Action of the Week: Help Finalize Decision to Keep Imidacloprid Out of Willapa Bay

Help Finalize Decision to Keep Imidacloprid Out of National Treasure, Willapa Bay; Previous Public Comments Led to Temporary Denial of Use.

The Washington State Department of Ecology (Ecology) temporarily denied a permit to spray Willapa Bay and Grays Harbor with the toxic neonicotinoid insecticide imidacloprid. National Treasure Willapa BayYour comments helped achieve the temporary decision and comments are now needed again to make the denial permanent. The public comment period closes on May 14, 2018.

>>Tell Ecology to restore the bays instead of spraying them!

Willapa Bay and Grays Harbor, with a number of unique ecosystems, and among the most pristine estuaries in the U.S., have been targeted with a plan to spray the toxic neonicotinoid insecticide imidacloprid to kill the native burrowing shrimp in beds of commercial Japanese oysters. This insecticide use will have deadly effects on keystone aquatic organisms. Based on a Supplemental Environmental Impact Statement (SEIS) and public input, Ecology temporarily denied the permit.

Ecology bases its decision on these factors:

  • Too great an impact on the marine organisms that live in the sediments where the pesticide application is proposed.
  • Too much uncertainty about the long-term impacts associated with this pesticide.
  • Negative impacts on fish and birds caused by killing sources of food and disrupting the food web.
  • Even at low concentrations, imidacloprid has significant impacts on the environment.

Among the knowledge gaps found by Ecology are uncertainties over whether imidacloprid is effective for its stated purpose. These uncertainties are crucial, because no spraying can be justified if it is not effective.

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, sublethal 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” or non-disclosed 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 permit cannot be approved without accounting for impacts on non-target animals consuming vegetation in treated areas.

Willapa Bay and Grays Harbor have been affected over the past century by human activity that has contributed to problems experienced by all who use the bays. The best alternative to address these problems is one that was not considered in the SEIS –restoring the habitat by removing stressors coming into the bays from streams flowing into them.

Please use the letter below, with your own adapatations. When you press "submit," it will be delivered to the Washington State Department of Ecology.

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12345 Honey Hammock Hill
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