Annie Herrold

Dear Mr. Rockett:

I am a fourth generation oyster farmer in Willapa Bay and I strongly believe that the Draft SEIS supports the issuance of a Draft Permit. My family has been farming in Willapa Bay for over 100 years and we have worked to control burrowing shrimp populations since their explosion in the 1960’s. Currently we are facing an infestation and without any tools to reduce the population on our beds they are being destroyed and the estuary as a whole is beginning to see what will be devastating effects if burrowing shrimp are left unchecked. If you have taken the time to walk the beds, then you’ve seen the disastrous effects the shrimp are having. As a member of the local Chinook Indian tribe and family that are long time Pacific County residents, I care deeply about the health and sustainability of Willapa Bay. Farming oysters is a way of life for us, and without a healthy balanced ecosystem our way of life would cease to exist…READ MORE

Association of Washington Business

Dear Mr. Rockett,

Thank you for considering the Association of Washington Business’s (AWB) comments on the Draft Suppl emental Environmental Impact Statement for the Proposed Use of Imidacloprid for Burrowing Shrimp Control on Commercial Oyster and Clam Beds in Willapa Bay and Grays Harbor . AWB is Washington’s oldest and largest statewide business association, and includes nearly 7,000 members representing 700,000 employees. AWB serves as both the state’s chamber of commerce and the manufacturing and technology association…READ MORE

Brian Sheldon

Dear Mr. Rockett,

We appreciate the opportunity to provide comment on the draft Supplemental Environmental Impact Statement (SEIS) for the use of imidacloprid to control burrowing shrimp in Willapa Bay and Grays Harbor. These written comments are in addition to the verbal in p ut we provided on this subject at the October 7, 2017. Having reviewed the SEIS, prior EIS, and many other documents, we find that these documents support the issuance of an NPDES permit to allow the control of burrowing shrimp on shellfish beds in Willa pa Bay and Grays Harbor…READ MORE

Coalition of Coastal Fishers

RE: Willapa Bay/Grays Harbor Burrowing Shrimp Control

TAKE HOME MESSAGE of this letter: The Coalition of Coastal Fisheries fully supports the WGHOGA Willapa Bay/Grays Harbor Burrowing Shrimp Control Permit of Imidacloprid for the following reasons.

Areas infested with ghost shrimp are virtual biologic deserts that have little ecological value and do not support any of the biological diversity found in productive oyster beds brought into production using the insecticide that have been treated with Imidacloprid that we have personally witnessed on several trips to Willapa Bay. Ghost shrimp must be controlled…READ MORE

Dan Cheney

I’ve been involved with various aspects of shellfish farm management in Willapa Bay and elsewhere since the 1970 ‘s. The SEIS correctly observes the difficulties farmers face in growing oysters on grounds densely colonized with burrowing shrimp. The high shrimp densities observed since the 1960’s have been described as reflecting both human disturbances and changing ocean – system dynamics. The current proposal to apply imidacloprid to reduce shrimp densities on the most productive grounds in Willapa Bay and Grays Harbor, is the result of concentrated efforts since the mid – 1990’s to: 1) examine alternative control and culture methods; 2) study the ecology and marine chemistry of the growing areas; 3) better understand the ecosystem services provided by shellfish culture; and 4) conduct laboratory and field experiments on the effects of a range of chemical, physical and electrical tools for shrimp control…READ MORE

David Beugli

Thank you for providing an opportunity to comment on this new Supplemental Environmental Impact Statement for the control of burrowing shrimp using imidacloprid.

The Willapa Grays Harbor Oyster Growers Association was founded in 1959 as a way for shellfish farmers to work together to solve common problems. Current membership includes about 20 farms located in Willapa Bay and Grays Harbor. The majority of these farms are family owned and have been farmed by the same families for multiple generations. The shellfish industry is the single largest private employer in Pacific County responsible for nearly 2000 family wage jobs. This represents over 100 million dollars in economic output on a yearly basis. In addition, Willapa Bay and Grays Harbor represent the largest oyster growing areas in the US producing nearly 25% of the nation’s oysters…READ MORE

David Ryan

My name is David Ryan. My wife and I live in Ocean Park. My education and experience is as a forester and a natural resource manager. I have experience in managing for habitat and I support the Willapa Grays Harbor Oyster Growers Association proposal to manage burrowing shrimp.

I have spoken with representatives from the shellfish industry, scientists, community members, and I have read the reports . The more I learn, the more I know that the oyster growers have done their due diligence and are working to find the best path to a healthy bay. I understand what Imidicloprid is and what it does. I understand the concerns around its use . I have all those same concerns . And I know that the oyster growers have those concerns too…READ MORE

Dick Sheldon

I submit this testimony based upon 77 years hands-on interaction with the tide and bedlands of Willapa Bay. I met my first Ghost Shrimp at age 5 digging cohogs at Stackpole Harbor in 1940.

I’ve spent most of my life working the bedlands of Willapa for local oyster companies and our own Northern Oyster Company holdings. I doubled our company through observation of key tidal flows, current patterns, soil structure, stability and many other subtle indicators that those overlooked wastelands could be made productive. Every one of these bedlands were at the time quicksand, Ghost Shrimp monocultures, unused by shorebirds, devoid of eel grass, zero habitat for prey species, and benthic invertebrates with no possibility of spawning grounds for herring, sandlance, or other fishes, no depressions or vegetated tidal pools, nothing but quick sand and strings of filimus algae destined to form large mats that settle onto oyster beds poisening every benthic creature trapped beneath it…READ MORE

Kathleen Sayce

It is critical to any decision-making by Ecology about pesticide usage in estuaries that science-based information be the basis for estuarine management decisions. The trend in this agency towards decisions led by public opinion is dismaying. Please get back to facts, back to science, and back to factual ecological outcomes for the shellfish industry. In that light, as an ecologist, I support science-based management of pest species in coastal estuaries, including the use of appropriate pesticides, properly applied. I also support better management of historic predatory fish species to provide control of burrowing shrimp species in the coastal estuaries of Washington.

Nisbet Oyster Co.

On behalf of Nisbet Oyster Co., Inc., I am pleased to submit comments in support of the Draft Supplemental Environmental Impact Statement (Draft SEIS) for control of Burrowing Shrimp using Imidacloprid on Commercial Oyster and Clam Beds in Willapa and Grays Harbor, Washington issued by the Washington Department of Ecology for public comment on September 15, 2017. We support the of issuance of a National Pollution Discharge Elimination Permit (“NPDES”) as analyzed in the preferred alternative of the Draft SEIS and offer these comments in addition to those submitted through the WIllapa Grays Harbor Oyster Growers Association…READ MORE

Pacific Coast Shellfish Growers Association

Thank you for providing an opportunity to comment on the Draft Supplemental Environmental Impact Statement (SEIS) relating to the Willapa Grays Harbor Oyster Growers Association’s (WGHOGA) permit application to use the pesticide Imidacloprid on burrowing shrimp in Willapa Bay and Grays Harbor. These comments are submitted on behalf of the members of the Pacific Coast Shellfish Growers Association (PCSGA)…READ MORE

Tiffany Turner

Good Afternoon Mr. Rocket,

I am a local hotel and restaurant owner in Long Beach WA. As someone who was against the first permit in 2015, I wanted to submit comment on the draft SEIS.

Since spring of 2015, I have done considerable research on the impact of burrowing shrimp on commercial oyster and clam beds as well as the health of the entire ecosystem.

The oyster and clam industry is critical to the economic health of our area, and burrowing shrimp pose a significant threat to many family farms who have been incredible stewards of the bay for generations. Many families and businesses have worked for decades and spent considerable dollars to find a less impactful solution to control burrowing shrimp…READ MORE

Vicki and Steve Wilson – Arcadia Point Seafood

Thank you for this opportunity to provide comments on the draft SEIS. Our family operates a small shellfish company in South Puget Sound. Although burrowing shrimp are not as large a problem on our farms as they are in the WIllapa Bay and Grays Harbor areas, we have seen first hand the negative impacts they can have on the ecology and productivity of tidelands.

We recognize that Ecology is in the pre-decisional phase of the process and the current focus is on the draft SEIS. However, before turning to the SEIS we want to make it clear that we support issuance of this NPDES permit as soon as is reasonable, with of course appropriate conditions and monitoring requirements that are (1) operationally realistic, (2) aligned with best available science/information, and (3) allow for adaptive management as experience dictates…READ MORE

Washington Farm Bureau

On behalf of the Washington Farm Bureau, we are providing comments on the Willapa-Grays Harbor Oyster Growers Association request for a permit to use the pesticide imidacloprid to control burrowing shrimp in Willapa Bay and Grays Harbor.

As a grassroots organization with over 46,000 members, Washington Farm Bureau works to protect the interests of farm families across the state. Today, our members face unprecedented regulatory pressures that threaten the viability of their operations and their capacity to produce good local food on working lands…READ MORE

Willapa/Grays Harbor Oyster Growers Association

The Willapa/Grays Harbor Oyster Growers Association (“WGHOGA”) submits these comments in support of the Draft Supplemental Environmental Impact Statement for Control of Burrowing Shrimp using Imidacloprid on Commercial Oyster and Clam Beds in Willapa Bay and Grays Harbor, Washington (the “Draft SEIS”) issued by the Washington Department of Ecology for public comment on September 15, 2017. WGHOGA is supportive of issuance of a National Pollution Discharge Elimination Permit (“NPDES”) as analyzed in the preferred alternative of the Draft SEIS, and offers the following comments that (1) emphasize the economic importance of the shellfish industry in Pacific and Grays Harbor County; (2) stresses the importance of a burrowing shrimp control program as part of the continued economic viability of the shellfish industry in those two counties; and (3) clarifies, corrects, or provides additional details relevant to the analysis undertaken by Ecology in the Draft SEIS…READ MORE