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:
http://app.leg.wa.gov/DistrictFinder/

Ethics in Science - Imidacloprid in Willapa Bay: Lead Washington State University Scientist Under Ethics Investigation

"State officials and employees of government hold a public trust that obligates them, in a special way, to honesty and integrity in fulfilling the responsibilities to which they are elected and appointed. Paramount in that trust is the principle that public office, whether elected or appointed, may not be used for personal gain or private advantage." RCW 42.52.900, Ethics in Public Service

Killing a native species with pesticides

in Willapa Bay. Based on what science?

There's a shrimp burrowing through trust in DOE's decision making.

The Department of Ecology has released its Draft Environmental Impact Statement on the application of Imidacloprid on up to 2,425 acres of shellfish beds in Willapa Bay over a 5 year period. The DEIS notes on page 1: "The Willapa Grays Harbor Oyster Growers Association (WGHOGA) and Washington State University's Long Beach Research and Extension Unit began testing imidacloprid (a neonicotinoid instecticide) in 1996..." WSU's Kim Patten has been involved since 1996, being the head of the Extension Office since 1990. Kim Patten owns tidelands which benefit directly from DOE's reliance on his studies, comments, and/or papers.

"Dr. Patten led most of the studies

 of the effectiveness of imidacloprid in reducing burrowing

shrimp densities in Willapa Bay, Washington"

(DEIS, page A-10)

Shellfish bed owner, user of state resources

for personal gain, Kim Patten

Education: Bachelor’s degree in plant science 

from University of California-Davis in 1977; 

master’s degree in horticulture from Iowa State University in 1980;

 Ph.D. in horticulture from Washington State University in 1984
Aquaculture is not horticulture.

DOE was aware of the conflict of interest, but chose to ignore it. [click here for letter provided to DOE's director Maia Bellon in January of this year]

September 8, after an investigation begun in January, the Washington State Executive Ethics Board found there "...is reasonable cause to believe..." that Kim Patten has or may be violating RCW 42.52, the Ethics in Public Service law. The detailed conflicts of interest and use of public resources for individual gain detailed in the investigation, were known to the Department of Ecology prior to their decision to renew and modify the permit for the application of the herbicide Imazamox to shellfish beds in Willapa Bay. Despite knowledge of the clear conflict of interest - detailed in a comment letter to DOE  which pointed out his ownership of tidelands which would benefit from issuance of the permit- DOE simply dismissed the detailed information in their response to comments (p. 8 bottom) and said: 

"Ecology is not aware of an instance where purposely misleading data or falsified data has been submitted regarding this permit. Additionally, we rely upon the best available science at the time that the Ecology action is taken."

Integrity above all.

The Department of Ecology has many responsibilities to the public, but paramount to all of these is trust. Trust that when DOE makes a decision it is made based on studies created by those who have no conflict of interest in the outcome of those studies. Trust that when DOE is provided summaries of studies all studies related to the question at hand are provided, not a select few which support the sought for outcome, which would result in financial gain to the person providing those studies. Trust that when a probable conflict of interest is pointed out they not dismiss it but examine the questions completely. Once again, DOE is aware of Kim Patten's clear conflict of interest in his supporting the application of the pesticide Imidacloprid on Willapa Bay shellfish beds and public waters.

Get involved.

Spraying pesticides onto Willapa Bay shellfish beds is a bad idea, no matter who creates the "science." There are alternative growing methods used by Taylor Shellfish, Coast Seafoods and others who have said they do not need to use Imidacloprid. Get involved and tell DOE to reject this DEIS on its face and not approve a permit. Comments - and a copy of the ethics violation - may be sent to DOE at:

Email: burrowingshrimp@ecy.wa.gov

Derek Rockett, droc461@ecy.wa.gov

Water Quality Program

Washington State Department of Ecology

Southwest Regional Office

PO Box 47775

Olympia, WA 98504

Attend the Open House/Public Hearings. 

Open House/Public Hearing 

Oct 7 and Oct 10

[click here for additional information]

Most effectively: Stop buying/eating oysters and clams from Willapa Bay until this proposal is dropped.