23
Oct
Take Action: Your Comments Are Needed, Again, to Save a National Treasure –Willapa Bay
(Beyond Pesticides, October 23, 2017) Willapa Bay and Grays Harbor, with a number of unique ecosystems, and among the most important estuaries in the U.S, are once more in danger of being sprayed with the toxic neonicotinoid insecticide 
imidacloprid. A draft Supplemental Environmental Impact Statement (SEIS) produced by the Washington State Department of Ecology (Ecology) considers two options for spraying imidacloprid and one no-action alternative. Imidacloprid would be sprayed to kill the native burrowing shrimp in beds of commercial Japanese oysters.
Tell Ecology to restore the bays instead of spraying them!
Ecology’ssummary highlights:
⦁ Immediate adverse, unavoidable impacts to juvenile worms, crustaceans, and shellfish in the areas treated with imidacloprid and the nearby areas covered by incoming tides.
⦁ Limited impacts bay-wide, but significant uncertainty about the cumulative impacts and other unknown impacts, including those to other marine invertebrates and lifecycles.
⦁ Little direct risk to fish, birds, marine mammals, and human health.
⦁ Potential indirect impacts to fish and birds if food sources are disrupted.
⦁ Continued knowledge gaps about imidacloprid. Further research is needed.
The SEIS fails to give adequate weight to the “knowledge gaps” it identifies, in some cases indicating that monitoring during use of imidacloprid could be used to reduce uncertainty. In order to protect the bays, facts need to be established before permitting the use of another toxic chemical in Willapa Bay and Grays Harbor.
Among the knowledge gaps found by Ecology are uncertainties over whether imidacloprid is effective for its stated purpose. These uncertainties are crucial, since no spraying can be justified if it is not effective.
Tell Ecology to restore the bays instead of spraying them!
The SEIS finds a number of uncertainties concerning the direct effects of spraying imidacloprid, including accumulation in sediments, long-term toxic impacts, impacts on zooplankton, sub-lethal effects, impacts on vegetation, impacts of degradation products, and the area that would be affected.
The SEIS does not evaluate synergistic impacts of imidacloprid combined with other chemicals (“inert” ingredients, other chemicals used in the bays, and other pollutants) or other stressors. Among the organisms known to be at risk is the commercially important Dungeness crab, which has been shown to be susceptible to the effects of imidacloprid, and whose populations experience large natural fluctuations, putting them at risk of extinction.
Given the systemic mode of action of imidacloprid in crop plants, the failure to account for impacts on non-target animals consuming vegetation in treated areas is not acceptable.
Willapa Bay and Grays Harbor have been affected by human activity over the past century that has contributed to problems experience by all who use the bays. Of the three alternatives presented, the “No Action” option is the best. However, what is truly necessary to address these problems is an alternative that was not considered in the SEIS –a plan to restore the habitat by removing stressors from streams flowing into the bays.
