"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 sampling

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 divers 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 species. 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 depends on the size of the waterbody. Our surveyor typically spends

about 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 government
staff 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 same 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 they 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 surprise).

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 determine 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 TMDLS. 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 nonpoint 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 during 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 dollars 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 they 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 people 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 volunteers – 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 typically 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 applicator)?

They are required to do all these things in Washington. 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 on 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?)

Education
7. 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 includes 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 solve 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 3rd party.