Our mission is to protect the habitat of Puget Sound tidelands from the underregulated expansion of new and intensive shellfish aquaculture methods. These methods were never anticipated when the Shoreline Management Act was passed. They are transforming the natural tideland ecosystems in Puget Sound and are resulting in a fractured shoreline habitat. In South Puget Sound much of this has been done with few if any meaningful shoreline permits and with limited public input. It is exactly what the Shoreline Management Act was intended to prevent.

Get involved and contact your elected officials to let them you do not support aquaculture's industrial transformation of Puget Sound's tidelands.

Governor Inslee:

Friday, January 3, 2014

Willapa Bay - A Proposal to Spice up The Chemical Soup* With Imidacloprid and Imazamox

New Chemicals Proposed
For the Chemical Soup*
Of Willapa Bay
(*Washington Attorney General's description of Willapa Bay, November 2012)

Public Notice
Washington's Department of Ecology has announced an upcoming public meeting and comment period for a proposal to add some "spice" to Willapa Bay, waters which Washington's Attorney General has described as a "chemical soup" (Public Notice is copied at the end of this post).  Proposed are the addition of the insecticide imidacloprid* to "control" burrowing shrimp and the herbicide imazamox to control Japanese eelgrass on commercial clam beds.
*Imidacloprid is within the class of Neonicotinoid pesticides which are believed to be a cause of honey bee colony collapse disorder. The European Union has voted to heavily restrict its use.

Chemically Treated Oysters
From Willapa Bay - Their "Merroir" Explained

One thing leads to another -
In the mid-1800's Willapa Bay's tidelands were made up of vast reefs of Olympia oysters. To feed the booming population of San Francisco vast harvesting took place which brought to near extinction the native Olympia oyster. In its place came eastern oysters, and with them Spartina. After the eastern oysters experienced a mass mortality oysters from Japan were imported and began to be commercially grown. They reproduce both naturally and through the introduction of seed produced in hatcheries.
A new home brings a new resident

A new home a new resident
With the removal of the large oyster reefs an opportunity for burrowing shrimp to expand into new habitat was presented. With this expansion and their ability to churn the sediments came a softening of those sediments, to the point which oysters were unable to stay on the surface. Like dinosaurs in the La Brea Tar pit, they slowly sank below the surface and died.

Modern Science: 
Kill the shrimp with Carbaryl
And maybe improve the "merroir"?

Modern science and chemical application into Willapa Bay
To counteract the effects of what the shellfish industry now considered a "pest" the chemical Carbaryl was sprayed onto the sediments and into the waters of Willapa Bay to kill the shrimp. Along with whatever other crustaceans happened to be in the area of application.
CAUTION! May kill shrimp and crabs. Do not use in areas where these are important resources. (Warning on Carbaryl label)
Another new home, another new resident, an interesting perspective
As noted on the warning label quoted above, Carbaryl does kill shrimp. Along with the eradication of the shrimp also came the eradication of their effects on the sediments, making them firmer so oysters would not sink. However, that same firmness is also what Japanese eelgrass needs to take root. Just like the burrowing shrimp took advantage of the new habitat created by overharvesting, so too did Japanese eelgrass find an opportunity to expand with firmer sediments. As noted in a 2003 study:
"We believe the removal of the shrimp will continue to broaden the distribution of Z. japonica [Japanese eelgrass] in Washington coastal estuaries where carbaryl use is permitted and add an interesting perspective to this controversial management issue." 
Brian  Sheldon: His clams are small.
New problems, new lobbying, new chemicals
With the expansion of Japanese eelgrass into firmer sediments created by killing off the burrowing shrimp now came a new problem. According to Brian Sheldon his clams are now smaller. His belief is it is due to Japanese eelgrass. Based in large part on lobbying from Pacific County and Mr. Sheldon the Noxious Weed Board agreed to declare Japanese eelgrass a Class C noxious weed. This in turn opened the door for further lobbying for the application of  imazamox on "commercial clam beds" to kill off the perceived "weed." All this despite numerous objections from state agencies who believed that Japanese eelgrass had become a naturalized species, as the non-native Manila clam in Puget Sound has become. Unfortunately for the species who are now dependent on the Japanese eelgrass in Willapa Bay Mr. Sheldon has small clams in a big bay who, with the Pacific Coast Shellfish Growers Association, is an effective lobbyist. Brants geese lost out.

Local politics gets results - be careful what you wish for
Driven by local politics in Pacific County and the Pacific Coast Shellfish Growers Association the Department of Ecology has become convinced it must begin the public permitting process to allow for the application of two new chemicals to the "chemical soup" making up Willapa Bay. If effective the application of imazamox will not only eradicate Japanese eelgrass but, as it is indiscriminant, it will also impact the native eelgrass. Of more significance, once approval for application in Willapa Bay is approved the next target of the shellfish industry will be Puget Sound.

China to the rescue - building awareness of chemicals in shellfish
Looming on the horizon is a consumer with strong concerns about chemicals in its shellfish - China. As seen last month, virtually the entire geoduck industry has been shut down because Chinese testing of geoduck shipments from Alaska and Washington discovered elevated levels of Arsenic and paralytic shellfish poisoning toxins (PSP or PST).* How China will perceive the additional chemcials added to Willapa Bay and their willingness to accept the risk of them "becoming one" with the shellfish from those waters remains to be seen. At the very least the Chinese have created a building awareness that the waters and sediments creating the "merroir" of an oyster - or any other shellfish species - may not always be what you want to know.
*The Department of Health was to have released results from testing geoduck from the Poverty Bay area last Friday (January 3). DOH announced it has been delayed until sometime next week, over one month from the time China made the announcement they had discovered Arsenic in geoducks from Puget Sound. DOH did not explain why the release of the results had been delayed or why testing was taking longer than anticipated.

Just because you can't see it
doesn't mean it's not there.

Public Notice from Ecology
Hello.  I’d like to let you know about an upcoming public meeting and comment period the Department of Ecology is offering for two separate proposals related to commercial shellfish operations in Willapa Bay and Grays Harbor.
The Willapa/Grays Harbor Oyster Growers Association has requested Ecology consider two new control tools to support commercial shellfish Use of the pesticide imidacloprid is being proposed to control burrowing shrimp that harm commercial oyster beds, while use of the herbicide imazamox is proposed to control non-native eelgrass on commercial clam beds.
Ecology is inviting people to comment on:
  • the scope of an environmental impact statement (EIS) for the burrowing shrimp control proposal, and
  • a draft permit and draft EIS for controlling non-native eelgrass in the Bay.
While separate actions, the comment periods for each proposal are the same,Jan 2 to Feb. 15, 2014.
Ecology also will hold a public meeting on Feb. 1, 2014 during which people can learn more about both of these proposals and submit comments on either proposal. The event will start at 10:00 a.m. and run through the afternoon at the Willapa Harbor Community Center, 916 West First Street, South Bend.  It will include:
·         Concurrent “Open House” sessions for both proposals
·         Workshop, public hearing and public testimony on the proposal to control non-native eelgrass
·         Workshop, public meeting and opportunity to provide scoping comments for the EIS studying the proposal to control burrowing shrimp
Additional information on the burrowing shrimp control proposal is available on Ecology’s website:
Additional information on the non-native eelgrass control proposal is available on Ecology’s webpage on the non-native eelgrass proposal:http://www.ecy.wa.gov/programs/wq/pesticides/eelgrass.html
If you have any questions, please contact either of us (although Derek is your best source of information).  Also, if your office receives questions about these issues, please do not hesitate to direct them to us.
Best Regards,
Derek Rockett
Nonpoint Specialist
Department of Ecology
PO Box 47775
Olympia, WA 98504-7775
Gregory Zentner
Acting Southwest Region Manager
Water Quality Program
Department of Ecology
PO Box 47775
Olympia, WA 98504-7775

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