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
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
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
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
- 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
2016 Permit and SIZ Documents:
To stay informed on opportunities to comment on this process, please join our Aquatic Pesticide Permit ListServ.
Washington State Department of Ecology
Water Quality Program, Permit Writer
Southwest Regional Office
PO Box 47775
Olympia, WA 98504
2015 Permit and SIZ Documents