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, February 2, 2018

Willapa Bay and Imidacloprid: EPA Risk Assessment Released December 22, After DOE Closes Public Comments

Willapa Bay is Too Important
Don't allow another problem like the escape 
of Atlantic salmon to occur. It can be stopped now.
This is a public body of water 
for all of the public to enjoy.

You can't have a food chain without a foundation.
After public comments closed on November 1, of  2017, the EPA released its preliminary risk assessment on imidacloprid on December 22. Shellfish growers in Willapa Bay wish to apply imidacloprid directly to the waters and shellfish beds of Willapa Bay. In the EPA's assessment, a clear risk to aquatic organisms was shown, due to imidacloprid's persistence and how it spread throughout the aquatic ecosystem once it entered. Those aquatic organisms make up the very base of the food chain which species build on, causing a cascading effect on the aquatic food web. [Click here to see EPA's risk assessment, dated December 22.]

Critical points made in the report released December 22, after DOE closed the comment period on November 1.
1. "...aquatic invertebrates in particular are highly sensitive to imidacloprid exposure." (p. 7)
2. "...the potential exists for indirect risks to fish and aquatic-phase amphibians through reduction in their invertebrate prey base." (p. 8)
3. "Chronic risks were also identified for saltwater invertebrates from all foliar spray and combination application method scenarios modeled." (p. 8) [Note: The assessment did not look at the direct application of imidacloprid to the aquatic ecosystem proposed by the shellfish industry.]
4. "The vast majority of use scenarios modeled with soil applications also indicated chronic risk concerns with freshwater and saltwater invertebrates" (p. 8) [Note: Same as above - direct application to the marine environment was not looked at.]
5. "...concentrations of imidacloprid detected in streams, rivers, lakes and drainage canals routinely exceed acute and chronic toxicity endpoints derived for freshwater invertebrates...' (p. 9) [Note: There has been no testing on widespread application to aquatic environments such as that proposed by shellfish growers, only small sample areas.]
6. "the risk findings summarized in this assessment are in general agreement with recent findings published by Canada’s Pest Management Regulatory Agency and the European Food Safety Authority." (p. 10) [Note: Preceding this comment in the report was mortality of crayfish due to a "run off event". Again, this was not a direct application to the aquatic ecosystem as proposed by the shellfish growers in Willapa Bay.] 
7. "...environmental fate properties of imidacloprid suggest high mobility and solubility" (p. 11)
8. "Aquatic invertebrates, specifically aquatic insects, have been shown to be among the most sensitive taxa to acute and chronic exposures of imidacloprid" (p.11)
9. "...new aquatic toxicity data has been generated for imidacloprid since the Agency conducted its most recent ecological risk assessments..." (p. 12) [Some from Willapa Bay, some generated from a scientists found in violation of state ethics laws for not disclosing, in part, his ownership of shellfish beds and a contractual relationship with one of the largest shellfish growers who would benefit if  studies of herbicide application showed positive results. Click here to read agreed to stipulation.

Get involved
Willapa Bay is a public body of water within which a diverse set of aquatic species exist. The Department of Ecology's denial or approval of this permit is dependent on having a clear picture of what the short term and long term impacts of this proposal will be. As noted in the EPA assessment, aquatic invertebrates are "highly sensitive" to imidacloprid. These make up the very base of the food chain upon which a larger population depends on.  The assessment showed there was "high mobility and solubility" in the marine environment, meaning it very likely when applied this pesticide would spread and kill an unknown number of non-target species. 

Shellfish Growers Have Alternatives to Pesticides in Public Waters
Washington's marine ecosystems are too important to simply brush aside the very real adverse and significant impacts which come along with aquaculture, which in this case is the proposal to apply a pesticide to Willapa Bay's public waters. There are funding opportunities to develop alternative growing methods (already used by some growers) which the National Marine Fisheries Services pointed out in their November 1 public comment letter, which opposed approval of this permit. Those funding sources include NMFS' Saltonstal-Kennedy Grant Program; NOAA Sea Grant's Marine Aquaculture Grant Program; NOAA Small Business innovation Research Program; and, NMFS' Finance Program. 

Tell your elected officials you are opposed to the application of pesticides in Willapa Bay. The shellfish industry has both alternative methods and funding to develop those methods available.

Elected representatives:

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