:00 PM

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Comment From: Lori Stark

11/03/19 @ 5:00 PM

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Comment From: Pamela Collord

11/03/19 @ 5:00 PM

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Comment From: Nancy Goodwin

11/03/19 @ 5:00 PM

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Comment From: Lynn Englehart

11/03/19 @ 5:00 PM

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Comment From: Cynthia Marrs

11/03/19 @ 5:00 PM

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Comment From: Michael Czuczak

11/03/19 @ 5:00 PM

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Comment From: Mark Wirth

11/03/19 @ 5:00 PM

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Comment From: Wayne Kelly

11/03/19 @ 5:00 PM

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Comment From: Jackie Critser

11/03/19 @ 5:00 PM

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Comment From: Leonard Hearne

11/03/19 @ 5:00 PM

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Comment From: Billie Abbott

11/03/19 @ 5:00 PM

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Comment From: Diana Williams

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