Oyster Growers plan to pour tons of carbaryl in Washington State bay
Subject: STOP PESTICIDE SPRAYING IN WILLAPA BAY!
Date: Wed, 6 Mar 2002 09:39:20 -0500
From: Stephen Tvedten <steve@getipm.com>
Organization: Get Set Inc. (www.getipm.com)
To: Paul Helliker <phelliker@cdpr.ca.gov>
Director, State of
California, Department of Pesticide Regulation
cc: Christine Whitman whitman.christine@epa.gov
Dear Mr. Helliker, I thought you might like to read the following ACTION ALERT:
ACTION ALERT - STOP PESTICIDE SPRAYING IN WILLAPA BAY!
The Willapa Bay and Grays Harbor Oyster Growers Association wants to spray more than three tons of pesticides onto the
tidelands of Willapa Bay and Grays Harbor in order to control native shrimp that are considered a problem for oyster
production.
The Oyster Growers plan to use carbaryl, a pesticide that is:
o highly toxic to many animals, including birds, amphibians, crabs, and fish;
o toxic to the nervous system and suspected to disrupt hormonal systems; and
o likely to pose a serious threat to salmon and trout in the bay.
The Oyster Growers have applied for a water quality permit from the Washington State Department of Ecology (Ecology) to
carry out the pesticide spray.
Despite the concerns of local residents, other oyster growers who produce oysters without pesticides, and the Shoalwater Bay
Tribe, Ecology has now issued a draft permit that violates the Clean Water Act and allows the oyster growers to pollute water
with huge quantities of carbaryl. If the final permit allows the spray, Willapa Bay and Grays Harbor would be the only place in
the country where spraying carbaryl into water or on tidelands is allowed.
Please write the Department of Ecology before March 22 to make sure the agency upholds the Clean Water Act, protects the
public and environment from the harmful effects of carbaryl, and requires the oyster growers to use alternative methods to
produce oysters.
Alternatives to carbaryl are available and they're working. This spray is dangerous and unnecessary!
Ask the Department to issue a permit that:
o Requires the oyster growers to meet the water quality standards.
o Requires the development and use of alternatives to pesticides.
Submit your comments to:
Kathleen Emmett
Water Quality Program
PO Box 47600
Olympia, WA 98504-7600
Telephone 360-407-6478
Fax 360-407-6426
kemm461@ecy.wa.gov
If you have questions, please contact Erika Schreder, Washington Toxics Coalition, 206-632-1545 x19 or
eschreder@watoxics.org.
Background:
Oyster growers are allowed to apply the insecticide carbaryl to tidelands only in southwestern Washington, under a special pesticide registration by the Washington State Department of Agriculture. Carbaryl may not be applied to water or tidelands anywhere else in the country. In Willapa Bay and Grays Harbor, however, oyster growers have used carbaryl as their main tool against burrowing shrimp since 1963.
Carbaryl is toxic to both people and animals. Because its use in Willapa Bay results in such high concentrations in the bay, it poses a particular threat to salmon and other aquatic life. Five species of salmon are present in Willapa Bay, as well as cutthroat trout. Coho in Willapa Bay are candidates for Endangered Species Act listing, and listing of cutthroat trout has been proposed. Carbaryl has a number of effects on salmon and trout, including impaired growth and reproductive success, bone abnormalities, and disruption of schooling behavior. It is also certain to affect their food supply.
For a number of years, the Washington State Department of Ecology has allowed oyster growers to violate water quality standards by issuing a "short-term modification of the water quality standards." This year, the growers are required to obtain a National Pollutant Discharge Elimination System (NPDES) permit under the Clean Water Act for the first time as a result of a federal court ruling that such permits are required for applications of pesticides to surface water.
Under the NPDES permit system, polluters must meet either water quality standards or standards based on the best available technology. The draft permit issued by Ecology requires neither. The oyster growers would be allowed to violate the water quality standards with concentrations a thousand times greater than the standards; they would only be required to meet the standards 1,978 feet from the site where the pesticide is applied. Ecology has not completed an analysis of what constitutes the best available technology, and is basing the permit on applications allowed by the pesticide label. Thus, the draft permit does not meet the requirements of the NPDES permit system.
Burrowing shrimp are considered a problem for oyster production because they make the tideflats too soft for "bottom culture," or oyster production directly on the tideflats. Many oyster growers, however, use production methods that do not rely on pesticides. Some methods solve the problem by keeping oysters off the tideflat surface. For example, many growers use stakes or stake-and-line production; others use bags and racks. In addition, some growers spread oyster shells or use crop rotation to allow production on the tideflats. These methods could be used by many more growers to end the need for the use of pesticides to control burrowing shrimp.
Well Mr. Helliker, If this were in California, you would not allow the use of any unregistered alternative no matter how safe or effective. Why?
Respectfully, Stephen L. Tvedten
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