From Jim Trondsen, the chair of the Water Committee of the Finger Lakes Group.
-------- Original Message -------- Subject: Bad things happen to good lakes. Date: Tue, 15 Apr 2008 00:48:01 GMT From: Jane & Jim Trondsen <[EMAIL PROTECTED]> To: Hi Everyone, This is Jim Trondsen with some disturbing news about state waters and about New York State Department of Environmental Conservation. This month marks the fifth anniversary of the experimental whole-lake application of the chemical fluoridone to Waneta Lake in the Finger Lakes area. The application was permitted by DEC for the purpose of eradicating eurasian water milfoil from the lake. At the time of this experiment it was the largest single application of fluoridone anywhere. The experiment was a disaster for the lake. Milfoil was not eradicated and is now back to pretreatment levels. Five species of native plants are still missing, and native plants are still depressed by 80%. Due to the highly disturbed condition of the lake, three more invasive species have infested the lake, including zebra mussels. Two important lessons should be learned from the Waneta Lake disaster: disturbed habitat invites infestations by invasive species; and treating a symptom (milfoil) while ignoring the root causes (disturbed condition of the lake) only makes the situation worse. The same group of people that were permitted to apply fluoridone five years ago are now applying to do the same thing with a different chemical called triclopyr. They want to apply 49,000 pounds of solid and 1135 gallons of liquid to all of Waneta Lake and its sister lake Lamoka and Mill Pond, an adjoining wetland. This is another experiment because it would be the largest aquatic application of this chemical anywhere. Concentrations of triclopyr would be over 100 times the concentration used for fluoridone. And triclopyr has very disturbing characteristics: it is known for its ability to penetrate into ground water and it may be considered a type C carcinogen. Evidently DEC is poised to permit application of triclopyr, since they have already awarded the permit applicants a grant of $200,000 of New York State funds intended for eradication of aquatic invasive species. This is a disproportionate 15% of the total funds for the entire state. One questions the fairness, especially since the award is for two lakes from which the public is excluded. There is no public shoreline access on either lake. Finally, it appears from the Supplemental Environmental Impact Statement and the manufacturer's data that triclopyr will have to be applied indefinitely, perhaps every year, in order to "control" milfoil. Is DEC prepared to support this application indefinitely if a precedent is established? The public comment period for the permit ends April 21. If any of this bothers you, please consider mailing or emailing your comments to DEC at [EMAIL PROTECTED] <http://us.f534.mail.yahoo.com/ym/[EMAIL PROTECTED]>. If you get responses, I would be interested to see them. I look forward to hearing from you. Thanks for your consideration. Regards, Jim Trondsen p.s. Some individual decision-makers at DEC are as follows: Pete Grannis, Commissioner http://www.dec.ny.gov/about/556.html and "email the commissioner" Paul D'Amato, Region 8 Director (585) 226-5366 John Cole, permit administrator [EMAIL PROTECTED] <http://us.f534.mail.yahoo.com/ym/[EMAIL PROTECTED]> Scott Jones, wetlands [EMAIL PROTECTED] <http://us.f534.mail.yahoo.com/ym/[EMAIL PROTECTED]> Matt Sanderson, fisheries [EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> _____________________________________________________________ I wrote the following detailed letter to DEC: Dear Department of Environmental Conservation: I am commenting on the permit application to apply herbicide to Waneta and Lamoka Lakes in the years 2008 and following. I request that Department of Environmental Conservation not permit this application in whole or in part, for several reasons. First, I believe that the application of herbicides is intended to treat a symptom and not the root causes of a problem and will not have an outcome consistent with environmental conservation. I believe that the root cause of invasive infestations is that the lakes are disturbed habitat. Septic system leakage, lawn and farm fertilizer, silt, road salt, pesticides and other pollutants have been allowed to flow into the lakes. Shoreline aquatic vegetation has been forcibly removed, killed with illegal herbicides and disturbed by watercraft. Nutrient levels in the lakes have become excessive. The lakes have become disturbed habitat. As you know, invasive species exploit disturbed habitat. As a result, invasive species such as Eurasian Water Milfoil became established and thrived. But instead of managing the watershed to re-establish a healthy lake, shoreline property owners were permitted to use herbicides over the whole lake (Waneta) in an attempt to eradicate the invasive species, with disastrous results. The symptom was not remedied and the root causes became worse. The latest published survey of Waneta Lake, taken four growing seasons after the 2003 herbicide treatment, shows that the herbicide did not eradicate EWM. The herbicide did eradicate five of the original native species of plant in the lake, and added two more invasive plant species including one (curly-leaf pondweed) that grew so fast it soon dominated the lake. The native plant biomass is down 80%, and EWM is back to its pretreatment level. The whole-lake herbicide treatment took a bad situation and made it much worse. The assurances by the permit applicants, their consultants and applicators, of minimal damage to native vegetation and a speedy recovery of the lake did not come true. Furthermore, another invasive species, zebra mussels, has become established all over Waneta Lake, another consequence of the profoundly disturbed habitat. For a role model in watershed management, one has only to look to neighboring Keuka Lake. Despite the inherent problems of a densely-populated watershed including many municipalities, heavy agricultural usage and millions of tourists, Keuka has the highest water quality in the Finger Lakes, according to surveys by the Finger Lakes Institute. Hard work and patience have paid off. Why can’t this be done on Waneta and Lamoka? A second reason to not permit this application is the similarity to the disastrous 2003 application. Department of Environmental Conservation made a leap of faith in permitting the largest-scale application of fluoridone with no comparable experience. Prior to the application, the manufacturer reported the expected half-life of the fluoridone herbicide to be 30 days. The actual measured half-life in Waneta Lake in 2003 was more like 90 days. This increased the killing potential of the herbicide by a factor of three, just as effectively as tripling the initial concentration. This persistence of the fluoridone has not been explained, however factors may include the typical low sunlight in our area, murky water and the large mass of the body of water treated. Triclopyr degrades by the same mechanisms that fluoridone does. Why wouldn’t triclopyr have an extra-long half-life in these lakes in the same way as fluoridone? This is a risk factor that has not been addressed. Furthermore, whole-lake application as is proposed for Lamoka Lake does not provide refugia for susceptible species. Whole-lake application was a very bad management practice in 2003, especially since it was known that five of the native plants in Waneta are susceptible to damage by fluoridone. The 2008 whole-lake permit request for Lamoka Lake is particularly irresponsible in that several native plant species are known to be susceptible to damage by triclopyr, and possibly some fish and invertebrates as well. This is the same group of people involved, the same herbicide supplier, making the same proposal for eradicating a species by whole-lake herbicide treatments, again on a scale previously untested. Has Department of Environmental Conservation not learned from the 2003 disaster? A third reason to not permit this application is misrepresentation of the efficacy of the herbicide by the permit applicant. The project description and purpose is written as follows: "Apply the herbicide Renovate OTF to eradicate the invasive plant Eurasian watermilfoil (EWM) from Waneta Lake." This description implies that EWM will be completely eradicated within the time frame of the 2008/2009 application. Nowhere in the SEIS or in the manufacturer’s application literature is there a claim that this herbicide will eradicate EWM, but merely control it by repeated applications. The misrepresentation of eradication was repeated in a DEC press release dated 11/23/2007. The press release announced DEC-administered state grants for the Waneta-Lamoka project in the amount of $200,000, nearly 15% of the total funds in the state-wide program. The permit application requests permission to apply 49,000 pounds of solid and 1135 gallons of liquid herbicide. Since the manufacturer claims only partial control and not eradication, evidently the applications will have to be done forever. A precedent has now been established. Does Department of Environmental Conservation plan on funding these applications indefinitely? One would question the fairness of disproportionate state grants being awarded to two lakes from which the public is excluded. There is no public shoreline access on either lake. The most recent published survey of Lamoka Lake (2006) shows that native plants are healthy and dominant, accounting for 78% of the biomass. Lamoka also has one of the richest aquatic systems in Central New York in species diversity, with 26 native species. A healthy assemblage of native plants is the first line of defense against invasives. Experience shows that there is a high risk of damage to these native plants from an application of herbicide, especially if the irrational whole-lake proposal is permitted. Experience in these lakes also shows that herbicides have no long-term effect on EWM, but that native plants are damaged beyond repair. The proposed 2008 treatment would be the fourth in a series of ineffective or disastrous herbicide treatments permitted in these lakes by Department of Environmental Conservation. The fourth reason to not permit the 2008 experiment is that herbicides are ineffective, destructive of native plants, and a huge disturbance to the habitat. A fifth reason to not permit is that the herbicides target wetlands species. The functions and benefits of submergent wetlands are at risk. Flooding mitigation is of high importance to the residents downstream of the outlet at Bradford Dam. If the submergent wetlands are damaged at a critical time during heavy spring rains, there will be nothing to restrict the flow and flooding is more likely. The 100-foot Adjacent Areas adjoining the Class I and II wetlands are regulated Freshwater Wetlands. The proposal for herbicide application to Class I and II regulated wetlands must by law demonstrate that there is an urgent and intense need, which clearly outweighs the loss of the wetland in a way that is beyond serious debate, and must demonstrate that there is no practicable alternative whatever. There is no demonstration of an urgent and intense need in the permit application or any of the attached documentation. What is this urgent and intense need, and how does it outweigh the loss of the functions and benefits of the wetlands? And why has the practicable and necessary alternative of watershed management been excluded from consideration? A sixth reason to not permit is the effect on farmers and gardeners downstream of the lakes. There are restrictions on irrigation of crops, grazing restrictions, and restrictions on slaughter of farm animals. Have these restrictions been explained to those who would be affected? A seventh reason to not permit is the public health risk. Triclopyr has not been proven safe for humans or animals. No clinical or epidemiological studies have been done. In fact testing on mammals has produced breast tumors, kidney and liver aberrations. Using EPA’s classification, triclopyr may be considered a group C carcinogen. Triclopyr is known for penetrating into ground water. Triclopyr is persistent in anaerobic conditions such as at the depths of lakes where contamination of the aquifer is possible. With the application of 49,000 pounds of herbicide, potentially every year, there is a good possibility of accumulation and contamination of water supplies for many people. This is the largest single aquatic application ever of the killer chemical triclopyr. What is the urgent and intense need that prompts taking this public health risk? It has been nearly five years since the disastrous 2003 experiment that nearly destroyed the lower end of the food chain in Waneta Lake. One thinks of the wasted resources, both in public and private funding. One thinks of the lost opportunities to remedy watershed pollution. One thinks of poor stewardship and destruction of public resources. One thinks of the $600,000 expense for the proposed 2008-9 experiment, and the likelihood that it will be continued indefinitely in a vicious cycle of disturbed habitat and extermination of native plants. What is the urgent and intense need, which clearly outweighs the loss of one of the richest aquatic habitats in the state, and why has the practicable and necessary alternative of watershed management been ignored? Please say no to this permit application. Thank you for your consideration, James C. 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