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Water Quality Program

Willapa Bay - Grays Harbor
Burrowing Shrimp Control - Imidacloprid

Burrowing Shrimp Control - Imidacloprid

We are evaluating a new application requesting permission to use the pesticide Imidacloprid to control burrowing shrimp in Willapa Bay and Grays Harbor. The application was filed by about a dozen oyster farmers from the Willapa Grays Harbor Oyster Growers Association, who propose to use the pesticide to treat tide lands to support their aquaculture practices.

We are now in the process of evaluating the environmental impacts of the proposal – which we will request your comments and suggestions on when we issue our draft environmental report at the end of this summer.

Similar to previous permit request

This request for a permit is similar – but not the same as – an earlier permit application to use Imidacloprid to control burrowing shrimp. The previous permit application process ended in 2015, but following public concern over the permit, the growers withdrew it, and the permit was never used.

About a dozen of the oyster growers from the earlier permit process have now re-applied for a new permit.

New application process began in 2016

The growers have completed and submitted to Ecology an application for the required National Pollution Discharge Elimination System permit, and applications for two Sediment Impact Zone authorizations for areas in Willapa Bay and Grays Harbor.

These permits regulate a source of pollution in water (in this case, the discharge of a pesticide) and set rules for the discharge, such as containing that pollution to a specific area and requiring that the effect of the discharge is at or below a minor adverse biological effects level.

What’s different this time around?

For this new application, fewer growers propose treating less acreage than the previous application (485 in Willapa Bay and 15 acres in Grays Harbor, as opposed to the previous proposal of 2,000 across both bays) and spraying from boats and/or ground equipment rather than by helicopter.

There is also new information to consider when evaluating the potential environmental impacts of this proposal. New research and new risk assessments have been released by scientists and government agencies. There is also a growing public concern about Imidacloprid, which is a neonicitinoid pesticide.

New review, new decision process

This new, independent permit application will go through the full, normal regulatory process. Now that we have complete applications from the growers, we have begun working on the review and decision process.

This process breaks down into three distinct phases: review of the environmental impacts, a decision on whether or not to develop a permit, and the permit development process.
First phases in the process:

  • Environmental review
    We made a determination of significance and adopted the full Environmental Impact Statement from the previous 2015 permit. We are developing a Supplemental Environmental Impact Statement (SEIS) to evaluate and consider all new relevant information.
  • Public input on environmental review
    We will hold a 45-day public comment period on our draft SEIS. This will include public hearings, stakeholder and tribal briefings, and other opportunities for review and input. We will consider and respond to all comments before adopting our final review of environmental impact.
  • Permit decision point
    At this point, we will consider everything we learned from our environmental review and determine whether or not to proceed with the permit development process. To decide to draft a permit, we must determine the proposal will meet the regulations and environmental impacts from the use of Imidacloprid can be avoided or mitigated enough to be a safe option to control burrowing shrimp.

If we decide the proposal cannot be sufficiently conditioned to be in compliance with the regulations (for example, the proposal has too many acute, unavoidable environmental impacts), we will deny the application and the process will end. If we determine the proposal can be conditioned to meet all the requirements in the regulations, we will continue with the permit development process.

Environmental review process

We have the responsibility to evaluate projects that may have a significant environmental impact under the Washington State Environmental Policy Act. We are evaluating this proposal to determine whether there will be potential to harm the environment. We’re preparing an additional environmental study to inform our decision of whether to deny the permit application or to develop a draft permit approval.

We prepared an Environmental Impact Statement for the 2015 permit process, and we will supplement it with the most up-to-date research and information available. We will develop what’s called a Supplemental Environmental Impact Statement – it will build on the Environmental Impact Statement from 2015.

We’re still early in the review process. Right now we are compiling new research and information that wasn’t available to us when we prepared the 2015 Environmental Impact Statement. This will go into a new draft report, which we will publish for public review and comments.

Even though we’re not ready for official public comments yet, we encourage anyone who wishes to share their views on the applications, or Ecology’s action moving forward, to contact us. Also, if you have information you want to ensure we consider for our supplemental environmental review, please send it to us.

Upcoming public comment period

Once we have a draft Supplemental Environmental Impact Statement prepared, we’ll open a 45-day public comment period. This will be the time to review and comment on the draft environmental report. We’ll also host several public meetings on the draft report in key locations across western Washington.

2016 Permit and SIZ Documents:

To stay informed on opportunities to comment on this process, please join our Aquatic Pesticide Permit ListServ.


Derek Rockett
Email: derek.rockett@ecy.wa.gov
Washington State Department of Ecology
Water Quality Program, Permit Writer
Southwest Regional Office
PO Box 47775
Olympia, WA 98504

2015 Permit and SIZ Documents

Oysters in basket after harvest

Aquatic Pesticides Contacts

Aquatic Pesticide Permit ListServ

Focus Sheet: Control of burrowing shrimp on shellfish beds in Willapa Bay and Grays Harbor

Blog: Ecology has received a new request to use Imidacloprid to control burrowing shrimp