Imidacloprid in Willapa Bay: Goose Point Oyster/Others Press On - "No other way."

Pristine Waters of Willapa Bay?

It just needs pesticides added directly to it.

Growers complain of urban runoff. 

But direct application of pesticides by them is okay.

Welcome to business. If it were easy, everyone would be doing it. 
In a presentation put forth for OPB, owners of Goose Point oyster claim there is no other way for them to grow oysters than to be allowed to spray their beds with the pesticide Imidacloprid, banned in the European Union. Because there is a lack of willingness to develop and implement alternative growing methods such as those Taylor Shellfish has, Goose Point's owners believe the only way is to spray Willapa Bay with Imidacloprid, one of the neonicotinoids being banned in foreign countries*.

*Some ask why let a foreign country control US policy? Some ask why foreign countries grounded 737 Max jets before the US. Sometimes the US isn't always right.

The threat to Willapa Bay is not native species.

It is pesticide use from oyster growers.

And a lack of imagination and willingness

to accept that sometimes business has expenses.

Welcome to "pristine" waters of Willapa Bay. Where pesticides were applied directly.

Willapa Bay is often described as having "pristine waters" which grow some of the best oysters in the world. While it's true that Willapa Bay grows an enormous number of oysters, claiming the waters to be "pristine" while spraying pesticides on oyster beds for decades stretches integrity. Washington's Attorney General went so far as to describe the waters as a "chemical soup" in 2012 (see p. 32 here). Direct application of Carbaryl/Sevin by growers then only made it worse, as Imidacloprid will today.

Use some Thinking Time.

It's not rocket science.

Welcome to business problem solving. It's not, "We don't know what else to do!"

Oyster growers claiming there is no other way are not taking the time to problem solve. Some claim that pole and rack/line systems would work like those used by Taylor Shellfish, but sediments are so soft poles used fall over. Do they not make longer poles which get driven into firmer sediments?  Just because oyster growers have been used to simply throwing oyster shell onto the bedlands of Willapa Bay, spraying pesticides, and using the public waters as a food source to grow oysters doesn't mean there aren't alternative methods. It only means there is a lack of will because it may cost more to grow oysters. Business is tough sometimes.

All the PR help in a tall building

will not convince consumers

oysters from beds sprayed with 

pesticides are safe/good to eat.

Welcome to bad PR advice. The Hard Reality: You will kill demand for oysters from Willapa Bay and all of Washington.

Public Relations firms will be more than happy to take money and make a point you want them to. It's what they get paid to do in their 25th floor offices. It's not to tell you the hard realities in life. In this case, if oyster growers are successful in their appeal to Washington and are granted a permit, the demand for Willapa Bay and Washington oysters will drop. Efforts to export Washington oysters to the European Union will be for nothing when they discover Imidacloprid - a pesticide the EU has banned - is being sprayed on the oyster beds Washington oysters are grown on. The East Coast Shellfish Growers Association has already said, pointedly, they "...use no feeds, fertilizers, pesticides or antibiotics." That is the hard reality Washington oyster growers will be up against if Willapa Bay growers are successful. That advice is free.

Canada Further Restricts Use of Imidacloprid/Neonicotinoids: Willapa Bay Shellfish Growers Continue Appeal to Use in Marine Waters and On Washington Oyster Beds

My grandfather did it this way

and my father did it this way.

It doesn't make it right.

Should Canada drive policy decisions? They helped ground the 737 MAX when the FAA wouldn't. They should also help drive the decision to reject the appeal by the Willapa Grays Harbor Shellfish Growers Association who continue to walk into a cement wall of resistance to applying pesticides to oyster beds, not understanding the wall isn't going to move.

(See article on increased restrictions of Imidacloprid here: https://ipolitics.ca/2019/04/11/health-canada-restricts-certain-pesticide-uses-because-of-bee-health-concerns/)

Despite being told by the public, in no uncertain terms, they do not want oysters raised on beds sprayed with pesticides, Washington shellfish growers either support or are silent on the pursuit of a permit to do so. (Read on decision to appeal here: https://www.kiro7.com/news/local/oyster-growers-appeal-state-decision-to-deny-pesticide-use-1/863242698)

Despite being told by agencies the application of Imidacloprid on Washington oyster beds should not be permitted, Washington shellfish growers either support or are silent on the appeal of that decision by WGHOGA. (See denial letter from DOE to WGHOGA here:  https://ecology.wa.gov/DOE/files/9f/9f907372-0c3d-4d5c-aea2-116a38516e10.pdf)

"Our Imidacloprid is different."

How much did it cost to convince 

a lobbyist to believe that?

Despite being printed on virtually every label of a product containing Imidacloprid that it is toxic to marine invertebrates and should not be applied in the intertidal area, shellfish lobbyists convinced the EPA that in the case of Willapa Bay and Grays Harbor, their proposed use of Imidacloprid was different. Their profits should override the concerns every other manufacturer of products containing Imidaicloprid had and they should be allowed use it to eliminate native burrowing shrimp - and any other marine invertebrate which happens to be in the area - so they are able to grow nonnative Pacific oysters. All the while complaining about urban runoff, dairy/cattle farms, and septic systems  impacting marine waters and their ability to grow oysters.

How many times does Washington's shellfish industry need to walk into this wall of resistance to their idea - or silence on it - before they realize it is their product which will be tainted and, along with it, whatever profits they hoped to gain.

The European Union will never accept oysters from Washington when they find out what growers in Governor Inslee's "green state" have done and want to continue to do. That's a wall you don't want to walk into.

Get involved. Tell Washington oyster growers - whether they support the appeal or are currently silent on it - to stop the process. There are alternative ways to grow oysters which will effect their profits far less than a market refusing to buy oysters from Washington where pesticides are applied to oyster beds.

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.