The time is now to do what is right.

Christina Conroy

It does not make sense to kill everything just to protect an industry.

Herbicides and pesticides are all toxic to invertebrate life, aquatic or land based. As these creatures are the base of life’s pyramid, we are playing with fire in mindlessly destroying systems of nature whose many ways of supporting our whole ecosystem are but imperfectly understood.

Pesticides sh should not be used in an ocean environment as the harm to other organisms cannot be controlled.

Please protect our water, our children and the future!

Ellen M Singer

Helen Rueda

As a veteran of 20 years as a beekeeper, who firsthand has seen a radical and alarming loss of our bees, I urge you to abandon the idea of using the highly Bee-toxic Imidacloprid in our waterways. Bees must drink water. Further, studies have found Neonicotinoids in water and air samples- showing that these pesticides do not readily breakdown and can easily migrate into the air and even the rain cycle.


Bees are crucial for pollinating 70 Of 100 of our most commonly eaten foods. They contribute billons annually to our economy- and one in twelve jobs in the US is currently food-related. In short, we need to protect our bees, which are disappearing precipitously.


Recent studies have found 700 species of native bees, nearly 1 in 4 species, are threatened or spiraling toward extinction in the US.

“In the first comprehensive review of the more than 4,000 native bee species in North America and Hawaii, the Center for Biological Diversity has found that more than half the species with sufficient data to assess are declining. Nearly 1 in 4 is imperiled and at increasing risk of extinction.”

https://www.biologicaldiversity.org/campaigns/native_pollinators/pdfs/Pollinators_in_Peril.pdf


Further, we continue to annually lose roughly 40% of all domesticated honeybees in the US.

https://www.sciencedaily.com/releases/2016/05/160510093908.htm
Neonicotinoid pesticides (which include imidacloprid) have been indicated in many scientific studies as significant contributors to our current Bee decline.


“More than 70% of pollen and honey samples collected from foraging bees in Massachusetts contain at least one neonicotinoid, a class of pesticide that has been implicated in Colony Collapse Disorder (CCD), in which adult bees abandon their hives during winter, according to a new study from Harvard T.H. Chan School of Public Health.”

https://www.hsph.harvard.edu/news/press-releases/pesticides-found-in-most-pollen-collected-from-foraging-bees-in-massachusetts/


And another USGS report confirms these concerns:

“Although overall toxicity of these (Neonicotinoid) pesticides to native bees is unknown, the chemicals do not have to kill the bees to have an effect. For example, neonicotinoids can cause a reduction in population densities and reproductive success, and impairing the bees’ ability to forage. Insecticides and fungicides can also increase a bee’s susceptibility to disease and parasites.”

http://www.nature.com/nature/journal/v521/n7550/full/nature14420.html#affil-auth

https://toxics.usgs.gov/highlights/2015-11-04-pesticides_bees.html


Further, according to the USGS, Neonicotinoids affect the nervous system of insects, and were commonly found in water samples in the Midwest:

“Neonicotinids are a class of insecticides that are chemically similar to nicotine, and affect the central nervous system of insects. The chronic aquatic toxicity of imidacloprid is in the range of 10 to 100 ng/L. Clothianidin and thiamethoxam have a common mode of action and therefore are expected generally to have similar effect levels. Neonicotinoid insecticides are highly soluble in water and do not readily degrade in the environment, therefore they are likely to be transported away from the initial application area to surface water and groundwater. This study provides the first broad-scale investigation of neonicotinoid insecticides in the Midwestern U.S. and one of the first conducted within the entire U.S. Information on neonicotinoid insecticides in the environment is limited; additional information is needed on concentrations of neonicotinoid insecticides in streams and other environmental settings across the U.S., the potential environmental contributions from use as a seed treatment, and potential health effects on biota, including pollinators and aquatic invertebrates.


Three neonicotinoid insecticides (clothianidin, thiamethoxam and imidacloprid) were detected commonly throughout the growing season in water samples collected from nine Midwestern stream sites during the 2013 growing season according to a team of U.S. Geological Survey (USGS) scientists. Clothianidin was detected most frequently (75 percent) and at the highest maximum concentration (257 nanograms per liter [ng/L]); thiamethoxam and imidacloprid followed with decreasing frequency of detection (47, and 23 percent) and maximum concentrations (185 ng/L, and 42.7 ng/L), respectively. “

https://toxics.usgs.gov/highlights/2014-07-21-neonics.html


Here is a summary of many Neonicotinoid studies by the Xerces Society:

http://xerces.org/neonic-report-exec-summary/


A 2014 CA study found Neonics were migrating to groundwater and possibly pose serious concern for aquatic health:

https://ca.water.usgs.gov/pubs/2014/HladikKolpinKuivila2014.pdf


Further, if all the systemic pesticides, Imidacloprid was found most likely to penetrate soils vertically. This indicates one application of Imidacloprid to waterways could result in the pesticide accumulating in the beds where you grow oysters, harming the oysters and other aquatic creatures, and the humans who consume them.

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4284396/


I strongly urge you to be more creative and exhaustive to solve your invasive shrimp problems. For example, could these shrimp be extracted with wet vacuums then sold to the pet foos industry to pay for the costs of extraction? You may find locals in Wallapa Bay quite willing to buy these shrimp to feed their pets to support oyster farmers and to protect the bay.


Thank you so much for your attention. We love Oregon oysters and want the industry to thrive, along with our bees and agriculture.


Very best regards,

Jen Davis

Founder/ chief organizer

Bee Friendly Portland

And co-founder of The Pollinator Collective, working with Portland Metro, The Xerces Society, the Audubon Society and many other groups for a healthier environment to help our pollinators survive.