The Xerces Society and partners provide comprehensive comments on the proposed use of insecticides to control native burrowing shrimp in Willapa Bay and Grays Harbor

The comments are in response to the Washington State Department of Ecology’s proposal to develop an Environmental Impact Statement for use of the toxic neonicotinoid imidacloprid for the control of two species of native burrowing shrimp, Neotrypaea californiensis and Upogebia pugettensis, on commercial shellfish beds in Willapa Bay and Grays Harbor.

There is substantial information that the application of imidacloprid has great potential to damage the rich marine ecosystems of Willapa Bay and Grays Harbor. The pesticide is water soluble, long-lived, and highly toxic to aquatic invertebrates, such as insects and shrimp and other crustaceans. Imidacloprid can kill large portions of invertebrate populations and consequently harm fish—including salmon and steelhead listed under the Endangered Species Act—birds, and other organisms that rely on them for sustenance. An initial evaluation of this proposed use of imidacloprid found unacceptable risk to Dungeness crabs.

Birds depend heavily on the aquatic systems at the center of the food web. The expected reduction in invertebrate prey as a result of imidacloprid applications could reduce the health and fitness of birds, especially breeding and migrating birds and young hatchlings. There are also issues with compliance with the Migratory Bird Treaty Act and the Endangered Species Act.

For the full comments click here.

For additional information contact Aimee Code at [email protected] or 541-232-9767.

To read the Washington State Department of Ecology’s proposal, click here.

These comments are a collaborative effort of the American Bird Conservancy, Beyond Pesticides, Beyond Toxics, the Center for Food Safety, the Endocrine Disruption Exchange, Haereticus Environmental Laboratory, Institute for Fisheries Resources, the Northwest Center for Alternatives to Pesticides, Pacific Coast Federation of Fishermen’s Associations, Pesticide Action Network North America, the Xerces Society for Invertebrate Conservation, and Robert Michael Pyle.