## FACT SHEET FOR AQUATIC PLANT AND ALGAE

MANAGEMENT GENERAL PERMIT

SUMMARY

The State of Washington Department of Ecology (Ecology) is issuing a state waste discharge general permit for the management of aquatic plants and algae in water bodies. This permit combines and replaces porti ons of the Aquatic Noxious Weed Control General National Pollution Discharge Elim ination System (NPDES) Permit and the Aquatic Nuisance Weed and Algae Control General NPDES Permit. This permit only

covers chemical control of plants and algae. The use of products not regulated under FIFRA is allowed under this permit, if the pr oduct or active ingredient has been reviewed and approved by Ecology. Other permits may be necessary if the plant or algae control activities are conducted using manual, mechanical, or biological methods.

The use of herbicides and al gaecides is also regulated under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) by th e United States Environmental Protection Agency (EPA). On March 12, 2001, the U.S. Ni nth Circuit Court of Appeals ruled that the application of an herbic ide in compliance with the la beling requirements of FIFRA did not exempt an irrigation district from needing to obtain an NPDES permit ( Headwaters, Inc. v. Talent Irrigation District ). Ecology has issued coverage under general NPDES permits since 2002 for the application of pesticides to control aquatic plants and algae.

On September 8, 2005, the U.S. Ninth Circuit Court of Appeals ruled that a pesticide applied according to the label that left no re sidue and that did not have any unintended impacts was not a waste and therefor e did not require an NPDES permit ( Fairhurst v. Hagener ). The EPA is completing federal rulemaki ng. As drafted, the rule states that a pesticide applied according to the FIFRA la bel is not a “chemical waste” as defined by the Clean Water Act and therefore does not require an NPDES permit.

Under 90.48.465 RCW, the legislature directed Ecology to either modify or rescind aquatic NPDES permits if one of four things occurs: (1) the Talent decision was modified or overturned by another court ruling, (2) EP A rulemaking, (3) a clarification of scope by the EPA, or (4) the legislature took action.

Ecology’s new Aquatic Plant and Algae Manage ment permit is not an NPDES permit, it is a state-issued waste discharge general permit, issued under the authority of RCW 90.48. Such issuance complies with state law and maintains the st ate’s ability to regulate the use of pesticides in aqua tic settings. Ecology has decide d to issue a permit that is based solely on state authority to regulate the discharge of waste materials into waters of

the state.

This permit revokes and repla ces the Aquatic Nuisance Plan t and Algae Control general permit (effective date: July 5, 2002) for activiti es associated with aquatic nuisance plantand algae control as specifie d in S1.A of this permit. The permit also revokes and replaces the Aquatic Noxious Weed Control general permit (effective date: June 14, 2002) for any activities associated with in-l ake or shoreline emergent aquatic noxious weed control as specified in S1.A of this permit.

This permit addresses three different aquatic plant and algae management scenarios. One portion of the permit establishe s conditions for the eradicat ion, or 100 percent removal of aquatic noxious weeds. The second sect ion establishes conditions for the control

, or limited removal of aquatic nuisance weed s, noxious weeds, and al gae. The final section

establishes conditions fo r nutrient inactivation pr ojects in water bodies.

### TABLE OF CONTENTS

SUMMARY ........................................................................................................................ 1

TABLE OF CONTENTS .................................................................................................... 3

INTRODUCTION .............................................................................................................. 5

BACKGROUND INFORMATION ................................................................................... 6

LEGAL BACKGROUND .............................................................................................. 6

BIOLOGICAL BACKGROUND ................................................................................... 7

BACKGROUND INFROMATION ................................................................................... 8

Regulatory Pollution Reduction Requirements .............................................................. 8

Technology-Based Requirements ................................................................................... 8

Water Quality-Based Requirements ............................................................................... 8

SEPA Compliance ........................................................................................................ 10

Permit Modifications .................................................................................................... 10

Responsibility to Comply With Other Requirements ................................................... 10

SPECIAL CONDITIONS ................................................................................................. 11

S1. PERMIT COVERAGE ..................................................................................... 11

A. Activities Covered Under Permit ...................................................................... 11

B. Activities Excluded From Coverage Under This Permit .................................. 14

C. Geographic Area Covered ................................................................................. 14

D. Additional Requirements for Discharges to Water Bodies Where Sensitive, Threatened, or Endangere d Plants are Present .......................................................... 14

S2. PERMIT APPLICATION REQUIREMENTS ................................................. 15

A. Who Applies for Coverage ............................................................................... 15

B. How to Apply for Coverage .............................................................................. 16

C. Public Notice Requirements ............................................................................. 16

D. Permit Coverage Timeline ................................................................................ 16

E. Denial and /or Revocation of Coverage ............................................................ 16

F. Length of Coverage ........................................................................................... 17

S3. COMPLIANCE WITH STANDARDS ............................................................ 17

S4. WETLANDS ..................................................................................................... 18

S5. RESTRICTIONS ON THE APPLICATION OF PRODUCTS ........................ 18

A. Short-Term Modification of Water Quality Standards ..................................... 18

B. Authorized Discharges ...................................................................................... 18

C. Prohibited Discharges ....................................................................................... 18

D. Products Allowed for Use Under This Permit .................................................. 18

E. Experimental Use Permits ................................................................................. 19

Aquatic Plant and Algae Management Fact Sheet Page 3 of 25F. Specific Restrictions on the Application of Products ....................................... 19

S6. NOTIFICATION AND POSTING REQUIREMENTS ................................... 21

S7. MONITORING REQUIREMENTS ................................................................. 21

A. Application of Herbicides and Algaecides ....................................................... 21

B. Application of Phosphor us Inactivation Products ............................................. 22

S8. SAMPLING AND ANALYTICAL PROCEDURES ....................................... 22

S9. REPORTS AND RECORDKEEPING REQUIREMENTS ............................. 22

S10. SPILL PREVENTION AND CONTROL ........................................................ 22

S11. CONDITIONAL APPROVAL FOR THE USE OF PRODUCTS NOT

SPECIFIED IN THE CURRENT PERMIT ................................................................. 22

S12. CRITERIA FOR SENSITIVE, THRE ATENED, OR ENDANGERED PLANT

PROTECTION PLANS FOR CONTROL PROJECTS ............................................... 23

GENERAL CONDITIONS .............................................................................................. 23

APPENDIX A - REFERENCES ...................................................................................... 25

Aquatic Plant and Algae Management Fact Sheet Page 4 of 25

### INTRODUCTION

This fact sheet, a companion document to the draft State Waste Discharge Draft General Permit for Aquatic Plant and Algae Manageme nt, provides the legal and technical basis for permit issuance. The Washington State De partment of Ecology (E cology) proposes to issue this permit to allow the use of herbic ides, algaecides, nutrient reduction products, marker dyes, shading products, adjuvants, a nd water clarification products to surface

waters of the state of Washi ngton for the purposes of control ling aquatic plants and algae and eradicating noxious weeds. This fact sheet explains the nature of the proposed discharges, Ecology’s decisions on limiting the pollutants in the receiving water, and the regulatory and technical ba sis for these decisions.

This waste discharge permit is issued under the authority of Chapter 90.48 Revised Code of Washington (RCW). This state statute de fines Ecology's authorit y and obligations in administering the wastewater discharge permit program.

Regulations adopted by the state include proced ures for issuing general permits (Chapter 173-226 Washington Administrative Code (WAC )), water quality cr iteria for surface waters (Chapter 173-201A WAC), ground water quality st andards (Chapter 173-200 WAC), and sediment management standards (Chapter 173-204 WAC). These regulations require that a permit be issued before discha rge of pollutants to waters of the state is allowed. The regulations also establish requi rements which are to be included in the permit. One of the requirements for issui ng a general permit (WAC 173-226-110) is the preparation of a permit and an accompanying fact sheet. Public notice of the draft permit, public hearings, comment periods, and public notice of issuance are all required before the general permit is is sued (WAC 173-226-130).

In drafting this permit, Ecology sought i nput from an External Advisory Committee composed of representatives from local and state government agencies, pesticide application companies, lake groups, and envi ronmental organizations. Changes identified

in their review have been made before going to public notice.

After the public comment period has clos ed, Ecology will summarize the substantive comments and respond to each comment. Comments may cause Ecology to change some of the permit requirements. The summary and response to comments will become part of the file on the permit. Parties submitting comments will receive a copy of Ecology’s response. The original fact sheet may or may not be revised after the public notice is published. Comments and the resultant cha nges to the permit will be summarized in Appendix B--Response to Comments.

Aquatic Plant and Algae Management Fact Sheet Page 5 of 25

### BACKGROUND INFORMATION

LEGAL BACKGROUND

Headwaters, Inc. and Oregon Natural Resour ces Council filed a Cl ean Water Act (CWA) citizen suit against the Talent Irrigation Distri ct (TID) for applying aquatic herbicide into a system of irrigation canals. Reversing a district court’s opinion, the Ninth Circuit held that application of the herbicide in comp liance with the labeling requirements of the Federal Insecticide, Fungicide, and Roden ticide Act (FIFRA) did not exempt TID from the requirement to obtain an NPDES permit. The court further ruled that the irrigation

ditches were "waters of the United States" under the Clean Water Act.

The March 12, 2001, Talent decision was a precedent setti ng case. It was the first time

the courts made a distinction between the process used to ap prove pesticides and the way in which the Clean Water Act is enforced. It has caused the EPA to further explore the

differences between the Office of Pesticide Programs (OPP) and the Office of Water.

An effort is underway at the EPA to further interpret the Headwaters Inc. v. Talent Irrigation District decision as it relates to requirements of the Clean Water Act. The EPA opened a public comment period in January 2005 on a proposed rule. The proposed rule would allow the application of pesticides in aquatic environments to be exempted from CWA NPDES permitting requirements. The propos ed rule states that NPDES permits are intended to protect water from potential waste. The EPA made the argument that when a pesticide is applied according to the FIFRA la bel, the pesticide is not a waste. This proposed rule is scheduled to be prom ulgated by EPA in early 2006. EPA’s proposed rule, along with a recent Ninth Circuit decision ( Fairhurst v. Hagener ), led Ecology to decide to issue the new permit for the use of aquatic herbicides under state authority.

Under RCW 90.48.080, Ecology has the authority to regulate the discharge of any

material into waters of the state that has ei ther the potential to pollute or to alter the biological or chemical characte ristics of that water body. Ecol ogy is further directed in Chapter 173-201A WAC to require any discharger to waters of the state to comply with the state’s surface water quality standard s. Chapter 173-201A WAC provides specific language that allows for the use of herbicides in aquatic settings, so long as a short-term

modification of the state’s surf ace water quality standards is ob tained prior to treatment. This permit include the conditions of th e short-term water quality modification.

Ecology incorporates technology-based limitation s, water quality-based limitations, and standard regulatory requirements into the permit. The permit also incorporates monitoring and reporting require ments to assure compliance with the conditions of the permit. These requirements are included in all general permits (90.48 RCW, Chapter 173- 216 WAC, and Chapter 173-226 WAC).

Aquatic Plant and Algae Management Fact Sheet Page 6 of 25BIOLOGICAL BACKGROUND

The following is a brief description of the pr oblems caused by aquatic plants and algae in addition to a brief description of the cu rrent control methods. For more detailed information, Ecology refers the reader to the re ferences cited in the back of this fact sheet, Washington State Department of Ecol ogy Environmental Impact Statements (EIS) 1980, 1992, 2001, and at this link: http://www.ecy.wa.gov/programs/wq/plants/management/index.html

.

Native aquatic plants and algae provide habita t and food for aquatic life. When nutrients such as phosphorus and nitrogen enter watersheds, they cause an increase in the population of plants and algae. When plant and algae populations become very dense, they have the ability to in terfere with some uses of a water body (such as swimming, boating, fishing, water skiing, and aesthetic s). When phosphorus and nitrogen inputs increase within a water body, macrophytes a nd phytoplankton growth increases, which can negatively affecting habitat, recreation, and human health.

Cyanobacteria (also known as blue-green algae) can also increase in growth with excess phosphorus and nitrogen inputs. Cyanobacteria produce toxins and ingestion of toxic algae has resulted in animal deaths in Wa shington State. Cyanobacteria also produce extremely unhealthy conditions for fish and wildlife.

Noxious freshwater weeds are plants that are not native to Washington State. Noxious weed growth is also enhanced by excess nutri ents. These species have a tendency to be invasive and may pose a serious threat to Washington State waters. Nonnative plants have few natural population controls in their new habitat. They often invade rapidly, destroy native plant and animal habita t, damage recreational opportunities, clog waterways, and reduce property values.

Ecology has examined various options (mech anical, manual, biological, and chemical) for aquatic plant and algae control (Eco logy 1980, 1992, 2001). One solution to excessive aquatic plant and algae growth is to prevent nutrients from entering the water body. While Ecology believes nutrient control is th e best long-term solu tion to controlling native vegetation, this option may not produ ce immediate effects. Nutrient reduction requires behavioral changes and can be comp lex. Therefore, Ecology has determined that chemical control methods may be acceptable in some instances to maintain beneficial uses of the water body; however, chemical control methods must be conducted under

controlled conditions. This state waste discha rge general permit applies only to chemical

control methods. Mechanical/manual methods of aquatic plant c ontrol do not require coverage under this permit but may require a Hydraulic Project Approval (HPA) from Washington State Department of Fish and Wildlife (WDFW). Likewise the use of grass carp does not require this pe rmit but does requires a perm it from WDFW. Additionally, some projects may require consultation with local, state, or federal government(s).

Aquatic Plant and Algae Management Fact Sheet Page 7 of 25

### BACKGROUND INFROMATION

REGULATORY POLLUTION REDUCTION REQUIREMENTS

State regulations require that effluent limitations set forth in a state waste discharge permit must be either technology- or water quality-based. Technology-based limitations are set by regulation or developed on a cas e-by-case basis (Chapter 173-216 WAC). Water quality-based limitations are establis hed to ensure compliance with the Surface Water Quality Standards (Chapter 173-201A WAC), Ground Water Standards (Chapter 173-200 WAC), Sediment Management Sta ndards (Chapter 173-204 WAC) or the National Toxics Rule (Federal Regist er, Volume 57, No. 246, Tuesday, December 22, 1992). The more stringent of these two limits , either technology-base d or water qualitybased must be established for each parameter of concern.

TECHNOLOGY-BASED REQUIREMENTS

The state has technology-based requirements for pollutant control described as: "all known, available, and reasonable methods of prevention, control, and treatment" (AKART). AKART is referenced in state statute under RCW 90.48.010, RCW 90.48.520, RCW 90.52.040, and RCW 90.54.020.

AKART may be the use of Best Management Practices (BMPs). This permit requires the

use of BMPs to limit the number of acres of littoral zone treated at any given time, and limit the number of treatments allowed pe r season in a given water body. Compliance

with the FIFRA label further limits the overu se of products and the non-target impacts.

The pesticide application industry has been regulated by EPA under the terms of FIFRA via label use requirements developed by EPA. In developing label use requirements, EPA requires that the pesticide manu facturer register each pestic ide and provide evidence that the pesticide will perform as specified while minimizing environmental harm.

Monitoring of the pollutants addressed in this permit is difficult due to the diffuse nature and low concentrations that exist after pestic ides have been applie d (“become pollutant”). Washington state law allows Ecology to require permitting and monitoring for any discharge that has th e potential to pollute waters of the state (Chapter 90.48.080 RCW).

AKART is also employed when dealing with pesticide drift. Applicator’s can control pesticide drift during an app lication using physical barriers . Underwater curtains and other barriers can isolate the area of pestic ide application when downstream water users raise concerns or sensitive native plan ts or fisheries share the water body.

WATER QUALITY-BASED REQUIREMENTS

RCW 90.48.035 authorizes Ecology to establish water quality sta ndards for waters of the state. The state has implemented water qua lity standards in Ch apter 173-201A WAC. Aquatic plant and algae control activities affect surface waters of the state. Water quality

Aquatic Plant and Algae Management Fact Sheet Page 8 of 25standards establish the highest quality of state waters through the reduction or elimination of contaminant discharges to the waters of th e state, consistent with: public health; public enjoyment; the propagation and protection of fish, shellfish, and wildlife; and existing and future beneficial uses. This purpose is reached, in part, by compliance with the limitations, terms, and conditions of the draft general permit.

All waste discharge permits issued pursuant to state regulations are conditioned to ensure that all authorized discharges meet state water quality standards. Standards include an "antidegradation" policy whic h states that beneficial uses shall be protected. Characteristically, beneficial uses of surf ace waters include, but are not limited to, the following: domestic, industrial, and agricu ltural water supply; stock watering; the spawning, rearing, migration and harvesting of fish; the spawning, rearing and harvesting of shellfish; wildlife habita t; recreation (primary cont act, sport fishing, boating, and aesthetic enjoyment of nature ); commerce and navigation.

Discharges from aquatic weed control and eradication activities may contain pollutants which, in excessive amounts, have a reasona ble potential to cause, or contribute to, violations of state water quali ty standards due to the presen ce of toxic materials and the effects of dying vegetation. Ecology has determin ed through a risk assessment that, when properly applied and handled in accordance wi th the terms and conditions of the general permit, aquatic weed control and eradicati on activities will comply with state water quality standards, will maintain and protect the existing characteristic beneficial uses of

the surface waters of the stat e, and will protect human heal th. New information regarding previously unknown environmental and human health risks may cause Ecology to modify this general permit.

In determining whether a discharge will be in compliance with the state’s Water Quality Standards, Ecology uses the numeric and th e narrative criteria of Chapter 173-201A WAC (Water Quality Standards for Surface Wate rs of the State of Washington), Chapter 173-204 WAC (Sediment Management Standards) and the National Toxics Rule (Federal Register, V. 57, No. 246, Tuesday, December 22, 1992). In the absence of numeric criteria, Ecology may develop a numeric criterion on a case-by- case basis to comply with

the narrative criteria. There are no numeric criteria established fo r the products allowed under this permit. The permit imposes restrict ions intended to pr otect aquatic life and human health, and ensure compliance with the state’s Water Quality Standards.

Ecology has reviewed the ecologi cal effects of the chemicals used for control of aquatic weeds and algae (Ecology EIS 1980, 1992, 2001, 2004). Ecology developed restrictions in this permit to assure compliance with th e water quality standards. The restrictions, which vary with the chemical, implement AKART through Best Management Practices such as target applica tion rates, application methods, and other methods.

Aquatic Plant and Algae Management Fact Sheet Page 9 of 25ANTIDEGRADATION

Washington's Antidegradation Policy states th at discharges into a receiving water shall not further degrade the existing water qual ity of the water body. In cases where the

natural conditions of a receiving water are of lower quality than the criteria assigned, the

natural conditions shall constitute the water quality criteria. Similarly, when the natural conditions of a receiving water are of higher qua lity than the criteria assigned, the natural conditions shall be protected. More informa tion on the State Antidegradation Policy can

be obtained in WAC 173-201A-070.

Antidegradation by definition applies to site-s pecific conditions. A general permit applies to sites statewide. Discussion of antidegrad ation for each site covered under the draft permit is impractical. The permit requires discharges to comply with water quality standards. Compliance with standards typi cally affords the protection necessary to prevent ongoing degradation of a waterbody from aquatic pesticide discharges.

SEPA COMPLIANCE

The use of pesticides is conditioned to mitigate potential environmental impacts of

concern noted in the environmental and hum an health evaluations required under SEPA. Mitigations includes fish timing windows, m itigation measures to minimize harm to sensitive, threatened, or endangered plants, etc. Each coverage issued by Ecology will undergo SEPA review.

PERMIT MODIFICATIONS

Ecology may modify this permit to impose ne w or modified numerical limitations, if necessary to meet Water Quality Standa rds for Surface Waters (Chapter 173-201A WAC), Sediment Management Standards (Chapter 173-204 WAC), or Water Quality Standards for Ground Waters (Chapter 173-200 WAC) based on new information obtained from sources such as inspections, monitoring, or Ecology- approved engineering reports. Ecology may also modify this permit as a result of new or amended state or federal regulations.

RESPONSIBILITY TO COMPLY WITH OTHER REQUIREMENTS

Ecology has established, and will enforce, limits and conditions expressed in the general permit for the discharge of aquatic herbicides and algaecides registered for use by the EPA and the WSDA. Ecology has also established, and will enforce, limits and conditions expressed in the general permit fo r product types named in this permit but not governed by these agencies. EPA and WSDA wi ll enforce the use, storage, and disposal requirements expressed on pesticide labels. The Permittee must comply with both the pesticide label requirements and all of the c onditions of this general permit. This general permit does not supersede or preempt federal or state label requirements or any other applicable laws and regulations.

Aquatic Plant and Algae Management Fact Sheet Page 10 of 25

### SPECIAL CONDITIONS

S1. PERMIT COVERAGE

A. Activities Covered Under Permit

Washington State Water Quality statutes and regulations do not allow the discharge of pollutants to waters of the state without permit coverage (Chapter 173-201A WAC, RCW 90.48.080, and RCW 90.48.160). Herbicides, algaecides, adjuvants, nutrient inactivation products, marker dyes, shading pr oducts and water clar ification products are potential pollutants, and ther efore require a discharge permit to be applied to waters within Washington State.

This permit encompasses three aquatic plant and algae management categories: eradication, control, and nutri ent inactivation. Eradication al lows for the eradication of only those state-listed noxi ous weed species or weeds on the Washington State Department of Agriculture’s (W SDA) quarantine list. Eradicat ion is defined in the permit as “the permanent removal of all non-native, invasive aquatic plan ts of one or more species within a water body or along a shoreline.”

Control means “the partial removal of a quatic plants within a water body or along a shoreline to allow for the pr otection of beneficial uses of the water body.” Control projects may include treatment of native plan ts, state-listed noxious weeds, and certain types of algae.

Nutrient inactivation is a method for removi ng a limiting nutrient, such as phosphorus or nitrogen from a water body. The goal in removi ng the nutrient is to keep plant and algae production at manageable levels during the peak recreation season.

Thus, Ecology integrated portions of the cu rrent noxious weed permit with the aquatic nuisance weed and algae control permit into th is permit. This permit does not apply to the marine emergent species or the majority of the freshwater emergent species currently covered under the noxious weed permit issued to WSDA. As a resu lt of a settlement agreement among the Washington Toxics Co alition, People for Puget Sound, and WSDA, Ecology agreed to resume permitting activities for portions of the previous noxious weed permit.

Eradication Eradication of aquatic noxious weeds is required by state statute. The Washington State legislature declared in RCW 90.48.445 that:

“(1) the director shall issue or approve water qu ality permits for use by federal, state, or local governmental agencies and licensed appl icators for the purpose of using, for aquatic noxious weed control, herbicides and surfactants registered under state or federal pesticide control laws, and for the pur pose of experimental use of herbicides on aquatic sites, as defined in 40 C.F.R. Sec. 172.3. The issuance of the permits shall be

Aquatic Plant and Algae Management Fact Sheet Page 11 of 25subject only to compliance with: Federal and state pesticide labe l requirements, the requirements of the federal in secticide, fungicide, and roden ticide act, the Washington pesticide control act, the Washington pesticide application act, and the state environmental policy act, except that...:

(b) The director shall issue water quality permits for the purpose of using herbicides or surfactants registered by the department of agriculture to control aquatic noxious weeds, other than spartina, and the permit shall state that aerial and ground broadcast applications may not be made when the wind speed exceeds ten miles per hour.

And later,

“(4) As used in this section, "aquatic nox ious weed" means an aquatic weed on the state noxious weed list adopted under RCW 17.10.080.”

Section S.1.A.1. of the permit provides condi tions for noxious weed and quarantine weed eradication as defined in Chapter 17.10 RCW and Chapter 90.48 RCW. This section also provides conditions for the erad ication of newly discovered non-native and potentially invasive species. Thus, this permit enables permitting that does not currently exist to allow for the rapid response to ne wly discovered invasive species.

Early infestation and es tablished infestation The focus of a lake group attempting to eradicate an established infestation is slightly different than that of an early infestation. During an early infestation, most lake groups focus on learning about the type of plant that they are going to targ et, the scope of the infestation, and monetary resources that may be available to them. This is a learning phase.

For an established infestation eradication pr oject occurring over many years, the lake group is more experienced with the plant as we ll as the statewide availability of funding. The lake association or government entity likely has developed and are implementing an Integrated Aquatic Plant Management Plan w ith lake-wide eradication of the species the final goal.

Control Aquatic Plant Control Projects Control refers to the partial removal of na tive plants or noxious weeds for the protection of beneficial uses (primarily recreation or aesthetics) within a water body. Control projects aim primarily at eliminating native speci es that interfere with specific beneficial uses. This category also includes the control of algae and cyanobacteria within a water body for the protection of benefici al uses and human health.

Percent of Littoral Zone Treated To balance the protection of so me beneficial uses such as habitat with others such as recreation, the permit limits the amount of vegetation that can be removed from the

Aquatic Plant and Algae Management Fact Sheet Page 12 of 25littoral areas of a water body during control proj ects. Plant control in the littoral areas of

water bodies will be limited to 40% of the shoreline and littoral zone. Public swim beaches and public boat launches will be allowed to remove 100% of the vegetation in

the littoral zone or the define d swim beach area. These rest rictions conform to Ecology’s best professional judgment and informati on in the following references (Washington Department of Fish and Wildlife Pub No. APF-11-97; and The Water’s Edge , Wisconsin DNR).

Noxious weeds as identified in Chapter 16-750 of WAC Noxious weed management efforts can occur in either the control or eradication category. Eradication projects aim to eliminate the sp ecies from the entire water body. Eradication requires parties with an interest in the water body to work together to evaluate the best long-term management strategy.

Control of noxious weed species, on the othe r hand, recognizes that elimination of the species from the entire water body is not f easible. Control projects for noxious weeds aims to eliminate the plant’s presence in sp ecific areas. Control pr ojects do not require group participation.

Noxious weed control projects can occur in water bodies wh ere eradication is not an achievable goal or where no consensus of the lake group can be achieved to eradicate the plant throughout the water body. For example, eradication is not achievable in the

Columbia River’s Eurasian watermilfoil infestation. Although eradication is not occurring throughout the water body, individuals can obtain pe rmit coverage to control

this noxious weed in their immediate area.

Algae Control Projects Many different types of algae exist in fres hwater systems. Most phytoplankton play an important role in the food web and have negl igible impact on recreational uses of a water body. However, filamentous algae and cyanobacter ia have the potential to interfere with beneficial uses in a water body. High populations of filamentous algae impact beneficial

uses and can be a nuisance. High populations of cyanobacteria in a water body can adversely affect human health through their toxins. Thus, filamentous algae and cyanobacteria control project are permissi ble under the conditions of this permit.

Nutrient Inactivation Projects High concentrations of nutrient s runoff that enters water bodies can create ideal situations for the uncontrolled growth of harmful algal species. Projects focused on nutrient inactivation usually involve the inactivation of phosphorus, which is a limiting nutrient in most freshwater systems. A number of different mechanisms exist to inactivate phosphorus in water body which use a vari ety of substances. The compound most commonly used is called alum (aluminum sulf ate or sodium aluminate). Alum is applied as slurry to the water, where it creates a flocculent that attracts and binds to the phosphorus molecules and then settles to the bottom of the wa ter body, trapping the phosphorus.

Aquatic Plant and Algae Management Fact Sheet Page 13 of 25B. Activities Excluded From Coverage Under This Permit

The permit does not apply to activities occurring in a number of different water body types. Stormwater and wastewater detention and retention ponds are constructed (manmade) systems and are usually regulated unde r other permits (such as industrial or municipal stormwater permits). For ponds re gulated under other permits that condition chemical use for plant and algae control or eradication, permit cove rage under this permit is not required.

Retention and detention ponds not regulated under other permits may also be treated without applying for coverage under this permit if the pond is either (1 ) dry or, (2) if it contains water, and will not discharge to su rface waters within two weeks of treatment. Ecology believes that both dry conditions and the two week holding time will be sufficient to allow the dissipation of the product prior to possible discharge to surface

waters.

This permit exempts any enclosed constructe d water body that is five acres or less in surface area, which will not discharge to surf ace waters within two weeks of treatment. Ecology believes the two week holding time will be sufficient to allow the dissipation of the product prior to possible di scharge to surface waters.

This permit also exempts aquatic plant c ontrol in seasonally dry wetlands if the herbicides applications comply with the FI FRA label and if the herbicides will not be biologically available when the area is inunda ted with water. Ecology believes that if these conditions are met, the treatment poses no potential to violat e the state’s surface water quality standards.

C. Geographic Area Covered

This permit applies to the application of pr oducts to surface waters throughout the state.

Surface waters of the state are defined as “l akes, rivers, ponds, streams, inland waters, salt waters, wetlands, and all other surface waters and water courses within the jurisdiction of the st ate of Washington.” (C hapter 173-201A WAC)

Aquatic weeds have the potential to occur in or near virtually any freshwater or semiaquatic site in Washington State. These sites include but are not limited to riparian areas, wetlands, marshes, rivers, year round and s easonal streams, lakes, ponds, wet pastures,

and brackish estuaries.

D. Additional Requirements for Discharg es to Water Bodies Where Sensitive, Threatened, or Endangered Plants are Present

Due to potential impacts on non-target species when herbicides are used in a water body, Ecology requires that a plant survey be completed and mitigation measures be implemented to reduce unintended impacts. Th e permit requires a detailed survey that describes all the places in the water body where a plant should be protected to be

Aquatic Plant and Algae Management Fact Sheet Page 14 of 25prepared and submitted to Ecology. Ecology’s iden tification of a sensit ive, threatened, or endangered plant species in a water body require s that one or more mitigation measure(s) be employed in the water body during treatment to protect the sensitive, threatened, or endangered plant. The Permittee must keep records for the life of the permit detailing which mitigation(s) were chosen prior to treatment.

Currently, no state law protects rare (sensitive, threatened, or endangered) plant species in Washington. However, many federal and state land management agencies have policies that provide protecti on for rare species. In 1982, th e state legislature recognized the need for a systematic and objective appr oach to protect those features of natural ecosystems most at risk. RCW 79.70.060 create d the Natural Heritage Program within the Department of Natural Resources to assume this task. In addition, local jurisdictions may provide protection for rare species and high-quality ecosystems through ordinances, regulations, and permitting requirements. Once a species is lost, it cannot be replaced. Only if they are given special attention will these species survive in Washington State.

In the case of Trotland et al. v. Ecology and Tahuyeh Lake Community Club (1997), the Pollution Control Hearings Board (PCHB) f ound in favor of Ecol ogy’s issuance of an administrative order. The order provided a 100-foot buffer as recommended by the Ecology wetland biologist to pr otect rare peat bogs. The PC HB decision stated that “within this additional condition the proposed treatment is designed to achieve and maintain the water quality of the lake with respect to recreationa l opportunities without posing any significant adverse impact on the environment.”

S2. PERMIT APPLICATION REQUIREMENTS

A. Who Applies for Coverage

According to state regulations, the entity intend ing to discharge the material into waters of the state must apply for coverage (RCW 90.48, Chapter 173-216-070 WAC, and Chapter 173-226-210 WAC). In most cases, the applicator most closely fits the definition of owner/operator of the discharging enti ty and will be the permittee. Ecology has established the pesticide applicator as the permittee in the permit.

This permit also allows the permittee to be a government entity (such as city, county, county weed board, lake management district) if the entity uses an applicator on staff. In some cases, the permittee may be a government entity and the applicator who won the bid process for a specific trea tment. In this case the government entity may apply for the permit in advance of hiring the applicator. However, Ecology will not issue the permit until the applicator has been hired and has signed the application.

Special conditions exist in the case of children’s summer camps. The permit requires joint application by the app licator and the camp owner because the permit requires special notifications if treatments occu r 2 weeks prior to or during camp. This requirement is supported by a 2001 PCHB decision (PCHB No.01-102) that found in

Aquatic Plant and Algae Management Fact Sheet Page 15 of 25favor of Ecology in requiring bot h a summer camp and the pes ticide applicator to apply for the ability to apply herbicid es to Elbow Lake, Washington.

B. How to Apply for Coverage

For a timely and accurate application review to occur, the permit requires that all of the items listed in Condition S2.B be comple ted prior to Ecology action. Additional information may be requested from Ecology (such as maps, lake information, plant surveys). The processing of the application will not begin until all information required by condition S2.B has been accurately completed.

C. Public Notice Requirements

Ecology derived the requirements for public notice when applying for coverage under the general permit from state regulation, WAC 173-226-130.

D. Permit Coverage Timeline

This section of the permit explains the lengt h of time needed to obtain permit coverage once a complete application has been filed, the reasons for permit coverage denial, and the length of coverage awarded once an application is approved. Many of these requirements were adopted from previous langu age in short-term modifications and using language from other general permits.

Per WAC 173-226-200 (2), Ecology will respond in writing to any application for coverage. If Ecology does not respond in wr iting and does not obtai n significant written public comment, coverage under this genera l permit will commence on the later of the following:

• The thirty-first (31 st ) day following receipt by Ecology of a completed and approved Application for Coverage; • The thirty-first (31 st ) day following the end of a thirty (30) day public comment period; or • The effective date of the general permit.

If Ecology responds in writing to an applica tion for coverage or obtains significant written public comment, Ecology will not issue coverage under this general permit until Ecology is satisfied with the results obtained from written correspondence with the individual applicant and/ or the public commenter.

E. Denial and /or Revocation of Coverage

Chapters 173-226-230 WAC, 173-216-130 WA C, and 173-226-240 WAC give Ecology the authority to deny or revoke coverage under the general pe rmit for a number of reasons. If Ecology chooses to deny or revoke coverage, the Permittee shall be notified in writing of this decision.

Aquatic Plant and Algae Management Fact Sheet Page 16 of 25F. Length of Coverage

Chapter 173-216-110(2) WAC stat es that Ecology may issue permits for no longer than five years. This permit is a five year permit, with expiration in 2011.

S3. COMPLIANCE WITH STANDARDS

WAC 173-201A-240 states that “toxic substances shall not be introduced above natural background levels in waters of the state whic h have the potential ei ther singularly or cumulatively to adversely affect characteristic water uses, cause acute or chronic toxicity to the most sensitive biota dependent upon thos e waters, or adversely affect public health, as determined by the department.”

Ecology periodically reviews surf ace water quality data to dete rmine if water bodies meet criteria. Section 303(d) of the Clean Water Ac t requires that waters not meeting criteria undergo an evaluation of the cause and amount of the contaminant. Subsequent limits are placed on the amounts of pollutants allowed to be discharged and published in Total Maximum Daily Load (TMDL) reports.

Ecology has the authority and responsibility to periodically update the water quality standards, 90.48.035 RCW. In accordance with WAC 173-226-230(1)(b), a general permit may be modified when the state water quality standards have been modified through formal process. No “grandfather” clause is available that would allow a permittee

to continue under the old standards.

The latest updates of the State's water qual ity standards were approved by the EPA in 2005. This permit is written to comply with th e new surface water qua lity standards. If a new list is approved by EPA during the life of this permit, any changes to the permit will result in formal notification of all permitt ees in accordance with Chapter 90.48 RCW.

Pesticide applications subject to the permit to 303(d) wa ter bodies may have additional limits and conditions imposed upon them. The tw o parameters of concern identified in the permit are dissolved oxygen and phosphorus. Water bodies listed on the 303(d) list as impaired for dissolved oxygen are either year-round problems, or seasonally low dissolved oxygen levels. Low dissolved oxyge n levels in a water body can adversely affect fish populations. Contact herbicides, which primarily cause a burning back of the plants treated, have the greatest potentia l to adversely affect dissolved oxygen

concentrations within a wate r body. The goal of a contact herbicide treatment is usually to remove all of the plants from a specific area for the purposes of recreation. As a result of the treatment, a massive di e-back of plant life can occur in a specific area, creating a rapid expansion in the bacter ia population (feeding on dying plan ts). The bacteria can use the dissolved oxygen normally available in the system for other organisms.

The 303(d) water bodies listed for phosphorus are a concern because when plants die after an herbicide treatment, they release sequestered phosph orus into the water column.

Aquatic Plant and Algae Management Fact Sheet Page 17 of 25The rapid release of phosphorus can trigger algae blooms, which can adversely impact

human and environmental health.

S4. WETLANDS

The Ecology Wetland Program uses WAC 173- 22-030(19) to define wetlands and WAC 197-11-768 to define mitigation as guidance for any projects that impact wetlands (RCW 90.58). The Chapter 197-11 WAC has six elements that are used to protect wetlands. These elements require a pers on to: avoid the impact, minimi ze the impact, rectify the impact, reduce the impact over time, compensa te for the impact, and monitor the impact.

S5. RESTRICTIONS ON THE APPLICATION OF PRODUCTS

A. Short-Term Modification of Water Quality Standards

WAC 173-201A-110 allows short-term modi fication of the surface water quality

standards if certain conditions are met. Activ ities requiring short-te rm modification must be conditioned, timed, and restricted in a manner that will minimize water quality degradation to existing and characteristic uses. (Cha pters 90.48 RCW and 90.54 RCW)

B. Authorized Discharges

This permit allows the use of products re gulated under FIFRA, as well as any product category identified in the permit that could pot entially require modification of the state water quality standards if the conditions of this permit are met. These discharges are

allowed in accordance with the terms of WAC 173-201A-110 and Chapter 90.48 RCW.

C. Prohibited Discharges

RCW 90.48.080 states that “it shall be unlawful for any person to throw, drain, run, or otherwise discharge into any of th e waters of this state, or to cause, permit or suffer to be thrown, run, drained, allowed to seep or ot herwise discharged into such waters any organic or inorganic matter that shall cause or tend to cause pollution of such waters according to the determination of the department.”

D. Products Allowed for Use Under This Permit

The permit conditions the use of eight federally registered active ingredients. These eight active ingredients have undergone extensive risk assessment and review by Ecology prior to approval. Ecology has mitigated for possible risks by conditioning the use of these products under the general permit. Ecology determined that, if used according to the label and in compliance with the conditions of this general permit, these active ingredients will not violate water quality standa rds. By approving active ingr edients rather than brands, Ecology will not conduct a new risk assessment for each new brand that is released onto

the market.

Aquatic Plant and Algae Management Fact Sheet Page 18 of 25The permit provides a process for new active in gredients to be approved for use under the permit. The new ingredients must under go review by both the Washington State Department of Agriculture (WSDA) and Ecology (Special Condition S11), and upon Ecology’s approval, the permit will be modified to allow their use.

This permit also provides for the use of specific adjuvants that have received environmental review, Ecology approval, and a SEPA review. The adjuvants identified in the permit have been reviewed by WSDA fo r toxicity and poten tial environmental impacts. In the future, adjuvants may be added to the permit after obtaining approval from both WSDA and Ecology, and completing SEPA review. Ecology would modify the permit to allow the use of a newly approved adjuvant.

The permit allows the use of marker dye s, nutrient inactivation products, shading products and water clarification products . This permit does not require a licensed pesticide applicator for the application of th ese products, as they are not identified as pesticides and are not regulat ed under FIFRA. However, the permittee must follow all restrictions in this general perm it during the use of these products.

E. Experimental Use Permits

Experimental Use Permits (EUPs) are regulat ed by section 5(f) of FIFRA by EPA and Chapter 15.58.405(3) RCW by WSDA.

F. Specific Restrictions on the Application of Products

Table 1. Adjuvants

This table lists the adjuvants allowed for us e under this permit and states the type of adjuvant (surfactant, spreader, sticker, si nker, etc.). These adj uvants have all been approved by WSDA and Ecology.

Table 2. Specific Restrictions on the Applicat ion of Herbicides and Algaecides

This table details restrictions on herbicid e and algaecide active ingredients that are imposed by Ecology (over and above the federa l labeling restrictions). These decisions were made on consultation with experts in th e field of toxicology a nd fisheries. Many of

the restrictions are dervied from the ri sk assessments and Environmental Impact Statements prepared for each chemical.

The second column of the table refers to fish timing window restrictions. Ecology provided WDFW with information about specific active ingredients th at risk assessments indicated could adversely aff ect juvenile salmon, steelhea d, and bull trout populations in Washington waters. If the column states “yes,” WDFW has provided Ecology with certain specific windows of time when these active ingredients can be applied in

individual water bodies.

Aquatic Plant and Algae Management Fact Sheet Page 19 of 25Ecology obtained the recreationa l and/or swimming re strictions/advisori es listed in the third column by consulting a toxicologist at the Department of Health. Some of these may mirror label requirements, but most are more stringent requirements. An advisory requires that the public at least be notified via posting for those substances that may impact people swimming in the treated area for a time period following treatment.

The limitations noted in the fourth column of Table 1 are imposed by Ecology in addition to any federal label restrictions based on the mitigations recommended while the risk assessments were being prepared on each activ e ingredient. These are based on the best scientific information available at the time of chemical approval and Ecology’s best professional judgment.

Other specific restrictions detailed in column 4 are general restrictions imposed either by Ecology based on best professiona l judgment, or in the case of 2, 4-D, by a federal court decision affecting product use.

Table 3. Specific Restrictions on the Application of Products for Inactivation of Phosphorus

All of the restrictions and requirements detailed in Table 3 have been determined by Ecology’s review of available scientific in formation and consultation with a limnologist that specializes in nutrie nt inactivation techniques.

Chapter 173-201A WAC has specific restrict ions on the range of pH acceptable in different types of Washington water bodies. Nutrient inactivati on products have the potential to adversely affect the pH of a water body, causi ng either low or high pH

scenarios. These restrictions are intended to limit treatment impacts to pH as much as possible.

Table 4. Barley Straw Restrictions

Ecology included the application of barley straw in this permit because Chapter 90.48 RCW prohibits discharges of anything that could potentially alter the biological or

chemical characteristics of a water b ody without obtaining a permit from Ecology. Application of barley straw a lters both the biological and chem ical characteristics at the time of application and for a period of time after application. Therefore, barley straw application would be prohibited without a permit; based on Ecology’s best professional judgment, this permit best applies to barley straw applications.

Table 4 provides the information needed to correctly apply barley straw to a pond or

small lake. The table includes informati on on the length of time the product should remain in the water to avoid water qualit y degradation, applica tion rates and methods, and potential changes in wate r clarity or color requiring observation. Table 4 also lists other permits that may be needed prior to ap plication. All of the in formation provided in

Table 4 is based on best available scien ce and Ecology’s best pr ofessional judgment.

Aquatic Plant and Algae Management Fact Sheet Page 20 of 25Table 5. Restrictions on Application of Shad ing Products, Biological Water Clarifiers,

etc.

Most shading products and bi ological water clarifiers ar e not federally labeled as pesticides under FIFRA. The restrictions in Table 5 are based on Ecology’s best professional judgment on normal product use in Washington waters and potential downstream impacts. In the event that the produc t is federally labeled to have some plant or algae control properties, the permit restri ctions apply in addition to those imposed on

the label.

Table 6. Treatment Restrictions for Aquatic Plant Eradication Projects

The permit imposes the restrictions in Ta ble 6 in addition to any specific federal restrictions on the pesticide label. These restrictions limit the impact to non-target plants in a water body during an eradi cation project. The re strictions are based on best available science and the best professional judgment of Ecology experts on a quatic pesticides and aquatic plants.

S6. NOTIFICATION AND POSTING REQUIREMENTS

Ecology adopted the requirements for public noti ce, posting, and legal notice of pesticide applications from previous public notification requirements in Ecology-issued orders and short-term modifications. In some cases, the public notification requ irements were based on EPA FIFRA label requirements. In all other cases, the requirements are based on Ecology’s best professional judgmen t and the public’s right to know.

S7. MONITORING REQUIREMENTS

RCW 90.48.260 gives Ecology the au thority to establish inspection, monitoring, entry, and reporting requirements. WAC 173-220-210 gives Ecology the authority to require monitoring of the treated waters to determine the effects of discharges on surface waters

of the state.

A. Application of Herbicides and Algaecides

S7.A.1. Eradication projects The draft general permit requires that the pe rmittee monitor in accordance with Ecology’s monitoring plan. Eradication pr oject permittees must obtain re presentative water samples

from waters to which herbicides have been applied for eradicati on over the life of the permit. The permittee must submit the sample results to Ecology. Ecology maintains an eradication project database funded through the Aquatic Weeds Grant Program. Those projects completing monitoring are not sp ecifically regulated under this permit; Eradication project monitoring requirement s are imposed by the Aquatic Weeds Grant Program. Eradication projects required to samp le must submit their data to Ecology no

later than November 30 th of the year the treatment occurred.

Aquatic Plant and Algae Management Fact Sheet Page 21 of 25S7.A.2. Control projects

The permit requires monitoring on any projects occurring in water bodies 303(d)-listed for low dissolved oxygen where contact herbicid es are planned for use. This requirement is designed to provide Ecology with more in formation on the impacts of using a contact herbicide in a water body that is dissolved oxygen-impaired.

B. Application of Phosphorus Inactivation Products

The permit requires monitoring on any projec ts when phosphorus inactivation products are applied to waters of the state. Studies have shown that the addition of alum products has the ability to lower pH, and the addition of calcium hydroxide has the ability to raise pH in a waterbody. Therefore, it is Ecology’s be st professional judgment that pH should be monitored prior to and while the treatment takes place.

S8. SAMPLING AND ANALYTICAL PROCEDURES

With the exception of certain parameters us ed for process control the general permit requires all monitoring data to be prepared by a laboratory registered or accredited under the provisions of Chapter 173-50 WAC, Accr editation of Environmental Laboratories.

S9. REPORTS AND RECORDK EEPING REQUIREMENTS

Ecology established t he conditions of S9 based on the authority to specify any appropriate reporting and record keeping requirements to prevent and control wastewater discharges (WAC 173-226-090).

S10. SPILL PREVENTION AND CONTROL

WAC 173-216-110 requires that any site covered under a state waste discharge permit

shall maintain materials available on site fo r the control of over flow or spills, and requires upkeep and maintenance associated w ith prevention of spills and contaminating situations. Spills can occur at sites receiving coverage under this permit.

The permittee must be prepared to mitigate fo r any potential spills and, in the event of a spill onsite, perform the nece ssary cleanup, and notify the appropriate Ecology regional office (see RCW 90.48.080, and WAC 173-216-110).

S11. CONDITIONAL APPROVAL FO R THE USE OF PRODUCTS NOT

SPECIFIED IN THE CURRENT PERMIT

Given potential adverse impacts to threatened and endangered species associated with the application of pesticides to Washington waters, Ecology has outlined a detailed process for the review and potential approval of new products for use under this permit. The permit allows use of other pesticides after approval through EPA FIFRA, a risk

Aquatic Plant and Algae Management Fact Sheet Page 22 of 25assessment submittal and Ecology approval, and completion of a multi-agency State Environmental Policy Act (SEPA).

Based on Ecology’s best professional judgment, the process outlined Section S11 will provide for a thorough investigation of each chemical prior to its use in Washington waters, and allow the public to comment on the new chemical prior to approval.

S12. CRITERIA FOR SENSITIVE, THREATENED, OR ENDANGERED

PLANT PROTECTION PLANS FOR CONTROL PROJECTS

Due to potential impacts on non-target species when herbicides are used in a water body, Ecology requires that a plant survey be completed and mitigation measures be implemented to reduce unintended impacts. Th e permit requires a detailed survey that describes all the places in the water body where a plant should be protected to be prepared and submitted to Ecology. Ecology’s iden tification of a sensit ive, threatened, or endangered plant species in a water body require s that one or more mitigation measure(s) be employed in the water body during treatment to protect the sensitive, threatened, or endangered plant. The Permittee must keep records for the life of the permit detailing which mitigation(s) were chosen prior to treatment.

The permit requires a professiona l aquatic botanist or wetland specialist c onduct the plant survey because of the complexity of aquatic macrophyt e identification.

Currently, no state law protects rare (sensitive, threatened, or endangered) plant species in Washington. However, many federal and state land management agencies have policies that provide protecti on for rare species. In 1982, th e state legislature recognized the need for a systematic and objective appro ach to protect those fe atures of our natural ecosystem most at risk. RC W 79.70.060 created the Natural He ritage Program within the Department of Natural Resources to assume th is task. In addition, local jurisdictions may provide protection for rare species and high-quality eco systems through ordinances, regulations, and permitting requirements. Once a species is lost, it cannot be replaced. Only if they are given special attention will these species survive in Washington State.



### GENERAL CONDITIONS

General Conditions are based directly on stat e law and regulation; these conditions are required to be included in all general permits . Some of these have supplemental text that clarifies how they apply for this permit. Many of these regulations ar e not applicable to the application of herbicides.

PERMIT ISSUANCE PROCEDURES

PERMIT MODIFICATIONS Ecology may modify this permit to impose nume rical limitations, if necessary to meet Water Quality Standards for Surface Waters, Sediment Quality Standards, or Water

Aquatic Plant and Algae Management Fact Sheet Page 23 of 25Quality Standards for Ground Waters based on new information obtained from sources such as inspections, effluent monitoring, out fall studies, and effl uent mixing studies. Ecology may also modify this permit as a re sult of new or amended state or federal regulations.

RECOMMENDATION FOR PERMIT ISSUANCE This proposed permit meets all statutory re quirements for author izing a wastewater discharge, including those limitations and conditi ons believed necessary to control toxics, and protect human health, aquatic life, and the beneficial uses of waters of the State of Washington. Ecology proposes that this proposed permit be issued for five (5) years.

Aquatic Plant and Algae Management Fact Sheet Page 24 of 25

### APPENDIX A - REFERENCES

Washington State Dept. of Fish and Wildlife. 1998. Aquatic Plants and Fish. Publication

# APF-1-98.

Washington State Dept. of Ecology. 1980. Environmental Impact Statement: Aquatic Plant Management.

Washington State Dept. of Ecology. 1991. Summary of Criteria and Guidelines for Contaminated Freshwater Sediment. Appendix to Ecology 1993 Sediment Source Control

Users Manual.

Washington State Dept. of Ecology. 1992. Final Supplemental Impact Statement and Responsiveness Summary (FIES): Aquatic Plants Management Program for Washington

State.

Washington State Dept. of Ecology. 2001. Final Supplemental Impact Statement for Freshwater Aquatic Plant Management . Ecology Publication No. 00-10-040.

Wisconsin Department of Natural Resources. 2000. The Water’s Edge: Helping Fish and Widlife on your Waterfront Property . Publication No. FH-428 00.

Aquatic Plant and Algae Management Fact Sheet Page 25 of 25