Thank you for your efforts to save Willapa Bay and Grays Harbor.
Washington State Department of Ecology (Ecology) needs to hear from you as it completes a draft Supplemental Environmental Impact Statement (SEIS) on yet another application from oyster growers to poison Willapa Bay and Grays Harbor with the neonicotinoid imidicloprid. This is an unacceptable way to treat a critically important estuary, given what we know about the threat that neonicotinoid insecticides pose to aquatic organisms, in addition to their widely known adverse effects on pollinators.
According to the U.S. National Fish and Wildlife Service: “Willapa National Wildlife Refuge is located in and near Willapa Bay and preserves a number of unique ecosystems including salt marshes, muddy tideflats, rain drenched old growth forests, freshwater marshes, grasslands, and dynamic coastal dunes and beaches. Willapa Bay is one of the most pristine estuaries in the United States and is the second largest estuary on the Pacific Coast.”
The application to use neonics in Willapa Bay was recently submitted to Ecology by a group of oyster farmers from the Willapa Grays Harbor Oyster Growers Association (WGHOGA), who “propose to use the pesticide to treat tide lands to support their aquaculture practices.” Imidacloprid is known to be toxic to bees and aquatic organisms, raising questions on the impacts of its use on the long-term ecological health of the bay.
The target organisms are two species of “burrowing shrimp,” ghost shrimp, Neotrypaea californiensis, and mud shrimp, Upogebia pugettensis , native species that have an important function in this ecosystem, but are blamed by shellfish growers for their declining industry. According to an analysis conducted by the Xerces Society, “The benefits from these species are likely to include ecosystem services such as substrate bioturbation, improving water quality and nutrient availability.” Other species, like migratory birds that depend on shoreline aquatic invertebrates, can also be significantly affected.
An earlier permit issued for imidacloprid use in Willapa Bay and Grays Harbor was withdrawn in May 2015 following a nationwide public outcry. The new proposed permit would cover a smaller area, with application of imidacloprid from boats or ground equipment rather than aerially in helicopters. However, there is new information about the ecological hazards of imidicloprid in aquatic systems that must be considered in the new SEIS and Ecology decision.
The 2017 Preliminary Aquatic Risk Assessment for Imidacloprid by the U.S. Environmental Protection Agency (EPA) and similar risk assessments add new research to the supplemental environmental review being drafted by Ecology. In its 2017 risk assessment, EPA finds risks from imidacloprid exposure to ecologically important organisms not previously evaluated as part of its regulatory review. A 2013 comprehensive assessment of the effects of imidacloprid in surface water reports a wide variety of aquatic invertebrates adversely harmed by imidacloprid residues in water. Ecology needs to consider these important findings as well as others.