The Xerces Society submits comments on the Department of Ecology's proposal to apply the pesticide imidacloprid in Willapa Bay and Grays Harbor, a proposal driven by the shellfish industry.
See comment letter here: https://app.box.com/s/566kfjrrab8...n2ney9tlb
See comment letter here: https://app.box.com/s/566kfjrrab8...n2ney9tlb
Just another native "pest" to the shellfish industry.
In comments sent to the Department of Ecology, The Xerces Society for Invertebrate Conservation (supported by other numerous groups - see below) notes it has "...substantial concerns about the plan set forth in the draft permit and draft EIS" DOE has proposed which address the application of imidacloprid on shellfish farms in Willapa Bay and Grays Harbor. Its purpose would be to eliminate the native burrowing shrimp which shellfish growers claim make sediments too soft to grow shellfish on. Its action would result in far more damage.
Let them eat cake. Somewhere else.
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."
The letter goes on to detail the concerns over neonictinoid insecticides, which imidacloprid is, being applied to critical marine ecosystems of Washington. It clearly defines why it is premature to grant a permit and states clearly that DOE has not provided a "..structure for a robust integrated pest management program."
In its conclusion it states: "Ecology has not adequately justified the use of imidacloprid, especially not the expanded acreage currently proposed."
The letter is supported by the Audubon Washington, Beyond Pesticides, Center for Biological Diversity, Center for Food Safety, Coalition To Protect Puget Sound Habitat, Friends of the Earth, Institute for Fisheries Resources, Northwest Environmental Defense Center, and the Pacific Coast Federation of Fishermen’s Associations.
Citizens need to make clear to agencies the shellfish industry today is not what it was when the Shoreline Management Act was created in the early 1970's. It can no longer say it is a "preferred use" and simply do as it pleases. Get involved. The shellfish industry is, and has been for too long.
The letter goes on to detail the concerns over neonictinoid insecticides, which imidacloprid is, being applied to critical marine ecosystems of Washington. It clearly defines why it is premature to grant a permit and states clearly that DOE has not provided a "..structure for a robust integrated pest management program."
In its conclusion it states: "Ecology has not adequately justified the use of imidacloprid, especially not the expanded acreage currently proposed."
The letter is supported by the Audubon Washington, Beyond Pesticides, Center for Biological Diversity, Center for Food Safety, Coalition To Protect Puget Sound Habitat, Friends of the Earth, Institute for Fisheries Resources, Northwest Environmental Defense Center, and the Pacific Coast Federation of Fishermen’s Associations.
Citizens need to make clear to agencies the shellfish industry today is not what it was when the Shoreline Management Act was created in the early 1970's. It can no longer say it is a "preferred use" and simply do as it pleases. Get involved. The shellfish industry is, and has been for too long.
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