Evaluating impact of pesticides on salmonids

May 29, 2001

Bridget Moran
Endangered Species Coordinator
Washington State Department of Agriculture
PO Box 42589
Olympia, WA 98504

Dear Bridget:

We are pleased to comment on the Washington State Pesticides/ESA Task Force’s Draft Process for Evaluating Pesticides in Washington State Surface Waters for Potential Impacts to Salmonids.

Pesticides pose a very substantial threat to salmon survival that has not received sufficient attention from regulatory agencies in the past. Recent monitoring of Northwest surface waters has revealed that pesticides contaminate streams throughout the region, frequently at levels that can harm salmon. The US Geological Survey has found thirteen pesticides at levels that exceed criteria set to protect aquatic life, and others have been detected at levels shown by scientific studies to be harmful to salmon.

WSDA and the other members of the Pesticide/ESA Task Force are taking a good first step in addressing this issue by developing a process for evaluating the effects of pesticides on salmon. In order to protect salmon from pesticides, the Task Force strategy must include the following elements:

1. Phase out the use of the most hazardous pesticides. Where pesticide levels in water exceed standards or scientific evidence shows a threat to salmon, extra precaution is in order, ensuring salmon protection through a phase-out of use of the pesticide.
2. Adopt a precautionary approach. WSDA must ensure through rulemaking that pesticides are prevented from entering waterways where there is any uncertainty about the impacts of pesticides on salmon.
3. Act quickly to protect salmon. The Task Force should proceed with an aggressive timeline for analyzing pesticides and recommending action. WSDA must take swift action to follow Task Force recommendations with mandatory restrictions through rulemaking.

We encourage the development of additional information, including monitoring of surface water for additional pesticides and collection of pesticide use data, that will assist the Task Force in determining which pesticide uses are resulting in threats to salmon. We applaud the Task Force for considering the myriad effects of pesticides on salmon, including sublethal and indirect effects.

We agree that the Task Force should use the best available science on all effects, and incorporate information on pesticide formulations and all exposures as soon as possible. The Task Force should not exclude pesticides from consideration unless there is very strong evidence that they do not travel to salmon habitat or that they do not affect salmon.

Stopping the harm caused by pesticides is a critical link in salmon recovery. We commend the agencies making up the Pesticides Task Force for developing a strategy to address this problem. Pesticides that harm salmon should be phased out, and the Task Force should develop strategies for identifying and promoting alternatives to these pesticides. We call on you to strengthen the strategy to ensure that the harm caused by pesticides to salmon is stopped now. Thank you.

Sincerely,

Wendy Church
Citizens for Healthy Bay

Reverend Jim Mulligan
Earth Ministry

Timothy Coleman
Kettle Range Conservation Group

Paul Benz
Lutheran Public Policy Office

Tim Stearns
National Wildlife Federation

Mitch Friedman
Northwest Ecosystem Alliance

No Spray Zone

Norma Grier
Northwest Coalition for Alternatives to Pesticides

Steve Koehler
Olympic Environmental Council

Pam Johnson
People for Puget Sound

Trudy Bialic
Puget Consumers Co-op

Sue Joerger
Puget Soundkeeper Alliance

Carl Weimer
ReSources for Sustainable Communities

Joanna Buehler
Save Lake Sammamish

Conservation Committee
Tahoma Audubon Society

Ric Abbett
Washington Council of Trout Unlimited

Robert Pregulman
WashPIRG

Erika Schreder
Washington Toxics Coalition

John Leary
Washington Wilderness Coalition