"Hamel, Kathy (ECY)" <kham461@ECY.WA.GOV>

08/20/2009 06:27 PM 

### Hi Molly, Here is the survey:

Questions for Aquatic Herbicides in Lakes and Ponds :

Identification of Problem 1. If pesticide applicators are required to identify problem weed areas and application areas, what methods (including equipment) do you think they would use to perform this activity?

Most will survey using a boat and visually looking into the water to observe the plants and delineate problem areas. If they are good, they will use a sa mpling rake that they will throw at intervals to sample the plants and identify species. Some will use GPS units to mark locations. Some use viewing tubes that help them see into the water. Some have experimented with underwater video or cameras. We use di vers and snorkelers for our eradication projects. Divers will see plants that surface samplers will miss.

Some of the more sophisticated applicators may use sonic units to determine biovolumes or aerial surveys with ground truthing to verify plant specie s. It is only the big money projects where they can afford that kind of expense and survey technique. Here is a link to our site where we talk about the various kinds of survey methods. http://www.ecy.wa.gov/programs/wq/plants/management/survey.html

a. How much time do you think they would spend to identify these areas (i.e. number of hours per waterbody)?

This d e pends on the size of the waterbody. Our surveyor typically spends

a bout a day per lake (200 acres or less). An applicator would likely spend less time. In Washington, they are working for a client (typically a homeowners association) and the lake residents already have areas that they want treated. The applicator would go to those areas to see if the amount of plants would justify the treatment. Unscrupulous applicators may even treat unvegetated

areas. Given that the homeowners are paying the applicator, the applicator may tailor the survey to the level of reimbursement.

For our noxious weed eradication projects, we spend a lot more time delineating areas and searching for all noxious weeds and then tell the applicator where to go. Frankly, those without a profit motive have more incentive to locate ALL noxious weeds. We tend to rely on local governmentstaff or lake residents for this. Applicators tend to want to get into and out of a water body quickly to move on to their next job.

b. OR how much do you think this weed identification would typically cost (per city,
county or state)?

2. If pesticide applicators are required to identify weed species and conditions that necessitate weed control measures, what methods (including equipment) do you think they would use to perform this activity? This question is pretty much the sa me answer as 1. Applicators really do need to identify species in order to choose the appropriate herbicide. They should be identifying species as they survey. They should rely on field guides until the y are able to identify aquatic plants reliably

. It can be quite difficult to differentiate aquatic species. We government experts sometime rely on DNA analysis for some species. We offer a weed identification service. People used to collect and mail in samples. Now we find that a decent digital photograph is generally all we need. Weed ID should all be part of the survey and the time needed for this activity would not add on extra time. Most experienced applicators get good at recognizing the problem species. They tend to be the same from lake to lake.

Some applicators may tell residents that lake need treatment when it doesn’t. I find that many lake residents really like the bathtub approach to weed management. Ecology has gotten into lots of fights over this and in court we often don’t win (much to our surp rise).

a. How much time do you think they would spend to identify the species and conditions (i.e. number of hours per waterbody)? b. OR how much do you think this identification would typically cost (per city, county or state)?

3. If pesticide applicators are required to identify sources of the problem (i.e. nutrients, invasive species, etc.), what methods (including equipment) do you think they would use to perform this activity? For many native plant problems

, it is well beyond the ability of the applicator and the lake residents to determin e nutrient sources to the lake. Even if they could do that, they generally can’t do much about them. Oftentimes it is a combination of many watershed inputs. You are really talking about Phase I Lake Restoration projects and T MDLS. These cost minimum hundreds of thousands of dollars to millions of dollars per water body. Requiring this was one of the things that totally did not work with Ecology’s IPM plans. In fact, one lake group sued us and others for allowing all the nonpoi nt sources in the watershed to pollute the lake over the years (they didn’t win the suit). The reality is that many nutrients inputs are totally out of the control of lake residents. You could encourage lake education such as checking septic systems, using no P fertilizers, car washing, and all those good BMP’s out there. That would be more appropriate to do. Lake residents could implement BMP’s but they probably could not implement wide

- spread watershed management.Exotic plants would be identified durin g the plant survey.

How much time do you think they would spend to identify these sources (i.e. number of hours per waterbody)? It would take two to three years to identify nutrient sources and do a limnological assessment. It would cost up to million d ollars depending on the size of the lake. Then you have to implement the recommendations and that costs millions. This is well beyond the scope for a typical herbicide applicator.

a. OR how much do you think this identification would typically cost (per city

, county or state)?

Mechanical Control, Biological Control, and Habitat Modification 4. If pesticide applicators are required to implement mechanical control techniques:

If pesticide applicators are required to implement mechanical control techniques then t hey wouldn’t be pesticide applicators. That was another area where Ecology came adrift. Ecology doesn’t have regulatory authority to require that people use other techniques. Ecology does have regulatory authority over pesticide use. We could not force peo ple to use other techniques.

You need to think about how things play out in court. If you require that people use other techniques then you as the regulatory agency need to have rules about when people can and cannot use pesticides. If it is triggered by surveys, then you as regulatory agency need staff that can survey and do it properly and at the correct time. I have seen our staff look like fools in court as they are being grilled. “Well, I walked out to the end of the dock and looked at the weeds and they didn’t look very dense to me”. That just doesn’t cut it I am afraid. We absolutely do not have staff to do site visits, let along plant surveys before and after treatment. We have experienced a loss of our lake staff this year and those positions are gone!!

a. Please use table provided to answer the following questions: 1. How much time do you think they would spend on mechanical control? 2. How much do you think mechanical control would typically cost?Activity Number of Hours (Please specify; per waterbody, etc.) Cost (Please specify; per city, county or state, etc.) Weed removal by hand or machine By hand, this is only applicable to small areas

– no more than a couple of acres per lake. Depends on number of hand pullers and plant species, plant density. Very slow. Some species not possible to hand pull because of massive rhizomes. Harvesters

– Depends on type and density of plants and location of off loading sites. 1

- 5 acres per day Hand Removal

– With divers following safety rules

- $1,600 per day. With vol unteers

– 0 per day, but they tend to burn out. Harvesters

- $600 to 1,000 per acre.

Sediment tilling Only done with huge machines in Washington. About 1

- 2 acres per day. $1,500 to $ 2,000 acre. Please realize that these are estimates only. Soil and vegetation compression through “weed rolling” The only know of those devices that attach to docks so this is very limited in scale. I believe that these can clear an area in about a week of operation. Then you only need to use them once a week. The devices cost about $2,000. Operating costs

are negligible . They have not caught on in Washington. Not sure why though.

Other (please specify): Grass carp Triploid grass carp can be very effective, but their use is hit or miss. Often they may remove all submersed plants from a water body. I like them for golf course and back yard ponds. Also good for hydrilla. Depending on the number of fish purchased they can cost from $5 to 20 per triploid fish

. Stocking rates vary

. We often use 9 fish per acre.5. If pesticide applicators are required to utilize habitat modification practices:

a. Please use table provided to answer the following questions: 1. How much time do you think they would spend on habitat modification? 2. How much do you think habitat modification would typical ly cost?

Activity Number of Hours (Please specify; per waterbody, etc.) Cost (Please specify; per city, county or state, etc.) Light attenuation The only light attenuation that I know about is using aquatic dyes. These are very expensive so they are only used in small ponds. They also turn the water color and unnatural shade. Other (please specify): Bottom Barriers We use bottom barriers for early infestations of noxious weeds. Homeowners use them for control of native and exotic plants around their docks. Cities use them in public swim beaches. They take a few hours to install depending on the size of the area. Lake residents can install them themselves to they are inexpensive ($100 for materials). If installed commercially they are more expensive ( $750 for small area). Not suitable for expansive areas as cost would be prohibitive and Fish and Wildlife agencies are not keen on covering up so much habitat.

Pesticide Use 6. If pesticide applicators are required to conduct maintenance activities to minimize potential leaks, spills, and accidental releases of pesticides or to maintain equipment to ensure effective application and control, how much time do you think they would spend on these activities? (i.e. number of hours per establishment or per appli cator)?

They are required to do all these things in Washingto n. I would think that this is just standard practice for them and they would not have to spend a lot of time on this. We require them to carry spill equipment too. We have inspectors who check o n these things. I think that this “weeds” out any bad applicators quickly if they don’t pass their inspections.

a. OR how much do you think these maintenance activities would typically cost (per establishment, city, county, or state?)

Education7. If pesticide applicators are required to post information to users (to address weed

identification, the role of nutrient availability in weed occurrence and abundance, accidental weed introduction avoidance, and the pesticide product being used for aquatic weed control ), how much time do you think they would spend to post this information (i.e. number of hours per waterbody)? We require applicators to send a notice or deliver a notice to all residents and businesses within a quarter mile of a treatment area (just along the shoreline) ten to 21 days prior to treatment. This can cost thousands depending on number of notices. We also require the applicator to post signs every 100 feet in the treatment areas and 400 feet either side. This is also expensive and can take them up to a day to get the notices out

- again dependent on the size of the lake, number of residents, etc. I think that some information about the project and why it is being done would be appropriate to be included with the notice. The notice typically inclu des information about the pesticide and any use restrictions. Better bang for the buck in my opinion would be to pass regulations requiring use of low P fertilizers, requiring septic inspections. Things with teeth in them work better than education.

a. OR how much do you think education by posting would typically cost (per waterbody, city, county or state)?

Follow

-Up Personal Communication (August 21, 2009) Do you have a sense of cost for aquatic weed control in Washington?

There is no real information available. In Florida there are these big districts with huge budgets, but in Washington its much less centralized. We give out grants to landowners. We don’t have any reporting, and we don’t know the costs. George Forni, who is an industry

-type person,

might be able to provide estimates. They treat lakes in Washington, doing harvesting and chemicals.

Do you have an idea of how much pesticide is being used?

In Washington, to apply restricted use pesticides you need to be a licensed applicator and there are inspections done by the department of agriculture. You need to follow the label and you cannot exceed the limit places there. We require that you use the lowest rate possible to get good results. Other states may not require permits and people might use extra, and then it creates a cycle where people just use more and more.

Is there any use of IPM in Washington state ?

People are of aware of IPM. We tried to implement an IPM program, where people needed to create IPM plans, but it ended up backfiring . People were resentful. And we really had no way to force people to perform IPM instead of using chemicals.Instead we found it was easier to incentivize people to use IPM with money. We do a lot of

grant giving to lake groups that are looking to solv e plant problems with IPM tactics. That means, though, that we don’t know how the money is being used. We just give the money to fund the grant program and the actual IPM is performed by a 3 rd party.