We request our elected representatives stop the poison applications in Crystal Lake immediately and encourage public discussion and community consensus about EWM.
We understand that County Commissioners may not be empowered to directly determine what happens on Crystal Lake, but if the commissioners decisively withdrew support for using poisons, the poison would surely stop. Also, the commissioners could schedule public meetings to consider options. Anne and I would certainly help publicize those meetings, as we assume would CLWA.
There are two reasons why we are making this request.
1) Lack of community outreach and consensus on the use of poison.
The lack of community outreach and consensus regarding the use of poison in the shared waters of Crystal Lake during the summer of 2020, 2021 and 2022.
2) CLWA's current poison only protocol is ineffective and dangerous.
CLWA's current poison only protocol for removing EWM is not only ineffective but will likely exacerbate the EWM problem, while degrading human health. Poison alone doesn't reflect MI EGLE's recommendations, doesn't take into account the lessons learned by other lakes with longer EWM histories and exposes residents and visitors (children) to danger.
www.benzie.blue www.crystallake.community
Dan Kelly water@crystallake.community OR friends@love.farm 231 882-0460
Anne Rogers anne-e-rogers@outlook.com 231 387-3176
Lack of outreach and consensus
The lack of community outreach and consensus regarding the use of poison in the shared waters of Crystal Lake during the summer of 2020, 2021 and 2022.
• CLWA has done the bare minimum to inform the public, (posting a notice in the BRP a week before application), and has made no effort to involve and engage critics of their plans.
We can have no expectations of outreach and consensus building because CLWA is a non-governmental organization, 501c(3) with paid memberships. The electorate of Benzie County doesn't determine who's on CLWA's board or what their policies are. We never voted to allow them to determine Crystal Lake's future.
• Anne and Dan met with about 8 members of CLWA's board in 2020 via zoom and 3 members face to face in 2021. Although CLWA expressed interest in ongoing dialogue, we received no follow up contact and our suggestions for encouraging public dialogue were disregarded.
On Jun 6, 2021, at 11:22 PM, Danny Kelly <anything@artisthouse.com> wrote:
Hey Dave!
Thanks for your patience, took us a little longer to hash this out.
Anne and I have discussed the Saturday meeting. We can agree to two applications of herbicide this summer if CLWA's "wait and see" approach is replaced with a comprehensive long term strategy (5 years) to insure that the proposed 2021 herbicide applications are the only applications ever needed. We can provide volunteer and fundraising support to help accomplish this outcome. Ideally, herbicide applications at Beulah beach only and DASH operations everywhere else, eg public boat launches. Whether or not CLWA's board passes a resolution clarifying the organization's perspective on herbicides and EWM, let's figure out if a DASH component is possible for the other locations - budget and scheduling. I'd be happy to assist with outreach to DASH contractors.
I've included a publication from New Hampshire's Toxic Action Center that Anne found. NH lakes and ponds have been dealing with EWM for a decade longer than Micihgan has. She suggests checking out the case studies on pages 9-12. I suggest the warnings about herbicides on page 4 and then from page 20 on.
<CHEMICAL-FREE-LAKES.pdf>
Here is a draft resolution that CLWA's board can consider and perhaps adopt. We can certainly hash this out further, Crystal Lake Community is by no means trying to dictate policy to the CLWA, but rather offer another perspective that might fit into a broader interpretation of CLWA's mission. In my opinion, adoption would significantly expand CLWA’s support.
Let's discuss on the phone or in person,
Dan Kelly
231 882-0460
Draft resolution for CLWA
•••
We recognize that herbicides have detrimental effects for wild ecosystems and human health. Some of the health hazards of herbicides are known and others are only suspected. Poisons once deemed "safe" such as DDT and glyphosate (Roundup) have proved to be highly problematic, contrary to the claims of manufacturers and even government regulators. Use of herbicides is recognized as a tradeoff - possible human health risks, possible hybridization of EWM in exchange for immediate die back of current EWM infestation.
Because of the risks to health, herbicides are not appropriate as a long term (multi-year) control strategy. Other techniques such as DASH (diver assisted suction harvesting) will be added to CLWA's 2021 EWM control plan, with the goal of implementing effective, sustainable, chemical-free ongoing management of EWM starting in 2022. Volunteer divers will accompany professional crews in 2021 and report back about the feasibility of building / purchasing a DASH boat for Crystal Lake and training of divers and operators to insure DASH is cost effective going forward.
Herbicide applications by private riparians could have many undesirable outcomes, and might open those riparians up to legal liability. The CLWA herbicide strategy has been thoroughly researched, will involve professionals and special equipment and includes before and after monitoring following scientific principles and full transparency. The CLWA plan is preferable to ad hoc herbicide applications by individual riparians, especially when followed up by DASH in 2022.
A significant factor adding to the problem on Beulah beach is effluent from Cold Creek. Any long term EWM solution will involve a initiating a collaborative effort by all municipalities and residents of those municipalities within the watershed to help the Village of Beulah permanently remediate this legacy problem.
CLWA is committed to creating comprehensive awareness and consent from all landowners within the Crystal Lake watershed for future proposed remediation plans for Crystal Lake. Comprehensive awareness is defined as having 75% of land owners within the watershed (statistical sample) being familiar with remediation plans, samples being gathered through direct mailings, phone calls and possibly door to door interviews.
•••
On Jun 23, 2021, at 9:16 AM, Dan Kelly <friends@love.farm> wrote:
Hi Dave,
The day after Anne and I met with you, Bruce and Jim, I emailed discussion points for a new CLWA resolution that would establish a long term plan for managing EWM in Crystal Lake. You had expressed a desire to collaborate and keep communications open. I was surprised when you did not respond, even after I repeatedly reached out.
The resolution that the CLWA passed seems to be a rehash of the past, to whit no specific plan to transition from herbicide to non-chemical long term EWM maintenance. Without a long term plan, the CLWA could end up applying herbicides indefinitely, until EWM is no longer manageable with herbicides or health concerns trigger a public outcry. We want a long term solution to EWM management, not a quick fix that hides the hidden cost in human and environmental health.
Regrettably, without a long-term plan it looks like the resources that I and others are willing to contribute will be used to pay for legal expenses rather than collaborative, science based outcomes.
Dan Kelly
www.CrystalLake.community
• The riparians that we've talked to around Crystal Lake (40-50) during 2020 and 2021 had no idea that the treatments were happening or had happened. How many commissioners were aware that herbicides were being used before our contact last week?
• CLWA seems to take a cavalier attitude to the dangers posed by aquatic herbicides, brushing off research that doesn't conform to their interpretation of the science. Triclopyr, 2,4-D, ProcellaCOR EC
2,4-D
Notice in Benzie Record Patriot “2,4-D Restrictions: swimming or bathing: 1 day”
http://npic.orst.edu/factsheets/24Dgen.html
2,4-D goes through different changes in the environment depending on its form. Most of the time, 2,4-D breaks down in soil so that half of the original amount is gone in 1-14 days. This breakdown time is called the "half-life" of the pesticide. One form of 2,4-D, the butoxyethyl ester, had a much longer half-life in aquatic sediment of 186 days.
[While swimming, kids and adults might dive down to the lake bottom and grab a handful of sand. If that area was treated with the butoxyethyl ester 2,4-D application, then for 6 months after application, that swimmer would be child would be exposed to a concentrated 2,4-D plume. If June, that means the danger would be present for the entire summer.]
2,4-D is broken down by bacteria in water and in soil. Water alone can also break down 2,4-D. 2,4-D has been found at low levels in shallow groundwater and streams in both rural and urban areas.
https://www.nrdc.org/stories/24-d-most-dangerous-pesticide-youve-never-heard March 15, 2016
Researchers have observed apparent links between exposure to 2,4-D and non-Hodgkin's lymphoma (a blood cancer) and sarcoma (a soft-tissue cancer). But both of these can be caused by a number of chemicals, including dioxin, which was frequently mixed into formulations of 2,4-D until the mid-1990s. Nevertheless, in 2015, the International Agency for Research on Cancer declared 2,4-D a possible human carcinogen, based on evidence that it damages human cells and, in a number of studies, caused cancer in laboratory animals.
More conclusive is the proof that 2,4-D falls into a class of compounds called endocrine-disrupting chemicals, compounds that mimic or inhibit the body's hormones. Laboratory studies suggest that 2,4-D can impede the normal action of estrogen, androgen, and most conclusively, thyroid hormones. Dozens of epidemiological, animal, and laboratory studies have shown a link between 2,4-D and thyroid disorders. "That's really important when we're thinking about development," says Kristi Pullen, a staff scientist in NRDC's Health program. "Our thyroid works to ensure the proper timing and development of the brain."
https://www.seagrant.wisc.edu/news/treating-lakes-for-eurasian-watermilfoil-with-herbicides-can-harm-young-fish/ October 14, 2021
During his doctoral studies, Dehnert found that exposure to concentrations of 2,4-D similar to those allowed during application to lakes significantly decreased survival in fathead minnow larvae and also other young fish species such as walleye, yellow perch, largemouth bass, northern pike, white crappies and white suckers.
“We saw an increase in about 20 to 35% mortality of the young fish when exposed to 2,4-D,” Dehnert said. “But we kept getting this big question: We know what happens in the laboratory, but what happens in the real world?”
• CLWA's “call for more information” number belongs to the poison contractor. Was that contractor tasked by CLWA to count the number of calls, how many callers objected to the use of poison, or the reasons for their objections? If they were not, why not?
What is the company procedure for receiving calls regarding herbicides in Crystal Lake?
How many calls have you received?
How many objections to herbicide use?
What were the reason(s) for the objections?
Amount of chemicals used in 2021?
Amount of chemicals proposed for use in 2022?
What form of aquatic 2,4D? Butoxyethyl ester?
What spray adjuvant is used with ProcellaCOR EC?
CLWA's current poison only protocol is ineffective and dangerous.
CLWA's current poison only protocol for removing EWM is not only ineffective but will likely exacerbate the EWM problem, while degrading human health. Poison alone doesn't reflect MI EGLE's recommendations, doesn't take into account the lessons learned by other lakes with longer EWM histories and exposes residents and visitors (children) to danger.
• According to MTT DASH Divers Mike Smith, Michigan's department of Energy, Great Lakes and Energy recommends one herbicide treatment followed by DASH. CLWA has done 2 herbicide treatments and has announced two more. They have not scheduled DASH and unless our community buys and staffs a DASH boat, DASH is not available until late summer of 2023.
https://vimeo.com/manage/videos/724535533
• CLWA's “wait and see” strategy is not a long term plan. We have repeatedly requested that CLWA develop and share a long term plan for managing EWM without poisons. Repeated poison application can cause EWM to hybridize and become resistant to poison. Meanwhile, the poisons are degrading the environment and human health.
• Fertilizer use is a significant contributor to EWM, yet CLWA doesn't seem to have any programs, media to discourage use of fertilizers by lake shore residents.
• Examples of other Lakes
Higgins Lake
Since 2012, Higgins Lake has had their own DASH boat and paid crew, financed by the Higgins Lake Foundation, a non profit, much like CLWA. Higgins Lake has had an EWM issue since the late 90s, much longer than Crystal Lake. Why hasn't CLWA followed the effective strategy of Higgins Lake
https://www.higginslake-foundation.org/eurasian-milfoil/
Lake Leelanau
Lake Leelanau has had more success with benthic barriers (large underwater burlap tarps) than DASH. There is no mention of herbicides in their 2021 field report.
https://lakeleelanau.org/wp-content/uploads/2022/02/LLLA-2021-EWM-Field-Report-1.pdf
https://lakeleelanau.org/invasive-species/
Unfortunately, it is virtually impossible to completely eradicate the species once it is established. As a result, regular maintenance must be done once an infestation has been reduced to affordably controlled levels. Well-trained divers with proper techniques have been able to effectively control and then maintain many lakes, especially in the Adirondack Park in northern New York where chemicals, mechanical harvesters, and other disruptive and largely unsuccessful management techniques are banned. After only three years of hand-harvesting in Saranac Lake, the program was able to reduce the amount harvested from more than 18 tons to just 800 pounds per year.
Similarly, chemical control has been deployed where infestations are severe, but hand harvesting appears to be the more cost-effective and successful strategy with fewer potential side effects for the ecosystem.
To summarize, the most successful means of control appears to be hand harvesting, which requires using trained divers to dig up the plants by their roots." The plants are then fed by the divers into an underwater suction tube, drawing the plant out of the water and into a boat. The plants are collected in mesh bags, then composted or sent to a landfill.
1) People (citizens) should have authority over changes that effect them. What happens to our water happens to us.
representative democracy
2) People can have no authority (democracy) if they are not aware / informed about changes that might effect them
outreach with surveys, public forums, phone banks, interviews
3) Organizations should not act unilaterally to effect major changes to our shared resources, regardless of their good intentions or their interpretation of science, especially if they do not have the legitimacy of an electoral process.
electoral legitimacy, specific plans submitted for review and approval, regular updates, results and review
4) Opinions differ whether chemicals added to the water cause long or short term hazards. Should there be an open forum on this topic so that different opinions can be considered and the democratic process facilitated?
presentations, debate, consensus
5) Herbicides that were declared safe by corporations and regulators has been found to cause harm to humans and the environment. Round Up is still on the shelves in our community in spite of $10 billion out of court settlement.
more data and studies about these chemicals
6) Options for removal of milfoil (or any change that effects the community) are evaluated by benefits and impacts with consideration and inclusion of diverse perspectives
DASH, hand pulling, benthic barriers, herbicides, prevention (a robust program to discourage fertilizer and poisons use by lake shore property owners, lawns converted to meadows, etc.)