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15-104240RECEIVEQ„muNrry & EcoNoNuc DEVELOPMENT DEPARTMENT 33325 8th Avenue South AUG 21 2015 Federal Way, WA 98003-6325 CITY OF � 253-835-2607; Fax 253-835-2609 Federal Way CITY OF FEDERAL WAY www.ciiyoffederalwgy.com CDS SHORELINE SUBSTANTIAL DEVELOPMENT PERMIT EXEMPTION- APPLICATION He # 5 - ► 04240 - 00 SH TO BE COMPLETED By APPLICANT Project Name: [4� �'� L �� l e Project Address: Applicant: ! VkLA k Mm R 5� b f f �'-(d (1L' m ber 7 Mailing Address: 61 a kCe_ k1wJqVkcm6,alf�g Phone Number: 1" Z 1 E-mail:4141,ef-mtkr wet w nn,,� � Description of Project: i�11�AVJ VVY) 144'1,l' —tt;_ L C V1 -IZ Ee-v v� +F,1'- L� E [AnU 10 0ova] �w O P I} , Meets the criteria for exemption under which section of * WAC 173-27-040: 2 *Washington Administrative Code online: a s.le .wa. ov � Applicant's Signatur4 Date Bulletin #143 — March 25, 2013 1 of 2 k:\Handouts\Shoreline Exemption TO BE COMPLETED BY STAFF 1) The proposed development is consistent with Section _ Z (n) of WAC 173-27-040 and is therefore exempt from the Substantial Development Permit Process. Yes ❑ No (explanatory narrative attached) 2) Proposal requires: Yes No ❑ Shoreline Variance ❑ Shoreline Conditional Use ❑ Review, Approval or Permit by other State or Federal Agency i, 1 h r 3) Proposal complies with applicable provisions of the City's Shoreline Master Program. Yes ❑ No Condition(s) attached: ❑ Yes )i� No All iy6 y"r VY��1 �S'� '��`. i C1 '��)�lS1�_��—� �t=k c 4ii c 4) In accordance with FWRC Section 15.05.130, this application is hereby: Approved ❑ Denied APpriwaW VabI `*DWjh lhqrch Director, Community Development Department Date Distribution: Applicant Owner File ❑ Outside Agency Bulletin # 143 — March 25, 2013 2 of 2 k:\Handouts\Shoreline Exemption August 14, 2015 25 b� /mnimnarr Jim Ferrell, Mayor Mr. Isaac Conlen Planner Manager, Community Development Services City Of Federal Way 33325 8t' Ave S Federal Way, WA 98003-6325 Re: Administrative Decision Request, North Lake Dear Mr. Conlen: RECEIVED 13Y St ECONOMIC CDC OpMENT DEPARTMENT MENT AUG 17 N15 Please find below information to support an Administrative Decision regarding the implementation of aquatic vegetation control on North Lake (removal and/or treatment of invasive, noxious or nuisance vegetation from lakes and associated wetlands). Per your request, the Following information is offered regarding aquatic plant management activity (specifically herbicide treatments) taking place on North Lake, in consideration of FWRC 19.170.050: • Lake Management District Number 2 for North Lake was created on September 10, 2009 pursuant to City of Federal Way Ordinance No. 09-622 (enclosed). • The October 2004 North Integrated Aquatic Vegetation Management Plan (enclosed) forms the basis for North Lake District Number 2. The IAVMP addresses options that maximize control, while at the same time minimizes negative environmental, economic, and beneficial use impacts. • The LMD aquatic plant management contractor, AquaTechnex, LLC, utilizes a state -issued Aquatic Plant and Algae Management General NPDES Permit (enclosed) for aquatic plant management work. The city is a co-permittee (sponsor). Per section S2.F, the permittee may treat aquatic noxious weeds in any identified wetland areas, but they must make every effort to protect native wetland vegetation. Under the permit program, AquaTechnex uses trained and licensed applicators. Additionally, they utilize best management practices designed to target noxious weeds only, with minimal or no impacts to adjacent vegetation. • The North Lake LMD Advisory Committee, representing the lake community, discusses and approves identified aquatic vegetation control options on an annual basis. ■ Targeted noxious plants identified and treated on North Lake have included Eurasian watermilfoil, fragrant water lily, yellow flag iris and purple loosestrife. For purple loosestrife, see RCW 17.26.010, (restriction on state agencies and local governments). This section states: State agencies and local governments may not use any other local, state, or federal permitting requirement, regulatory authority, or legal mechanism to override the legislative intent and statutory mandates of chapter 255, Laws of 1995. Thank you for your consideration. Please contact Mr. Dan Smith, Surface Water Quality Program Coordinator with questions or concerns. Sincerely, Ms. Theresa Thurlow, P.E. Surface Water Manager TT DS:mt Eric: Ordinance No. 09-622 North Lake IAVMP Aquatic Plant and Algae General Permit cc: Dan Smith, Surface water Quality Program Coordinator Project File/DS Day File k: swm\waterquality.north lake\north2015',north ad 2015Aoc 33325 8th Avenue South, Federal Way, WA 98003-6325 (253) 835-7000 www.cityoffederalway.com Issuance Date: Effective Date: Expiration Date: Modification Date: Modification Effective Date: February 16, 2011 March 18, 2011 March 18, 2016 April 4, 2012 May 4, 2012 AQUATIC PLANT AND ALGAE MANAGEMENT GENERAL. PERMIT National Pollutant Discharge Elimination System and State Waste Discharge General Permit State of Washington Department of Ecology Olympia, Washington 98504 In compliance with the provisions of Chapter 90.48 Revised Code of Washington (State of Washington Water Pollution Control Act) and Title 33 United States Code, Section 1251 et seq. The Federal Water Pollution Control Act (The Clean Water Act) Until this permit expires, is modified or revoked, Permitfees that have properly obtained coverage under this general permit are authorized to discharge in accordance with the special and general conditions that follow. eWaQuality , P.E., P.G. Program Manager Washington State Department of Ecology TABLE OF CONTENTS SUMMARY OF PERMIT REPORT SUBMITTALS......................................................... 5 SPECIAL PERMIT CONDITIONS................................................................................... 6 S1. PERMIT COVERAGE.................................................................................................................................6 A. Activities Covered Under This Permit............................................................................................................6 B. Geographic Area Covered...............................................................................................................................9 C. Activities Excluded from Coverage Under This Permit..................................................................................9 S2. APPLICATION FOR COVERAGE............................................................................................................9 A. Who May Obtain Permit Coverage.................................................................................................................9 B. How to Apply for Coverage..........................................................................................................................10 C. How to Terminate Permit Coverage..............................................................................................................12 S3. DISCHARGE LIMITS...............................................................................................................................12 A. Compliance with Standards...........................................................................................................................12 B. Temporary Exceedance of Water Quality Standards.....................................................................................12 C. Application Requirements.............................................................................................................................13 D. Discharge Management Plan.........................................................................................................................13 E. Impaired Water Bodies..................................................................................................................................14 F. Identified Wetlands.......................................................................................................................................15 G. Additional Requirements for Discharges to Water Bodies Where Sensitive, Threatened, or Endangered PlantsAre Present...................................................................................................................................................15 S4. THE APPLICATION OF PRODUCTS....................................................................................................15 A. Prohibited Discharges....................................................................................................................................15 B. Authorized Discharges..................................................................................................................................15 C. Experimental Use..........................................................................................................................................18 D. General Application Restrictions..................................................................................................................19 S5. NOTIFICATION, INSPECTION, AND POSTING REQUIREMENTS...............................................27 A. Ecology Notification Requirements..............................................................................................................27 B. Ecology Inspection Coordination Requirements...........................................................................................27 C. Residential and Business Notification...........................................................................................................28 D. Children's Camp Notification Requirements................................................................................................29 E. Shoreline Posting Requirements....................................................................................................................29 S6. MONITORING REQUIREMENTS..........................................................................................................31 A. Application of Herbicides and Algaecides....................................................................................................31 B. Application of Phosphorus Inactivation Products.........................................................................................32 S7. ANALYTICAL PROCEDURES................................................................................................................33 S8. REPORTING AND RECORDKEEPING REQUIREMENTS...............................................................33 A. Annual Treatment/Monitoring Reports.........................................................................................................33 B. Records Retention.........................................................................................................................................34 C. Recording of Results.....................................................................................................................................34 D. Noncompliance Notification........................................................................................................................34 S9. SPILL PREVENTION AND CONTROL.................................................................................................34 Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 2 A. Spill Prevention.............................................................................................................................................34 B. Spill Notification Requirements....................................................................................................................35 C. Spill Cleanup Requirements..........................................................................................................................35 S10. MITIGATION FOR PROTECTION OF SENSITIVE, THREATENED, OR ENDANGERED PLANTS: AQUATICPLANT CONTROL PROJECTS.........................................................................................................35 A. Survey Requirements....................................................................................................................................35 B. Mitigation......................................................................................................................................................35 S11. APPENDICES.............................................................................................................................................37 GENERALCONDITIONS.......................................................................................................................................38 G1. DISCHARGE VIOLATIONS....................................................................................................................38 G2. PROPER OPERATION AND MAINTENANCE....................................................................................38 G3. RIGHT OF ENTRY...........................................................................................................................:........38 G4. PERMIT COVERAGE REVOCATION...................................................................................................38 G5. GENERAL PERMIT MODIFICATION OR REVOCATION...............................................................39 G6. REPORTING A CAUSE FOR MODIFICATION...................................................................................39 G7. TOXIC POLLUTANTS..............................................................................................................................40 G8. OTHER REQUIREMENTS OF 40 CFR..................................................................................................40 G9. COMPLIANCE WITH OTHER LAWS AND STATUTES....................................................................40 G10. ADDITIONAL MONITORING.................................................................................................................40 G11. PAYMENT OF FEES.................................................................................................................................40 G12. REQUESTS TO BE EXCLUDED FROM COVERAGE UNDER A GENERAL PERMIT................40 G13. TRANSFER OF PERMIT COVERAGE..................................................................................................41 G14. PENALTIES FOR VIOLATING PERMIT CONDITIONS...................................................................41 G15. SIGNATORY REQUIREMENTS.............................................................................................................41 G16. APPEALS.....................................................................................................................................................42 G17. SEVERABILITY.........................................................................................................................................43 G18. DUTY TO REAPPLY.................................................................................................................................43 APPENDIXA - DEFINITIONS...................................................................................... 44 APPENDIXB - PUBLIC NOTICE................................................................................. 53 Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 3 APPENDIX C — ECOLOGY NOTIFICATION TEMPLATE.. .......................................... 54 APPENDIX D — BUSINESS AND RESIDENTIAL NOTICE TEMPLATE ...................... 56 APPENDIX E — POSTING TEMPLATES...................................................................... 57 LIST OF TABLES Table 1. Required permit submittals.............................................................................................. 5 Table2: Listed Adjuvants............................................................................................................ 17 Table 3: Specific Restrictions on the Application of Herbicides and Algaecides for Control and EradicationProjects.............................................................................................................. 21 Table 4: Specific Restrictions on Application of Products for Inactivation of Phosphorus ........ 25 Table 5: Restrictions on Applications of Shading Products and Biological Water Clarifiers ..... 26 Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 4 SUMMARY OF PERMIT REPORT SUBMITTALS Refer to the Special and General Conditions of this permit for submittal requirements. Table 1. Required permit submittals Permit Section Submittal Frequency Due Date(s) S2. Application for New Coverage As necessary to least 60 days prior to the start of discharge Discharge Management Plan (for New applicants: With projects where the total proposed treated Once per NOI; SID. area in the water body is five or more coverage Continuing Permittees: acres) By March 18, 2012 SIG & plant Survey and Mitigation Measures As necessary As necessary S10. Each week or By 8:00 a.m. Monday as necessary of the first week of S5.A. Ecology Pre -and Post -Treatment Notice during the treatment each treatment treatment season season No later than one S5.C. Business and Residential Notice As necessary business day following notification Dissolved Oxygen Data from 303(d) — Within 30 days for the S6.A.2 Listed Water Bodies for Dissolved As necessary post -treatment Oxygen When Using Contact monitoring date Herbicides S8.A Annual Monitoring Report Annually December 31 S8.D. Noncompliance Notification As necessary As necessary G5. Permit Modification and Revocation As necessary Within 14 days of request G6. Request for Modification As necessary As necessary G13. Request for Transfer of Coverage As necessary As necessary Once per At least 180 days prior G.18. Re -Application for Permit Coverage permit cycle to the permit expiration date Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 5 The text of this permit contains words or phrases in bold and italics. These words or phrases are the first usage in the permit and are defined in Appendix A. SPECIAL PERMIT CONDITIONS S1. PERMIT COVERAGE The Aquatic Plant and Algae Management General Permit regulates the use of pesticides and other products applied to manage aquatic nuisance plants, noxious weeds, quarantine - listed weeds, algae, and nutrients in fresh surface waters of the state of Washington. A. Activities Covered Under This Permit This general permit covers aquatic plant and algae management activities that result in a discharge of herbicides, algaecides, adjuvants, marker dyes, shading products, biological water clarifiers, and nutrient inactivation products (referred to hereafter as chemicals) into fresh water bodies of the state of Washington. The permit also covers lake shoreline and roadside/ditch bank emergent vegetation management activities where chemicals may enter the water. Aquatic plant and algae management activities are organized into three categories: Eradication, Control, and Nutrient Management. The permit has different requirements for each category. Eradication Eradication projects target only state -listed noxious weeds or quarantine -list weeds. The goal is the complete and permanent removal of these species from the entire water body. As such, littoral zone limitations do not apply to eradication of noxious weeds or weeds on the quarantine list. Impacts to non -target plants are acceptable to the extent needed to eradicate the target plants. Eradication is allowed only for: a. All noxious weeds as identified in chapter 16-750 of the Washington Administrative Code (WAC). b. Plants listed on the quarantine list as identified in chapter 16-752 WAC. c. Non-native and potentially invasive plants not listed on the above lists, as determined by the Washington State Noxious Weed Control Board, the Washington State Department of Agriculture (WSDA), or the Washington State Department of Ecology (Ecology). 2. Control Ecology limits direct herbicide application to a percentage of the littoral zone for most control treatments to preserve native plant habitat. Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 6 a. Aquatic plant control The goal is to maintain native aquatic vegetation for habitat while allowing partial plant removal for recreation and other beneficial uses. Permit requirements differ depending on plant growth forms and the legal status of the plant species. Minimal impact to non -target plants is acceptable to the extent needed to control the target plants. i. Aquatic noxious weed control Littoral zone limitations do not apply to control of noxious weeds or weeds on the quarantine list, but some treatment limitations may apply - see (2) below. The Permittee may intentionally apply herbicides to: (1) 100 percent of noxious weeds if they are Class A weeds, Class B weeds in areas where they are designated for control, as identified in chapter 16-750 WAC, and Class C weeds where they are selected for control by a county Noxious Weed Control Board (RCW 17.10.080). (2) 100 percent of any submersed noxious or quarantine -list weeds not covered under (1) if the Permittee conducts weed control using a selective herbicide. (3) 100 percent of any emergent or floating -leaved noxious weeds and quarantine listed weeds. ii. Aquatic nuisance plant control The Permittee may intentionally apply chemicals to: (1) No more than 25 feet on either side of a dock or no more than an area 50 feet wide per lot for individual treatments targeting submersed and floating -leaved plants. Treatment of the vegetated area may extend up to 25 feet beyond the end of the dock. On individual lots with no docks, treatment of the vegetated area can extend up to 50 feet from the shore. (2) No more than 40 percent of emergent shoreline plants such as cattails and bulrush on individual lots for individual treatments. (3) A percentage of a water body's littoral zone based on the littoral acres of the water body and the size of the water body. a. The geographic area where the Permittee intentionally applies chemicals must remain the same for the entire length of the permit coverage up to the maximum percentage of the littoral zone allowed for by water body size. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 7 b. All untreated littoral areas must include native vegetation from the shore to the edge of the littoral zone where the plants stop growing in deeper water. c. The cumulative percentage of the littoral zone where herbicides, may be intentionally applied must not exceed the amount allowed below: a) In water bodies up to 15 acres in size, the Permittee may intentionally apply herbicides to no more than 75 percent of the littoral zone. b) In water bodies over 15 acres and up to 50 acres in size, the Permittee may intentionally apply herbicides to no more than 60 percent of the littoral zone. c) In water bodies over 50 acres and up to 500 acres in size, the Permittee may intentionally apply herbicides to no more than 50 percent of the littoral zone. d) In water bodies over 500 acres in size, the Permittee may intentionally apply herbicides to no more than 30 percent of the littoral zone. iii. Roadside and ditch bank plant control (1) For activities conducted by state and local agencies, the Permittee may intentionally apply herbicides to 100 percent of the plants within the right of way. (2) The Permittee may intentionally apply herbicides to no more than 40 percent of native vegetation of roadsides and ditches on privately owned individual lots, but may intentionally apply herbicide to 100 percent of any noxious or quarantine -listed weeds. b. Algae control i. The Permittee may intentionally apply algaecides to the entire water body or sections of the water body, as needed, when cyanobacteria or other potentially toxic or environmentally harmful algae species are expected to form blooms in the water body. ii. The Permittee may intentionally apply algaecides to filamentous algae so long as the treated areas do not exceed the maximum amount of littoral zone allowed for treatment in Sl.A.2.a.ii. t Different littoral zone limitations apply to the herbicide fluridone. See Treatment Limitations in Table 3. Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 8 c. Nutrient Inactivation The Permittee may intentionally apply approved buffering agents and alum and calcium hydroxide/oxide and calcium carbonate as phosphorus inactivation products to the entire water body or sections of the water body per permit sections S4.D.Table 4 and S6.B and C. Limited use of other nutrient inactivation products is allowed under permit section S4.C. B. Geographic Area Covered This general permit covers the activities listed in S LA throughout surface freshwaters of the state of Washington, except for federal and tribal lands. C. Activities Excluded from Coverage Under This Permit Ecology will not require coverage under this permit for the use of chemicals on the following sites: 1. Constructed detention or retention ponds designed specifically for wastewater or stormwater treatment that do not discharge to other water bodies during and for two weeks after treatment, or where Ecology regulates the discharge under another permit that allows chemical treatment. 2. Any constructed water body five acres or less in surface area with no discharge to other surface waters of the state during and for two weeks after treatment. 3. Any constructed water body ten acres or less in surface area under single ownership with no public access and no discharge to other surface waters of the state during and for two weeks after treatment. 4. Upland farm ponds with no discharge to other surface waters of the state during and for two weeks after treatment. 5. Treatment conducted on seasonally dry land surfaces (including seasonally dry wetlands) so long as the treatment occurs when the area is dry and the active ingredient is not biologically available when the water returns. 6. Research activities when applying chemicals or products to water bodies under a State Experimental Use Permit (See S4.C). S2. APPLICATION FOR COVERAGE A. Who May Obtain Permit Coverage 1. Pesticide applicators (WAC 16-228-1545) may apply for coverage. Applicators must be licensed in Washington State with an aquatic endorsement (WAC16-228- 1545 3(t)). Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 9 a. Applicators must obtain separate permit coverage for each water body that they plan to treat. Each coverage requires a sponsor. Applicators may obtain a single permit coverage for multiple water bodies where a single, non- governmental sponsor has authority to treat more than one water body. The water bodies need not be hydraulically connected, but must be part of the same distinct community (e.g., ABC Homeowners Association). b. In water bodies with multiple sponsors or multiple permit coverages, applicators must obtain separate permit coverages for each location within the water body (e.g., Lake Washington). 2. Dischargers are not required to be licensed to apply nutrient inactivation chemicals. For these projects, the discharger may apply for permit coverage. Applicants must have a sponsor for each nutrient inactivation coverage. 3. Any state or local government entity may apply for coverage. a. Government entities may obtain a single coverage that includes multiple water bodies under its jurisdiction. Government entities are considered sponsors. b. Government entities must keep Ecology updated with a current list of its licensed pesticide applicator(s), including license numbers and license expiration dates. B. How to Apply for Coverage Applicants that propose to begin aquatic plant or algae management activities that will result in a discharge to waters of the state on or after the effective date of this permit must: 1. Submit a complete permit application (Notice of Intent or NOI) to Ecology at least 60 days before starting the activity. 2. Complete the NOI for the proposed activity online. The applicant must access Ecology's online data management system SecureAccess Washington (http:llsecureaccess.waZov), fill out the NOI online, print it, and sign it. Applicators must ensure that their sponsor(s) also sign the document. a. The sponsor's signatory must certify to Ecology in the NOI that he or she has the authority to administer the treatment. Sponsors must also certify that they either represent an entity that has the authority to administer common areas of the water body or locations within the water body for the purposes of aquatic plant and algae management or that the sponsor intends to form an entity with that authority. New sponsors that do not represent such an entity may apply for and get coverage, but they must form an entity with authority to manage aquatic plants and algae in common areas of the water body within three years Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 10 from the date of the coverage letter. After that time, Ecology may terminate permit coverage. b. Sponsors continuing coverage from the previous permit that do not currently represent an entity that has the authority to administer common areas of the water body or locations within the water body for the purposes of aquatic plant and algae management have three years from the date of permit reissuance to form an entity for these purposes. After that time, Ecology may terminate permit coverage. c. The requirements in 2.a. and 2.b. above regarding sponsor entities do not apply to individual lot treatments or government entities. In such cases, the government entity or the sponsor of the individual lot treatment must certify to Ecology in the NOI that he or she has the authority to administer the treatment. 3. Applicants for projects where the total proposed treated area in the water body is less than five acres or when the project is for only ditch bank or roadside vegetation control must complete and submit a State Environmental Policy Act (SEPA) checklist for the proposed activity. The applicant can access the SEPA checklist at httR://www.ecy.wa.gov/12rograms/sea/sepa/fonns.htm. 4. Applicants for projects where the total proposed treated area in the water body is five or more acres must complete, sign, and submit a Discharge Management Plan (DMP) and SEPA Addendum for the proposed activity (see S3.1)). The applicant can access the DMP/SEPA Addendum template at htt12-//www.ecy.wa.gov�1 .pro-r4,ms/w 1 esticides/final pesticide ermits/a uatic Pl ants/aquatic plant-Rermit_index.htm1 5. Government applicants submitting a NOI for multiple water bodies under their jurisdiction must complete, sign, and submit a separate DMP/SEPA addendum for each water body where the proposed treatment area is five or more acres or a SEPA checklist for each water body where the proposed treatment area is less than five acres. 6. If the treatment affects potable water use on water bodies with municipal or community drinking water intakes, the applicant must obtain and submit written consent to the treatment from the municipality or community. 7. Mail the complete NOI to: Department of Ecology Water Quality Program Attn: Aquatic Pesticide Permit Manager P.O. Box 47600 Olympia, WA 98504-7600 Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 11 8. After the applicant has submitted the completed NOI to Ecology, fill out the Public Notice Template provided in Appendix B. Publish the public notice twice, one week apart, in a local newspaper of general circulation (or a regional newspaper if a local newspaper is not available) that an application for permit coverage has been made. At the time the second notice is published, a 30-day comment period begins. 9. Mail or deliver the public notice to all potentially affected waterfront residents (those within one -quarter mile in each direction along the shoreline or across the water from proposed treatment areas) within one week of publishing the first newspaper notice. At the end of the required 30-day public comment period, Ecology will consider comments about the applicability of this permit to the proposed aquatic plant or algae management activity before issuing a decision on permit coverage. If the applicant does not receive notification of a coverage decision from Ecology, coverage under this permit will begin automatically on the 615t day following Ecology's acceptance of a completed NOI. C. How to Terminate Permit Coverage A Permittee may request termination of permit coverage by submitting a Notice of Termination form (NOT) to Ecology. The Permittee will continue to incur an annual permit fee unless it submits a NOT. S3. DISCHARGE LLVHTS A. Compliance with Standards 1. The application of pesticides must not cause or contribute to a violation of the Water Quality Standards for Surface Waters of the State of Washington (chapter 173-201A WAC), Ground Water Quality Standards (chapter 173-200 WAC), Sediment Management Standards (chapter 173-204 WAC), and human health - based criteria in the National Toxics Rule (40 CRF 131.36). Ecology prohibits discharges that do not comply with these standards. 2. Permittees must use all known, available, and reasonable methods of pollution control, prevention, and treatment (AKAR7) when applying pesticides. Compliance with this permit, the Washington Pesticide Control Act and the requirements of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) label constitute AKART. B. Temporary Exceedance of Water Quality Standards Short and long-term exceedance of water quality standards are allowed under this permit provided the Permittee complies with the provisions of WAC 173-201A-410. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 12 C. Application Requirements The Permittee must comply with the FIFRA label when using pesticides. Permit requirements do not reduce the requirements on the FIFRA label. The Permittee must ensure that: 1. A licensed pesticide applicator, with the appropriate Washington State Department of Agriculture (WSDA) license and certification, has direct supervision responsibilities for the use of pesticides during application. 2. All applicators (either under the direct supervision of the licensed applicator for pesticides or under the supervision of the discharger for non -pesticides) have current training in the use of the equipment necessary to apply chemicals correctly and that they use approved application techniques. 3. Appropriately trained personnel calibrate the application equipment for the chemical used. D. Discharge Management Plan 1. New applicants and Permittees continuing coverage do not need to develop a DMP when: a. The total treatment area for each coverage is less than five acres. b. Treating only for ditchbank or roadside vegetation. c. Treating under experimental use permits where the sole purpose is for research and development. 2. New applicants and Permittees continuing coverages where the total treatment area for each coverage is equal to or greater than five acres must develop a DMP for each coverage using the appropriate template bttp://www.eqy.wa.gov/prog!ams/wq1 esticideslfnal pesticide ermitsla uatic pi ants/aquatic plant permit index.html a. New applicants must submit their DMP with their NOI. The DMP template for new applicants is also a SEPA addendum. b. Permittees that continued coverage from the previous permit must submit their DMPs to Ecology by March 18, 2012. 3. Applicators must develop their DMPs jointly with each sponsor. 4. Government Permittees with single permit coverages for multiple water bodies must develop a separate DMP for each water body where the treatment area is Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 13 equal to or greater than five acres. Permittees must make these DMPs available to the water body residents on request. 5. If a water body plan exists that is equivalent to the DMP, the applicant/Permittee may submit this plan in lieu of developing a DMP. However, the applicant/Permittee must certify to Ecology that the equivalent plan contains all the elements included in the DMP template. If the equivalent plan lacks some elements of the DMP template, the applicant/Permittee may attach an addendum with the additional information to the equivalent plan. 6. After the effective date of this permit, the Permittee must keep the DMP updated. The Permittee should update the plan when significant project changes occur. The Permittee must keep an updated copy of the DMP at its business office and make it available upon request to Ecology. E. Impaired Water Bodies The Permittee must not cause further permanent impairment of any 303(d)-listed water body for any listed parameter. 2. The Permittee must prevent further permanent impairment of water bodies listed on the 303(d) list for dissolved oxygen as a result of treatment. It may do so by choosing appropriate chemicals such as a systemic herbicide instead of a contact herbicide and must implement one or more of the following mitigation measures: a. Do not treat in the summer or when water temperatures are warm enough to contribute to low dissolved oxygen concentrations after treatment. b. Limit the area treated each time that treatment occurs. c. Remove decaying plants following treatment. d. Aerate the water following treatments. 3. The Permittee must prevent further permanent impairment of water bodies listed on the 303(d) list for phosphorus as a result of treatment. It may do so by choosing appropriate chemicals to minimize release of phosphorus from non -target plants or algae and must implement at least one or more of the following mitigation measures. a. When treating for a floating plant such as duckweed or for algae blooms ensure that a healthy population of native emergent, submersed, or floating - leaved plants remain in the water body after treatment. b. Time treatment so that plant nutrients are not released during summer months. c. Limit the area treated at any one time. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 14 d. Remove decaying plants following treatment F. Identified Wetlands The Permittee may treat only high use areas to provide for safe recreation (e.g., defined swimming corridors) and boating (e.g., defined navigation channels) in identified andlor emergent wetlands. The Permittee must limit the treated area to protect native wetland vegetation. For eradication projects, the Permittee must make every effort to protect native wetland vegetation while removing noxious weeds. G. Additional Requirements for Discharges to Water Bodies Where Sensitive, Threatened, or Endangered Plants Are Present Before issuing permit coverage, Ecology will determine whether sensitive, threatened, or endangered (rare) plants are present in the proposed treatment area. If present: 1. For eradication projects, Ecology will consult with the Washington Natural Heritage Program and may condition the permit coverage based on the consultation. 2. For aquatic plant control projects, the Permittee must submit a detailed plant survey and if a rare plant is present in the treatment area, implement one or more mitigation measures (see S 10.). S4. THE APPLICATION OF PRODUCTS A. Prohibited Discharges Ecology prohibits treatment that causes oxygen depletion to the point of stress or lethality to aquatic biota from plant or algae die -off, the mortality of aquatic vertebrates, or unintended impacts to water quality or biota. B. Authorized Discharges 1. Beginning on the effective date of this permit and until Ecology modifies, reissues, or revokes this permit; this permit authorizes the Permittee to discharge the chemicals listed in the permit into freshwaters of the state. 2. This permit does not convey any property rights of any sort, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights. 3. The Permittee must comply with the specific restrictions/limitations on the use of each chemical listed in Tables 3-5. 4. The Permittee-may apply -the following listed active ingredients that are labeled for use on aquatic sites: Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 15 a. 2,4-D: 2,4-Dichlorophenoxyacetic acid, butoxyethyl ester b. 2,4-D: 2,4-Dichlorophenoxyacetic acid, dimethylamine salt c. Bispyribac-sodium: Sodium, 2,6-bis [(4,6-dimethoxy-pyrimidin-2-yl)oxy] benzoate d. Carfentrazone-ethyl: Ethyl a,2-dichloro-5-[4-(difluoromethyl)-4,5-dihydro-3- methyl-5-oxo-1 H-1,2,4-triazol-l-yl]-4-fluorobenzenepropanoate e. Diquat: Dibromide salt of 6,7-dihydrodipyrido (1,2-a:2',1"-c) pyrazinediium f. Endothall: Dipotassium salt of 7-oxabicyclo[2.2.1]heptane-2,3dicarboxylic acid g. Endothall: mono(N,N-dimethylalkyalmine) salt of 7- oxabicyclo[2.2.1]heptane-2,3-dicarboxylic acid h. Flumioxazin: 2-[7-fluro-3,4-dihydro-3-oxo-4-(2-propynyl)-2H-1,4- benzoxazin-6-yl] -4, 5, 6, 7-tetrahydro-1 H-isoindole-1, 3 (2H)-dione i. Fluridone:l-methyl-3-phenyl-5-[3-(trifluoromethyl)phenyl]-4(1H)-pyridinone j. Glyphosate: N-(phosphonomethyl)glycine, isopropylamine salt k. hnazamox: 2-[4,5-dihydro-4-methyl-(1-methylethyl)-5-oxo-lH-imidazol- 2y1]-5-(methoxymethyl)-3-pyridinecarboxylic acid 1. Imazapyr: 2-(4,5-dihydro-4-methyl-4-(1-methyleth7yl)-5-oxo- lH-imidazol-2- yl)-3-pyridinecarboxylic acid m. Penoxsulam:2-(2,2-difluoroethoxy)--6-(trifluoromethyl-N-(5,8- dimethoxy[1,2,4] triazolo[1,5-c]pyrimidin-2-yl)) benzenesulfonamide n. Sodium carbonate peroxyhydrate: 2Na2CO3 3H2O2 o. Triclopyr TEA: Triethyiamine salt of3,5,6-trichioro-2-pyridyloxyacetic acid 5. The Permittee may apply the adjuvants listed in Table 2. Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 16 Table 2: Listed Adjuvants Adjuvant (Trade Name) Product use Agri-DexTM Crop Oil Concentrate AquaSurfrm I Surfactant Spreader, Sticker, and Deposition BondTM Aid Bronc MaxTM Water Conditioning Agent Water Conditioning Agent, Bronc Plus Dry-EDTTM Surfactant, Deposition Aid, and Anti -foam Agent Water Conditioning Agent and Class Act NGTM Surfactant Modified Vegetable Oil and CompetitorTM Surfactant Cut-RateTM Water Conditioning Agent Surfactant and Modified Vegetable Cygnet PIusTM Oil Modified Vegetable Oil and DestinyHCTM Surfactant Dyne-AmicTM Modified Vegetable Oil and Surfactant Water Conditioning Agent and ExciterTM Surfactant FractionTM Water Conditioning Agent Deposition Aid and Drift Control InterlockTM Agent KineticTM Surfactant Surfactant, Water Conditioning Level 7TM Agent, and Acidifier Surfactant, Acidifier, Deposition LI-70OTM Aid, and Drift Control Agent Surfactant, Deposition Aid, and LiberateTM Drift Control Agent Water Conditioning Agent and MagnifyTM Surfactant Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 17 Adjuvant (Trade Name) Product use One-Ap XLTM Water Conditioning Agent, Surfactant, Deposition Aid, and Antifoaming Agent Pro AMS P1usTM Water Conditioning Agent and Surfactant SinkerTM Carrier, Drift Control Agent, and Deposition Aid Spray-RiteTM Water Conditioning Agent Superb HCTM High Surfactant Oil Concentrate TacticTM Spreader/sticker and Deposition Aid TronicTM Surfactant 6. The Permittee may apply nutrient inactivation products, including aluminum sulfate, sodium aluminate, calcium hydroxide/oxide, and calcium carbonate and the approved buffering agents. See Table 4 for specific restrictions on nutrient inactivation products. 7. The Permittee may apply marker dyes, shading products, and water clarification products (including bacterial products). See Table 5 for specific restrictions on these products. C. Experimental Use 1. The Permittee may apply chemicals not listed in this permit on a limited basis in the context of a research and development effort under the jurisdiction of the Environmental Protection Agency (EPA) through the issuance of a federal experimental use permit (40 CFR 172) and the WSDA through the issuance of a state experimental use permit (EUP). Discharges for the sole purpose of research and development are not required to be covered under a DMP (S3.D.l.c.). a. Project proponents must obtain coverage under this general permit for any in - water projects conducted under a federal EUP (projects over one acre or more in size), unless the project is conducted at a site excluded from coverage under this permit. b. Ecology does not require coverage under this general permit for research and development projects of one acre or less in size where the project proponent operates under a state EUP (issued by WSDA). Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 18 2. The Permittee may apply nutrient inactivation products not listed in this permit on a limited basis in the context of a research and development effort so long as the Permittee develops a plan that is approved by Ecology for this activity. The plan must undergo a public review process. D. General Application Restrictions 1. The Permittee must avoid treatments that restrict public water use during the opening week of fishing season or during tribal fisheries, Memorial Day weekend, Independence Day weekend, and Labor Day weekend and must minimize treatments that restrict public water use during weekends. 2. When there are potable water restrictions on the label and the treatment is within the setback distance listed on the product label, the Permittee must not apply any chemical until it has notified people who withdraw potable water from the water body. If requested by the affected water user(s), the Permittee must provide an alternative potable water supply until the intake water tests at or below the concentration specified for that chemical in Table 3, or until the time period specified in Table 3 for that chemical has elapsed. If there is no potable water restriction listed in Table 3, the Permittee must follow all label conditions for potable water supply. If requested by an affected water user, the Permittee must provide at least two weeks advance notice of pending treatments. 3. People withdrawing water under a legal water right or claim for irrigation or livestock watering purposes may request an alternate water supply during the treatment if the label has restrictions for those uses and the treatment is inside the setback distance listed on the product label. The Permittee must provide an alternative water supply until the intake water tests at or below the irrigation restriction concentration or livestock drinking water concentration on the label or until the time interval specified on the label has elapsed. If requested by an affected water user, the Pennittee must provide at least two weeks advance notice of pending treatments. 4. The Permittee must avoid treatments that adversely affect salmon or steelhead in hatcheries when applying treatments to areas upstream of a hatchery water intake. Ecology will coordinate with the Permittee, the Washington State Department of Fish and Wildlife (WDFW), and affected tribes to ensure treatments proposed upstream of a hatchery intake do not adversely affect hatchery fish or hatchery operations. 5. The Permittee must ensure that there is adequate contact time between the targeted vegetation and the selected herbicide when treating in reservoirs or in flowing water to avoid non -target downstream impacts. 6. The Permittee must comply with WDFW timing windows referenced in Tables 3 and 4 to protect salmon, steelhead, and bull trout populations and WDFW priority Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 19 habitats and species. WDFW may periodically update this table as new information becomes available or on request from Ecology. The timing table is available at: htt ://www.ec .wa. ovl row ms/w 1 esticides/finaI pesticide permits/aquatic pi a! slaquatic.Vlant permit index.htmi. a. Timing windows do not apply to nonnative fish such as bass. At their discretion, Permittees may choose to comply with the bass timing windows noted in the WDFW timing table. b. Permittees may consult with Ecology and WDFW to develop alternate timing windows if necessary so long as the new treatment windows do not adversely impact priority species and habitats. 7. The Permittee must follow the specific restrictions and advisories identified in Tables 3 and 4. Swimming restrictions/advisories apply to primary contact activities such as swimming, wading, and water skiing. Drinking water restrictions apply to residents drinking lake water as their sole source of potable water or where they hold a water right for potable water. 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E m m E c me 3 Y m 3 a) +.. �m3co�0.0EE O _ O U0 0 a) O E N E O) co .— i 0 0= a) a) U 0 a 0 3 °- " N ?. —a) 0 O_ 0 0 M 0 L 3 C C Co y Q vQid 3f- E 00 ?:m 3 A A A A A V) O A t •U 3 7 U)) L O N m— C +. a) O cr C 3 a) M L' O Q L m E �i O - O) ` N E O m m N O c m 0 •L o 0 �Y-L- �0� E a) > E cL 0)E 0 a) L ,O E a (C6 f0 M 0 0 'C N L a a) -C i Q- n= m ui a 04) io c — -a m 0 N o Ca) is c n 0 0 3 .L. N a a C N 3 �ac°imE 0- d 0 0 0 3 0 aL E O 0 -2 c C (U _0 (D Q o .0 (D CL 0 c 7 U C O@ 0 o- 0 N E a) 4 n a)) - C--(n n '.E `°0Eo m m .- 0 N 0= 0 L > L O Q« H O N U LL a) Y L U �O L - N U .O .T) a) N N m N O C O O Z ip Q 0 O N ca 0 O cd v N ME. N 0 N r 41 U Lm i s o t o .- y w O N rn y m � s U N � � U IO '! ate+ 7 N y �0 s O O N I6 O C — O O O o, E U E M N N m N U �' y L L y L O M O C CO O N T N O 0 O 0-0 ` C _T N n m G O! Q 3 O T•` U O C ! j rO. O 0 y co D N L1 7 Q N f0 y U UL 7 O 0. (0 � O U N O � O U) m S5. NOTIFICATION, INSPECTION, AND POSTING REQUIREMENTS A. Ecology Notification Requirements Pre- and post -treatment notification The Permittee must email pre -and post -treatment information to Ecology each week that treatment occurs using the form in Appendix C. Ecology headquarters and appropriate regional staff must receive the form no later than 8:00 am on each Monday (see the contact list below). For unforeseen events, the Permittee may occasionally provide Ecology with less notice so long as pre-treatment notification occurs at least two days prior to the treatment. Contact Information Telephone Central Regional Office, Yakima (509) 457-7107 Eastern Regional Office, Spokane (509) 329-3610 Northwest Regional Office, Bellevue (425) 649-7000 Southwest Regional Office, Lacey (360) 690-4796 Ecology Headquarters, Lacey (360) 407-6283 2. Adverse incidents or spills Email Charlie.McKinne tzec .wa o� Jerem .R f ec .wa.gov Tri c ia.S hobl oin[a).ecy. wa. gov Rod.ThyselI Regyma.gov JonathanjenninesO,ecv.waxov The Permittee must immediately call the appropriate Ecology regional contact and Ecology headquarters or 1-800-6457-911 when they are made aware of any of the following conditions occurring during or after a treatment: a. Any person(s) exhibiting or indicating any toxic and/or allergic response as a result of the treatment. b. Any fish or fauna exhibiting stress or dying inside or outside of the treatment area. c. Any spill of chemicals covered under this permit that occurs into the water or onto land with a potential for entry into waters of the state. B. Ecology Inspection Coordination Requirements At Ecology's request, each Permittee must coordinate and schedule inspections with Ecology staff. The location and starting time for the scheduled inspection must be on record in writing at Ecology. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 27 2. For scheduled inspections, the Permittee must not apply chemicals until Ecology staff is present, unless they do not arrive within 30 minutes of the scheduled start time. C. Residential and Business Notification 1. Using the template in Appendix E, the Permittee must provide Residential and Business Notice (notice) to all waterfront residences and businesses within one - quarter mile in each direction along the water body shoreline or across the water from proposed treatment areas. The Permittee may provide the notice by mail, newsletter, or handbills delivered directly to the residences or businesses. If using handbills, the Permittee must secure the notice to the door in a fashion that will hold it in place but will not damage property. If the residence or business is gated or guarded by dogs, the Permittee may secure the notice in clear view on the outside of the gateway or may attach the notice to the outside of the residence or business in a fashion that will hold it in place but will not damage property. 3. Businesses and residents must receive the notice at least 10 days in advance and at most 42 days before the first treatment of each year. If the notice explains the application schedule for the entire treatment season and there is no deviation from that schedule (with an exception for cyanobacteria treatment), Ecology requires no further notice for the rest of the treatment season. On water bodies with a history of cyanobacterial blooms, the Permittee may explain in the notice that algae treatment may occasionally occur outside of the scheduled time periods without prior notice depending on bloom conditions. The Permittee must provide additional notification to any resident or business that specifically requests further notification of treatment dates. 4. The Permittee must provide a copy of the notice including the date of distribution to the appropriate Ecology regional office contact and to the Department of Natural Resources (DNR) contact (todd.palzerCcr.wa.gov,) no later than one ,dnbusiness day following public distribution. The Permittee need not notify DNR for treatments occurring on privately -owned lakes with no public access. Ecology does not require notice for applications made to limited access highways, fenced wetland mitigation sites, or other facilities where no reasonable public access exists. Aquatic Plant and Algae Management General Permit—April4, 2012 Page 28 D. Children Is Camp Notification Requirements 1. Permittees must coordinate with camp managers to ensure that the manager notifies the parents or guardians of campers if a pesticide application is expected to occur in or within 400 feet of a camp swimming area or a camp recreational area during or up to one week before their child attends camp. 2. Camp notification must include the name of the product being applied, the time period during which treatment will occur, any swimming or recreational advisories or restrictions, and camp and Permittee contact information. E. Shoreline Posting Requirements Ecology does not require shoreline posting in areas where public access is limited to boat only access and there are no private residents or for continuous alum treatments. 1. General Requirements for Posting Shorelines The Permittee must: a. Use templates provided in Appendix E. b. Post signs no more than 48 hours prior to treatment. c. Post signs so that they are secure from the normal effects of weather and water currents, but cause minimal damage to property. d. Make best efforts to ensure that the signs remain in place and are legible until the end of the period of water use restrictions. e. Remove all old signs before a new treatment begins or before the end of the treatment season, whichever comes first. If applying more than one chemical in an area, the Permittee may list all chemicals on the sign, but must use the template and restrictions for the chemical with the most stringent water use restrictions. If the majority of the affected community speaks a language other than English, the Permittee may use online translation websites to make signs for these communities. For continuous injection treatments for nutrient inactivation projects, the Permittee does not need to post the lake. 2. Posting Privately or Publicly -Owned Shoreline Areas (excluding public access areas) with 8 '/2 by 11 Inch Signs Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 29 a. The Permittee must post signs at each waterfront private residence or business property that is within 400 feet of a treated area. b. The Permittee must post the signs to face both the water and the shore and site them where they are most visible to residents (within approximately ten feet of the shoreline). The Permittee must post one sign for approximately every 100 feet of shoreline. c. If the shoreline is only accessible by entering through a gate, the Permittee may post a sign at each gate that allows access to, or is within 400 feet of a treated area. The Permittee does not need to post additional signs. 3. Posting Shoreline Public Access Areas with Two Foot by Three Foot Signs a. The Permittee must post signs at all public access areas on the water body that are within 400 feet of a treated area and at all public boat launches on the water body within one quarter mile of a treated area. b. The Permittee must site the signs so that they are clearly visible to people using the public access area, spacing the signs approximately every 100 feet of shoreline and within approximately 25 feet of the shoreline. Signs must face both the water and the shore. At public boat launches, signs need only face the shore. c. If a public shoreline is only accessible by entering through a gate, the Permittee may post a sign at each gate that allows access to, or is within 400 feet of a treated area. The Permittee does not need to post additional signs. d. Signs must be a minimum size of two feet by three feet and constructed of durable weather -resistant material. The Permittee must attach an 8 '/z by 11 inch weather resistant map detailing the treatment areas for each chemical used. The map must identify the location(s) of the treatment site(s) and mark the reader's location. If the Permittee applies more than one chemical, it must mark each treated area and appropriate chemical on the map. Signs must: i. Include the word "CAUTION" in bold black type at least two inches high. ii. Use a font at least % inches high for all other words. 4. Posting Public Pathways Along a Treated Water body a. The Permittee must post two foot by three foot signs at public entrances to public pathways that allow reasonable direct access to the water body and that Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 30 are within 400 feet of a treated area. b. The Permittee must post 8 '/2 by 11 inch signs at approximately 100 foot intervals along the pathway along any treated areas and within 400 feet of any treated areas. 5. Posting for Roadside/Ditch Bank Aquatic Applications a. The Permittee does not need to post signs for roadside applications or applications to areas with no reasonable public access. b. For those sites with public access areas, the Permittee must: i. Post signs no more than 48 hours before an application. ii. Place signs at any boat launch within 1/4 mile of any treated area. Signs must be within 25 feet of the shoreline, facing both the water and shore. The Permittee is responsible for the removal of all signs at the end of each treatment season, but may use biodegradable sign material so that removal is not necessary. S6. MONITORING REQUIREMENTS A. Application of Herbicides and Algaecides 1. Eradication Projects Under the Aquatic Weeds Management Fund, Ecology requires monitoring for herbicide residues for herbicide treatments funded by Ecology grants. Grant - funded monitoring is in lieu of additional monitoring under this permit. 2. Control Projects The Permittee must monitor dissolved oxygen levels pre- and post -treatment when contact herbicides are used in water bodies on the 303(d)-list for dissolved oxygen. a. Immediately before treating, the Permittee must monitor surface and bottom dissolved oxygen concentrations at a sampling location in the center and at the edge of the proposed treatment area(s). The Permittee must select at least one representative treatment area to monitor each time the water body is treated. b. The Permittee must monitor post -treatment surface and bottom dissolved oxygen concentrations no earlier than seven days and no later than 14 days after the treatment, at the same time of day that the pre-treatment monitoring Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 31 occurred and at the same sites and depths. c. The Permittee must submit these data to the Ecology permit manager no later than 30 days after the post -treatment monitoring date. B. Application of Phosphorus Inactivation Products 1. Aluminum sulfate or sodium aluminate (alum). a. The minimum monitoring requirement for whole or partial lake treatments is one surface water pH measurement in the morning prior to any alum addition and one surface water pH measurement one hour after alum addition has stopped for that day. The Permittee must monitor pH for the duration of the treatment and for 24 hours following treatment completion. The monitoring location must be representative of water body -wide conditions. If the pH decreases to less than 6.2, the Permittee must stop treatment, analyze for alkalinity, and must take immediate steps to increase the pH. b. For continuous injection treatments, the Permittee must measure pH at a minimum once every two weeks during the first month of continuous injection and thereafter once a month for the duration of the injection process. The Permittee must ensure that pH measurements represent water body -wide conditions, unless the injection system is in an isolated area in relation to the main water body (e.g., in a bay with a narrow channel to the main water body). For isolated areas of water bodies, the Permittee must measure pH at the end of the bay and in the main water body. 2. Calcium hydroxide/oxide or calcium carbonate treatment a. The Permittee must measure pH once on the day before treatment, and once in the morning and once in the afternoon for the duration of the treatment and for 24 hours following treatment. If the pH is above 9.0 due to the effects of the treatment (rather than through photosynthesis), the Permittee must stop treatment. b. For continuous injection systems, the Permittee must measure pH at a minimum once every two weeks during the first month of continuous injection and thereafter once a month for the duration of the injection process. The Permittee must ensure that pH measurements represent water body -wide conditions, unless the injection system is in an isolated area in relation to the main water body (e.g., in a bay with a narrow channel to the main water body). For isolated areas of water bodies, the Permittee must measure pH at the end of the bay and in the main water body. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 32 S7. ANALYTICAL PROCEDURES A. The Permittee must use either an EPA method or one of the methods specified in section STC. or STD. to fulfill the analytical requirements of this permit. B. The Permittee must ensure that all monitoring data are analyzed by a laboratory registered or accredited under the provisions of chapter 173-50 WAC, Accreditation of Environmental Laboratories. C. Ecology does not require the use of an accredited laboratory for temperature, dissolved oxygen, pH, alkalinity titration, or Secchi disk measurement. All dissolved oxygen and pH monitoring must follow the protocols in A Citizens Guide to Understanding and Monitoring Lakes and Streams which may be accessed at www.ecy.wa.gov/programs/wq/plants/Management/j oysmanual/index.html. D. Analyses conducted using enzyme linked immunosorbent assay (ELISA) methods may substitute for the requirements in STA. S8. REPORTING AND RECORDKEEPING REQUIREMENTS The Permittee must submit pesticide/product application information in accordance with the following conditions. A. Annual Treatment/Monitoring Reports 1. By December 31 of each year, the Permittee must submit its report electronically through Ecology's online data management system (SecureAccess Washington at htts://secureaccess.wa. ov . A signed and dated copy of the report must be mailed to: Department of Ecology Water Quality Program Attn: Aquatic Pesticide Permit Manager P.O. Box 47600 Olympia, WA 98504-7600 2. The Permittee must submit an annual treatment/monitoring report regardless of whether treatment or monitoring occurred and this report must include: Water body name, dates treatment occurred, chemicals used, amount of active ingredient applied, acreage treated, monitoring results, and the plant species targeted. 3. The Permittee must submit any dissolved oxygen monitoring data to the Aquatic Pesticide Permit Manager and the appropriate regional contact, no later than 30. days after the post -treatment monitoring date. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 33 B. Records Retention 1. The Permittee must retain records of all permitting and monitoring information for a minimum of five (5) years. Such information must include copies of all reports required by this permit, plant surveys, and records of all data used to complete the application for this permit. 2. The Permittee must keep records longer in the event of any unresolved litigation regarding the discharge of pollutants by the Permittee or when requested by Ecology. 3. The Permittee must make the records, reports, surveys, plans, public notices (including a list of locations or addresses to which they were delivered), and other information required by this permit available to Ecology upon request. C. Recording of Results For each measurement or sample taken, the Permittee must follow the recording provisions outlined in WAC 173-226-090 (2). D. Noncompliance Notification If the Permittee is unable to comply with any of the terms and conditions of this permit for any cause, the Permittee must immediately stop the activity causing the noncompliance, correct the problem, notify Ecology of the failure to comply, and return to compliance as quickly as possible. S9. SPILL PREVENTION AND CONTROL A. Spill Prevention The Permittee must: 1. Handle, store, and use all oil, fuel, chemicals, or products authorized under this permit in a manner that prevents spills. 2. Ensure that it maintains all mobile equipment to prevent leaks or spills of petroleum products. 3. Have absorbent materials available for cleanup or the spill containment materials recommended in the Material Safety Data Sheet for that product, including appropriate cleanup materials for a spill of the products being applied. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 34 B. Spill Notification Requirements The Permittee must immediately report spills to Ecology by calling 1-800-6457-911. See http://www.ecy.wa.gov/prog-rams/spills/other/reportaspill for more environmental reporting information. C. Spill Cleanup Requirements In the event of a spill, the Permittee must begin immediate containment and cleanup using appropriate materials. Cleanup takes precedent over normal work. 2. Cleanup includes proper disposal of any spilled materials and used cleanup materials. 510. MITIGATION FOR PROTECTION OF SENSITIVE, THREATENED, OR ENDANGERED PLANTS: AQUATIC PLANT CONTROL PROJECTS A. Survey Requirements If Ecology notifies the Permittee that a rare plant species (rare plant) is reported to be present in a proposed treatment area, the Permittee must conduct a detailed plant survey (unless Ecology waives this requirement). The survey must be performed by a professional aquatic botanist or wetland specialist. The person conducting the survey must not have a financial or personal interest in the treatment. 2. The botanist or wetland specialist must survey when plants are present and can be positively identified, but no earlier than three months before treatment. Ecology may waive the three month requirement if the plant cannot be positively identified during that time frame. 3. , The Permittee must survey each year before treatment for rare submersed, floating, or floating -leaved plants and once every five years for rare emergent shoreline plants. 4. The Permittee must submit the survey data to Ecology no later than thirty days before treatment. Ecology may modify or suspend the annual survey requirement if it determines that the treatment(s) have had no adverse effect on the rare plant population. B. Mitigation 1. When a rare plant is in the treatment area, the Permittee must apply prescribed buffers (where required) and select one or more mitigation choices listed below to Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 35 minimize treatment impacts to the rare plant. Monitoring the vitality of rare plant populations after treatment may be required by Ecology. The Permittee must not allow treatment to affect the viability of the rare plant population. 2. Mitigation measures for: a. Submersed, floating, or floating -leaved plants: If the rare plant is submersed, floating, or floating -leaved and the herbicide application is intended to control submersed species, the Permittee must maintain a no -treatment buffer around the rare plants. The Permittee must maintain a 100-foot buffer when using contact herbicides and must consult with Ecology when using systemic herbicides to determine appropriate buffer distances. If the Permittee has difficulty maintaining a buffer from the majority of the rare plant population, it must consult with Ecology for other options (e.g., physically relocating the plants). In addition to the buffer, the Permittee must choose one or more mitigation measures below: i. Use a selective herbicide (if applicable) or an herbicide demonstrated to have little effect on the rare plant. H. Use the lowest effective concentration of herbicide for the target plant if the Permittee can demonstrate that the rare plant is tolerant to the herbicide at that concentration. iii. Use barriers or containment structures (e.g. silt curtains) to protect the rare plant. iv. For floating rare plants, temporarily relocate the plants to an untreated area. V. Time the treatment. b. Emergent plants: If the rare plant is emergent or floating -leaved and the targeted plants are being treated above the water (i.e., target plants are emergent), the Permittee must maintain a no treatment buffer of 10 feet from the rare plant and choose one or more of the following mitigation measures: i. Use a selective herbicide (if applicable) or an herbicide demonstrated to have little effect on the rare plant. ii. Select an application technique designed to cause less non -target damage (e.g., low -drift nozzle heads, wiper applications, sponge bars, temporarily covering the rare species, etc.). Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 36 iii. Time the treatment during the growing season to prevent impacts to the rare plant. S11. APPENDICES The attached appendices are incorporated by reference into this permit. APPENDIX A - DEFINITIONS APPENDIX B - PUBLIC NOTICE APPENDIX C - ECOLOGY NOTIFICATION TEMPLATE APPENDIX D - BUSINESS AND RESIDENTUAL NOTICE TEMPLATE APPENDIX E - POSTING TEMPLATES Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 37 GENERAL CONDITIONS G1. DISCHARGE VIOLATIONS All discharges and activities authorized by this general permit must be consistent with the terms and conditions of this permit. The discharge of any pollutant more frequently than, or at a concentration in excess authorized by this permit, constitutes a violation of the terms and conditions of this permit. G2. PROPER OPERATION AND MAINTENANCE The Permittee must at all times properly operate and maintain all systems of treatment and control to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary systems which are installed by a Permittee only when the operation is necessary to achieve compliance with the conditions of this permit. The Permittee must not allow concentrations of the product(s) to exceed FIFRA label or permit conditions. G3. RIGHT OF ENTRY The Permittee must allow an authorized representative of Ecology, upon the presentation of credentials and such other documents as may be required by law, at reasonable times: A. To enter upon the premises where a discharge is located or where any records must be kept under the terms and conditions of this permit; B. To have access to and to copy any records that must be kept under the terms of the permit; C. To inspect any postings, monitoring equipment, or method of monitoring required in this permit; D. To inspect any collection, treatment, pollution management, or discharge facilities; and E. To sample any discharge of pollutants. G4. PERMIT COVERAGE REVOCATION Pursuant to chapter 43.2113 RCW and chapter 173-226 WAC, the Director may require any discharger authorized by this general permit to apply for and obtain coverage under an individual permit or another more specific and appropriate general permit. Cases where revocation of coverage may be required include, but are not limited to the following: A. Violation of any term or condition of this general permit. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 38 B. Obtaining coverage under this general permit by misrepresentation or failure to disclose fully all relevant facts. C. Failure or refusal of the Permittee to allow entry as required in RCW 90.48.090. D. A determination that the permitted activity endangers human health or the environment, or significantly contributes to water quality standards violations. E. Nonpayment of permit fees or penalties assessed pursuant to chapter 90.48.465 RCW and chapter 173-224 WAC. F. Failure of the Permittee to satisfy the public notice requirements of WAC 173-226- 130(5), when applicable; or Permittees who have their coverage revoked for cause according to WAC 173-226-240, may request temporary coverage under this permit during the time an individual permit is being developed, provided the request is made within ninety (90) days from the time of revocation and is submitted along with a complete individual permit application form G5. GENERAL PERMIT MODIFICATION OR REVOCATION This permit may be modified, revoked and reissued, or terminated in accordance with the provisions of chapter 173-226 WAC. Grounds for modification or revocation and reissuance include, but are not limited to, the following: A. When a change that occurs in the technology or practices for control or abatement of pollutants applicable to the category of dischargers covered under this permit. B. When effluent limitation guidelines or standards are promulgated pursuant to the Federal Water Pollution Control Act or chapter 90.48 RCW for the category of dischargers covered under this general permit. C. When a water quality management plan containing requirements applicable to the category of dischargers covered under this general permit is approved. D. When information is obtained which indicates that cumulative effects on the environment from dischargers covered under this general permit are unacceptable. G6. REPORTING A CAUSE FOR MODIFICATION A Permittee who knows or has reason to believe that any activity has occurred or will occur which would constitute cause for revocation under condition G5 above or 40 CFR 122.62 must report such information to Ecology so that a decision can be made on whether action to modify or revoke coverage under this general permit will be required. Ecology may then require submission of a new application for coverage under this, or another general permit, or an application for an individual permit. Submission of a new application does not relieve the Permittee of the duty to comply with all the terms and conditions of the existing general Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 39 permit until the new application for coverage has been approved and corresponding permit has been issued. G7. TOXIC POLLUTANTS The Permittee must comply with effluent standards or prohibitions established under Section 307(a) of the Clean Water Act for toxic pollutants within the time provided in the regulations that establish those standards or prohibitions, even if this permit has not yet been modified to incorporate the requirement. G8. OTHER REQUIREMENTS OF 40 CFR All other applicable requirements of 40 CFR 122.41 and 122.42 are incorporated in this general permit by reference. G9. COMPLIANCE WITH OTHER LAWS AND STATUTES Nothing in this permit excuses the Permittee from compliance with any applicable federal, state, or local statutes, ordinances, or regulations. G10.ADDITIONAL MONITORING Ecology may establish specific monitoring requirements in addition to those contained in this general permit by administrative order or permit modification. G11.PAYMENT OF FEES The Permittee must submit payment of fees associated with this permit as assessed by Ecology. Ecology may revoke this permit coverage or take enforcement, collection, or other actions, if the permit fees established under chapter 173-224 WAC are not paid. G12. REQUESTS TO BE EXCLUDED FROM COVERAGE UNDER A GENERAL PERMIT Any discharger authorized by this general permit may request to be excluded from coverage under this general permit by applying for an individual permit. The discharger must submit to the Director an application as described in WAC 173-220-040 or WAC 173-216-070, whichever is applicable, with reasons supporting the request. These reasons must fully document how an individual permit will apply to the applicant in a way that the general permit cannot. Ecology may make specific requests for information to support the request The Director may either issue an individual permit or deny the request with a statement explaining the reason for the denial. When an individual permit is issued to a discharger otherwise subject to this general permit, the applicability of this general permit to that Permittee is automatically terminated on the effective date of the individual permit. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 40 GUTRANSFER OF PERMIT COVERAGE This permit coverage may be automatically transferred to a new Permittee if: A. The Permittee notifies Ecology at least 30 days in advance of the proposed transfer date. B. The notice includes a written signed agreement between the existing and the new Permittee containing a specific date for transfer of permit responsibility, coverage, and liability between them. C. The Department does not notify the existing Permittee and the proposed new Permittee of its intent to modify or revoke permit coverage. G14.PENALTIES FOR VIOLATING PERMIT CONDITIONS Any person who is found guilty of willfully violating the terms and conditions of this permit is deemed guilty of a crime, and upon conviction thereof shall be punished by a fine of up to ten thousand dollars ($10,000) and costs of prosecution, or by imprisonment in the discretion of the court. Each day upon which a willful violation occurs may be deemed a separate and additional violation. Any person who violates the terms and conditions of a waste discharge permit will incur, in addition to any other penalty as provided by law, a civil penalty in the amount of up to ten thousand dollars ($10,000) for every such violation. Each and every violation is a separate and distinct offense, and in case of a continuing violation, every day's continuance shall be deemed to be a separate and distinct violation. G15. SIGNATORY REQUIREMENTS All applications, reports, or information submitted to Ecology must be signed and certified. A. In the case of a municipal, state, or public facility, all permit applications must be signed by a principal executive officer or ranking elected official. In the case of a corporation, partnership, or sole proprietorship, all permit applications must be signed by either a principal executive officer of at least the level of vice president of a corporation, a general partner of a partnership, or the proprietor of a sole proprietorship. B. All reports required by this permit and other information requested by Ecology must be signed by a person described above or by a duly authorized representative of that person. A person is a duly authorized representative only if: 1. The authorization is made in writing by a person described above and submitted to Ecology. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 41 2. The authorization specifies either an individual or a position having responsibility for the overall operation of a regulated facility, such as the position of plant manager, superintendent, position of equivalent responsibility, or an individual or position having overall responsibility for environmental matters. (A duly authorized representative may thus be either a named individual or any individual occupying a named position.) C. Changes to authorization. If an authorization under paragraph B.2 above is no longer accurate because a different individual or position has responsibility for environmental matter, a new authorization satisfying the requirements of paragraph 13.2 must be submitted to Ecology prior to or together with any reports, information, or applications to be signed by an authorized representative. D. Certification. Any person signing a document under this section must make the following certification: I certify under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiries of the person or persons who manage the system, or those persons directly responsible for gathering information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. G16. APPEALS The terms and conditions of the Aquatic Plant and Algae Management general permit are subject to appeal. There are two different appeal categories. A. The permit terms and conditions as they apply to the appropriate class of dischargers are subject to appeal within thirty (30) days of issuance of this general permit in accordance with chapter 43.21(B) RCW and chapter 173-226 WAC; and B. The applicability of the permit terms and conditions to an individual discharger are subject to appeal in accordance with chapter 43.21(B) RCW within thirty (30) days of effective date of coverage of that discharger. An appeal of the coverage of this permit to an individual discharger is limited to the applicability or non -applicability of this permit to that same discharger. Appeal of this permit coverage of an individual discharger will not affect any other individual dischargers. If the terms and conditions of this general permit are found to be inapplicable to any discharger(s), the matter must be remanded to Ecology for consideration of issuance of an individual permit or permits. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 42 GM SEVERABILITY The provisions of this general permit are severable, and if any provision of this general permit, or application of any provision of this general permit to any circumstance, is held invalid, the application of such provision to other circumstances and the remainder of this general permit shall not be affected thereby. G18.DUTY TO REAPPLY The Permittee must reapply for coverage under this general permit at least one hundred and eighty (180) days prior to the specified expiration date of this general permit. An expired general permit and coverage under the permit continues in force and effect until Ecology issues a new general permit or until Ecology cancels it. Only those Permittees that reapply for coverage are covered under the continued permit. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 43 APPENDIX A — DEFINITIONS All definitions listed below are for use in the context of this permit only. 303(d): Section 303(d) of the federal Clean Water Act requires states to develop a list of polluted water bodies every two years. For each of those water bodies, the law requires states to develop Total Maximum Daily Loads (TMDLs). A TMDL is the amount of pollutant loading that can occur in a given water body (river, marine water, wetland, stream, or lake) and still meet water quality standards. Adjuvant: An additive, such as a surfactant, that enhances the effectiveness of the primary chemical (active ingredient). Algae: Primitive, chiefly aquatic, one -celled, or multicellular plant -like organisms that lack true stems, roots, and leaves but usually contain chlorophyll. Algaecide: A chemical compound that kills or reduces the growth of algae or cyanobacteria. Algae control: Applying algaecides to kill or suppress the growth of cyanobacteria, filamentous algae, or any algal species that have the potential to affect human or environmental health. All known, available, and reasonable methods of pollution control, prevention, and treatment (AKAR7): A technology -based approach to limiting pollutants from discharges. Described in chapters 90.48 and 90.54 RCW and chapters 173-201A, 173-204, 173-216 and 173- 220 WAC. Applicant: The licensed pesticide applicator or state or local government entity choosing to get coverage under this permit. For nutrient inactivation projects the applicant does not need to be a licensed applicator but may be a government entity or the person that discharges the product. Application schedule: The proposed treatment date(s) for a specific water body or specific area within a water body during one treatment season. Applicator: The person that discharges the chemical to a water body. Applicators are required to be licensed to apply registered pesticides. Some chemicals such as alum are not registered or used as pesticides and therefore the applicator does not, by state law, have to be licensed. Aquatic nuisance plants: Any non -noxious aquatic plants that are at a density and location so as to substantially interfere with or eliminate some beneficial uses of the water body. Typically these beneficial uses include activities such as boating, swimming, fishing, or waterskiing. Aquatic plant control: The partial removal of aquatic plants within a water body or along a shoreline to allow for the protection of beneficial uses of the water body. Beneficial uses: See WAC 173-201A-200. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 44 Biological water clarifiers: Microbial or bacterial products sold for the purpose of water clarification, removal of organic materials from sediment, and reduction of nutrients (as claimed by manufacturers). Blooms: A high density or rapid increase in abundance of algae (cyanobacteria). Children's camps: A site located along a water body that provides water contact recreation and other activities for children particularly during the summer months and includes day camps as well as residential camps. Constructed water body: A man-made water body created in an area that was not part of a previously existing watercourse, such as a pond, stream, wetland, etc. Contact herbicide: An herbicide that typically affects only the part of the plant that the herbicide is applied to. Contact herbicides often act as chemical mowers, leaving roots available for re- growth. Contact herbicides are fast -acting, but tend to result in temporary removal of the targeted plants. Control: The partial removal of native plants, non-native non -noxious plants, algae, and noxious or quarantine -list weeds (that are not being eradicated lake -wide) from a water body. The purpose of control activities is to protect some of the beneficial uses of a water body such as swimming, boating, water skiing, fishing access, etc. The goal is to maintain some native aquatic vegetation for habitat while allowing some removal for beneficial use protection. Cyanobacteria: A group of usually unicellular photosynthetic organisms without a well-defined nucleus; sometimes called "blue-green algae" although they are not actually algae. Some genera of cyanobacteria produce potent liver or nerve toxins. Defined navigation channels: Clearly delineated areas that are intended to provide safe access to different sections of the water body by boat. Defined swimming channels: Clearly delineated areas intended for safe passage of swimmer between swimming areas on a water body. Detention or retention ponds: Man-made water bodies specifically constructed to manage stormwater. Detention ponds are generally dry until a significant storm event. Retention (wet) ponds are designed to have a permanent pool of water and gradually release stormwater through an outlet. Direct supervision responsibilities: Licensed certified applicators may directly supervise unlicensed applicators. Direct supervision by aquatic certified applicators means direct on-the- job supervision and requires that the certified applicator be physically present at the application site and that the person making the application be in voice and visual contact with the certified applicator at all times during the application. Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 45 Discharge Management Plan: A site -specific water body plan that incorporates elements of intcgrated pest management. For new applicants with projects five or more acres, the Discharge Management Plan also serves as a SEPA addendum. Emergent vegetation: Aquatic plants that generally have their roots in the water, but the rest of the plant is above water (e.g., cattails, bulrush). Eradication: Eradication is the permanent removal of all non-native, invasive aquatic plants of one or more species within a water body or along a shoreline. The goal of eradication projects is to allow a diverse native plant community to flourish once the invasive species is eliminated. It may take years to achieve eradication of a target species. Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): A set of EPA regulations that establishes uniform pesticide product labeling, use restrictions, and review and labeling of new pesticides. Filamentous algae: Typically green algae species that grow in long strings or form cloud -like mats in water. Filamentous algae do not produce toxins. Floating plants: Plants that are not rooted in the sediment (e.g., duckweed). These plants freely float in or on the water surface, but are most often observed in shallow water. Floating -leaved plants: Plants that are rooted in the sediment but have leaves floating on the water's surface (e.g., water lilies). Herbicide: Any substance or mixture of substances intended to prevent, destroy, repel, or mitigate any weed or other higher plant (see chapter 17.21.020 RCW). High use areas: Any areas that get a high level of human use. Examples include community and public boat launches, marinas, public or community swim beaches, and canals. Identified andlor emergent wetlands: Identified wetlands are those identified by either local, state, or federal agencies as being important wetlands. Emergent wetlands (marshes) are characterized by plants growing with their roots underwater and leaves extending above the water (emergent plants). Impact to non -target plants: Plants inadvertently affected by an herbicide treatment that was intended to treat other plants. Impacts to the non -target plants may include death or affected growth or vigor. Individual treatments: Treatments done at the request of an individual owner under a permit coverage specific to that property only. Intentionally apply: The permit allows the applicator to directly discharge an herbicide, algaecide, or other product identified in this permit into areas designated for treatment (e.g., via Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 46 hoses, granular pellets, etc.). Note that products applied directly to the water may disperse outside of the boundaries of the treated area. Invasive: Tending to spread and then dominate the area by outcompeting other plants. Some non- native species can become invasive when introduced outside of their native range. Some native plants can be invasive too (e.g., cattails). Legal oversight: Having authority under the law to manage aquatic plants or algae in a water body. See also the sponsor definition. Legal water right: A water right is a legal authorization to use a predefined quantity of public water for a designated use. The purpose must qualify as a beneficial use such as irrigation, domestic water supply, etc. Any use of surface water which began after the state water code was enacted in 1917 requires a water -right permit or certificate. Legal water right claim: A water right claim is statement of beneficial use of water that began prior to 1917 for surface water. Claims remain valid until such time that adjudication occurs, whereby the validity of the claim must be proven before a court of law. During adjudication, claimants are required to prove that water has been in constant beneficial use prior to 1917 for surface water. Five or more consecutive years of non-use may invalidate a claim. Licensed pesticide applicator: Any individual who is licensed as a commercial pesticide applicator, commercial pesticide operator, public operator, private -commercial applicator, demonstration and research applicator, or certified private applicator, or any other individual who is certified by the director of WSDA to use or supervise the use of any pesticide which is classified by the EPA as a restricted use pesticide or by the state as restricted to use by certified applicators only. WSDA classifies aquatic herbicides as restricted use pesticides. Littoral zone: The vegetated area from the water body's edge to the maximum water depth where plant growth occurs. The littoral zone varies between water bodies depending on bathometry, water clarity, water quality, and other environmental conditions. Lot: A parcel of land having fixed boundaries. Marker dyes: Colorants that are sprayed onto the targeted weed along with the herbicide. Marker dyes allow better targeting of herbicide sprays since treated and untreated areas are more clearly seen by the applicator. Municipal or community drinking water intakes: A drinking water intake that supplies water to a city, town, or a community. Native and non-native plants: Native plants are plants that are indigenous to the region; non- native plants are not indigenous to the region, but are not on Washington's quarantine list or noxious weed list. Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 47 New applicants: An applicator or government entity that proposes to discharge pesticide into waters of the state, but does not already have coverage under the Aquatic Plant and Algae Management Permit for the proposed treatment site. Non-native: A plant living outside of its natural or historical range of distribution. Plants considered to be non-native were not present in Washington prior to European settlement. Most non-native plants are not considered to be noxious weeds. Notice of Intent (NOI): An application to obtain coverage under an NPDES permit. Noxious weed. A legal term defined in chapter 17.10 RCW that means a non-native plant that when established is highly destructive, competitive, or difficult to control by cultural or chemical practices. The Washington State Noxious Weed Control Board maintains a legal list of noxious weeds (see chapter 16.750 WAC for the current list of noxious weeds). Nutrient management: The use of chemical precipitants to bind soluble reactive phosphorus into an insoluble form that is unavailable to aquatic organisms, to clarify the water column, and to reduce the release of phosphorus from sediments. Nutrient inactivation is typically used to prevent algae blooms by inhibiting phosphorus release from sediments. Nutrient inactivation products: Products used to inactivate nutrients in the sediments include aluminum sulfate or sodium aluminate (alum) and calcium hydroxide. Occasionally: No more than a few times (1-3) per treatment season and only for unforeseen events (e.g., disruption with product deliveries or severe adverse weather conditions). Permittee: The licensed applicator or government entities that have obtained coverage under the permit. For nutrient inactivation projects, the Permittee may be the discharger that most closely resembles a licensed applicator. Pesticide: WAC 15.58.030 (31) "Pesticide" means, but is not limited to: a) Any substance or mixture of substances intended to prevent, destroy, control, repel, or mitigate any insect, rodent, snail, slug, fungus, weed, and any other form of plant or animal life or virus, except virus on or in a living person or other animal which is normally considered to be a pest or which the director may declare to be a pest; b) Any substance or mixture of substances intended to be used as a plant regulator, defoliant or desiccant; and c) Any spray adjuvant. Plant growth forms: The growth characteristics (morphology) of aquatic plants such as emergent plants (cattails), submersed plants (Eurasian watermilfoil), and floating -leaved plants (water lilies). Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 48 Potentially invasive plants: Species that are not indigenous to the region, have been shown to have invasive tendencies, and have a probability of becoming listed as a noxious weed. Private property: Any property owned by a single person or multiple persons or business that provides no public access to a water body. Priority habitats and species: Habitats and species that WDFW considers priorities for conservation and management in Washington. Priority species require protective measures for their survival due to their population status, sensitivity to habitat alternation, and/or recreational, commercial or tribal importance. Priority habitats are habitat types or elements with unique or significant value to a diverse assemblage of species. Privately or publicly -owned shoreline: Any shoreline area without public access, owned by an individual, business, or a public entity. Professional aquatic botanist: A scientist that specializes in the study and identification of aquatic plants. Public access: Identified legal passage to any of the public waters of the State, assuring that members of the public have access to and use of public waters for recreational purposes. Public access areas include public- or community -provided swimming beaches, picnic areas, docks, marinas, and boat launches at state or local parks and private resorts. Public access areas: These areas include public- or community -provided swimming beaches, picnic areas, docks, marinas, and boat launches at state or local parks and private resorts. Public boat launch: A public- or community -provided location on a water body that is designated for the purpose of launching or placing a boat in the water, usually for recreational purposes. Boat launches also include sites used as put -ins and take-outs for small watercraft such as canoes or kayaks. Public entrance: A location where people typically access a public pathway. Public pathway: A trail along a water body that allows access to the water body by the public. Quarantine -listed weeds: Plants listed on the WSDA Quarantine list as identified in chapter 16.750 WAC. Reasonable public access: Identified legal passage to any of the public waters of the State, or areas where it is apparent that the public have been accessing the water (well worn pathways or other indications of recent human usage of the site). Recreation: Water skiing, boating, swimming, wading, fishing, and other such water -related activities. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 49 Right of way: A strip of land that is granted, through an easement or other mechanism, for transportation or other typically public uses. Right of way locations may include roadsides and/or highways, railroads, power lines and irrigation ditches. Same time of day: The same two-hour time window for pre- and post -treatment monitoring on any given day (applies to pH and dissolved oxygen monitoring). Selective herbicide: An herbicide that kills or affects specific plant species, sparing other less - susceptible species. Selectivity occurs through different types of toxic action or by the manner in which the material is used (its formulation, dosage, timing, placement, etc.). Sensitive, threatened, or endangered plants: Sensitive: Any species that is vulnerable or declining and could become endangered or threatened in the state without active management or removal of threats. Threatened: Any species likely to become endangered in Washington within the foreseeable future if factors contributing to its population decline or habitat degradation or loss continue. Endangered: Any species in danger of becoming extinct or extirpated from Washington within the foreseeable future if factors contributing to its decline continue. Populations of these species are at critically low levels or their habitats have been degraded or depleted to a significant degree. SEPA addendum: See also the definition for the State Environmental Policy Act (SEPA). "Addendum" means an environmental document used to provide additional information or analysis that does not substantially change the analysis of significant impacts and alternatives in the existing environmental document. The term does not include supplemental EISs. An addendum may be used at any time during the SEPA process (WAC 197-11-706)." A SEPA addendum provides additional site -specific information about a project. Shading products: These compounds are usually non -toxic dyes and are designed to reduce the amount of light penetrating the surface of a water body, thereby reducing plant and algae growth. Shoreline: The area where water and land meet. Shoreline emergent vegetation: Plants growing along the edges of lakes, ponds, rivers, and streams that have at least part of their stems, leaves, and flowers emerging above the water surface and are rooted in the sediment (e.g., cattails, bulrush, bogbean). Sponsor: A private or public entity or a private individual with a vested or financial interest in the treatment. Typically the sponsor contracts with a licensed applicator to apply pesticides for aquatic plant or algae management. A sponsor is an individual or an entity that has authority to administer common areas of the water body or locations within the water body for the purposes of aquatic plant and algae management. Entities with this authority include Lake Management Districts formed under chapter 36.61 RCW, Special Purpose Districts formed under Title 57 RCW, Homeowners Associations formed under chapter 64.38 RCW, and groups operating under Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 50 the provisions of chapter 90.24 RCW. There may be other entities with the authority to manage common areas in public or private water bodies. For treatment on individual lots, the sponsor must have the authority to contract for aquatic plant and algae management within the lot boundaries. State Environmental Policy Act (SEPA): A state policy that requires state and local agencies to consider the likely environmental consequences of a proposal before approving or denying the proposal (See chapter 43.21C RCW and chapter 197 -11 WAC). State experimental use permit: A permit issued by WSDA allowing use of pesticides that are not registered, or for experiments involving uses not allowed by the pesticide label. Aquatic applications are limited to one acre or less in size. Submersed: Underwater. Submersed plants generally always remain under water, although many submersed species produce above -water flowers (e.g., pondweeds, milfoil). Surface waters of the state of Washington: All waters defined as "waters of the United States" in 40 CRF 122.2 within the geographic boundaries of the state of Washington. All waters defined in RCW 90.48.020. This includes lakes, rivers, ponds, streams, inland waters, and all other fresh or brackish surface waters and water courses within the jurisdiction of the state of Washington. Also includes drainages to surface waters. Swimming advisory: Information required to be posted on all public signs advising people not to swim in the treated area for a number of hours after treatment. An advisory is a recommendation rather than a restriction. Swimming restriction: Information required to be posted on all public signs stating that no swimming must occur in the treatment area for a number of hours after treatment. Systemic herbicide: A chemical that moves (translocates) throughout the plant and kills both the roots and the top part of the plant. Systemic herbicides are generally slower -acting than contact herbicides, but tend to result in permanent removal of the targeted plants. Treatment: The application of an aquatic herbicide, algaecide, or control product to the water or directly to vegetation to control vegetation, algae, or remove or inactivate phosphorus. Treated area: The area where pesticide is applied and where the concentration of the pesticide is sufficient to cause the intended effect on aquatic plants or algae. Upland farm pond. Private farm ponds created from upland sites that did not incorporate natural water bodies (WAC 173-201A-260(3)(f)). Washington Pesticide Control Act: Chapter 15.58 RCW. Wetland: Any area inundated with water sometime during the growing season, and identified as a Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 51 wetland by a local, state, or federal agency. Welland Specialist: A biologist who specializes in the study and identification of wetland plant species. In the absence of other definitions set forth herein, the definitions set forth in 40 CFR Part 403.3 or in chapter 90.48 RCW apply. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 52 APPENDIX B — PUBLIC NOTICE Public notice must be published at least once each week for two consecutive weeks, in a single newspaper of general circulation in the county or counties where the treatment will take place. The applicant must mail or deliver this notice to all potentially affected waterfront residents (those within one -quarter mile in each direction along the shoreline or across the water from proposed treatment areas) within one week of publishing the first newspaper notice. The applicant may add additional project information to this template, but must not remove or change any bolded language (other than changing fonts or removing bolding). PUBLIC NOTICE TEMPLATE Applicant name and contact information (e.g., phone number, Email address, website) is seeking coverage under the NPDES Waste Discharge General Permit for aquatic plant and algae management. The proposed coverage applies to list water body name, acres proposed for treatment, and their location within the water body. Water body name may be treated to control aquatic plants and algae. The chemicals planned for use are: list all active ingredients anticipated for use. Any person desiring to present their views to the Department of Ecology regarding this application must do so in writing within 30 days of the last date of publication of this notice. Comments must be submitted to the Department of Ecology. Any person interested in the Department's action on the application may notify the Department of their interest within 30 days of the last date of publication of this notice. Submit comments to: Department of Ecology P.O. Box 47696 Olympia, WA 98504-7600 Attn: Water Quality Program, Aquatic Pesticide Permit Manager Email: jonathan.jennings@ecy.wa.gov Telephone: 360-407-6283 The chemicals planned for use have (name water use restrictions — such as drinking water or irrigation water use restrictions) for up to (number of days or other information about use restrictions). Persons with legal water rights should contact the applicant if this coverage will result in a restriction of these rights. Permittees are required to provide an alternative water supply during treatment. Copies of the application are available by contacting the Aquatic Pesticide Permit Manager. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 53 L C N L o }, N L V a) a Q a) ca -0 a) U -C c L O L E a L� U 0 (0 Vca C Q O � O O ? d O r a) Ea E ++ L y- O O L- d W U. a � d � O �+ V O E O �+ E) N = H a = W 'a fA O 3 ao '~ _N O .E � d N O d a v a0 33 __ O d *+ £ O d �_ O 1 _ 3 O V V o a L d � O � = o = � L a ZO N O N *+ c d L (Q O O C 3 3 d O ° a To a CL 0 0 V H � d L Q i+ �+ H �1 c H a V L w N 3 u E 3 d V O v a r c 3 O V O ca �+ � 3 � c d a w e � �� as 10 aD .. m := a 3 O N L 3 C c O w E L C O H m w M E im C _ E is H C O s � 3 0 aY a N 0 N APPENDIX D — BUSINESS AND RESIDENTIAL NOTICE TEMPLATE The applicant may add project information to this template but must not remove or change any bolded language (other than changing fonts or removing bolding). Business and Residential Notice Distribution Date: Date notices mailed or delivered Water body will be treated with name type of product (e.g., aquatic herbicides, algaecides, bacterial products, etc.) on or between treatment dates. Product(s) planned for use: list product names Active ingredient(s): list the active ingredients Plants/Algae targeted: describe what will be treated and why Location of treatment(s): describe locations or include a map The applicator will post signs in the treated and potentially affected areas no more than 48 hours prior to treatment. The signs will describe any water use restrictions or advisories. If you are withdrawing water for potable or domestic water use, livestock watering, or irrigation, and have no alternate water source, please contact name of applicator at phone number or e-mail to arrange an alternate water supply. Note: Business and residential notification only goes '/ mile from each treatment site. Check the product label to ensure that treatment does not impact potable water users more than 4 mile from treatment area. If you want additional notification prior to treatment, or have further questions, please contact me using the information above. Optional: include contact information for the sponsor here. This herbicide treatment is regulated under a permit issued by the Washington State Department of Ecology. Permit No. applicator to enter the permit coverage number Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 56 APPENDIX E - POSTING TEMPLATES Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 57 CAUTION The aquatic herbicide 2, 4-D (amine formulation) will be applied under permit to these waters on to control aquatic vegetation. Ecology recommends no swimming in the sign -posted area for 24 hours following treatment due to possible eye irritation. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: ( ) This application is regulated by Department of Ecology: Phone THIS SIGN MUST REMAIN IN PLACE UNTIL 2 GAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 58 WARNING The aquatic herbicide 2,4-D (ester formulation) will applied under permit to these waters on control aquatic vegetation. Use Restrictions: No swimming in the sign -posted during and for 24-hours following treatment. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: (_) be to area This application is regulated by the Department of Ecology: Phone (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 ❑AYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 59 CAUTION The biological water clarifier under permit to these waters on will be applied There are no swimming or recreation restrictions. For more information contact the applicator: Phone number: �) Or the Department of Ecology at ( ) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 60 CAUTION Diquat Dibromide will be applied under permit to these waters on to control aquatic vegetation. Ecology recommends no swimming in the sign -posted area for 24 hours following treatment due to possible eye irritation. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Domestic Animal Watering Restrictions: For more information contact the applicator: Phone number: (_) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 61 CAUTION Endothall (Dipotassium salt) will be applied under permit to these waters on to control aquatic vegetation. Ecology recommends no swimming in the sign -posted area for 24 hours following treatment due to possible eye irritation. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Fishing Restrictions: For more information contact the applicator: Phone number: () Or the Department of Ecology at () THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 62 WARNING Endothall (Hydrothol 191 TM) will be applied under permit to these waters on to control algae. Ecology recommends no swimming in the sign -posted area during and for 24-hours following treatment. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: ( ) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 63 CAUTION Fluridone will be applied under permit to these waters on to control aquatic vegetation. There are no swimming or recreation restrictions. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock.Watering Restrictions: For more information contact the applicator: Phone number: (_) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 64 CAUTION Glyphosate will be applied under permit to these waters on to control aquatic vegetation. There are no swimming or recreation restrictions. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: (_) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 65 CAUTION Imazapyr will be applied under permit to these waters on to control aquatic vegetation. There are no swimming or recreation restrictions. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: (_) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 66 CAUTION The shading product these waters on algae. will be applied under permit to to control aquatic vegetation and/or There are no swimming or recreation restrictions. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: (_) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 67 CAUTION Sodium carbonate peroxyhydrate will be applied under permit to these waters on to control algae. Ecology recommends no swimming in the sign -posted area for 12 hours following treatment due to possible eye irritation. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: (_) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION, Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 68 CAUTION Triclopyr TEA will be applied under permit to these waters on to control aquatic vegetation. Ecology recommends no swimming in the sign -posted area for 12 hours following treatment due to possible eye irritation. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Fishing Restrictions: For more information contact the applicator: Phone number: (_) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 69 CAUTION Imazamox will be applied under permit to these waters on to control aquatic vegetation. There are no swimming or recreation restrictions. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: (_) Or the Department of Ecology at ( ) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 70 CAUTION Bispyribac-sodium will be applied under permit to these waters on to control aquatic vegetation. There are no swimming or recreation restrictions. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: ( ) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 71 CAUTION Carfentrazone-ethyl will be applied under permit to these waters on to control aquatic vegetation. There are no swimming or recreation restrictions. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: ) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 72 CAUTION Flumioxazin will be applied under permit to these waters on to control aquatic vegetation. There are no swimming or recreation restrictions. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: (_) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION Aquatic Plant and Algae Management General Permit—April4, 2012 Page 73 CAUTION Penoxsulam will be applied under permit to these waters on to control aquatic vegetation. There are no swimming or recreation restrictions. Applicator to put additional label restrictions or advisories here: Drinking Water Restrictions: Irrigation Restrictions: Stock Watering Restrictions: For more information contact the applicator: Phone number: ) Or the Department of Ecology at (_) THIS SIGN MUST REMAIN IN (PLACE UNTIL 2 D►o►YS AFTER APPLICATION Aquatic Plant and Algae Management General Permit — April 4, 2012 Page 74 CAUTION The nutrient inactivation product (list product alum or calcium products) will be applied under permit to these waters on There are no swimming or recreation restrictions. For more information contact the applicator: Phone number: ( ) Or the Department of Ecology at ( ) THIS SIGN MUST REMAIN IN PLACE UNTIL 2 DAYS AFTER APPLICATION. Aquatic Plant and Algae Management General Permit —April 4, 2012 Page 75 North Lake Integrated Aquatic Vegetation Management Plan October 2004 OW King County North Lake Integrated Aquatic Vegetation Management Plan O King County Department of Natural Resources and Parks Water and Land Resources Division Lake Stewardship Program Noxious Weed Control Program King Street Center 201 South Jackson, Suite 600 Seattle, WA 98104 (206) 296-6519 TTY Relay: 711 www.metrokc.gov/dnr October 2004 King County Executive Ron Sims Director of Department of Natural Resources and Parks Pam Bissonnette Division Manager of Water and Land Resources Division Daryl Grigsby Water and Land Resources Division Staff Sally Abella Beth Cullen Drew Kerr Michael Murphy Washington State Department of Ecology Staff Kathy Hamel North Lake Community Steering Committee Mark Braverman Julie Cleary Beth Cullen Chuck Gibson Cover Photos: North Lake Improvement Club North Lake IAVMP 12/21/2004 Debra Hansen Wendy Honey Tom Jovanovich IV ACKNOWLEDGEMENTS The King County Lake Stcwardship Program and the Noxious Weed Control Program wish to thank the members of the Steering Committee for the North Lake Integrated Aquatic Vegetation Management Plan. Members include Mark Braverman, Julie Cleary, Beth Cullen, Chuck Gibson, Debra Hansen, Wendy Honey, and Tom Jovanovich. King County staff were instrumental in developing the IAVMP. Key staff included Drew Kerr and Monica Walker of the Noxious Weed Control Program, as well as Sally Abella, Michael Murphy (Murph), and Beth Cullen from the Lake Stewardship Program. Washington Department of Ecology staff provided invaluable technical guidance during development of the IAVMP. Special thanks to Kathy Hamel of the Aquatic Weeds Management Fund for her prompt, thoughtful and thorough response to all questions. Finally, special thanks to the North Lake community. Their enthusiasm and dedication to preserving the aesthetic beauty, recreational opportunities, and ecological integrity of North Lake is inspiring. North Lake IAVMP 12/21/2004 iii EXECUTIVESUMMARY...................................................................................................... I PROBLEMSTATEMENT..................................................................................................... 2 MANAGEMENTGOALS...................................................................................................... 4 COMMUNITYINVOLVEMENT.......................................................................................... 5 CommunityHistory ................... ............................................................................................ . 5 CommunityCommitment...................................................................................................... 6 Steering Committee, Outreach, and Education Process...................................... ................... Publiccomment...................................................................................................................... 9 Publicconsensus.................................................................................................................... 9 Continuing Community Education....................................................................................... 9 WATERSHED AND WATERBODY CHARACTERISTICS .......................................... 12 WaterbodyCharacteristics................................................................................................... 13 WaterQuality....................................................................................................................... 14 Fish and Wildlife Communities.......................................................................--.---.............. 15 Beneficial and Recreational Uses......................................................................................... 18 Characterization of Aquatic Plants in North Lake............................................................... 19 Noxious Aquatic Weeds in North Lake............................................................................... 23 AQUATIC PLANT CONTROL ALTERNATIVES.......................................................... 26 Aquatic Herbicides. .............................................................................................................. 26 ManualMethods.................................................................................................................. 36 DiverDredging................................................................................................................. 39 BottomScreens.................................................................................................................... 41 BiologicalControl................................................................................................................ 43 GrassCarp ........ .................. .................................................................................................. 45 WatermilfoilWeevil............................................................................................................. 49 Rotovation, Harvesting, and Cutting................................................................................... 51 Drawdown............................................................................................................................ 52 NutrientReduction............................................................................................................... 52 NoAction Alternative..................................................................... ............................... 53 INTEGRATED TREATMENT PLAN................................................................................ 54 Eurasian watermilfoil (Myriophyllum spicatum)................................................................. 54 Fragrant waterlily (Nymphaea odorata)............................................................................... 56 Purple loosestrife (Lythrum salicaria)................................................................................. 57 Yellow flag iris (Iris pseudacorus)...................................................................................... 57 PLAN ELEMENTS, COSTS, AND FUNDING.................................................................. 58 IMPLEMENTATION AND EVALUATION...................................................................... 63 BIBLIOGRAPHY.................................................................................................................. 64 North Lake IAVMP 12/21/2004 iv LIST OF TABLES Table 1: Average Values for Select Trophic Parameters at North Lake .................................. 15 Table2: Wildlife List ...................................................... ...............----- .--...................... 17 Table 3: 1996 Aquatic Plant Survey........................................................................................ 22 Table 4: Budget with use of Triclopyr..................................................................................... 58 Table 5: Project budget with use of 2,4-D............................................................................... 59 Table 6: Total Matching Funds (triclopyr)............................................................. ......... 60 Table 7: Total Matching Funds (2,4-D)................................................................................... 61 Table 8: In -kind Matching Funds............................................................................................. 61 Table 9: Cash Matching Funds................................................................................................ 61 Table 10: KC Staff Salary and Burden Rates........................................................................... 62 Table 11: Federal Way Staff and Benefit Rates....................................................................... 62 LIST OF FIGURES Figure 1: North Lake Watershed and Tributary 0016.............................................................. 13 Figure 2: North Lake Land Use.........................................................................20 Figure 3: North Lake Aquatic Plant Map.............................................................22 North Lake IAVMP 12/21/2004 v EXECUTIVE SUMMARY Eurasian watermilfoil (Myriophyllum spicatum) is a submersed aquatic noxious weed that proliferates to form dense mats of vegetation in the littoral zone of lakes and reservoirs. It reproduces by fragmentation, and is often spread as fragments that "hitch -hike" on boat trailers from one lake to another. This noxious weed can degrade the ecological integrity of a water body in just a few growing seasons. Dense stands of milfoil crowd out native aquatic vegetation, which in turn alters predator -prey relationships among fish and other aquatic animals. M. spicatum can also reduce dissolved oxygen — first by inhibiting water mixing in areas where it grows, and then as oxygen is consumed by bacteria during decomposition of dead plant material. Decomposition of M. spicatum also adds nutrients to the water that could contribute to increased algal growth and related water quality problems. Further, dense mats of M. spicatum can increase the water temperature by absorbing sunlight, create mosquito breeding areas, and negatively affect recreational activities such as swimming, fishing, and boating. North Lake lies along the eastern border of Federal Way in the upper White River watershed in King County Washington. The 55-acre lake is moderately infested with M. spicatum. Members of the North Lake Improvement Club (NLIC) realized the seriousness of the aquatic weed problem and initiated a partnership with staff from the King County Department of Natural Resources and Parks, Weyerhaeuser, and the City of Federal Way to apply for an Aquatic Weeds Management Fund grant through the Washington Department of Ecology (Ecology). If awarded, grant money will fund initial eradication efforts, as well as several years of follow-up survey and control. Since complete eradication is very difficult to achieve, and re -introduction is very likely, the community is organizing a management structure and the funding mechanisms necessary to implement ongoing monitoring and spot control. Three other noxious weed species with expanding infestations at North Lake also threaten to degrade the ecological and recreational benefits of the system. Fragrant waterlily (Nymphaea odorata), purple loosestrife (Lythrum salicaria), and yellow flag iris (Iris pseudacorus) have expanded beyond a pioneering level of infestation and are well established around the shoreline and in the lake. This Integrated Aquatic Vegetation Management Plan (IAVMP) is a planning document developed to ensure that the applicant (King County) and the community have considered the best available information about the waterbody and the watershed prior to initiating control efforts. Members of the North Lake Improvement Club, King County staff, and Weyerhaeuser staff worked in partnership to develop this IAVMP for North Lake. To tackle the difficult task of generating community concern and action for an environmental issue, a core group of residents formed a steering committee, which included one King County staff member from the King County Lake Stewardship Program. Through their work, the Steering Committee was able to educate the wider community about the problem, inspire them to contribute feedback about potential treatment options, and explore ongoing community -based funding mechanisms. The community ultimately agreed upon an integrated treatment strategy, which includes an initial chemical treatment with a systemic aquatic herbicide, followed by a combination of manual, mechanical, and cultural control methods to maintain the outcome. This plan presents lake and watershed characteristics, details of the aquatic weed problems at North Lake, the process for gaining community involvement, discussion of control alternatives, and recommendations for initial and ongoing control of noxious aquatic weeds threatening North Lake. North Lake IAVMP 12/21/2004 .1e. &WAMMWAMLIki North Lake is located east of the city of Federal Way and Interstate 5, south of 320t' Street and north of Highway 18. The lake is located in the White River Watershed (WRIA 10), which encompasses parts of southern King County and extends into Pierce County. North Lake is located in a very urban area of King County along with neighboring lakes Lake Killarney, Lake Geneva, and Fivemile Lake. However, at this time Weyerhaeuser has no intention of developing the west side of the lake. The 52.3 acres of land owned and maintained by Weyerhaeuser will remain undeveloped. Only the eastern and southern shorelines of the lake are developed with single family residences. North Lake drains into the Commencement Bay through the Hylebos Creek. In the past Hylebos Creek has provided good habitat for Chinook salmon but the system has undergone extensive development over the years and salmon populations in the Hylebos Basin have been greatly reduced (Mobrand Biometrics, 2001). The estuarine area is still used by juvenile salmonid species including Chinook and coho. North Lake and neighboring Geneva, Killarney, and Fivemile Lakes all have public boat launches and are popular boating, fishing, and swimming destinations. Residents of the North Lake watershed are very proud of their setting, are active recreational users and are committed to social and environmental issues. Due to prolific growth of several species of dense, invasive aquatic noxious weeds, North Lake is in danger of losing its aesthetic beauty, its wildlife habitat, and its recreational attributes. If left untreated, the worst of these weeds, Eurasian water milfoil (Myriophyllum spicatum), will blanket the littoral zone of the lake in a short time, preventing most recreational uses and eliminating badly needed wildlife habitat. There will be long-term financial and recreational loss and the loss of conservation areas, all affecting watershed residents and other members of the public who use the lake. Increasing development in the area is likely to increase the number of people using the lake in coming years, which can accelerate the magnitude of the loss of beneficial uses to the community. The shallow shoreline area of the lake provides excellent habitat for aquatic plants. In the past few years aggressive, non-native Eurasian water milfoil (milfoil) has invaded the lake and is colonizing the near -shore aquatic habitat. The dense submersed growth of milfoil has begun to cause a significant deterioration in the quality of the lake and its value to the community. The boat launch area has dense patches of milfoil, which can spread to other lakes by fragments on boat trailers. Nearby lakes are threatened with new introductions of milfoil if North Lake is not controlled because of the high probability of transport by boat trailers to these nearby systems. Milfoil is the most significant submersed invasive threat but other noxious weeds have also invaded North Lake. These include fragrant waterlily (Nymphaea odorata), purple loosestrife (Lythrum salicaria), and yellow flag iris (Iris pseudacorus). All of these species are considered noxious weeds as listed in WAC 16-750. Waterlilies have been a real threat to the lake, covering up sections of the lake entirely. North Lake is shallow and waterlilies grow in the middle of the lake and close off sections of the lake from recreational activities. This has been a major issue with area residents as it has decreased their recreation because of safety issues. Waterlilies can also affect water quality by decreasing dissolved oxygen, out competing native plants, and adding excessive nutrients, to the lake when they die back in the fall. None of the native aquatic plants in the system are a management issue at this time. The native plants provide important benefits to the aquatic system and are not impeding any of the recreational uses of the lake. Removing the noxious invaders will halt the degradation of the system and allow the dynamic natural equilibrium to be maintained. North Lake IAVMP 12/21/2004 Unfortunately, these invasive plants concentrate in the near shore zone which is also that portion of the lake that is valued and utilized most by lake residents and visitors. Dense weed growth poses a threat to swimmers, and the portion of the lake where people can fish is shrinking. Both milfoil and fragrant waterlilies foul fishing gear, motors, and oars. It is no longer possible to troll through large portions of the lake. As a group these invasive plants: Pose a safety hazard to swimmers and boaters by entanglement • Snag fishing lines and hooks, eventually preventing shoreline fishing • Crowd out native plants, creating monocultures lacking in biodiversity • Significantly reduce fish and wildlife habitat, thereby weakening the local ecosystem as well as degrading wildlife and wildlife viewing opportunities Pose a threat to adjoining ecosystems North Lake IAVMP 12/21/2004 s The overarching management goal is to control noxious aquatic weeds in North Lake in a manner that allows sustainable native plant and animal communities to thrive, maintains acceptable water quality conditions, and facilitates recreational enjoyment of the lake. There are four main strategies to ensure success in meeting this goal: 1. Involve the community in each phase of the management process; 2. Use the best available science to identify and understand likely effects of management actions on aquatic and terrestrial ecosystems prior to implementation; 3. Review the effectiveness of management actions; 4. Adjust the management strategy as necessary to achieve the overall goal. Specific details related to the implementation of management objectives are covered in subsequent sections of this plan. North Lake IAVMP 12/21/2004 COMMUNITY INVOLVEMENT North Lake residents have been a very active community from the beginning and regularly demonstrate their commitment to improving their community and protecting the lake as well as the expansive natural areas owned by Weyerhaeuser around their homes. This section provides an overview of past, present, and future of community involvement. Community History From their earliest days, members of the North Lake community have worked together to promote common goals, including the health of the lake. The North Lake Improvement Club (NLIC) was formed in 1942 to work to maintain and improve North Lake and the region around the lake. The club has always been open to anyone living in the area. The NLIC purchased a piece of property and built a clubhouse in the early 1950's. The clubhouse has provided a convenient place for the community to get together for social gatherings and meetings to plan and execute projects to improve the North Lake neighborhood. The club membership has been active in monitoring the development of the properties around North Lake and to ensure that changes are made in a manner that is consistent with the neighborhood desires. There has been significant development in the watershed in the last five years and the community has been active in monitoring the development plans to assure the lake is protected. NLIC as an organization and members as individuals have commented at hearings on developments now underway in the watershed and hearings on developments that may have an impact on the quality of living in the North Lake area. One of the currently vested development with the greatest potential to impact the lake through stormwater runoff has been required to have the stormwater management plan reviewed by representatives of the NLIC before it is approved by the City of Federal Way. Being a participant in the King County's Volunteer Lake Monitoring Program through the Lake Stewardship Program is another way the community demonstrates its interest and commitment to lake health. Area residents have participated in the program on and off for the last 19 years. Most recently, community members became involved in the program in 2001. Initially only one community member participated in the program, but with the expansion of the program to include Level 1 and Level 2 sampling, several members joined in to share the monitoring duties. There are now six families sharing the monitoring duties, giving North Lake the distinction of having a monitoring program with the most active community participation. Lake Stewardship Program volunteers monitor lake level and precipitation daily, Secchi transparency, water temperature, algae and bird observations weekly, and collect water samples every other week from April through October. Water samples are analyzed for total phosphorus, total nitrogen, chlorophyll a and concentrations of phytoplankton species. Volunteer data are published each year in reports produced by the King County Lake Stewardship Program. To address the increasing populations of waterlilies in North Lake, lakefront property owners contracted for control of waterlilies in 1996. The control was done for one year. The contractor completed two applications on the lily pads on the residential side of the lake. This was done only in areas that fronted on property owners who agreed to pay the contractors. Qualitative evaluation of the application indicated that it was successful and reduced the expansion of coverage on the residential North Lake IAVMP 12/21/2004 side of the lake for a few years. However, since there was not a lake wide effort to control the lilies in following years, the infestation returned and became worse. The membership of today's NLIC reflects the strength of new perspectives and energies. As homes change hands and the last developable land disappear, families on the lake share a love of this unique ecosystem, and are committed to honor and perpetuate the legacy of good stewardship. Community Commitment The NLIC has held several informational meetings for its membership and others to learn about noxious and invasive plants identification and control. The Club has and continues to be active in public meetings where new developments plans are discussed and present comments to assure the lake water quality and area environment will continue to be healthy. Examples of issues discussed by the Community Club in recent years include: • The impact of letting purple loosestrife (Lythrum salicaria) continue to grow • How to eradicate purple loosestrife • Problems posed by fragrant waterlilies (Nymphaea odorata) • How to eradicate fragrant waterlilies The lakefront property owners have organized to obtain funding to begin a weed control program in 2004. A Small Change for a Big Difference grant was obtained from King County Department of Natural Resources and Parks (KCDNRP), which will be combined with funds from the Weyerhaeuser Company, and contributions and was used to begin waterlily control this year. The lakefront property owners intend to continue the effort to control the waterlilies and other noxious weeds in and around North Lake. The Steering Committee is spearheading this effort and is pursuing several options to eradicate noxious weeds and keep the lake free of noxious weeds in years to come. In the long run, success will require on ongoing funding mechanism for monitoring the success of control measures, surveying for noxious weed species each year, and responding to new infestations quickly to maintain a weed -free lake. The Steering Committee is exploring ways to provide maintenance funding in perpetuity. Community members are currently discussing several funding ideas; the best long -terra solution will inevitably utilize multiple mechanisms. 1. Voluntary contributions: Having enough lake front property owners commit to annual maintenance fee to maintain a fund for control of the weeds. The funding goals would be adjusted annually to meet the needs, with the largest amount needed to support the initial eradication program. Volunteer monies would be collected in several ways, including running fundraising activities as well as door to door campaigning. Although less consistent, this type of activity is expected to work because of the stability of the neighborhood. North Lake IAVMP 12/21/2004 2. Lake Management District (LMD): Forming an LMD would levy a "tax" on all lakefront property owners. The tax paid by each lakefront property owner would be determined by the size of the property. Funds collected would be used to address specific problems at the lake. In order to form an LMD, lakefront property owners need to vote to approve it, and the governing agency (King County or Federal Way) needs to adopt an ordinance recognizing the fee collection structure, problems to be addressed, and the methods by which problems will be addressed. 3. Volunteer maintenance: Train residents to perform the monitoring and removal efforts. There are certified divers on the lake. Funds would be collected by the Community Club to purchase necessary equipment and obtain training to conduct the milfoil removal operations by volunteers after the grant funds expire. Currently, lake residents perform invasive weed control efforts voluntarily on the emergent plants at North Lake. Steering Committee, Outreach, and Education Process Community participation has been an integral part of the development of the North Lake IAVMP. Community involvement educates community members about the potential problems posed by noxious aquatic weeds. Since watershed residents were given ample opportunity to comment throughout the process, there is greater community support for implementation efforts. Meeting agendas, attendance lists, and meeting notes are contained in Appendix A. The remainder of this section provides a chronological overview of the community involvement process from the first discussions through the completion of the IAVMP. Early Discussion: Explored potential for King County — North Lake partnership Initially, two board members of the North Lake Improvement Club and lakeside residents contacted King County Department of Natural Resources and Parks Lake Stewardship Program staff in winter of 2003. North Lake residents were interested in controlling noxious weeds and through the support of the community, the North Lake Steering Committee was formed. Five resident members now sit on the committee. The North Lake Steering Committee wanted to apply to the Washington State Department of Ecology (Ecology) Aquatic Weed Management Fund for money to help with North Lake weed control efforts in spring 2004. Given the amount of work required to develop an Integrated Aquatic Vegetation Management Plan, which is necessary for the grant application, North Lake Steering Committee and King County staff decided it would be better to develop a strategy and work toward to applying for the grant in fall of 2004. March 2004: First meeting with North Lake Steering Committee North Lake Steering Committee invited a King County Lake Stewardship Program representative and a Weyerhaeuser representative to a North Lake Steering Committee meeting on March 17, 2004. This initial Steering Committee meeting was for general information to determine what partners on the North Lake project were setting out to accomplish and how this could be done as a joint effort between North Lake residents, Weyerhaeuser, and King County. The Steering Committee and King County staff discussed the process by which the community could work with King County to submit a grant application from Ecology to control noxious aquatic weeds in North Lake. North Lake IAVMP 12/21/2004 April and May 2004: Project planning begins, Steering Committee meets, begins IAVMP Development A Steering Committee meeting was held on April 1, 2004 to discuss a King County Small Change grant application and initial notification to lakeside residents for an educational meeting to be held on April 5, 2004. The agenda and expectations were set for the meeting. The Steering Committee created and hand delivered all lakeside residents invitations to attend the education meeting. On April 5, 2004 thirty-two people attended the educational meeting. The primary purpose was to discuss the problem with Eurasian watermilfoil and other aquatic noxious weeds, management techniques and the IAVMP development process. The larger community's interest in furthering the process was also assessed, which was a resounding desire to pursue aquatic weed removal. Following the April 51' meeting, the Steering Committee members drafted and submitted the Small Change for a Big Difference Grant application to the King County Department of Natural Resources and Parks on April 17, 2004. This grant application helped support a joint waterlily treatment with Weyerhaeuser. In May of 2004 KC DNRP staff developed a draft of a project timeline, an education and outreach plan and began to research necessary components of the IAVMP. May 5, 2004 Beth Cullen from King County and North Lake Steering Committee members met to discuss the development of the IAVMP. The primary goal was to approve the project, address any concerns, and outline necessary tasks for the grant application process. A second IAVMP planning meeting was held at the end of May. Specific tasks were assigned to each Steering Committee member and timelines for the completion of draft assignments were set. At this meeting, members discussed the approval of the Small Change for a Big Difference grant and how to notify the lakeside residents for the beginning stages of the fragrant waterlily eradication. June 2004: Steering committee continues IAVMP work, hosts first watershed -wide meeting In the beginning of June, notification was distributed to all North Lake lakeside residents regarding the first chemical treatment for the waterlily control. The dates decided for treatment were June 170' and June W' pending weather conditions. The treatment did occur and approximately 10 acres of waterlilies were treated, three acres on .tune 17'h and 10 acres on the June I S'h. The treatment was successful and there was immediate damage to the lilies. Over the course of the month the lilies died back and areas of the lake were again open for recreation. The lily treatment had a draw -back because it opened up new ground for the milfoil to spread. With the cover of the lilies gone, sunlight was able to get to the bottom of lake, which encouraged more aggressive milfoil growth. On June 14a', 2004 the Steering Committee and Beth Cullen from King County met to discuss the progress and agenda for a watershed -wide meeting scheduled for June 28, 2004. At the June 28t' meeting the North Lake Steering Committee members presented the problems posed by the noxious aquatic weeds present in North Lake. Guests to this meeting included Beth Cullen from King County, Mark Braverman the Site Forestry Manager for Weyerhaeuser, Belinda Bowman, Whitworth Pest Solutions; and Dan Smith from the City of Federal Way. The objective of this meeting was to update the community on the waterlily eradication efforts and introduce the IAVMP. Before and after herbicide treatment photos were shown to the public. Beth Cullen provided a PowerPoint presentation giving a detailed description of the aquatic weeds in North Lake and the treatment methods selected by the North Lake Steering Committee. The meeting also provided open floor time for discussion and questions of all information presented. Members from neighboring Lake Geneva came to the watershed meeting to learn about the process to possibly emulate on their lake. North Lake IAVMP 12/21/2004 Public comment At the initial lakeside resident meeting, presenters encouraged attendees to ask questions and offer comments. The first lakeside residents meeting on April 5th, most comments supported acting as quickly as possible to control weeds in the lake. There were questions about the effectiveness of the various treatment options presented. Several comments expressed concern that the community members would need to "foot the bill" for control costs. Steering Committee members addressed concerns when possible and if answers were not readily apparent, offered to do more research and report back. At the June 28th watershed wide meeting, residents were still enthusiastic about the project and the results they were beginning to see from the initial treatment of Rodeo TM applied by Whitworth Pest Solutions. Many residents inquired when another later summer spray could occur and what the costs would be. The only concerns expressed by residents were the safety of the chemicals used to control invasive weeds for swimming, watering, and pets. Public consensus Members of the steering committee drafted a "Letter of Support" that members of the community could sign to demonstrate their support of the proposed milfoil control strategy while recognizing its potential cost. To date, there have been no objections to the proposed project or for the proposed methods of treatment. Every person who has learned about the project has voiced support. Given the community's small size, and their dedication and enthusiasm for keeping North Lake healthy, none of the steering committee members anticipate resistance to the proposed project prior to, during, or after implementation. The letter of support and copies of the signature sheets are in Appendix B. Continuing Community Education The North Lake Steering Committee will offer the means by which the community will organize ongoing education. In addition, the Steering Committee for the proposed aquatic weed removal project will remain intact, although membership on the steering committee is likely to change over time. To ensure that community efforts are consistent with best available science and water quality standards, the community club will designate a point of contact liaison within the KC DNRP. Information will be disseminated through community club meetings and watershed mailings when applicable. A liaison with school and youth organizations will also be designated. Additionally, the Steering Committee will work to recruit new lake monitors and surveyors. All of the documents and PowerPoint presentations generated by the Watershed -wide and Steering Committee meetings are available on request. Links are provided to the websites for the Washington State Department of Ecology, the King County Noxious Weed Control Program, and the King County Department of Natural Resources and Parks to learn more about aquatic noxious weeds and other natural resource management issues. North Lake IAVMP 12/21/2004 The public education program for North Lake will consist of two elements that will be implemented concurrently: 1. Noxious Aquatic Weeds Prevention and Detection Initial eradication and control efforts are only worth doing if future infestations are prevented, or detected and eliminated soon after detection. Since the re -introduction of milfoil and other weeds to North Lake is almost certain, a prevention and detection plan is essential. There are four main elements to the prevention and detection plan: a) Annual distribution of educational materials. Steering Committee members will compile published materials and generate literature specifically related to North Lake to distribute to all watershed residents each year at the beginning of the growing season. b) Annual aquatic plant identification workshops. Workshops each spring will cover native plants as well as noxious aquatic weeds. Samples of our target weeds will be collected and pressed in Year 1 as a permanent reference and education tool for the community. All watershed residents and lake -users will be invited and encouraged to attend. The lakefront residents at Lake Killarney, Lake Geneva and other nearby waterbodies might also be invited to expand the educational effort beyond North Lake. Aquatic plant experts could be invited from Ecology, the King County Noxious Weed Control Program, or other applicable agencies. A better -educated community of residents and lake -users will be more likely to identify and report noxious aquatic weeds and other potential problems. c) Two aquatic weed surveys each growing season. Volunteers (community members) will undergo training with lakes/aquatic plant specialists prior to conducting surveys. There are at least two certified divers living on the lake, both of whom have been active in developing the IAVMP and project proposal. Divers will be trained to survey the lake bottom to complement visual surveys from the surface and to take samples for identification. d) Boy Scout Troop 306 will be at the public boat launch on opening day of fishing to educate the public about the milfoil eradication efforts and what they can do as individuals to decrease the chances of reinfestation. They will also work on checking and cleaning boat trailers before they enter the water and after. 2. Lake Stewardship Education Program North Lake residents have a unique situation with having six families who rotate responsibility in the King County Lake Stewardship Program. While other lakes in King County may only have one or two volunteers for the lake stewardship program, North Lake has six families that volunteer. These families attend lake related workshops learning about nutrients in fertilizers, detergents, failing septic system, eroding soil, shoreline planting suggestions and resources, and how animal waste can cause algae and aquatic plants to grow and multiply. Another avenue to share information on appropriate shoreline plantings is our North Lake Garden Club. One of the goals of the steering committee is to develop a process to share this information with a broader audience of watershed residents. North Lake IAVMP 12/21/2.004 10 North Lake has a public boat launch on the northeast end of the lake. We understand that the Washington Department of Fish and Wildlife has begun a pilot project to address the concerns of lake -users spreading noxious weeds from lake to lake. An additional goal of the steering committee is to learn and understand how the finding from this pilot can be incorporated in the health of our lake. The North Lake community is an inclusive and involved community. We have many opportunities to share lake quality information with our watershed residents. These opportunities include monthly North Lake Improvement Club board meetings that are open to all members, the annual meeting of the NLIC, Fourth of July parade and community get-together, holiday boat parade, annual community garage sale and as needed NLIC cleanup. Each of these functions offers the steering committee the avenue to provide lake -related information to all watershed residents and lake -users.. Our overall goal is to develop a process to keep lake quality information current and available to all our watershed users. The Steering Committee has generated some ideas for signage related to the transport of milfoil by boats and trailers. If signs posted at the boat launch include step by step directions on how to properly clean boats and trailers, and why it is important, lake -users may be more apt to do the right thing. Obvious problems for boat cleaning involve questions of where it can be done and the right equipment to do the job. The boat launch at North Lake does not have any tools to perform this cleaning, which is similar to most other lakes in the area. Any adhering pollutants that are washed off by a diligent boat owner at the launch site will probably end up in the lake since there is no facility to collect the gray water. The Steering Committee has discussed the option of installing a Cleaning Station at the North Lake boat launch with a hose, handpump, and a catchment and drain to encourage the proper cleaning of boats and trailers. The handpump would hopefully discourage using the station for cleaning cars or other inappropriate uses. North Lake may pursue these issues with the Washington Department of Fish and Wildlife, which has just begun a pilot program to address these concerns. North Lake IAVMP 12/21/2004 11 D AND WATERBODY CHARACTERISTIC North Lake's watershed is located in south-western King County, Washington in an unincorporated area located right outside the Federal Way city limits. State resource agencies frequently use a system of Water Resource Inventory Areas (WRIA) to refer to the state's major watershed basins. North Lake is located in WRIA 10, which refers to the Puyallup — White River combination watershed and includes the Puyallup and White Rivers and the southern part of King County. The North Lake watershed constitutes approximately 425 acres (2.2%) of the Hylebos Creek Sub - basin of the White — Puyallup River watershed. The Hylebos Creek Sub -basin is 19221 acres and receives a mean annual rainfall of 40 inches. The sub -basin drains approximately 18 mile from the cities of Federal Way to Commencement Bay in Pierce County and it encompasses 35 miles of stream and 250 acres of wetlands (FOHC 2004). According to the Soil Survey for King County Area, Washington, the soils around North Lake watershed are primarily made up of the Alderwood series (U.S. Department of Agriculture, 1973). The primary soil types are the Alderwood gravelly sandy loam (AgQ and Alderwood gravelly sandy loam, 0 to 6 % slopes (AgB). The soil is comprised of moderately to well drained soils that have a weakly consolidated to strongly consolidated substratum at a depth of 24 to 40 inches. These soils are on uplands and formed under conifers, in glacial deposits. Permeability is moderately rapid in the surface layer and subsoil and very slow in the substratum. Roots penetrate easily to the consolidated substratum where they tend to mat on the surface. Water moves on top of the substratum in winter and the available water capacity is low. Runoff is slow to medium and the hazard of erosion is slight to moderate. There is one small section of Norma sandy loam (No) in the southern part of the lake and Orcas peat (Or) in the north. The Hylebos Creek Sub -basin tributaries drain approximately 18 mi2, including North Lake, Lake Killarney, and Lake Geneva. Commercial areas, single family and multifamily residences dominate the basin. North Lake is located in the upper part of the watershed by Federal Way, which is the most heavily urbanized area of the basin (King County 1991). There are now 54 lakeside homes, which indicates that single family high -density land use has continued to increase on the east side of the lake. Future land use plans include a single family, high density area stretching along the east side of the lake, east of 38'h Ave South. Although not directly on the shoreline the drainage from the new development will be going into North Lake as well as increase the number of people who will use the public boat launch. The west side of the lake is located within the city limits of Federal Way, however, the property is owned by Weyerhaeuser and is not open to development. The property is approximately 52.3 acres of second growth forest that lines the whole east side of North Lake to Weyerhaeuser Way South. North Lake IAVMP 12/21/2004 12 C3Watershed Boundary North Lake Major Roads North Lake Outlet i 1 Figure 1: North Lake Watershed and Tributary 0016 Tributary 0016 drains North Lake from its southern tip, and joins Tributary 0006, which drains Lake Killarney, a half mile south of Tributary 0016. Tributary 0016 enters Hylebos Creek, which continues southwest and enters Pierce County where it flows directly into Commencement Bay. There is a significant amount of shoreline that remains relatively undeveloped at North Lake, thanks to Weyerhaeuser preserving their land and not allowing for development on the west side of the lake. This undoubtedly limits the nonpoint source nutrients reaching the lake. This entire sub -basin benefits from the moderating effects of its many wetlands and lakes, which act as detention ponds to reduce runoff "pulses." However, as the number of nearshore houses has increased around North Lake, so has the clearing of buffering native vegetation along the shoreline to provide landscaping or to enhance lake access and views. Nonetheless, many of the residential properties have maintained a buffer strip, which helps to filter out nutrients and pollutants before they enter the lake, as well as providing habitat. The public boat launch area is the only point where a road actually reaches the water. 330 and 33rd Ave. South provide access to all of the homes on the fake and is set several hundred feet away from the water on the other side of the homes. The runoff from the road filters through the lakeside properties. Waterbody Characteristics North Lake is a 55-acre lake with a mean depth of 14 feet and a maximum depth of 34 feet, with an estimated lake volume of 770 acre-ft and 8930 ft. (1.69 mi.)-of shoreline. There are no major surface inflows to North Lake, with outflow into an unnamed tributary into the outlet channel with a weir. There is public boat access to the lake provided by a boat launch owned by the Washington Department of Fish & Wildlife (WDFW) located on the northwest side of the lake. North Lake IAVMP 12/21/2004 13 The sediments in North Lake are mainly loose and unconsolidated, with high silt. Some areas are flocculent, especially up at the north end. The majority of the residential parcels also have loose sediment away from the shoreline; some residents in the past have added gravel to shallow areas. Water Quality Since 1985, King County residents have participated in a volunteer monitoring program to create a long-term record of water quality for the region's small lakes. Volunteers from North Lake have contributed samples in the early 1980's, the mid 1990's, and then 2001 through 2004. (King County, 2001). Prior to this time, the former Municipality of Metropolitan Seattle (METRO) performed annual lake monitoring in the time periods 1979, 1980 and 1983. Lakes can be classified by measurements of potential and actual biological activity, also known as "trophic state." Lakes with high concentration of nutrients and algae, generally accompanied by low water transparencies, are termed eutrophic or highly productive. Lakes with low concentrations of nutrients and algae, most often accompanied by high transparencies, are categorized as oligotrophic or low in productivity. Lakes intermediate between eutrophic and oligotrophic are termed mesotrophic. A commonly used index of water quality for lakes is the Trophic State Index (TSI) originally developed by Robert Carlson (1977), which separates lakes into the three categories by scoring water clarity, and concentrations of both phosphorus and chlorophyll a, relating them to a scale based on phytoplankton biovolume. Lakes can be naturally eutrophic, mesotrophic, or oligotrophic based on the inherent character and stability of the surrounding watershed. Eutrophication or the increase in a lake's biological activity over time is a process that occurs naturally in some lakes and may be accelerated in other by human activities (King County 2003). North Lakes productivity is mesotrophic (moderate), characterized by moderate water clarity and chlorophyll a values, and low to moderate phosphorous levels. Data from the 16-year record from 1985 to 2000 are summarized in Table 1, taken from King County Lake Water Quality: A Trend Reoort on King County Small Lakes [November 20011 Summary of water quality characteristics • water clarity (Secchi depth) ranged from 2.1 — 4.1 meters (May -October average) • total phosphorous ranged from 9 —16 µg/L (May -October average) • Chlorophyll a ranged from 2.2 — 4.2 µg/L (May -October average), but most years were below 4.0 • TSI Secchi ranged from 40 — 50 • TSI Chlorophyll a ranged from 38 — 45 • TSI TP ranged from 36 — 44 ■ TSI annual average 38 — 46 North Lake IAVMP 12/21/2004 14 Table 1: Average Values for Select Trophic Parameters at North Lake Year No. of Samples Secchi (meter) Chl a* (µg/L) TP* (µg/L) TSI* Secchi TSI* Chl a TSI* TP TSI* Average 1985 8 4.1 2.2 9 40 38 36 38 1986 8 3.9 3.9 15 40 441 43 43 1987 8 3.2 3.2 13 43 421 42 42 1988 8 3.3 2.7 16 43 401 44 42 1989 9 2.71 2.3 13 45 391 41 42 1990 --- --- --- --- --- --- --- --- 1991 --- --- --- --- --- --- --- --- 1992 --- --- --- --- --- --- --- --- 1993 --- --- --- --- --- --- --- --- 1994 --- --- I --- --- --- --- --- --- 1995 11 3.81 3.3 15 41 42 43 42 1996 9 2.51 2.6 15 47 40 43 43 1997 9 2.11 4.2 16 50 45 44 46 1998 12 2.8 2.4 13 45 39 41 42 1999 --- --- --- --- --- --- --- -__ 2000 --- --- --- --- --- I --- --- --- *Chl a --chlorophyll a, TPrtotal phosphorus, and TSI=Trophic State Index While nine years of data could be used to analyze trends employing the non -parametric Mann- Kendall's test for trend, the existing pattern of missing data points made trend analysis inaccurate. Therefore, trend analyses were not completed for North Lake (King County, 2001). Fish and Wildlife Communities North Lake and its surrounding habitats support a variety of fish, birds, and animals by providing nesting, forage, and cover. According to Chad Jackson at the Washington State Department of Fish and Wildlife (WDFW), the lake is stocked on a yearly basis with rainbow trout. Other warm water fish are present in the lake and most likely are the following species: perch, large mouth bass, pumpkinseed, bullheads, sculpins, and suckers. Parts of the Hylebos Creek offer spawning and rearing habitat for salmonid species. Salmonids are unable to get up to North Lake because of full fish blockages along Hylebos Creek. Wendy Honey, a North Lake resident, spoke with the Department of Fish and Wildlife on August 4, 2004. It was mentioned that several times since 1950 North Lake was "rehabilitated" with Rotenone; it was put in the lake in 1950, 1954, 1963, 1968, 1972, and 1979. Rotenone is a piscicide that is used to remove undesirable fish from lakes and streams. It was likely used to manage North Lake to maintain populations of fish species popular for sport fishermen. Copies of the application records are in Appendix D of this document. North Lake IAVMP 12/21/2004 15 The mixed forest and wetland plant communities around the lake provide non -breeding habitat for a few Puget Sound lowland amphibian species, such as the Pacific chorus frog (Psudacris regilla). The non-native bullfrog (Rana catesbeiana) is also quite common the North Lake, and they can have a negative impact on our native amphibians through direct predations (Richter & Azous, 2001 a). Mammals expected to make use of the lake and adjacent forested areas include: opossum (didelphus marsupialis), bats such as the little brown bat (myotis lucifugus), Douglas squirrel (tamias doglasii), muskrat (ondatra zibethica), and raccoon (procyn lotor). River otter (Lutra canadensis) are considered a rare treat to observe. Beaver (Castor canadensis) and coyote (canis latrans) are potential visitors to the lake. Julie Cleary, a resident on North Lake, provided a bird list collected by her neighbor Beverly Rosenow. North Lake IAVMP 12/21/2004 16 Table 2: Wildlife List Checklist of Birds Probable on North Lake In order by FAMILY Observed and Probable Birds in Bold Other Possible Birds in Italics LOON ❑ Common Loon SS GREBES ❑ Pied -billed Grebe ❑ Horned Grebe ❑ Western Grebe SC CORMORANT ❑ Double -crested Cormorant WADERS ❑ Great Blue Heron KCS ❑ Green Heron WATERFOWL ❑ Trumpeter Swan ❑ Greater White - fronted Goose ❑ Snow Goose ❑ Canada Goose ❑ Wood Duck ❑ Green -winged Teal ❑ Mallard ❑ Northern Pintail ❑ Blue -winged Teal ❑ Cinnamon Teal ❑ Northern Shoveler ❑ Eurasian Wigeon ❑ American Wigeon ❑ Canvasback ❑ Redhead ❑ Ring-necked Duck ❑ Greater Scaup ❑ Lesser Scaup North Lake IAVMP ❑ Common . Goldeneye ❑ Barrow's Goldeneye ❑ Bufflehead ❑ Hooded Merganser ❑ Common Merganser ❑ Red -breasted Merganser ❑ Ruddy Duck RAPTORS ❑ Osprey KCS ❑ Bald Eagle ST, FT RAILS ❑ Virginia Rail ❑ Sora ❑ American Coot SHOREBIRDS ❑ Killdeer ❑ Spotted Sandpiper ❑ Common Snipe ❑ Long -billed Dowitcher* GULLS ❑ Mew Gull ❑ Ring -billed Gull ❑ Glaucous - winged Gull SWIFTS ❑ Black Swift ❑ Vaux's Swift SC KINGFISHER ❑ Belted Kingfisher SWALLOWS ❑ Purple Martin Sc ❑ Tree Swallow ❑ Violet -green Swallow ❑ Northern Rough -winged ❑ Cliff Swallow ❑ Barn Swallow WRENS ❑ Marsh Wren WARBLERS ❑ Common Yellowthroat BLACKBIRDS ❑ Red -winged Blackbird NOTES SC = state candidate SS = state sensitive ST = state threatened FT = federally threatened KCS = King County Comprehensive Plan Shall be Protected Reported 12/21 /2004 17 Beneficial and Recreational Uses North Lake and its surroundings support a variety of uses to humans. Recreational activities include swimming, fishing, boating (no combustion motors), bird watching, and wildlife viewing. Residents access the lake for these activities from any of the small private docks around the lake associated with the residential parcels. A public boat launch maintained by Washington Department of Fish & Wildlife allows everybody to benefit from this beautiful resource as well. Internal combustion engines are not allowed on the lake (KCC 12.44.330), consequently there are no activities such as water skiing or jet skiing. One consequence of this ban is that the natural character and integrity of the system have been preserved. Also, the system is spared potential pollution from petroleum releases and noise pollution. There is also no hunting allowed on North Lake. —i r 7 rr Property Owners State of Wasmrig ton Weyerhaeuser Residental Figure 2: North Lake Land Use North Lake IAVMP 12/21/2004 18 Characterization of Aquatic Plants in North Lake The most recent comprehensive aquatic plant survey of North Lake occurred on July 26, 1995 as part of a plant -mapping project on 36 lakes carried out by King County's Lake Stewardship Program (King County, 1996). The surveys were conducted by boat using a two -person crew plus a volunteer (or volunteers) when available. Surveyors used GPS to establish shoreline sections between two fixed points. Each shoreline section was characterized by community type, species present, percent cover of community type, and relative species density within a community type. Community types were defined as emergent, floating, or submergent North Lake IAVMP 12/21/2004 19 North Aquatic Plants Map Floating Emergent 5uhmergenr No p6nts or SpvrSe Na Plants -deep '� loasesrriFe �• 5h"line Section brmdary Sod= 2 5udon 7 y lake Ama. 57.4 acres Mean Depth: 74 Feet Maximum Depth: 34 feet section 7 0 100 200 400 #act S4piam6r 1996 Ap—r Plant MapohT f-n,ro,—,—g County Lak- Rage 71 Figure 3: Aquatic Plant Map North Lake IAVMP 12/21/2004 20 Nineteen plant species were identified at North Lake, including eight emergent types, three floating types, and eight submergent types. Emergents are plants that are rooted in the sediment at the water's edge but have stems and leaves which grow above the water surface. Floating rooted plants are rooted in the sediment and send leaves to the water's surface. Submergent plants are either freely -floating or are rooted in the lake bottom but grow within the water column. The floating plant coverage totaled 14.4 acres, while the submergent community comprised 20.7 acres. Purple loosestrife (Lythrum salicaria) could be found along the entire shoreline. In 2002, two consulting firms AquaTechnex and Envirovision Corporation produced a Regional Eurasian Milfoil Control Plan for King County in 2002. At this time, North Lake was not documented to have Eurasian water milfoil. On May 4, 2004, King County Lake Stewardship staff and a member of the King County Noxious Weed Group conducted a preliminary snorkel survey, characterizing the milfoil infestation of the lake. The survey was conducted with one person in the boat taking notes and two snorkelers surveying the entire littoral zone. The catalyst for this survey was complaints from the North Lake community that non-native waterlilies and Eurasian watermilfoil were increasing in density. On the survey several fragments of milfoil were found in the lake and a few scattered rooted milfoil plants. The majority of the infestation was found at the boat launch on the north end of the lake. Waterlilies were documented in covering the majority of the littoral zone and spreading into the middle of the lake. Lythrum salicaria is now common in buffer shoreline vegetation; populations and distribution of L. salicaria have been partially contained by community efforts to stop seed production through manual control efforts. The plant has obviously continued to increase over the years despite these recent control efforts. The Washington Natural Heritage Program (WNHP) performed a search of their Natural Heritage Information System database for rare plant species, select rare animal species, and high quality wetland and terrestrial ecosystems in the vicinity of North Lake (http://www.wa.mov/dnr/htdocs/fr/nh/wanh .html . This search did not find any endangered, threatened, or sensitive plant species recorded for North Lake, nor did it find the presence of any animal species tracked by their system. North Lake IAVMP 12/21/2004 21 L k CL k k E ) c F- � E z E E U 2 k � § a ! § e�#aci /®$+�$cw3 2 � §§ / ; w w R N N LO�� !- C q n C _ C4 CJ� ; w w¥ w¥ o 0 g m- q n n 0 _0 -a w�(D ¥ 3 a o w 3woJa�w o(�� 3®¥� i.4 +Lo+ao�+-af w+�& �C0- � � � n CN 04 = o e c W__(n m c c e � e e e e e © � � � w e e e e e E E E E E@@ E E ©u E 3 / I I= g g E� g g 3 3 3 3 � n @U)U) @@ U) D \ �: g22Jf = em(na)E e � _ _ _o @& S #oa Eg 2# �-le ±$> L �M��-- /�ƒ /f � /f t��/IZ / _ » R ) o= LL % m -� mC2w�-1-1Z kƒƒa_$$Ef f § ' $ f m n $ A§/ 2\ E a a 2 f - (D g k m k: ' CL 0 2 i E xƒ$ o m w m 7 5 Mf c CL - c_ W—=M- CLco o . t G R E= m 7=� - =�2% $ f; cu- 5 .Eƒ e o 8 2 E$ f: 2± k& 2 t° 2� § 2f2 \2 2EEE2 ' \ m E— u z m$ n m � I Q \ e Noxious Aquatic Weeds in North Lake The term "noxious weed" refers to those non-native plants that are legally defined by Washington's Noxious Weed Control Law (RCW 17.10) as highly destructive, competitive, or difficult to control once established. Noxious weeds have usually been.introduced accidentally as a contaminant, or as ornamentals. Non-native plants often do not have natural predators (i.e. herbivores, pathogens) or strong competitors to control their numbers as they may have had in their home range. WAC 16.750 sets out three classes (A, B, C) of noxious weeds based on their distribution in the state, each class having different control requirements. County Weed Boards are given some discretion as to setting control priorities for Class B and C weeds. Table 2 shows the 19 species found in the 1995 plant survey, including three listed noxious weed species: Purple loosestrife (Lythrum saiicaria), fragrant waterlily (Nymphaea odorata), and yellow flag iris (Iris pseudacorw). In 1995 Eurasian watermilfoil was not detected in the lake. However, in the winter of 2004 North Lake residents discovered milfoil and upon surveying King County confirmed milfoil has been introduced into the lake. Purple loosestrife, fragrant waterlily, yellow flag iris and Eurasian water milfoil will be the focus of the plant management efforts on North Lake. Purple loosestrife and milfoil are Class B Noxious weeds; Class B are required by law to be controlled and contained. Fragrant waterlily and yellow flag iris are Class C Noxious Weeds; Class C weeds are generally not required by law to be controlled and contained, but counties may designate a Class C weed for control in their county or in certain areas of their county. Neither yellow flag iris nor fragrant waterlily are required to be controlled in King County. Eurasian watermilfoil (Myriophyllum spicatum) Eurasian watermilfoil is native to Europe, Asia, and North Africa and also occurs in Greenland (Washington State Noxious Weed Control Board, 1995). The oldest record of Eurasian watermilfoil in Washington is from a 1965 herbarium specimen collected from Lake Meridian, King County. It was first identified causing problems in the 1970s in Lake Washington and proceeded to move down the I-5 corridor, probably transported to new lakes on boats and trailers. Eurasian watermilfoil is among the worst aquatic pests in North America. M. spicatum is a submersed, perennial aquatic plant with feather -like leaves. It usually has 12 to 16 leaflets (usually more than 14) on each leaf arranged in whorls of 4 around the stem. Leaves near the surface may be reddish or brown. Sometimes there are emergent flower stalks during the summers that have tiny emergent leaves. In western Washington, Eurasian watermilfoil frequently over -winters in an evergreen form and may maintain considerable winter biomass (K. Hamel, pers. comm.). This plant forms dense mats of vegetation just below the water's surface. In the late summer and fall, the plants break into fragments with attached roots that float with the currents, infesting new areas. Disturbed plants will also fragment at other times of the year. A new plant can start from a tiny piece of a milfoil plant. M. spicatum was not previously thought to reproduce from seed in this region. However, aquatic plant experts are beginning to think that milfoil seeds might be playing a bigger role in repopulating lakes than was previously hoped (K. Hamel, pers. comm.). This is especially true if the lake dewaters. Milfoil starts spring growth earlier than native aquatic plants, and thereby gets a "head start" on other plants. Eurasian watermilfoil can degrade the ecological integrity of water body in just a few growing seasons. Dense stands of milfoil crowd out native aquatic vegetation, which in turn alters predator -prey relationships among fish and other aquatic animals. Eurasian watermilfoil can also reduce dissolved North Lake IAVMP 12/21/2004 23 oxygen — first by inhibiting water mixing in areas where it grows, and then as oxygen is consumed by bacteria during decomposition of dead plant material. Decomposition of M. spicatum also releases phosphorus and nitrogen to the water that could increase algal growth. Further, dense mats of Eurasian watermilfoil can increase water temperature by absorbing sunlight, raise the pH, and create stagnant water mosquito breeding areas. Eurasian watermilfoil will negatively affect recreational activities such as swimming, fishing, and boating. The dense beds of vegetation make swimming dangerous, snag fish hooks on every cast, and inhibit boating by entangling propellers or paddles and slowing the movement of boats across the water. At North Lake, M. spicatum is moderate to light in density. The infestation is still patchy with only a few high -density milfoil stands. As of 2004, most of the patches are still moderate to low density, and therefore are not yet causing enormous impacts. It is likely that the milfoil infestation will continue to expand if left untreated, dramatically increasing negative impacts to the beneficial uses of North Lake. Purple loosestrife (Lythrum salicaria) Purple loosestrife is native to Europe and Asia and was introduced through ship ballast water to the Atlantic Coast in the mid- 1800s (Washington State Noxious Weed Control Board, 1997). In Washington, purple loosestrife was first collected from the Seattle area in 1929 from Lake Washington. Purple loosestrife is a perennial that can reach 9 feet tall with long spikes of magenta flowers. The flowers usually have 6 petals, and the stems are squared -off. Purple loosestrife is considered a facultative wetland (+) species (FACW+), with a 67-99% probability of occurring in wetlands as opposed to upland areas (Reed, 1988). Vigorous plants can produce over 2 million tiny, lightweight seeds (120,000 per spike) that are easily spread by waterfowl and other animals (Washington State Noxious Weed Control Board, 1997). Although a prolific seeder, purple loosestrife can also spread through vegetative production by shoots and rhizomes as well as by root fragmentation. It has a woody taproot with a fibrous root system that forms a dense mat, keeping other plants from establishing in a space. Purple loosestrife has colonized the shoreline of North Lake. This plant disrupts wetland ecosystems by displacing native or beneficial plants and animals. Waterfowl, fur -bearing animals, and birds vacate wetland habitat when native vegetation is displaced by purple loosestrife. Loss of native vegetation results in decreased sources of food, nesting material, and shelter. Economic impacts are high in agricultural communities when irrigation systems are clogged or when wet pastures are unavailable for grazing. Purple loosestrife is aggressive and competitive, taking full advantage of disturbance to natural wetland vegetation caused by anthropogenic alterations of the landscape. Seed banks build for years since seeds may remain viable for up to 3 years. Monospecific stands are long- lived in North America as compared to European stands, illustrating the competitive edge loosestrife has over other plant species. The Purple loosestrife on North Lake will need a combined approach to achieve adequate control. In August 2002, approximately 200-300 beetles (Galerucella calmariensis) were released at the North Lake boat launch and in July 2003, approximately 400-500 beetles were released at the boat launch. No beetles have been released in 2004. It typically takes about five years to see any control from the beetles, so the lack of visible beetle damage at this point is not unexpected (M. Walker, pers. comm.). However, the beetles will not be sufficient in and of themselves. A portion of the lake is often shaded and the beetles need sun to thrive. An integrated approach to controlling the purple loosestrife on North Lake would be the most beneficial. North Lake IAVMP 12/21/2004 24 Fragrant waterlily (Nymphaea odorata) This species is native to the eastern half of North America (Washington State Noxious Weed Control Board, 2001b). It was probably introduced into Washington during the Alaska Pacific Yukon Exposition in Seattle in the late 1800's. It has often been introduced to ponds and lakes because of its beautiful, large white or pink (occasionally light yellow), many -petaled flowers that float on the water's surface, surrounded by large, round green leaves. The leaves are attached to flexible underwater stalks rising from thick fleshy rhizomes. Adventitious roots attach the horizontal creeping and branching rhizomes. This aquatic perennial herb spreads aggressively, rooting in murky or silty sediments in water up to 7 feet deep. It prefers quiet waters such as ponds, lake margins and slow streams and will grow in a wide range of pH. Shallow lakes are particularly vulnerable to being totally covered by fragrant waterlilies. Waterlily spreads by seeds and by rhizome fragments. A planted rhizome will cover about a 15-foot diameter circle in five years (Washington State Noxious Weed Control Board, 2001b). Fragrant waterlily (Nymphaea odorata) is quickly expanding its distribution on North Lake (W. Honey, pers. comm.). When uncontrolled, this species tends to form dense monospecific stands that can persist until senescence in the fall. Mats of these floating leaves prevent wind mixing and extensive areas of low oxygen can develop under the waterlily beds in the summer. Waterlilies can restrict lakefront access and hinder swimming, boating, and other recreational activity. They may also limit our native waterlily (Nuphar luteum) with which it overlaps in distribution. The fragrant waterlily is still expanding in patches on North Lake, and so its future impacts are not clear. Some patches have connected, limiting recreational activities such as boating, fishing, and swimming. Even canoes can have great difficulty moving across dense floating mats of fragrant waterlily, not to mention entanglement with propellers of boat motors. Yellow flag iris (iris pseudacorus) Yellow flag iris is native to mainland Europe, the British Isles, and the Mediterranean region of North Africa (Washington State Noxious Weed Control Board, 2001a). This plant was introduced widely as a garden ornamental. It has also been used for erosion control. The earliest collection in Washington is from Lake McMurray in Skagit County in 1948 (Washington State Noxious Weed Control Board, 2001a). The yellow flowers are a distinguishing characteristic, but when not flowering it may be confused with cattail (Typha sp.) or broad -fruited bur -reed (Sparganium eurycarpum). Yellow flag iris is considered an obligate wetland species (OBL), with a >99% probability of occurring in wetlands as opposed to upland areas (Reed, 1988). The plants produce large fruit capsules and corky seeds in the late summer. Yellow flag iris spreads by rhizomes and seeds. Up to several hundred flowering plants may be connected rhizomatously. Rhizome fragments can form new plants. Yellow flag iris can spread by rhizome growth to form dense stands that can exclude even the toughest of our native wetland species, such as cattail (Typha latifolia). This noxious weed has already colonized the shoreline of North Lake. In addition to threatening to lower plant diversity, this noxious weed can also alter hydrologic dynamics through sediment accretion along the shoreline. This species produces prolific seed that could easily be transported downstream to invade this valuable resource area. North Lake IAVMP 12/21/2004 25 AQUATIC PLANT CONTROL ALTERNATIVES This section outlines common methods used to control aquatic weeds. Much of the information in this section is quoted directly from the Ecology's website: http://www.eU.NN-aZov/ ro ramslw / lants/mans ement/index.htm] Additional information is derived from the field experience of the King County Noxious Weed Control Program, in particular from Drew Kerr, Aquatic Noxious Weed Specialist and WSDA licensed aquatic herbicide applicator. Recommendations found in the 2001 draft version of the "King County Regional Milfoil Plan" have also been taken into consideration. Control/eradication methods discussed herein include Aquatic Herbicide, Manual Methods, Bottom Screens, Diver Dredging, Biological Control, Rotovation, Cutting, Harvesting, and Drawdown. Aquatic Herbicides Description of Method http://,�vww.er.v.wa.Rov/programs/wa/nlants/mana2ement/anuaO28.him [ Aquatic herbicides are chemicals specifically formulated for use in water to eradicate or control aquatic plants. Herbicides approved for aquatic use by the United States Environmental Protection Agency (EPA) have been reviewed and considered compatible with the aquatic environment when used according to label directions. However, individual states may also impose additional constraints on their use. Aquatic herbicides are sprayed directly onto floating or emergent aquatic plants, or are applied to the water in either a liquid or pellet form. Systemic herbicides are capable of killing the entire plant by translocating from foliage or stems and killing the root. Contact herbicides cause the parts of the plant in contact with the herbicide to die back, leaving the roots alive and capable of re -growth (chemical mowing). Non -selective herbicides will generally affect all plants that they come in contact with, both monocots and dicots. Selective herbicides will affect only some plants (usually dicots — broad leafed plants like Eurasian watermilfoil will be affected by selective herbicides whereas monocots like Brazilian elodea and our native pondweeds may not be affected). Because of environmental risks from improper application, aquatic herbicide use in Washington State waters is regulated and has certain restrictions. The Washington State Department of Agriculture must license aquatic applicators. In addition, because of a March 2001 court decision (Ninth Circuit Court of Appeals), coverage under a discharge permit called a National Pollutant Discharge Elimination System (NPDES) permit must be obtained before aquatic herbicides can be applied to some waters of the U.S. This ruling, referred to as the Talent Irrigation District decision, has further defined Section 402 of the Clean Water Act. Ecology has developed a general NPDES permit which is available for coverage under the Washington Department of Agriculture for the management of noxious weeds growing in an aquatic situation and a separate general permit for nuisance aquatic weeds (native plants) and algae control. For nuisance weeds (native species also referred to as beneficial vegetation) and algae, applicators and the local sponsor of the project must obtain a North Lake IAVMP 12/21/2004 26 NPDES permit from the Washington Department of Ecology before applying herbicides to Washington water bodies. Although there are a number of EPA registered aquatic herbicides, the Department of Ecology currently issues permits for seven aquatic herbicides (as of 2004 treatment season). Several other herbicides are undergoing review and it is likely that other chemicals may be approved for use in Washington in the future. As an example, Renovate® (Triclopyr) has been approved by the U.S. EPA for aquatic use in November 2002, making it the first aquatic herbicide to receive registration since 1988. Renovate® was designed to be effective on both emergent and submersed plants. The chemicals that are currently permitted for use in 2004 are: Aquatic Herbicides (see Appendix for herbicide labels) Glyphosate - (Trade names for aquatic products with glyphosate as the active ingredient include Rodeo', AquaMaster�, and AquaPro). This systemic broad-spectrum herbicide is used to control floating -leaved plants like waterlilies and shoreline plants like purple loosestrife. It is generally applied as a liquid to the leaves. Glyphosate does not work on underwater plants such as Eurasian watermilfoil or hydrilla. Although glyphosate is a broad spectrum, non -selective herbicide, a good applicator can somewhat selectively remove targeted plants by focusing the spray only on the plants to be removed. Plants can take several weeks to die and a repeat application is often necessary to remove plants that were missed during the first application. ■ Fluridone — (Trade names for fluridone products include: Sonar® and Avast!. Fluridone is a slow -acting systemic herbicide used to control Eurasian watermilfoil, hydrilla and other underwater plants. It may be applied as a pellet or as a liquid. Fluridone can show good control of submersed plants where there is little water movement and an extended time for the treatment. Its use is most applicable to whole -lake or isolated bay treatments where dilution can be minimized. It is not considered effective for spot treatments of areas less than five acres. It is slow acting and may take six to twelve weeks before the dying plants fall to the sediment and decompose. When used to manage Eurasian watermilfoil in Washington, fluridone is applied several times during the spring/summer to maintain a low, but consistent concentration in the water. Although fluridone is considered to be a broad-spectrum herbicide, when used at very low concentrations, it can be used to selectively remove Eurasian watermilfoil. Some native aquatic plants, especially pondweeds, are minimally affected by low concentrations of fluridone. • 2,4-D — There are two formulations of 2,4-D approved for aquatic use. The granular formulation contains the low -volatile butoxy-ethyl-ester (BEE) formulation of 2,4-D (Trade names include: AquaKleeno and Navigate. The liquid formulation contains the dimethylamine salt (DMA)of 2,4-D (Trade name - DMA*4IVM). 2,4-D is a relatively fast -acting, systemic, selective herbicide used for the control of Eurasian watermilfoil and other broad-leaved species. Both the granular and liquid formulations can be effective for spot treatment of Eurasian watermilfoil. 2,4-D has been shown to be selective to Eurasian watermilfoil when used at the labeled rate, leaving native aquatic species relatively unaffected. However, 2,4-D is not effective against hydrilla. • Endothall - Dipotassium Salt — (Trade name Aquatho! Endothall is a fast -acting non- selective contact herbicide, which destroys the vegetative part of the plant but generally does not kill the roots. Endothall may be applied in a granular or liquid form. Typically endothall compounds are used primarily for short-term (one season) control of a variety of aquatic plants, North Lake IAVMP 12/21/2004 27 including hydrilla. However, there has been some recent research that indicates that when used in low concentrations, endothall can be used to selectively remove exotic weeds; leaving some native species unaffected. Because it is fast acting, endothall can be used to treat smaller areas effectively. Endothall is not effective in controlling American waterweed (Elodea canadensis) or Brazilian elodea (Egeria densa). Diquat — (Trade name Reward. Diquat is a fast -acting non -selective contact herbicide that destroys the vegetative part of the plant but does not kill the roots. It is applied as a liquid. Typically diquat is used primarily for short-term (one season) control of a variety of submersed aquatic plants. It is very fast acting and is suitable for spot treatment. However, turbid water or dense algal blooms can interfere with its effectiveness. Diquat was allowed for use in Washington in 2003 and Ecology will be collecting information about its efficacy against Brazilian elodea in 2003. It is effective in controlling hydrilla. ■ Triclopyr - (Trade name Renovate3®). There are two formulations of triclopyr. It is the triethylamine salt (TEA) formation of triclopyr that is registered for use in aquatic or riparian environments. Triclopyr, applied as a liquid, is a relatively fast -acting, systemic, selective herbicide used for the control of Eurasian watermilfoil and other broad-leaved species such as purple loosestrife. Triclopyr can be effective for spot treatment of Eurasian watermilfoil and is . relatively selective to Eurasian watermilfoil when used at the labeled rate. Many native aquatic species are unaffected by triclopyr. Triclopyr is very useful for purple loosestrife control since native grasses and sedges are unaffected by this herbicide. When applied directly to water, Ecology has imposed a 12-hour swimming restriction to minimize eye irritation. Triclopyr received its aquatic registration from EPA in 2003 and was allowed for use in Washington in 2004. Imazapyr - (Trade name Habitat. This systemic broad spectrum herbicide, applied as a liquid, is used to control emergent plants like spartina, reed canarygrass, and phragmites and floating - leaved plants like waterlilies. Imazapyr does not work on underwater plants such as Eurasian watermilfoil. Although imazapyr is a broad spectrum, non -selective herbicide, a good applicator can somewhat selectively remove targeted plants by focusing the spray only on the plants to be removed. Imazapyr was allowed for use in Washington in 2004. Advantages ■ Aquatic herbicide application can be less expensive than other aquatic plant control methods. Aquatic herbicides are easily applied around docks and underwater obstructions. • 2,4-D DMA, 2,4-D BEE, and Triclopyr TEA have been shown to be effective in controlling smaller infestations (not lake -wide) of Eurasian watermilfoil in Washington, and could also be used on the purple loosestrife and yellow flag iris. ■ Washington has had some success in eradicating Eurasian watermilfoil from some smaller lakes (320 acres or less) using Sonar'. ■ Glyphosate is the recommended chemical for fragrant waterlily control. North Lake IAVMP 12/21/2004 28 Disadvantages • Some herbicides have swimming, drinking, fishing, irrigation, and water use restrictions. • Herbicide use may have unwanted impacts to people who use the water and to the environment. • Non -targeted plants as well as nuisance plants may be controlled or killed by some herbicides. • Depending on the herbicide used, it may take several days to weeks or several treatments during a growing season before the herbicide controls or kills treated plants. • Rapid -acting herbicides like Aquathol® may cause low oxygen conditions to develop as plants decompose. Low oxygen can cause fish kills. • To be most effective, generally herbicides must be applied to rapidly growing plants. • Some expertise in using herbicides is necessary in order to be successful and to avoid unwanted impacts. • Many people have strong feelings against using chemicals in water. • Some cities or counties may have policies forbidding or discouraging the use of aquatic herbicides. Permits A NPDES permit is needed. Both the noxious and nuisance NPDES permits require the development of Integrated Aquatic Vegetation Management Plans (IAVMP) by the third year of chemical control work. The requirement of monitoring of herbicide levels started in 2003, whether the chemical has been applied directly to the water or along the shoreline where it may have gotten into the adjacent surface water. For noxious weed control, the applicator must apply to the Washington Department of Agriculture (Agriculture) for coverage under their NPDES permit each treatment season. There is no permit or application fee to obtain NPDES coverage under Agriculture's permit for Noxious Weeds. Since North Lake is in unincorporated King County, the King County Department of Development and Environmental Services (DDES) will require a permit for application of herbicide in Sensitive Areas to submergent, floating and emergent aquatic plants. This falls under their Clearing and Grading Permit. A Shoreline Exemption Permit will also be required by DDES. Costs Approximate costs for one -acre herbicide treatment (costs will vary from site to site): ■ Glyphosate: $250 ■ Fluridone: $900 to $1,000 • Endothall: $650 North Lake IAVMP 12/21/2004 29 • 2,4-D: $600 • Diquat: $300 to $400 • Triclopyr: $1,000 Other Considerations The focus of the discussion below are the active ingredients 2,4-D, Triclopyr and Glyphosate since the Steering Committee, with input from the watershed -wide public meetings, have chosen these chemicals as the best options for the start of the Integrated Treatment Strategy for North Lake. Since fluridone (Sonar®) would have required a whole lake treatment and is very expensive per unit, it was not chosen as a viable option and is not discussed in further detail. Although not the preferred method of control, 2,4-D has been an effective tool in the past in Washington lakes and will be looked at as an alternative in North Lakes integrated approach. EPA studies yield the parameters LD50 (acute lethal dose to 50% of a test population), NOEL (No Observable Effect Level, which is the highest test dosage causing no adverse responses), and Rf ) (EPA Reference Dose determined by applying at least a 100-fold uncertainty factor to the NOEL). The EPA defines the Rff) as the level that a human could be exposed to daily with reasonable certainty of no adverse effect from any cause, in other words, a "safe" dose. Exposures to bystanders or consumers are deemed safe when the RfD is not exceeded (Felsot, 1998). Since all substances, natural or manmade, may prove toxic at a sufficiently high dose, one should remember the old adage "dose makes the poison." The LD50 value is useful for comparing one compound with another and for grouping compounds into general hazard classes. According to Felsot (1998), any pesticide, such as triclopyr, glyphosate or 2,4-D that does not produce adverse effects on aquatic organisms until levels in water reach milligram per liter (i.e., mg/L, equivalent to a part per million, ppm) would be considered of comparatively low hazard. Substances that are biologically active in water at levels one -thousand -fold less, (i.e., µg/L, parts per billion, ppb), are considered highly hazardous to aquatic life. Most pesticides falling in the latter category are insecticides rather than herbicides. Also, compounds that have half-lives less than 100 days are considered non -persistent compared to compounds having half-lives approaching one year or longer (for example, DDT). The half-life of triclopyr in water ranges from one day to seven days, while 2,4-D is about 7 days in water and glyphosate is about 12 days in water. Since there are multiple factors that modulate the pesticides' hazard, just focusing on the half-life itself can be misleading for hazard assessment. It is now known that the longer a residue remains in soil/sediment, the less likely it will be taken up by plants, leach, or runoff (Felsot, 1998). This phenomenon is called residue aging and involves changes in the forces governing interactions of the chemical with the soil matrix over time. Triclopyr There are minimal restrictions for aquatic triclopyr applications. Washington State Department of Ecology has issued a 12-hour restriction on swimming to minimize the potential for eye irritation. There is a 120-day restriction on using water treated with triclopyr for irrigation on sensitive plants such as grapes and tomatoes. The alternative to waiting for 120 days is treated water can be used once it is determined that the water has reached a non -detectable level by laboratory analysis. There is no restriction for using treated water on established grasses. North Lake IAVMP 12/21/2004 30 Animal health Sensitive and environmentally relevant species such as the various salmon species have demonstrated LC50s that range between 96 and 182 ppm acid equivalent (a.e.). These toxicity values place triclopyr TEA in the US EPA's ecotoxicological categories of slightly toxic (LC50 =>10 to 100 ppm) to practically non -toxic (LC50 = > I00ppm). There have been no verified cases of toxicity to fish when triclopyr is used at the maximum use rate of 2.5 ppm a.e. In the field where triclopyr TEA was used to control Eurasian watermilfoil, waterhyacinth, or purple loosestrife, no invertebrate mortality or changes in invertebrate population structure was seen that could be attributed to the uses of triclopyr TEA. Triclopyr acid is slightly toxic to birds when orally dosed or consumed in the diet. The triethylamine salt is slightly toxic to practically non -toxic when orally dosed or consumed in the diet. Reproduction of birds may be affected at levels greater than 100 ppm (Washington Department of Ecology, 2004). Triclopyr TEA appears to be safe for use in aquatic ecosystems. When expected environmental concentrations (EEC) of triclopyr are compared with laboratory LC50s, the highest concentration that may be encountered immediately after application (2.5 ppm a.e. for control of submerged weeds or 4.4 ppm a.e. for control of floating and emerged weeds in shallow water) may affect more sensitive species. However, fish and non -mollusk species would not be harmed by these concentrations. The most sensitive fish species is rainbow trout with a 96-hour LC50 of 82 ppm a.e. and the most sensitive non -mollusk invertebrate is the red swamp crayfish with a 96-hour LC50 of>103 ppm a.e. Exposure to terrestrial wildlife occurs through two common routes, drinking water treated with triclopyr and eating aquatic plants, fish, or other aquatic organisms from the treatment site. Based on acute and chronic studies, triclopyr and its products used as aquatic herbicides do not pose a significant acute or chronic risk to terrestrial mammals (WDOE, 2004). Human health The Reference Dose (Rf )), the amount of triclopyr residuals that could be consumed daily over a lifetime without adverse effects, was established at 0.05g mg/kg/day, based on the two generation reproduction toxicity study in rats with a no observed effect level (NOEL) of 5.0 mg/kg/day, the lowest dose tested. Concentrations of triclopyr in sites with short half-lives will typically fall below the temporary drinking water tolerance within one to three days of application (WDOE, 2004). The only health concerns for swimming are minor eye irritation and exposure to children immediately after application. Due to dilution, the chances of overexposure are limited; a mandatory waiting time after application before swimming is allowed. Exposure and risk calculations were determined for hypothetical situations involving ingestion and dermal contact with treated water while swimming and drinking potable water. Calculation of the exposures utilized the swimmer's weight, the skin surface area available for exposure, the amount of time spent in the treated water containing 2.5 and 0.5 ppm triclopyr, amount of water swallowed while swimming over specific time periods, and the estimated human skin permeability coefficient. Risk analyses were completed for various populations. The most sensitive population was found to be children who swim for three hours and ingest water while swimming. A child would have to ingest 3.5 gallons of lake water where triclopyr had been recently applied to cause risk factors to be exceeded. Based on specifications on the label and the results of triclopyr toxicity studies, the aggregate or combined daily exposure to the chemical does not pose an adverse health concern. The Washington Department of Health (WDOH) has recommended a 12-hour restriction for reentry into treated water to assure that eye irritation North Lake IAVMP 12/21/2004 31 potential and any other adverse effects will not occur. WDOH also recommends that those wanting to avoid all exposures can wait one to two weeks following application when the triclopyr residues have dissipated from the water and sediments (WDOE 2004). 2,4-D As far as restrictions for aquatic 2,4-D applications, there is no fishing restriction, and three to five days after treatment the water is generally below the drinking water standard (70ppb, irrigation standard is 100ppb for broad -leafed plants). Although 2,4-D should not damage grass or other monocots, it is not recommended that one use treated water to water lawns during this first three to five days since over -spray will kill ornamentals or plants such as tomatoes and grapes that are very sensitive to 2,4-D. There is no swimming restriction for 2,4-D use. Ecology advises that swimmers wait for 24 hours after application before swimming in the treatment area, but that is an advisory only. The choice is up to the individual. Human and aeneral mammalian health The oral LD50 for 2,4-D (acid) is 764 mg/kg and the dermal LD50 is >2000 mg/kg. This chemical has a low acute toxicity (from an LD50 standpoint, is less toxic than caffeine and slightly more toxic than aspirin). The RfD for 2,4-D (acid) is 0.01 mg/kg/d. Recent, state-of-the-art EPA studies continue to find that it is not considered a carcinogen or mutagen, nor does it cause birth defects. It has a relatively short persistence in water, since it tends to bind to organic matter in the sediments. The herbicide 2,4-D generally does not bioaccumulate to a great extent, and the small amounts which do accumulate are rapidly eliminated once exposure ceases (Washington State Department of Ecology, 2001b). The risks to human health from exposure to aquatic 2,4-D applications were evaluated in terms of the most likely forms of contact between humans and the water to which the herbicide was applied. Ecology's Risk Assessment results indicate that 2,4-D should present little or no risk to the public from acute (one time) exposures via dermal contact with the sediment, dermal contact with water (swimming), or ingestion of fish (Washington'State Department of Ecology, 2001b). Based on the low dermal absorption of the chemical, the dose of 2,4-D received from skin contact with treated water is not considered significant. Dose levels used in studies are often far beyond what an animal or human would experience as a result of an aquatic application. Many experiments have examined the potential for contact by the herbicide applicator, although these concentrations have little relevance to environmental exposure by those not directly involved with the herbicide application. Once the herbicide has entered the water, its concentration will quickly decline because of turbulence associated mixing and dilution, volatilization, and degradation by sunlight and secondarily by microorganisms (Felsot, 1998). Results of chronic exposure assessments indicate that human health should not be adversely impacted by chronic 2,4-D exposure via ingestion of fish, ingestion of surface water while swimming, incidental ingestion of sediments, dermal contact with sediments, or dermal contact with water (Washington State Department of Ecology, 2001b). Pharmacokinetic investigations have demonstrated that 2,4-D is rapidly absorbed from the gastrointestinal tract and is quickly excreted. Animal toxicological investigations carried out at high doses showed a reduction in the ability of the kidneys to excrete the chemical, and resulted in some systemic toxicity. However, the high doses tested may not be relevant to the typical low dose human exposures resulting from labeled use. A review of the scientific and medical literature failed to provide any human case reports of systemic North Lake IAVMP 12/21/2004 32 toxicity or poisoning following overexposure to these herbicide products when used according to label instructions (Washington State Department of Ecology, 2001b). The risks to mammalian pets and wildlife should be closely related to these reported human risks, especially since many of the toxicity experiments are carried out on test animals by necessity. The potential hazard to pregnant women and to the reproductive health of both men and women was evaluated. The results of the 2,4-D developmental or teratology (birth defects) and multigenerational reproduction studies indicate that the chemical is not considered to be a reproductive hazard or cause birth defects (teratogen) when administered below maternally toxic doses (Washington State Department of Ecology, 2001b). A review of the histopathological sections of various 2,4-D subchronic and chronic studies provides further support that the chemical does not affect the reproductive organs, except in some higher dose groups beyond the potential level of incidental exposure after an aquatic weed application. Fish health Based on laboratory data reported in the Department of Ecology's Risk Assessment of 2,4-D, 2,4-D DMA has a low acute toxicity to fish (LC50 >_100 to 524 mg a.i./L for the rainbow trout and bluegill sunfish respectively). No Federally sensitive, threatened or endangered species were tested with 2,4- D DMA. However, it is likely that endangered salmonids would not exhibit higher toxic effects to 2,4-D DMA than those seen in rainbow trout. Since the maximum use rate of 2,4-D DMA would be no higher than the maximum labeled use rate (4.8 mg a.i./L) even the most sensitive fish species within the biota should not suffer adverse impacts from the effects of 2,4-D DMA. In conclusion, 2,4- D DMA will not effect fish or free-swimming invertebrate biota acutely or chronically when applied at typical use rates of 1.36 to 4.8 mg a.i./L (Washington State Dept. of Ecology, 2001b). However, more sensitive species of benthic invertebrates like glass shrimp may be affected by 2,4-D DMA, but 80 and 90% of the benthic species should be safe when exposed to 2,4-D DMA acutely or chronically at rates recommended on the label. Field work indicates that 2,4-D has no significant adverse impacts on fish, free-swimming invertebrates and benthic invertebrates, but well designed field studies are in short supply. According to the Department of Ecology's Risk Assessment of 2,4-D, in the United States, 2,4-D BEE is the most common herbicide used to control aquatic weeds. 2,4-D BEE, has a high laboratory acute toxicity to fish (LC50 = 0.3 to 5.6 mg a.i./L for rainbow trout fry and fathead minnow fingerlings, respectively). Formal risk assessment indicates that short-term exposure to 2,4-D BEE should cause adverse impact to fish since the risk quotient is above the acute level of concern of 0.01 (RQ = 0.1 ppm/0.3 ppm = 0.33). However, the low solubility of 2,4-D BEE and its rapid hydrolysis to 2,4-D acid means fish are more likely to be exposed to the much less toxic 2,4-D acid. 2,4-D acid has a toxicity similar to 2,4-D DMA to fish (LC50 = 20 mg to 358 mg a.i./L for the common carp and rainbow trout, respectively). In contrast, formal risk assessment with 2,4-D acid indicates that short- term exposure to 2,4-D BEE should not cause adverse impact to fish since the risk quotient is below the federal level of concern of 0.01 (RQ = 0.1 ppm/20 ppm = 0.005). To conclude, 2,4-D BEE will have no significant impact on the animal biota acutely or chronically when using applied rates recommended on the label (Washington State Dept. of Ecology, 2001b). Although laboratory data indicates that 2,4-D BEE may be toxic to fish, free-swimming invertebrates and benthic invertebrates, data indicates that its toxic potential is not realized under typical concentrations and conditions found in the field. This lack of field toxicity is likely due to the low solubility of 2,4-D BEE and its rapid hydrolysis to the practically non -toxic 2,4-D acid within a few hours to a day following the application. North Lake IAVMP 12/21/2004 33 Glyphosate Examination of mammalian toxicity has shown that the acute oral and dermal toxicity of glyphosate would fall into EPA's toxicity category III. This category characterizes slightly to moderately toxic compounds. Glyphosate is practically nontoxic by ingestion, with a reported acute oral LD50 of 5600 mg/kg in tested rats. The risks of incidental contact from swimming in treated water have also been judged as low with a dermal LD50 of 7940 mg/kg, a very high threshold. The RfD for glyphosate is 0.1 mg/kg/d. To place the level of hazard to humans in perspective, the commonly consumed chemicals caffeine (present in coffee, tea, and certain soft drinks), aspirin (acetylsalicylic acid), and nicotine (the neuroactive ingredient in tobacco) have acute oral LD50's of 192, 1683, and 53 mg/kg, respectively. Thus, the herbicides for the most part are comparatively less toxic than chemicals to which consumers voluntarily expose themselves (Felsot, 1998). Since the shikimic acid pathway does not exist in animals, the acute toxicity of glyphosate is very low. Animal studies, which the Environmental Protection Agency has evaluated in support of the registration of glyphosate, can be used to make inferences relative to human health. The U.S. Forest Service's glyphosate fact sheet reports that the EPA has concluded that glyphosate should be classified as a compound with evidence of non -carcinogenicity for humans (Information Ventures, Inc.). This conclusion is based on the lack of convincing carcinogenicity evidence in adequate studies in two animal species. Laboratory studies on glyphosate using pregnant rats (dose levels up to 3500 mg/kg per day) and rabbits (dose levels up to 350 mg/kg per day), indicated no evidence of teratology (birth defects). A three -generation reproduction study in rats did not show any adverse effects on fertility or reproduction at doses up to 30 mg/kg per day. Glyphosate was negative in all tests for mutagenicity (the ability to cause genetic damage). Technically, glyphosate acid is practically nontoxic to fish and may be slightly toxic to aquatic invertebrates (EXTOXNET, 1996). Some formulations may be more toxic to fish and aquatic species due to differences in toxicity between the salts and the parent acid, or to surfactants used in the formulation. There is a very low potential for the compound to build up in the tissues of aquatic invertebrates or other aquatic organisms. In water, glyphosate is strongly adsorbed to suspended organic and mineral matter and is broken down primarily by microorganisms. In relation to shoreline applications, glyphosate is moderately persistent in soil, with an estimated average half-life of 47 days. It is strongly adsorbed to most soils, even those with lower organic and clay content. Thus, even though it is highly soluble in water, field and laboratory studies show it does not leach appreciably, and has low potential for runoff (except as adsorbed to colloidal matter). One estimate indicated that less than 2% of the applied chemical is lost to runoff (Malik et. al., 1989). Microbes are primarily responsible for the breakdown of the product, and volatilization or photodegradation losses will be negligible. The manufacturer of Rodeo®, one of the aquatic formulations of glyphosate, recommends use of a nonionic surfactant with all applications to improve efficacy. Of the approved surfactants for aquatic use in Washington, only LI-700 (Loveland Industries, Inc.) may be used for fragrant waterlily control and will therefore be applied. directly to the water. Based on the results of searches of the published literature and the Toxic Substances Control Act Test Submission (TSCATS) database, little data are available regarding the toxicity of the surfactant formulations (Diamond & Durkin, 1997). The oral LD50 was >5000 and 5900 mg/kg in male and female rats, respectively, and the dermal LD50 for a 24- hour exposure was >5000 mg/kg in rabbits. These values are in the same range as glyphosate alone, EPA's toxicity category I1I, which puts LI-700 in a category of lower risk to mammals. North Lake IAVMP 12/21/2004 34 Suitability for North Lake Aquatic herbicides can provide an effective method for control and eventual eradication of noxious weeds. The use of a formulation of triclopyr or 2,4-D should provide excellent in control of the Eurasian watermilfoil while allowing for the more -appropriate spot treatments in this scattered infestation. We should be able to avoid an expensive, lake -wide treatment with fluridone for control of Eurasian watermilfoil. The loose sediments in North Lake are high in organic content and are flocculent around much of the lake's littoral zone. Triclopyr TEA and 2,4-D DMA would be applied in liquid formulation would be applied in a liquid formulation. The 2,4-D DMA also carries with it the reduced acute toxicity reported above, which could mitigate any potential harm to fish and their food web. Work in 2003 with 2,4-D DMA in Spring Lake resulted in excellent control of milfoil with no observed regrowth (M. Murphy, pers. comm.). North Lake does not have anadromous salmonids because impassable fish barriers exist along the Hylebos Creek system. Neither herbicide (Triclopyr or 2,4-D DMA) should have any downstream effects since the rapid hydrolysis produces a chemical that is practically non -toxic. Glyphosate should be very effective on the other target species: purple loosestrife, fragrant waterlily, and yellow flag iris. Westerdahl and Getsinger (1988) report excellent control of the fragrant waterlily with glyphosate. Generally glyphosate is the recommended herbicide for waterlily control because it can be applied directly to the floating leaves, unlike fluridone or endothall which must be applied to the water. The application of glyphosate allows specific plants or areas of plants to be targeted for removal. Generally two applications of glyphosate are needed. The second application later in the summer controls the plants that were missed during the first herbicide application. The control effectiveness of fragrant waterlily is easy to measure through visual surveys due to the floating leaves. Glyphosate should provide excellent systemic control of mature purple loosestrife plants and seedlings. This herbicide is very effective on purple loosestrife and we can expect better than 70-80% control on existing plants after Year 1. Seeds of purple Ioosestrife can remain viable for three years in the laboratory, but may remain viable for a much shorter time in the natural environment (Washington State Noxious Weed Control Board, 1997). Therefore, the existing mature plants and seedbank may be exhausted within the time frame of the project. Finally, Glyphosate should also provide excellent systemic control of yellow flag iris. This species has an abundant leaf surface area to absorb the chemical for translocation to the rhizome. The use of a herbicide will enable the elimination of the mature plants without potentially destructive disturbance of the shoreline by excavation. Both triclopyr and 2,4-D used for milfoil control, may also be an effective alternative for the purple loosestrife and yellow flag iris control efforts. However, this chemical is more expensive, so an evaluation of the effectiveness of glyphosate on these species will determine whether a change in herbicide would be beneficial. One of the main reasons to eradicate milfoil and fragrant waterlily is to maintain the health of the native aquatic plant community for all of the species that utilize them in their life cycles, as well as to maintain the viability of the lake for human recreational uses. The nature of the control methods to be implemented will minimize impacts to native aquatic vegetation. The control of the Eurasian watermilfoil and fragrant waterlily will be conducted by methods designed to preserve (and eventually enhance or conserve) the native plant communities. Herbicide selective to Eurasian watermilfoil will be used for its control and will not require a whole -lake treatment that would expose North Lake IAVMP 12/21/2004 3b all the submersed plants to the herbicide. The herbicide for the fragrant waterlily will be applied to the floating leaves, and therefore should be easily focused to kill only the target vegetation. Follow- up control methods (diver hand pulling and/or diver dredging) will focus specifically on these two target species and should also leave beneficial plants intact. With these constraints in place, conservation areas should not need to be established to serve vital ecosystem functions until native plants re-establish. The application of herbicide to the emergent species (purple loosestrife and yellow flag iris) will also be conducted by manual spot applications. An experienced herbicide applicator can selectively target individual weed species and limit collateral damage to other species to a minimum. This is especially true when infestations are small so that large areas with a diverse plant distribution don't have to be treated. Emergent noxious weed infestations at North Lake are wide spread in the lake but careful application of herbicide to the waterlilies should avoid collateral damage and preserve the native plant community. We do not anticipate any need to revegetate after controlling the milfoil and fragrant waterlily since less than 25% of the lake is currently colonized with aquatic plants. In the terrestrial environment in the Pacific Northwest, bare ground will often be colonized rapidly by invasive species, but this is not usually a problem in lacustrine areas. A drawback of using herbicides is the "uplifting" of mats of decomposing waterlily roots that can form large floating islands in the waterbody after the herbicides have killed the plants. The waterlilies are in large monospecific stands around the lake. These areas could potentially generate floating sediment mats because of their size. Volunteers from the community will remove any sediment mats created in these areas, for which we will need to get Hydraulic Project Approval from WDFW. For smaller mats, we may tow them to shore and remove the sediment with hand tools. If larger mats occur, we will have to investigate machinery mounted on a barge to dig or dredge out the sediment mat. Past community efforts at North Lake have used aquatic herbicides, so we do not anticipate disagreement with this recommendation from the community. Initial support has been documented in the form of signatures on a Letter of Support distributed after the second watershed -wide meeting on June 28h, 2004. Prior to any activities on the lake, outreach materials will be sent to all watershed residents informing them of the actions and appropriate contact information will be provided for any questions or comments. The watershed residents will be notified prior to any treatments with the anticipated treatment dates Some residences on North Lake have water rights. To ensure that all residents who might draw water from the lake are aware of water use restrictions, there will be announcements sent to all lakeside residents prior to each herbicide treatment. One announcement will be sent at the beginning of the summer with approximate dates of planned treatments, and subsequent announcements will be sent 7- 10 days prior to each treatment, with exact dates of treatment and use restrictions. The announcement must let water right holders know who to contact should this interfere with their rights. The lake group may have to provide alternate water sources to these people should they object to the treatment Manual Methods Hand -Pulling Hand -pulling aquatic plants is similar to pulling weeds out of a garden. It involves removing entire plants (leaves, stems, and roots) from the area of concern and disposing of them in an area away from the shoreline. In water less than three feet deep no specialized equipment is required, although a North Lake IAVMP 12/21/2004 36 i spade, trowel, or long knife may be needed if the sediment is packed or heavy. In deeper water, hand pulling is best accomplished by divers with SCUBA equipment and mesh bags for the collection of plant fragments. Some sites may not be suitable for hand pulling such as areas where deep flocculent sediments may cause a person hand pulling to sink deeply into the sediment. Cutting Cutting differs from hand pulling in that plants are cut and the roots are not removed. Cutting is performed by standing on a dock or on shore and throwing a cutting tool out into the water. A non - mechanical aquatic weed cutter is commercially available. Two single -sided, razor sharp stainless steel blades forming a "V" shape are connected to a handle, which is tied to a long rope. The cutter can be thrown about 20 — 30 feet into the water. As the cutter is pulled through the water, it cuts a 48- inch wide swath. Cut plants rise to the surface where they can be removed. Washington State requires that cut plants be removed from the water. The stainless steel blades that form the V are extremely sharp and great care must be taken with this implement. It should be stored in a secure area where children do not have access. Raking A sturdy rake makes a useful tool for removing aquatic plants. Attaching a rope to the rake allows removal of a greater area of weeds. Raking literally tears plants from the sediment, breaking some plants off and removing some roots as well. Specially designed aquatic plant rakes are available. Rakes can be equipped with floats to allow easier plant and fragment collection. The operator should pull towards the shore because a substantial amount of plant material can be collected in a short distance. Cleanup All of the manual control methods create plant fragments. It's important to remove all fragments from the water to prevent them from re -rooting or drifting onshore. Plants and fragments can be composted or added directly to a garden. Advantages • Manual methods are easy to use around docks and swimming areas. • The equipment is inexpensive. • Hand -pulling allows the flexibility to remove undesirable aquatic plants while leaving desirable plants. • These methods are environmentally safe. • Manual methods don't require expensive permits, and can be performed on aquatic noxious weeds with Hydraulic Project Approval obtained by reading and following the pamphlet Aquatic Plants and Fish (publication #APF-1-98) available from the Washington Department of Fish & Wildlife North Lake IAVMP 12/21/2004 37 Disadvantages • As plants re -grow or fragments re -colonize the cleared area, the treatment may need to be repeated several times each summer. ► Because these methods are labor intensive, they may not be practical for large areas or for thick weed beds. Even with the best containment efforts, it is difficult to collect all plant fragments, leading to re - colonization. • Some plants, like waterlilies, which have massive rhizomes, are difficult to remove by hand pulling. • Pulling weeds and raking stirs up the sediment and makes it difficult to see remaining plants. Sediment re -suspension can also increase nutrient levels in lake water. • Hand pulling and raking impacts bottom -dwelling animals. • The V-shaped cutting tool is extremely sharp and can be dangerous to use. Permits Permits are required for many types of manual projects in lakes and streams. The Washington State Department of Fish and Wildlife requires a Hydraulic Project Approval permit for all activities taking place in the water including hand pulling, raking, and cutting of aquatic plants. Costs • Hand -pulling costs up to $130 for the average waterfront lot for a hired commercial puller. • A commercial grade weed cutter costs about $130 with accessories. A commercial rake costs about $95 to $125. A homemade weed rake costs about $85 (asphalt rake is about $75 and the rope costs 35-75 cents per foot). Other Considerations The community may need to invest money into buying the equipment and operation. Manual methods must include regular scheduled surveys to determine the extent of the remaining weeds and/or the appearance of new plants after eradication has been attained. This is a large time investment by lakeside residents. Suitability for North Lake Manual methods will be important in assisting in milfoil eradication, after the chemical control methods have been evaluated for their effectiveness. At this point, diver hand -pulling should be sufficient to remove all of the remaining Eurasian watermilfoil plants. Manual methods will also be vital in combating new infestations of Eurasian watermilfoil in subsequent years, especially around the boat launch. Based on the ways in which milfoil propagates, most manual methods are not North Lake IAVMP 12/21/2004 38 r ti appropriate for milfoil eradication. Several of the methods create plant fragments, which can spread the milfoil throughout the lake. Manual methods have the potential for missing Eurasian watermilfoil plants, especially after stirring up sediments. Cutting can be used to control small areas of fragrant waterlily, especially those close to the shoreline. Using this method out in the open water would require a stable boat (not canoe) and great care not to injure oneself or another passenger. Since repeated cutting over several seasons may be required to starve the roots, this would fit best as a supplement to other control methods. Many landowners have already been manually removing their loosestrife for several seasons. This does not kill the mature perennial plants, but does halt seed production and can contain the infestation at current levels. If done repeatedly over several seasons it should starve the roots and kill the plants. Manual removal of seedlings (pulling) of purple loosestrife is much easier than the removal of well - rooted, mature plants. This technique can be used to exhaust the seed bank and supplement other eradication efforts. Manual efforts are much more difficult on yellow flag iris since the plants don't emerge from simple stems that can be cut, and they arise from massive rhizomes inhibiting pulling or digging. There is a large amount of root mass associated with the iris in this area that would take a significant effort to remove by excavation. Diver Dredginci Diver dredging (suction dredging) is a method whereby SCUBA divers use hoses attached to small dredges (often dredges used by miners for mining gold from streams) to suck plant material from the sediment. The purpose of diver dredging is to remove all parts of the plant including the roots. A good operator can accurately remove target plants, like Eurasian watermilfoil, while leaving native species untouched. The suction hose pumps the plant material and the sediments to the surface where they are deposited into a screened basket. The water and sediment are returned back to the water column (if the permit allows this), and the plant material is retained. The turbid water is generally discharged to an area curtained off from the rest of the lake by a silt curtain. The plants are disposed of on shore. Removal rates vary from approximately 0.25 acres per day to one acre per day depending on plant density, sediment type, size of team, and diver efficiency. Diver dredging is more effective - in areas where softer sediment allows easy removal of the entire plants, although water turbidity is increased with softer sediments. Harder sediment may require the use of a knife or tool to help loosen sediment from around the roots. In very hard sediments, milfoil plants tend to break off leaving the roots behind and defeating the purpose of diver dredging. Diver dredging has been used in British Columbia, Washington, and Idaho to remove early infestations of Eurasian watermilfoil. In a large-scale operation in western Washington, two years of diver dredging reduced the population of milfoil by 80 percent (Silver Lake, Everett). Diver dredging is less effective on plants where seeds, turions, or tubers remain in the sediments to sprout the next growing season. For that reason, Eurasian watermilfoil is generally the target plant for removal during diver dredging operations. North Lake IAVMP 12/21/2004 39 Advantages • Diver dredging can be a very selective technique for removing pioneer colonies of Eurasian watermilfoil. • Divers can remove plants around docks and in other difficult to reach areas. Diver dredging can be used in situations where herbicide use is not an option for aquatic plant management. Disadvantages • Diver dredging is very expensive. • Dredging stirs up large amounts of sediment. This may lead to the release of nutrients or long - buried toxic materials into the water column. • Only the tops of plants growing in rocky or hard sediments may be removed, leaving a viable root crown behind to initiate growth. • In some states, acquisition of permits can take years. Permits Permits are required for many types of projects in lakes and streams. Diver dredging requires Hydraulic Approval from the Department of Fish and Wildlife. Check with your city or county for any local requirements before proceeding with a diver -dredging project. Also diver dredging may require a Section 404 permit from the U.S. Army Corps of Engineers. Costs Depending on the density of the plants, specific equipment used, number of divers and disposal requirements, costs can range from a minimum of $1,500 to $2,000 per day. Other Considerations Could be good spot control method in subsequent years (coordinated with diver survey). Suitability for North Lake Diver dredging removes the plant in its entirety. It removes the biomass above the sediment as well as the tubers in the sediment. This option is best used for pioneering infestation and in soft sediments. Diver dredging could be used after the initial herbicide applications to remove plants that were missed or unaffected by the herbicide. The soft organic sediments in North Lake should make this method effective. However, permit costs may warrant having this work done as diver hand pulling since the roots should be largely removed from the loose sediments without the need for dredging. Diver dredging greatly disturbs sediments and can affect nutrient concentrations and algal production in the lake (see Disadvantages above). If other techniques of for removal are suitable, this should not be considered. North Lake IAVMP 12/21/2004 40 Bottom Screens A bottom screen or benthic barrier covers the sediment like a blanket, compressing aquatic plants while reducing or blocking light. Materials such as burlap, plastics, perforated black Mylar, and woven synthetics can all be used as bottom screens. Some people report success using pond liner materials. There is also a commercial bottom screen fabric called Texel, a heavy, felt -like polyester material, which is specifically designed for aquatic plant control. An ideal bottom screen should be durable, heavier than water, reduce or block light, prevent plants from growing into and under the fabric, be easy to install and maintain, and should readily allow gases produced by rotting weeds to escape without "ballooning" the fabric upwards. Even the most porous materials, such as window screen, will billow due to gas buildup. Therefore, it is very important to anchor the bottom barrier securely to the bottom. Unsecured screens can create navigation hazards and are dangerous to swimmers. Anchors must be effective in keeping the material down and must be regularly checked. Natural materials such as rocks or sandbags are preferred as anchors. The duration of weed control depends on the rate that weeds can grow through or on top of the bottom screen, the rate that new sediment is deposited on the barrier, and the durability and longevity of the material. For example, burlap may rot within two years, plants can grow through window screening material, and can grow on top of felt -like Texel fabric. Regular maintenance is essential and can extend the life of most bottom barriers. Bottom screens will control most aquatic plants, however freely -floating species such as the bladderworts or coontail will not be controlled by bottom screens. Plants like Eurasian watermilfoil will send out lateral surface shoots and may canopy over the area that has been screened giving less than adequate control. In addition to controlling nuisance weeds around docks and in swimming beaches, bottom screening has become an important tool to help eradicate and contain early infestations of noxious weeds such as Eurasian watermilfoil and Brazilian elodea. Pioneering colonies that are too extensive to be hand pulled can sometimes be covered with bottom screening material. For these projects, we suggest using burlap with rocks or burlap sandbags for anchors. By the time the material decomposes, the milfoil patches will be dead as long as all plants were completely covered. Snohomish County staff reported native aquatic plants colonizing burlap areas that covered pioneering patches of Eurasian watermilfoil. When using this technique for Eurasian watermilfoil eradication projects, divers should recheck the screen within a few weeks to make sure that all milfoil plants remain covered and that no new fragments have taken root nearby. Bottom screens can be installed by the homeowner or by a commercial plant control specialist. Installation is easier in winter or early spring when plants have died back. In summer, cutting or hand pulling the plants first will facilitate bottom screen installation. Research has shown that much more gas is produced under bottom screens that are installed over the top of aquatic plants. The less plant material that is present before installing the screen, the more successful the screen will be in staying in place. Bottom screens may also be attached to frames rather than placed directly onto the sediment. The frames may then be moved for control of a larger area. North Lake IAVMP 12/21/2004 41 Advantages • Installation of a bottom screen creates an immediate open area of water. • Bottom screens are easily installed around docks and in swimming areas. • Properly installed bottom screens can control up to 100 percent of aquatic plants. • Screen materials are readily available and can be installed by homeowners or by divers. Disadvantages • Because bottom screens reduce habitat by covering the sediment, they are suitable only for localized control. • For safety and performance reasons, bottom screens must be regularly inspected and maintained. • Harvesters, rotovators, fishing gear, propeller backwash, or boat anchors may damage or dislodge bottom screens. • Improperly anchored bottom screens may create safety hazards for boaters and swimmers. • Swimmers may be injured by poorly maintained anchors used to pin bottom screens to the sediment. • Some bottom screens are difficult to anchor on deep muck sediments. ■ Bottom screens interfere with fish spawning and bottom -dwelling animals. • Without regular maintenance aquatic plants may quickly colonize the bottom screen. Permits Bottom screening in Washington requires Hydraulic Project Approval. Local jurisdictions may require shoreline permits. Costs Barrier materials cost $0.22 to $1.25 per square foot. The cost of some commercial barriers includes an installation fee. Commercial installation costs vary depending on sediment characteristics and type of bottom screen selected. It costs up to about $750 to have 1,000 square feet of bottom screen installed. Maintenance costs for a waterfront lot are about $120 each year. Other Considerations None North Lake IAVMP 12/21/2004 42 Suitability for North Lake Bottom barriers have been used in other lakes to control aquatic plants. Without constant upkeep and maintenance the long-term benefits of bottom barriers are minimal. Currently, infested areas are to spread out to use a bottom barrier without becoming cost prohibitive. Most of the lakeshore residences have only small infestations and the bottom barrier would just reduce habitat by covering the sediment. Barriers could be effective at the boat ramp to prevent re -infestation after initial control, or in areas that have dense milfoil and have shown resistance to the herbicide. Installing a bottom barrier at the boat launch can provide these benefits. Since there is not a swimming beach at North Lake, the boat launch seems the only appropriate place to install a bottom barrier to enhance the recreational potential of the lake. Biological Control_ General Overview Many problematic aquatic plants in the western United States are non -indigenous species. Plants like Eurasian watermilfoil, Brazilian elodea, and purple loosestrife have been introduced to North America from other continents. Here they grow extremely aggressively, forming monocultures that exclude native aquatic plants and degrade fish and wildlife habitat. Yet, often these same species are not aggressive or invasive in their native range. This may be in part because their populations are kept under control by insects, diseases, or other factors not found in areas new to them. The biological control of aquatic plants focuses on the selection and introduction of other organisms that have an impact on the growth or reproduction of a target plant, usually from their native ranges. Theoretically, by stocking an infested waterbody or wetland with these organisms, the target plant can be controlled and native plants can recover. Classic biological control uses control agents that are host specific. These organisms attack only the species targeted for control. Generally these biocontrol agents are found in the native range of the nuisance aquatic plants and, like the targeted plant, these biocontrol agents are also non -indigenous species. With classic biological control an exotic species is introduced to control another exotic species. However, extensive research must be conducted before release to ensure that biological control agents are host specific and will not harm the environment in other ways. The authors of Biological Control of Weeds —A World Catalogue of Agents and Their Target Weeds state that after 100 years of using biocontrol agents, there are only eight examples, world-wide, of damage to non - target plants, "none of which has caused serious economic or environmental damage...". Search for a classical biological control agent typically starts in the region of the world that is home to the nuisance aquatic plant. Researchers collect and rear insects and/or pathogens that appear to have an impact on the growth or reproduction of the target species. Those insects/pathogens that appear to be generalists (feeding or impacting other aquatic plant species) are rejected as biological control agents. Insects that impact the target species (or very closely related species) exclusively are considered for release. North Lake IAVMP 12/21/2004 43 Once collected, these insects are reared and tested for host specificity and other parameters. Only extensively researched, host -specific organisms are cleared by the United States for release. It generally takes a number of years of study and specific testing before a biological control agent is approved. Even with an approved host -specific bio-control agent, control can be difficult to achieve. Some biological control organisms are very successful in controlling exotic species and others are of little value. A number of factors come into play. It is sometimes difficult to establish reproducing populations of a bio-control agent. The ease of collection of the biocontrol and placement on the target species can also have a role in the effectiveness. Climate or other factors may prevent its establishment, with some species not proving capable of over -wintering in their new setting. Sometimes the bio-control insects become prey for native predator species, and sometimes the impact of the insect on the target plant just isn't enough to control the growth and reproduction of the species. People who work in this field say that the more biological control species that you can put to work on a problem plant, the better success you will have in controlling the targeted species. There are some good examples where numerous biological control agents have had little effect on a targeted species, and other examples where one bio-control agent was responsible for the complete control of,a problem species. However, even when biological control works, a classic biological control agent generally does not totally eliminate all target plants. A predator -prey cycle establishes where increasing predator populations will reduce the targeted species. In response to decreased food supply (the target plant is the sole food source for the predator), the predator species will decline. The target plant species rebounds due to the decline of the predator species. The cycle continues with the predator populations building in response to an increased food supply. Although a successful biological control agent rarely eradicates a problem species, it can reduce populations substantially, allowing native species to return. Used in an integrated approach with other control techniques, biological agents can stress target plants making them more susceptible to other control methods. A number of exotic aquatic species have approved classic biological control agents'available for release in the US. These species include Hydrilla, water hyacinth, alligator weed, and purple loosestrife. In 1992 three beetles were released in Washington for purple loosestrife control. Their damaging impact on purple loosestrife populations was evident in the Winchester Wasteway area of Grant County in 1996. In 1998, 1999, and 2000, the Washington State Noxious Weed Control Board organized insect collection for state, local, and federal staff. Thousands of insects were collected and distributed to purple loosestrife sites throughout the state and even the United States. The King County Noxious Weed Control Program has placed Galerucella sp. from the Winchester Wasteway on a number of purple loosestrife sites, including North Lake. North Lake was chosen because of a high density of the target plant and the fact that other control methods were impractical. Large numbers of purple loosestrife dominates the boat launch at North Lake and surrounding shoreline. Chemical control was a much more expensive alternative and the beetle is showing success at being a control tool. Three releases have been done at the North Lake boat launch, one in 2002 and two in North Lake IAVMP 12/21/2004 44 2003. Approximately 800 beetles were released and have since been found in other areas of the lake. In the summer of 2004, a homeowner along the north shore of the lake found the beetles on her stand of purple loosestrife. However, if the beetles are not expected to rid the lakeshore of the purple loosestrife, an integrated approach will be necessary to achieve eradication. Another type of biological control uses general agents such as grass carp (see below) to manage problem plants. Unlike classical bio-control agents, these fish are not host specific and will not target specific species. Although grass carp do have food preferences, under some circumstances, they can eliminate all submersed vegetation in a waterbody. Like classic biological control agents, grass carp are exotic species and originate from Asia. In'Washington, all grass carp must be certified sterile before they can be imported into the state. There are many waterbodies in Washington (mostly smaller sites) where grass carp are being used to control the growth of aquatic plants. During the past decade a third type of control agent has emerged. In this case, a native insect that feeds and reproduces on northern milfoil (Myriophyllum sibericum) which is native to North America, was found to also utilize the non-native Eurasian watermilfoil (Myriophyllum spicatum). Vermont government scientists first noticed that Eurasian watermilfoif had declined in some lakes and brought this to the attention of researchers. It was discovered that a native watermilfoil weevil (Euhrychiopsis lecontei) feeding on Eurasian watermilfoil caused the stems to collapse. Because native milfoil has thicker stems than Eurasian watermilfoil, the mining activity of the larvae does not cause it the same kind of damage. A number of declines of Eurasian watermilfoil have been documented around the United States and researchers believe that weevils may be implicated in many of these declines. Several researchers around the United States (Vermont, Minnesota, Wisconsin, Ohio, & Washington) have been working to determine the suitability of this insect as a bio-control agent. The University of Washington conducted research into the suitability of the milfoil weevil for the biological control of milfoil in Washington lakes and rivers. Surveys have shown that in Washington the weevil is found more often in eastern Washington lakes and it seems to prefer more alkaline waters. However, it is also present in cooler, wetter western Washington. The most likely candidates for use as biological controls are discussed in the following section. Grass Carp http//,�vww.ecv.wa.gov/pro zrrains/rvq//laiits/management/aqua424.htm1 The grass carp (Cteno pharynogodon), also known as the white amur, is a vegetarian fish native to the Amur River in Asia. Because this fish feeds on aquatic plants, it can be used as a biological tool to control nuisance aquatic plant growth. In some situations, sterile (triploid) grass carp may be permitted for introduction into Washington waters. Permits are most readily obtained if the lake or pond is privately owned, has no inlet or outlet, and is fairly small. The objective of using grass carp to control aquatic plant growth is to end up with a lake that has about 20 to 40 percent plant cover, not a lake devoid of plants. In practice, grass carp often fail to control the plants, or in cases of overstocking, all the submersed plants are eliminated from the waterbody. North Lake IAVMP 12/21/2004 45 The Washington Department of Fish and Wildlife determines the appropriate stocking rate for each waterbody when they issue the grass carp -stocking permit. Stocking rates for Washington lakes generally range from 9 to 25 eight- to eleven -inch fish per vegetated acre. This number will depend on the amount and type of plants in the lake as well as spring and summer water temperatures. To prevent stocked grass carp from migrating out of the lake and into streams and rivers, all inlets and outlets to the pond or lake must be screened. For this reason, residents on waterbodies that support a salmon or steelhead run are rarely allowed to stock grass carp into these systems. Once grass carp are stocked in a lake, it may take from two to five years for them to control nuisance plants. Survival rates of the fish will vary depending on factors like presence of otters, birds of prey, or fish disease. A lake will probably need restocking about every ten years. Success with grass carp in Washington has been varied. Sometimes the same stocking rate results in no control, control, or even complete elimination of all underwater plants. Bonar et. Al. Found that only 18 percent of 98 Washington lakes stocked with grass carp at a median level of 24 fish per vegetated acre had aquatic plants controlled to an intermediate level. In 39 percent of the lakes, all submersed plant species were eradicated. It has become the consensus among researchers and aquatic plant managers around the country that grass carp are an all or nothing control option. They should be stocked only in waterbodies where complete elimination of all submersed plant species can be tolerated. Grass carp exhibit definite food preferences and some aquatic plant species will be consumed more readily than others. Pauley and Bonar performed experiments to evaluate the importance of 20 Pacific Northwest aquatic plant species as food items for grass carp. Grass carp did not remove plants in a preferred species -by -species sequence in multi -species plant communities. Instead they grazed simultaneously on palatable plants of similar preference before gradually switching to less preferred groups of plants. The relative preference of many plants was dependent upon what other plants were associated with them. The relative preference rank for the 20 aquatic plants tested was as follows: Potamogeton crispus (curly leaf pondweed) = P. pectinatus (sago pondweed) > P. zosteriformes (flat - stemmed pondweed) > Chara sp.(muskgrasses) = Elodea canadensis (American waterweed) = thin - leaved pondweeds Potamogeton spp. > Egeria densa (Brazilian elodea) (large fish only) > P. praelongus (white -stemmed pondweed) = Vallisneria americana (water celery) > Myriophyllum spicatum (Eurasian watermilfoil) > Ceratophyllum demersum (coontail) >Utricularia vulgaris (bladderwort) > Polygonum amphibium (water smartweed) > P. natans (floating leaved pondweed) > P. amplifolius (big leaf pondweed) > Brasenia schreberi (watershield) = Juncus sp.(rush) > Egeria densa (Brazilian elodea) (fingerling fish only) > Nymphaea sp. (fragrant waterlily) > Typha sp. (cattail) > Nuphar sp. (spatterdock). Generally in Washington, grass carp do not consume emergent wetland vegetation or waterlilies even when the waterbody is heavily stocked or over stocked. A heavy stocking rate of triploid grass carp in Chambers Lake, Thurston County resulted in the loss of most submersed species, whereas the fragrant waterlilies, bog bean, and spatterdock remained at pre -stocking levels. A stocking of 83,000 triploid grass carp into Silver Lake Washington resulted in the total eradication of all submersed species, including Eurasian watermilfoil, Brazilian elodea, and swollen bladderwort. However, the extensive wetlands surrounding Silver Lake have generally remained intact. In southern states, grass carp have been shown to consume some emergent vegetation (Washington State Department of Ecology, 2002). North Lake IAVMP 12/21/2004 46 Grass carp stocked into Washington lakes must be certified disease free and sterile. Sterile fish, called triploids because they have an extra chromosome, are created when the fish eggs are subjected to a temperature or pressure shock. Fish are verified sterile by collecting and testing a blood sample. Triploid fish have slightly larger blood cells and can be differentiated from diploid (fertile) fish by this characteristic. Grass carp imported into Washington must be tested to ensure that they are sterile. Because Washington does not allow fertile fish within the state, all grass carp are imported into Washington from out of state locations. Most grass carp farms are located in the southern United States where warmer weather allows for fast fish growth rates. Large shipments are transported in special trucks and small shipments arrive via air. Here are some facts about grass carp: • Are only distantly related to the undesirable European carp, and share few of its habits. • Generally live for at least ten years and possibly much longer in Washington State waters. • Will grow rapidly and reach at least ten pounds. They have been known to reach 40 pounds in the southern United States. ■ Feed only on plants at the' age they are stocked into Washington waters. ■ Will not eat fish eggs, young fish or invertebrates, although baby grass carp are omnivorous. • Feed from the top of the plant down so that mud is not stirred up. However, in ponds and lakes where grass carp have eliminated all submersed vegetation the water becomes turbid. Hungry fish will eat organic material out of the sediments. • Have definite taste preferences. Plants like Eurasian milfoil and coontail are not preferred. American waterweed and thin leaved pondweeds are preferred. Waterlilies are rarely consumed in Washington waters. • Are dormant during the winter. Intensive feeding starts when water temperatures reach 68' F. ■ Prefer flowing water to still waters (original habitat is fluvial). • Are difficult to recapture once released. • They may not feed in swimming areas, docks, boating areas, or other sites where there is heavy human activity. Advantages • Grass carp are inexpensive compared to some other control methods and offer long-term control, but fish may need to be restocked at intervals. • Grass carp offer a biological alternative to aquatic plant control. North Lake IAVMP 12/21/2004 47 Disadvantages • Depending on plant densities and types, it may take several years to achieve plant control using grass carp and in many cases control may not occur. • If the waterbody is overstocked, all submersed aquatic plants may be eliminated. Removing excess fish is difficult and expensive. • The type of plants grass carp prefer may also be those most important for habitat and for waterfowl food. • If not enough fish are stocked, less -favored plants, such as Eurasian milfoil, may take over the lake. . • Stocking grass carp may lead to algae blooms. • All inlets and outlets to the lake or pond must be screened to prevent grass carp from escaping into streams, rivers, or other lakes. Permits Stocking grass carp requires a fish -stocking permit from the Washington Department of Fish and Wildlife. Also, if inlets or outlets need to be screened, an Hydraulic Project Approval application must be completed for the screening project. Costs In quantities of 10,000 or more, 8 to 12 inch sterile grass carp can be purchased for about $5.00 each for truck delivery. The cost of small air freighted orders will vary and is estimated at $8 to $10 per fish. Other Considerations • Would not achieve immediate results — takes time and is not guaranteed to work. • Community may have concerns with introduced species • Potential damage to the native plant community of the lake, which could result in the establishment of other aggressive plant species as pioneers • Concerns from fishermen about grass carp • Initial investment very expensive ■ The introduction of grass carp has generally been discouraged by State agencies, especially in systems like North Lake. North Lake IAVMP 12/21/2004 48 Suitability for North Lake Grass carp are not suitable for aquatic plant control in North Lake. The infestation of milfoil has not reached a level where a bio-control such as grass carp would be necessary and the carp could remove all the beneficial plants that support a healthy fish population. Without cover and the invertebrates associated with beneficial native aquatic vegetation, the system would be degraded and some species (invertebrates, fish, etc.) may be extirpated. Watermilfoil Weevil The following information and citations on the watermilfoil weevil are taken from the Washington State Department of Ecology's website on Aquatic Plant Management. http://www, eg.wa.gov/pro g rams/wq/p lants/manageme ii tlweev i l.hiin I The milfoil weevil, Euhrychiopsis lecontei, has been associated with declines of Eurasian watermilfoil (Myriophyllum spicatum) in the United States (e.g. Illinois, Minnesota, Vermont, and Wisconsin). Researchers in Vermont found that the milfoil weevil can negatively impact Eurasian watermilfoil by suppressing the plants growth and reducing its buoyancy (Creed and Sheldon 1995). In 1989, state biologists reported that Eurasian watermilfoil in Brownington Pond, Vermont had declined from approximately 10 hectares (in 1986) to less than 0.5 hectares. Researchers from Middlebury College, Vermont hypothesized that the milfoil weevil, which was present in Brownington Pond, played a role in reducing Eurasian watermilfoil (Creed and Sheldon 1995). During 1990 through 1992, researchers monitored the populations of Eurasian watermilfoil and the milfoil weevil in Brownington Pond. They found that by 1991 Eurasian watermilfoil cover had increased to approximately 2.5 hectares (approximately 55-65 g/m2) and then decreased to about 1 hectare (<15 g/m2) in 1992. Weevil abundance began increasing in 1990 and peaked in June of 1992, where 3 — 4 weevils (adults and larvae) per stem were detected (Creed and Sheldon 1995). These results supported the hypothesis that the milfoil weevil played a role in reducing Eurasian watermilfoil in Brownington Pond. Another documented example where a crash of Eurasian watermilfoil has been attributed to the milfoil weevil is in Cenaiko Lake, Minnesota. Researchers from the University of Minnesota reported a decline in the density of Eurasian watermilfoil from 123 g/m2 in July of 1996 to 14 g/m2 in September of 1996. Eurasian watermilfoiI remained below 5 g/m2 in 1997, there increased to 44 g/m2 in June and July of 1998 and declined again to 12 g/m2 in September of 1998 (Newman and Biesboer, in press). In contrast, researchers found that weevil abundance in Cenaiko Lake was 1.6 weevils (adults and larvae) per stem in July of 1996. Weevil abundance, however, decreased with declining densities of Eurasian watermilfoil in 1996 and by September 1997 weevils were undetectable. In September of 1998 weevil abundance had increased to >2 weevils per stem (Newman and Biesboer, in press). Based on observations made by researchers in Vermont, Ohio and Wisconsin it seems that having 2 weevils (or more) per stem is adequate to control Eurasian watermilfoil. However, as indicated by the study conducted in Cenaiko Lake, Minnesota, an abundance of 1.5 weevils per stem may be sufficient in some cases (Newman and Biesboer, in press). In Washington State, the milfoil weevil is present primarily in eastern Washington and occurs on both Eurasian and northern watermilfoil (M. sibiricum), the latter plant being native to the state (Tamayo et. Al. 1999). During the summer of 1999, researchers from the University of Washington determined the abundance of the milfoil weevil in 11 lakes in Washington. They found, that weevil North Lake IAVMP 12/21/2004 49 abundance ranged from undetectable levels to 0.3 weevils (adults and larvae) per stem. Fan Lake, Pend Oreille County had the greatest density per stem of 0.6 weevils (adults, larvae and eggs per stem). The weevils were present on northern watermilfoil. These abundance results are well below the recommendations made by other researchers in Minnesota, Ohio, Vermont, and Wisconsin of having at least 1.5 — 2.0 weevils per stem in order to control Eurasian watermilfoil. To date, there have not been any documented declines of Eurasian watermilfoil in Washington State that can be attributed to the milfoil weevil, although Creed speculated that declines of Eurasian watermilfoil in Lake Osoyoos and the Okanogan River may have been caused by the milfoil weevil. In Minnesota, Cenaiko Lake is the only lake in that state that has had a Eurasian watermilfoil crash due to the weevil; other weevil lakes are yet to show declines in Eurasian watermilfoil. Researchers in Minnesota have suggested that sunfish predation may be limiting weevil densities in some lakes (Sutter and Newman 1997). The latter may be true for Washington State, as sunfish populations are present in many lakes in the state, including those with weevils. In addition, other environmental factors that may be keeping weevil populations in check in Washington, but have yet to be studied, include over -wintering survival and habitat quality and quantity (Jester et. Al. 1997; Tamayo et. Al., in press). Although the milfoil weevil shows potential as a biological control for Eurasian watermilfoil more work is needed to determine which factors limit weevil densities and what lakes are suitable candidates for weevil treatments in order to implement a cost and control effective program. Advantages • Milfoil weevils offer a biological alternative to aquatic plant control. • They may be cheaper than other control strategies. • Biocontrols enable weed control in hard -to -access areas and can become self-supporting in some systems. • If they are capable of reaching a critical mass, biocontrols can decimate a weed population. Disadvantages • There are many uncertainties as to the effectiveness of this biocontrol in western Washington waters. •. There have not been any documented declines of Eurasian watermilfoil in Washington State that can be attributed to the milfoil weevil. • Many of our lakes, including North Lake, have introduced sunfish populations that may predate on the milfoil weevils. • Bio-controls often don't eradicate the target plant species, and there would be population fluctuations as the milfoil and weevil follow predator -prey cycles. North Lake IAVMP 12/21/2004 50 Permits The milfoil weevil is native to Washington and is present in a number of lakes and rivers. It is found associated with both native northern milfoil and Eurasian watermilfoil. A company is"selling milfoil weevils commercially. However, to import these out-of-state weevils into Washington requires a permit from the Washington Department of Agriculture. As of October 1, 2002 no permits have been issued for Washington. Costs The costs for researchers to locate, culture, and test bio-control agents is high. Once approved for use, insects can sell for $1.00 or more per insect. Sometimes it is possible to establish nurseries where weed specialists can collect insects for reestablishment elsewhere. Suitability for North Lake Since the milfoil weevil is a new bio-control agent, it has not been released yet intentionally in western Washington to control Eurasian watermilfoil. It is uncertain how effective the weevil will be and whether populations per stem can be maintained at levels high enough to eradicate Eurasian watermilfoil. Also, as with the grass carp, the infestation of milfoil in North Lake is not heavy enough to warrant bio-control introduction when other methods are still available. Rotovation Harvesting, and Cuttin Rotovation Rotovators use underwater rototiller-like blades to uproot Eurasian watermilfoil plants. The rotating blades churn seven to nine inches deep into the lake or river bottom to dislodge plant root crowns that are generally buoyant. The plants and roots may then be removed from the water using a weed rake attachment to the rototiller head or by harvester or manual collection. Harvesting Mechanical harvesters are large machines, which both cut and collect aquatic plants. Cut plants are removed from the water by a conveyor belt system and stored on the harvester until disposal. A barge may be stationed near the harvesting site for temporary plant storage or the harvester carries the cut weeds to shore. The shore station equipment is usually a shore conveyor that mates to the harvester and lifts the cut plants into a dump truck. Harvested weeds are disposed of in landfills, used as compost, or in reclaiming spent gravel pits or similar sites. Cutting Mechanical weed cutters cut aquatic plants several feet below the water's surface. Unlike harvesting, cut plants are not collected while the machinery operates. Suitability for North Lake None of these options are suitable for the level of infestation at North Lake. They are not eradication tools, but rather are used to manage and control heavy, widespread infestations of aquatic weeds. North Lake IAVMP 12/21/2004 31 These processes create plant fragments, and therefore should not be used in systems where milfoil is not already widespread. In a moderate infestation such as North Lake, these methods would probably serve to spread and expand the infestation. According to Ecology, "There is little or no reduction in plant density with mechanical harvesting." Since the aim of this project is to eliminate milfoil from the system, these are not compatible control strategies. Harvesting and cutting do not remove root systems. Rotovation would cause damage to the lake sediments and associated animals in a system that does not already receive dredging for navigability. Drawdown Lowering the water level of a lake or reservoir can have a dramatic impact on some aquatic weed problems. Water level drawdown can be used where there is a water control structure that allows the managers of lakes or reservoirs to drop the water level in the waterbody for extended periods of time. Water level drawdown often occurs regularly in reservoirs for power generation, flood control, or irrigation; a side benefit being the control of some aquatic plant species. However, regular drawdowns can also make it difficult to establish native aquatic plants for fish, wildlife, and waterfowl habitat in some reservoirs. Suitability for North Lake Drawdown is not a viable control strategy for North Lake. The outlet from North Lake has a permanent weir with limited drawdown capacities. Not only would drawdown be difficult to achieve, it would also cause significant damage to the ecosystem. The amount of drawdown required to impact milfoil would dry out the littoral zone of the lake. This would damage native plants and animals in the lake and have many negative consequences for residents living around the lake. Without a surface inflow to the system, returning the water level to a previous state would be both cost and time prohibitive. Nutrient Reduction Nutrient Reduction Alternative At lakes in watersheds with identifiable sources of excess nutrients, a program to reduce nutrients entering the lake could possibly be an effective method of controlling aquatic vegetation. Sources of excessive nutrients might include failing septic tanks, other accidental or planned wastewater effluent, or runoff from agricultural lands. If nutrient reduction were enacted as the primary method of weed control, extensive research would be necessary to determine the current nutrient budget for the lake and surrounding watershed, whether nutrient reduction would result in milfoil reduction, and to identify and mitigate the natural and human -mediated nutrient sources. Suitability for North Lake Nutrient reduction is not an appropriate control measure for the following reasons: o It is not an eradication method. • There is no evidence that there is significant point -source nutrient loading at North Lake. North Lake IAVMP 12/21/2004 52 ■ There is no evidence that reducing nutrient loads to the water column would impact milfoil growth. However, all lake groups should strive to reduce nutrient loading to their lake by practicing and implementing Best Management Practices. No Action Alternative One option for managing aquatic weeds in North Lake is to let aquatic weeds continue to grow, and do nothing to control them. This "no action" alternative would acknowledge the presence of the aquatic weeds but would not outline any management plan or enact any planned control efforts. Effectively, a no action determination would preclude any integrated treatment and/or control effort, placing the choice and responsibility of aquatic weed control with lakefront property owners. Suitability for North Lake The milfoil infestation is currently light to moderate in density; unless control measures are enacted, it is likely to increase each growing season in the future until the entire littoral zone of the lake is dominated by milfoil. Based on results of informal surveys by residents and King County staff, the infestations of milfoil, purple loosestrife, and fragrant waterlily have greatly increased since the last comprehensive plant survey in 1995 (King County, 1996). If there is no control effort, it is likely that weed infestations will continue to grow, making North Lake a prime source of milfoil fragments for other nearby lakes with public access and boat launch facilities, as well as a potential source of seed spread by purple loosestrife. Even if some of the residents chose to control the aquatic weeds near their properties, pockets of milfoil would remain. The surviving plants would fragment each autumn, spreading to other areas of the lake, including those that were treated by residents. The no action alternative is not preferred by members of the North Lake community, Weyerhaeuser, or the King County Department of Natural Resources and Parks. North Lake IAVMP 12/21/2004 53 INTEGRATED TREATMENT PLAN North Lake and its associated shoreline contain four listed noxious weed species that should have control measures implemented to halt the spread of their invasions and reverse the degradation currently occurring. The four target species are the Eurasian watermilfoil (Myriophyllum spicatum), fragrant waterlily (Nymphaea odorata), purple loosestrife (Lythrum salicaria), and yellow flag iris (Iris pseudacorus). Although all four species at North Lake are highly aggressive and are difficult to control/eradicate, we believe that the goal of eradication is reasonable for all of them, and we can be successful within the time frame of the project. Eurasian waterm_ ilfoil_ (Myrr_ophyllum spicatum) Year 1 Initial control of Eurasian watermilfoil will be accomplished using an aquatic formulation of Triclopyr TEA (Renovate3 ®) in late May to early June over approximately 10 acres of milfoil- infested area as estimated in 2004 by King County Lake Stewardship and Noxious Weed staff (depending on court decisions and award money or 2,4-D (DMA*4IVM8, Aquakleen® or Navigate®) could be used). The contractor should survey the entire lake with divers using a GPS and marking all the points that need treatment. The areas are marked on the water's surface with buoys and then the application is performed from a boat using trailing hoses to disperse the herbicide underwater. Due to the nature of the sediments in North Lake (as described in Aquatic Plant Control Alternatives), Triclopyr TEA is the preferred formulation. Eradication of Eurasian watermilfoil is the end goal. A follow-up application in Year 1, about three weeks after the first, may be applied to pick up missed plants or late emergents. Only 2.5 mg/L of the herbicide is allowed to be applied during the growing season in the treatment area. We will plan for a maximum of 25% of the original area of 10 acres to need the second treatment. Diver hand -pulling (or diver dredging) will clean up any remaining milfoil found after both herbicide applications have had time to take effect (i.e. two to three weeks after the second herbicide treatment). A bottom barrier will be installed at the boat launch in the winter of Year 1 to ensure eradication in the vicinity, and to aid in preventing new introductions. Community education efforts will be continued, including training in milfoil identification and survey methods. There will also be an increase in the signage at the boat launch. The NPDES permit coverage from WSDA requires notification and posting of the waterbody, and these specific protocols will be followed. The NPDES permit also requires monitoring of the herbicide levels in the lake after treatment. Independent samples will be collected at the time of the application and again five days post treatment. A baseline sample will also be taken before the application, especially since Water Quality experts at Ecology report heightened levels of 2,4-D in our surface waters due to runoff after heavy storm events (K. Hamel, pers. comm.) One sample is taken from within the treatment area, and one from outside. These four samples (per application) will be sent to an independent, Ecology -accredited laboratory for the analysis. As more of these samples need to be analyzed to meet NPDES requirements, some companies may get an ELIZA test accredited through Ecology which will be less expensive. As the permit stands in 2003, this procedure will be performed each year an application for milfoil is conducted. Surveys after the initial application are essential to determining the success of the effort, and will be used to determine North Lake IAVMP 12/21/2004 54 what measures need to be implemented to complete the milfoil control for Year 1 (and subsequent years). Problems may arise if the same firm that conducted the herbicide application also surveys for the success of the effort. We plan to hire a separate, independent firm to conduct these surveys to overcome this potential problem. Volunteers from the North Lake community will be directly involved with overseeing the implementation of control work to keep the contractors accountable. Year 2 Year 2 will begin with diver surveys of the lake to check the status of the infestation. Spot herbicide treatment with triclopyr (Renovate3l) or 2,4-D (DMA*4IVM®, Aquakleen® or Navigate®) will begin in late May to early June over an estimated maximum of 50% of the original milfoil infested area (max. six acres). Obviously, if the diver surveys find greater than six acres need to be treated, the real infestation size will be accommodated. At this point we will have a sense as to whether the herbicide has eliminated a significant amount of the Eurasian watermilfoil, or whether it has seemed to become less effective. After the first herbicide application in Year 2, we will conduct the first diver hand -pulling/ diver dredging about three to four weeks after the herbicide treatment. We plan for a maximum of 25% of the original area (or three acres) to need the first manual removal. We will follow this with a second survey in August with diver hand -pulling/ dredging as needed. At this point, we hope that less than 10% of the original area (or one acre) will be involved. Annual maintenance of the bottom barrier at the boat launch will consist of removal of rooted plants and sediment accumulations, as well as securing the barrier to the bottom to ensure safety and effectiveness. Continued community education will complete our Eurasian watermilfoil efforts for Year 2. Year 3 Year 3 will again begin with diver surveys of the lake to assess the milfoil distribution. If herbicide is needed we will stay with the original active ingredient for the herbicide treatment in Year 3. We project that no more than an acre total of Eurasian watermilfoil will need this treatment. We will then use diver hand -pulling/ diver dredging as necessary if individual plants are discovered in our mid- summer survey. Annual maintenance of the bottom barrier at the boat launch and continued community education will complete our Eurasian watermilfoil efforts for Year 3. In Years 4-7 (and beyond), diver and surface surveys will occur at least twice during the growing season. Because permits for herbicide applications must be acquired far in advance, we plan to rely on diver hand -pulling as the control method. If at any point we find that we are losing ground on eradication efforts, we will apply for the appropriate permits and perform spot applications with herbicide. We will need to continue the bottom barrier maintenance annually. There should be no need to revegetate the areas of Eurasian watermilfoil after treatment. Most of the native submersed species are monocots (Potamogeton sp.) that should be relatively unaffected by either the Triclopyr or 2,4-D application. Removing the noxious invaders will halt the degradation of the system and allow the dynamic natural equilibrium to be maintained. North Lake IAVMP 12/21/2004 55 Eurasian watermilfoil (Myriophyllum spicatum) may be eliminated by this outlined integrated approach. Two herbicide applications per season in the first year(s), followed by manual methods, should ensure that no milfoil plants survive. Once the established plants are eradicated, and follow up surveys have verified their absence for several seasons, potential reintroduction will be a remaining challenge. Any areas that dewater will be checked for milfoil seedlings. Since North Lake does not currently have prolific plant growth, milfoil plants should be found easily and manual control methods should prove more effective than in a lake with dense beds of native vegetation. Fragrant waterlily (Nymphaea odorata) Year 1 Control efforts on the fragrant waterlily began in the summer of 2004 with Glyphosate. 10 acres of the lake was treated. The intensity of control will be equal across the entire lake, with eradication as the end goal. Triclopyr and 2,4-D may have some effect on fragrant waterlily since it is also a broad - leafed plant and there is some overlap in the distribution of these plants in North Lake. However, 2,4- D is reported as not being very effective on this species (K. Hamel, pers. comm.). At the same time as the second herbicide application for the Eurasian watermilfoiI in Year 1, we will use Glyphosate (Rodeo or Aquamaster') on the fragrant waterlilies around the lake to continue control. In addition to posting requirements, the NPDES permit requires monitoring of the glyphosate levels in the lake after treatment. Independent samples will be collected about one hour after the application and again 24 hours post treatment. One sample is taken from within the treatment area, and one from outside. These four samples (per application) will be sent to an independent, Ecology -accredited laboratory for the analysis. A follow up treatment may be done in the later summer of 2004 to insure control over the fragrant waterlily population. It is not likely that the lilies will be eradicated -by year 1. Year 2 Year 2 will likely include another glyphosate application. Since milfoil will be treated with herbicide, we may get some control on the waterlilies from the triclopyr application. However, since triclopyr will be applied in spot applications to milfoil, there may be less and less overlap between milfoil and fragrant waterlily. In either case, a glyphosate application will be performed when floating leaves have formed on the waterlily (approximately the same time as Year 1). One glyphosate application is planned in Year 2 and will be followed by cutting and removing any plants not killed by the . herbicide. This manual control will be performed by the end of the summer before the plants set seed. Year 3 In future years, we may reed to eliminate returning plants or new infestations. We have planned for a "final" herbicide application in Year 3 as a contingency. Cutting will be used to control small areas of waterlily. If the level of waterlily infestation again gets to the point where manual control is no longer feasible, we will plan for an herbicide application the following summer. This lead-time is required to get the necessary permits. The native waterlily (Nuphar luteum) is well represented in the south end of the lake where much of the fragrant waterlily is currently found and is likely to expand its distribution. The selective nature of spot applications of Glyphosate should minimize impacts to non - target vegetation, and may allow the native waterlily to rebound or expand. North Lake IAVMP 12/21/2004 56 Purple loosestrife (LYthrum salicari'a) North Lake was chosen for Galerucella calmariensis, a biological control, release because of a high density of the target plant and the fact that other control methods were impractical. Large numbers of purple loosestrife dominates the boat launch at North Lake and surrounding shoreline. Chemical control was a much more expensive alternative and the beetle has proven to be a successful management tool. Three releases have been done at the North Lake boat launch, one in 2002 and two in 2003. Approximately 800 beetles were released and have since been found in other areas of the lake. According to the King County Noxious Weed specialist, Monica Walker, beetles alone are not sufficient to eradicate the purple loosestrife. An integrated approach will be necessary for eradication to be successful. One glyphosate application per year is planned for Years 1-3. Glyphosate will be wicked on to each plant, taking care that no other native, desirable plants receive the herbicide treatment. Plants will be rechecked 1 month after herbicide application, and any that have produced flowers will be manually controlled before they set seed. These plants will be cut at the base and disposed of as garbage. Guidance will be provided to residential landowners as to which native plants or non -aggressive exotics would serve well to perform the desired functions of buffer vegetation along their shorelines. Some landowners are concerned with aesthetic elements and would like to replace the beautiful floral display of purple loosestrife, whereas others have ecological concerns about buffering a waterbody with wetland vegetation to help maintain the health of the system. Part of the community education process will be bringing these two different views together to establish more natural landscapes on the residential parcels around the lake, and develop sustainable, noxious -weed -free systems. .Purple loosestrife has decreased slightly due to four years of manual and biological control methods. Yellow flaq iris (Iris pseudaco_rus Control efforts on the yellow flag iris will focus on the entire shoreline. We plan to use a treatment with glyphosate (Rodeo or Aquamaster*), which should be done at the same time as the purple loosestrife and fragrant waterlily control. We plan to make one herbicide application in each of the first 3 years. Control efforts around the remainder of the lake will be accomplished through educational outreach. We will begin by asking residents to continue taking seed heads off the plants in late summer before they expand the infestation. We will also encourage landowners to start digging out the individual plants on their shoreline. Caution must be taken when working the yellow flag iris as the plant sap is poisonous and can cause severe blistering and irritation, if ingested it can cause vomiting and diarrhea. Gloves and care must be used when working with this plant. Permission from all of the individual landowners will be necessary before any herbicide work can proceed on their land. These efforts will be ongoing. Suggestions will be provided to residential landowners as to native plants or non -aggressive exotics that would serve well to perform the desired functions of buffer vegetation along their shorelines. North Lake IAVMP 12/21/2004 57 Table 3 outlines the tasks and estimated costs of implementation on an annual basis. Implementation of the North Lake IAVW will span at least seven years, at a total estimated cost of $58,272. The majority of the costs accrue in the first several years, which is the period of most aggressive treatment. Beyond that, costs are directed at detecting and controlling re -introduction of noxious aquatic plant species. Table 4: Budget with use of Triclopyr Task Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 7 year total Lily Treatment $ 1,000.00 $ 1.000.00 $ 2.000.00 Herbicide (triclopyr) $ 10,000.00 $ 3.900.00 $ 13.900.00 Emergent Weed Treatment I S 1,500.00 $ 1.125.00 S 3-00.001 $ 2.925.00 Diver Survey $ 1.100.00 $ 1,600.00 $ 1.600.00 $ 1,600,00 $ 1.000.00 $ 1,000.00 $ 7.900.00 Diver Dredge/ handpull $ 7,680.00 $ 10,240.00 S 1.280.00 $ 1.280.00 $ 1,280.OD $ 640.00 S 640.00 $ 23.040.00 Boat launch bottom barrier. S 1,250.00 $ 215.00 $ 215.00 $ 215.00 $ 215,00 $ 215.00 S 215.00 $ 2,540.00 Education and Outreach $ 1.000.00 $ 1.000.00 S 750.00 $ 750.00 $ 500,00 $ 500.00 S 500.00 $ 5,000.00 Printing Costs S 1.000.00 $ 250.00 $ 250.00 $ 250.00 $ 1,750.00 Project Management $ 2.500.00 $ 2.500,00 $ 1.000.00 $ 1.000.00 $ 500.00 $ 500.00 $ 500.00 $ 8.500.00 Year 1 Year Year 3 Year4 Years Year year Totals $25,00.00 $21,330.00 55,395.w s5,095.0o s4.095.00 $$855.oa $2.855 w $67,555.00 W/ tax $5,923,63 10% Contingency $6,731.40 Grand Total $80,210.03 North Lake IAVMP 12/21/2004 58 Table 5: Project budget with use of 2,4-D Task Year t Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 7 year total Lily Treatment S 1,p00.rs0 $ 1,000.00 $ 2.000.00 Herbicide (2,4 D) 59,759.00 $3,900.00 $ 13.659.00 Emergent Weed Treatment 1 $ 1,500.00 $ 1.125.00 5 300.00 $ 2.925.00 Diver Survey $1,100.00 $1.50D.00 $1.600.00 $1,600.00 $1.000.00 $1,000.00 $ 7,900.00 Diver Dredgel handpull 57,680.00 $10,240.00 $1.280.00 $1.280.00 51,280.40 $640.00 $640.00 $ 23.040.00 Boat launch bottom barrier $1,25A:Q0 $215.00 $21500 $215.00 S215.00 $215.00 $215.00 $ 2.540.00 Education and Outreach 51 PO. O.Cl $1,000.00 $750.00 $750.00 $5D0.00 $500.00 5500.00 $ 5,000.00 Printing Costs $1,000W $250.00 $250.00 $250.00 $ 1.750.00 Project Management $ 2.500.00 $ 2,500.00 $ 1,000.00 $ 1,000.00 $ 500.00 $ 500.00 $ 500.00 $ 8.500.00 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Totals $25,689.00 521.330.00 $5,395.00 $5.096.00 $4.09500 S2,855,W $2,855.00 $67,314.00 W1 tax $5,791.63 10% contingency $6,581.40 Grand Total $79,687.03 North Lake IAVMP 12/21/2004 59 Sources of Funding There are several likely sources of funding available for project implementation: Grants The Washington State Department of Ecology has an Aquatic Weeds Management Fund (AWMF). This IAVMP was developed to be consistent with all AWMF guidelines and requirements. Given the relatively low-level infestation, outstanding ecological value of North Lake and its watershed, and the potential for infestation of neighboring lakes, it is hoped that Ecology and other grant programs will offer funding. Other possible funding sources include King County's WaterWorks and the Natural Resources Stewardship Network. Dedicated non -grant funds from King County The King County Noxious Weed Program has limited funds available to contribute to weed control projects. While this can not be considered an ongoing source of funding, $1000 is promised to the project in the first year of implementation. Community -Based Funding There is a proposal before the North Lake Improvement Club to begin collecting annual contributions estimated at $50, with the additional revenue to be dedicated to projects and programs designed to improve lake and watershed conditions. This could generate several thousand dollars over the first five years of the project. Noxious aquatic weed management currently tops the list of threats to the lake. If funds raised by requesting contributions prove insufficient, community members have discussed forming a Lake Management District (LMD). If implemented, a LMD would collect an annual fee from all watershed property owners. Fees would be weighted based on property size and proximity to the lake. Money collected through a LMD must be dedicated to addressing specific problems facing the lake and watershed. This IAVMP will provide some guidance should watershed residents choose to pursue a LMD. Matching Funds Table 6 shows the matching requirements outlined by Ecology's AWMF and the estimated in -kind match and cash match provided by King County and the North Lake Community. Table 6: Total Matching Funds (triclopyr) Total Project cost = $ 80,210.03 1 Budgeted Match % of Total 75%of total project $60,157.52 Required match $20,052.51 Budgeted in -kind match $13,825.00 17.2% Budgeted cash match $ 6,450.40 8.0% i Ecology $ after match $59,934.63 74.7% North Lake IAVMP 12/21/2004 60 Table 7: Total Matching Funds (2,4-D) Total Project cost = $79,687.03 Budgeted %of Total 75% of total project $ 59,765.27 Required match $19,921.76 $ 13,825.00 17.3% $ 6,450.40 8.1% Ecology $ after match $59,411.63 74.6% Table 8: In -kind Matching Funds Item Cost Units Units/ year Years Notes Total Volunteer hours $ 15.00 per hour 135 5 8-10 very active $10,125.00 community members.-2 certified divers on lake. Time estimates include boat surveys, diver training, bottom barrier maintenance, steering committee meetings,ID -workshops, educational flyer development Educational Materials $ 500.00 peryear 1 5 Communitymember $ 2,500.00 Development and time spent developing Presentation materials and presenting materials to youth groups and other organizations Boat rental $ 40.00 per day 6 j 5 $ 1,200.00 Total est. in -kind match $13,825.00 Table 9: Cash Matching Funds Item Cost Units Units/ year Years Notes Total Community self -tax $ 500.00 peryear 1 5 Based on $ 2,500.00 implementation of one or more community -based funding strategies outlined in IAVMP. Will be assessed annually into future (indefinitely). KC DNRP Noxious Weed $ 1,000.00 peryear 1 1 Dedicated costs hare 1 $ 1,000.00 Control Program Cost Share funds from Noxous Weed Control Program Grants $ 1,000.00 peryear 1 2 Estimate based on likely $ 2,000.00 sources. KC Staff -Aquatic Noxious $31.68 per hour 10 3 See below for salary and $ 950.40 Weed Specialist burden rates as of2003. Total est. cash match 1 $ 6,450.40 North Lake IAVMP 12/21/2004 61 Table 10: KC Staff Salary and Burden Rates lVee ,1 Burdened Position Hourly RateQ ��Hourly ry a, Rate Environmental Scientist $ 27.16 $ 7.99 1 $ 4.071 $ 6.791 $46.01 Water Quality Planner $ 25.29 $ 7.44 $ 3.79 1 $ 6.32 1 $42.84 Aquatic Weed Specialist $ 18.70 $ 5.501 $ 2.81 1 $ 4.68 1 $31.68 Table 11: Federal Way Staff and Benefit Rates Hourly Burdened � Position Hourly Rate ,e��`� Rate Smith $ 35.00 $ 8.40 ' $43.40 Russel $ 22.70 $ 6.13 $28.83 Donald $ 30.27 $ 7.87 $ 38.14 North Lake IAVMP 12/21/2004 62 The implementation of the plan will follow the process outlined below: 1. Convene a project Implementation Committee. Many Steering Committee members have indicated their willingness to transition into this role. 2. Review proposed plan and develop timeline with specific tasks. The IAVMP will guide this process. 3. Assign tasks to Implementation Committee members. 4.. Issue a Request for Proposals for weed survey and control work. 5. Secure necessary permits. Permit application will be coordinated with the contracted applicator. 6. Implement community education plan. 7. Apply herbicide treatment. Application will be completed as prescribed in IAVMP, unless consultation with Ecology and the applicator leads to defensible changes in the plan. 8. Conduct follow-up surveys. Professional contractors and community members who have received adequate training can complete this work, with community participation under supervision of King County staff. 9. Apply follow-up herbicide treatment if necessary. Follow-up surveys will determine the extent to which this work is necessary. 10. Conduct diver surveys and hand -pulling as necessary. Professional contractors and community members who have received adequate training can complete this work, with community participation under supervision of King County staff. North Lake IAVMP 12/21/2004 63 BIBLIOGRAPHY Aiken, S. G., P.R. Newroth, and I. Wile. 1979. The biology of Canadian weeds. 34. Myriophyllum spicatum L. Canadian Journal of Plant Science. 59:201-215. Cited in Sheldon and Creed, 1995. Beavers, Tom. July 2004. Personal communication. White River Basin Steward, King County Department of Natural Resources and Parks. Seattle, WA. Carlson, R.E. 1977. A trophic state index for lakes. Limnol. Oceanogr. 22:361- 368. Cleary, Julie. July 2004. E-mail correspondence. Resident of North Lake. King County, WA. Creed, R.P., Jr., and S.P. Sheldon. 1995. Weevils and watermilfoil: Did a North American herbivore cause the decline of an exotic weed? Ecological Applications 5(4): 1113-1121. Diamond, Gary L. and Patrick R. Durkin. 1997. Effects of Surfactants on the Toxicity of Glyphosate, with Specific Reference to RODEO. Animal and Plant Health Inspection Service (APHIS), SERA TR 97-206-lb. Extension Toxicology Network (EXTOXNET). 1996. Pesticide Information Profiles: Glyphosate. Oregon State University. Retrieved August 14, 2002. Available online at: http://ace.orst.edu/cgi- bm/mfs/0 I /Ripq/glahosa.htm Felsot, Allan S. 1998. Hazard Assessment of Herbicides Recommended for Use by the King County Noxious Weed Control Program. Prepared for the Utilities and Natural Resources Committee of the Metropolitan King County Council. Available online at: htti)://dnr.metrokc.gov/wir/lands/weeds/herbicid.htm Friends of Hylebos Creek, 2004. The Hylebos Watershed Webpage. Available online at: http://www.hylebos.org/watershed/index.htm Hamel, Kathy. September 2002- February 2003. Personal communication. Aquatic Plant Specialist, Washington State Department of Ecology. Olympia, WA. Honey, Wendy. June 2004. Personal communication. Resident of North Lake community. King County, WA. Information Ventures, Inc. 1995. Pesticide Fact Sheet: Glyphosate. Prepared for U.S. Department of Agriculture, Forest Service. Available online at: httt).//infoventures.com/e-hlth/ esteide/glyphos.html Jackson, Chad. October 2002. Personal Communication. Area Fish Biologist, Washington Department of Fish and Wildlife. Olympia, WA. King County, 1991. Draft Hylebos Creek and Lower Puget Sound Basin Plan. Surface Water Management Division. King County, 1996. Aquatic Plant Mapping for 36 King County Lakes. Surface Water Management Division. North Lake IAVMP 12/21/2004 64 King County, 2001. King County Lake Water Quality: A Trend Report on King County Small Lakes. Department of Natural Resources and Parks, Lake Stewardship Program. King County, 2003. Data from King County's Lake Stewardship Volunteer Monitoring Program. King County Department of Natural Resources and Parks. Malik, J., G. Barry, and G. Kishore. 1989. Mini -review: The herbicide glyphosate. BioFactors. 2(1): 17 25, 1989.10-100 Reed, P. 1988. National List of Plant Species that Occur in Wetlands: Northwest Region 9. U.S. Fish and Wildlife Service, Biological Report 88 (26.9). Richter, K.O. and A.L. Azous, 2001 a. Amphibian Distribution, Abundance, and Habitat Use in: Wetlands and Urbanization: Implication for the Future. Azous, A.L. and R.R. Horner (eds), Lewis Publishers, Boca Raton. 338 pp. United States Department of Agriculture, Soil Conservation Service. 1973. Soil Survey King County Area Washington. U.S. Government Printing Office, Washington D. C. Walker, Monica. August 2004. E-mail correspondence. Noxious Weed Specialist, King County Noxious Weed Group. Seattle, WA. Washington State Department of Ecology, 2001 a. An Aquatic Plant Identification Manual for Washington's Freshwater Plants. 195pp. Washington State Department of Ecology, 2001b. Herbicide Risk Assessment for the Aquatic Plant Management Final Supplemental Environmental Impact Statement (Appendix C - Volume 3: 2,4-D). Available online at:http://Nvww.ecv.wa.gov/pubs/00 I 0043.df Washington State Department of Ecology, 2002. Aquatic Plant Management website. Retrieved July 25, 2002. Available online at: htt ://�vww.eg .wa. ovl ro ams/w / ]ants/mana ementYindex.html Washington State Department of Ecology, 2004. Environmental Impact Statement (EIS) for Permitted use of Triclopyr. 115pp. Available online at: http://www.ecy.wa.govibiblio/0410018.html Washington State Noxious Weed Control Board. 1995. Eurasian watermilfoil. In: Written Findings. Available online at: h ://www.nweb.wa.aovfweed info/milfoil.html Washington State Noxious Weed Control Board. 2001. Iris pseudacorus. In: Written Findings. Washington State Noxious Weed Control Board. 1997. Lythrum salicaria. In: Written Findings. Available online at: hj!p://%vww.nwcb.wa.gov/weed info/ploosestrife.htm] Washington State Noxious Weed Control Board. 2001b. Nymphaea odorata. In: Written Findings. Westerdahl, H.E. and K.D. Getsinger (eds), 1988. Aquatic Plant Identification and Herbicide Use Guide; Volume I: Aquatic Herbicides and Application Equipment. Technical Report A-88-9, US Army Engineer Waterways Experiment Station, Vicksburg, TAS. North Lake IAVMP 12/21/2004 65 APPENDIX A Appendix A documents the public involvement process during the development of the North Lake Integrated Aquatic Vegetation Management Plan. Throughout this process, the Steering Committee made decisions based on input from and interactions with the wider community. Documents contained herein relate to planning and implementation of outreach and education activities including steering committee meeting agendas, meeting notes, flyers, and handouts. Documents appear in their original form, and have not been edited after the fact to reflect subsequent decisions or changes in the proposed project. As such, there are spelling and grammar errors, and varied document formats. North Lake IAVMP - Appendix A A-1 3-17-04 North Lake Steering Committee meeting Attendees: Julie Cleary, Tom Jovanovich, Wendy Honey, Debra Hansen, Mark Braverman representing Weyerhaeuser and Beth Cullen representing The King County Lake Stewardship Program (2 hour meeting) Notes: ■ Need to apply State Grant for Integrated Aquatic Vegetation Management Plan • State Grant can sustain for a couple of years • Beth Cullen would be the project manager including handling funds • Weyerhaeuser has a permit for treating the Lilly pads for 2004 and plans to do treatment end of May • Look at Spring Lake model at httn:lldnr.metrnkc.gov • Watershed Grant for $2000 available on-line o Identify scope of work (Wendy to talk to Dr. Whitworth of Whitworth Pest Solutions) o Receiving this grant would help in getting the State grant o First step is to partner with Weyerhaeuser, community and King County o Need to chip in $$ o Ken Pritchard is grant coordinator o Need to get this in quickly after April 5 meeting ■ Application for State Grant needs to be completed before October o Kathy Hammil in charge of State Grants o Possibility of up to $50,000 o Again look at Spring Lake process • We agreed to try to get the lakeside residents to the monthly board meeting on April 5. Wendy to contact Lois (NLIC Secretary) about possibility. • HPA needed to pull out Lilies, Milfoil by hand. HPA free from King County North Lake IAVMP - Appendix A A-2 4/01/04 North Lake Steering Committee Attendees: Debra Hanson, Wendy Honey, Julie Cleary (90 minute meeting) Meeting for April 5'h with North Lake Community • How will we know if we have been successful with this meeting? o Vote of support and address concerns • What do we need to do in preparation for this meeting? o Distribute flyers o Coffee/tea o Set up club house o What else? ■ Sign in sheet with Name/Address/Phone/email • What do we want to accomplish? o Community support and education Who is going to give an explanation of what we are trying to do and introduce Beth Cullen as a speaker? o Wendy Honey, Steering Committee Chairperson ■ Introduce Steering Committee members ■ Explain that we are starting a 7-10year community maintenance to control our communities noxious and invasive weed/plant problem • Introduce Beth Cullen to speak on educating community on noxious and invasive weed/plant • Small Change Grant Writing o Handouts provided by King County o Who is going to do what by when? ■ Questions were assigned to Steering Committee members to draft and complete by 4/07/04 (Wednesday) North Lake IAVMP - Appendix A A-3 PI:,EASE JOIN US! I North Lakeside residents, we need your help in returning North Lake to a Clean, recreational lake to live and play on. Milfoil, Lilly pads and Purple Loosestrife are threatening the health of our lake. We need to take action. Please join us for a discussion and direction setting Date: April Where: North Lake Improvement Club Time: 7:15pm Speaker: Beth Cullen from King County Lake Stewardship Program We have an opportunity to participate in clean up by using the permit Weyerhaeuser has obtained to address the Lilly problem in May of 2004 and the possibility of a grant from King County. Your participation in direction setting is critical to a successful clean up. North Lake Steering Committee Julie Cleary (253)874-9138 Debra Hansen (253)927-7789 Wendy Honey (253)952-5283 Tom Jovanovich (253)874-8239 North Lake IAVMP - Appendix A A-4 4/05/04 Speakers Notes (Wendy Honey) (attended by 31 residents including steering committee members 90 minute meeting) Thank neighbors for attending and support (include those not able to attend) Introduce Steering Committee: Julie Cleary, Debra Hansen, Tom Jovanovich, Wendy Honey Brief overview: • Began last year with conversations of the lily pads. Many neighbors have noticed and commented on increased lake weeds over the years. • Invited Beth Cullen and Katie Sauter Messick to talk with the North Lake Improvement Club Board members about weed control and funding options through grants • Our goal is to begin eradication of the non-native lily pads. Begin this process this spring. Count grant application for this process may be available. Cost is approximately $1500.00 in conjunction with Weyerhaeuser. Cost saving to begin now is $1050.00 ($250.00 per acre savings on treatment and shared permit) • Long term goal is to request a grant through the State Department of Ecology and develop an Integrated Aquatic Vegetation Management Plan for our lake. 7-10 year process. This will result in controlling other noxious weeds such as the Milfoil, Purple Loosestrife, and Yellow Flag Iris. • Approximately 50 lakeside neighbors contacted over the weekend. 30 (100%) that we were able to speak with gave their support o Support may come in the form of. Financial assistance Volunteer time • Introduce Beth Cullen, Water Quality Planner I Lake Stewardship Program, King County Water and Land Resources (206)263-6242 / beth.cullenfg7metrokc.imv North Lake IAVMP - Appendix A A-5 North Lake Steering Committee Wednesday May 5, 2004 Discussion Items: Next Steps: Community Feedback: Grant Process: Task Delegation: Dan Smith, City of Federal Way: North Lake IAVMP - Appendix A A-6 North Lake Steering Committee Wednesday May 5, 2004 Attendees: Wendy Honey, Julie Cleary, Tom Jovanovich, Chuck Gibson, Beth Cullen (6:30pm-8:30pm 2 hour meeting) Discussion Items: The goal of the committee is to eradicate milfoil, lilies, loosestrife and iris. The first few years of the management plan will focus on herbicide treatments but begin to add diver surveys and resident monitoring to the plan Next Steps: Start aggressive eradication. Consider $20,000 a year for first couple of years for herbicide treatments. 3-4 years for control of non-native water lilies/Purple Loosestrife/Milfoil Educational grant may be available. Could we utilize the Boy Scouts for volunteers? 2"d stage -monitoring / hand pulling We need to consider obtaining at least: 10% cash matching / 5% volunteer matching Community Feedback: All feedback from 4/05/2004 meeting positive and all committee members report positive feedback. No objections to the program mentioned. Grant Process: The King County grant to piggy -back on the lily control should be awarded by min -May Weyerhaeuser is waiting to hear about that grant before the contract begins IAVMP Grant available $60,000-$75,000 Due by October DOE grant contact: Kathy Hammil Neighboring Lakes Geneva, Killarney, and 5 mile have same problems with non-native and noxious weeds/plants Initial control of non-native water lilies will probably need 2 treatments of RODEO to be effective Need to develop letter of support and receive signatures for grant application Task Delegation: • Link for IAVMP • Draft budget • Community history -importance of North Lake to its residence, history of weeds, and previous treatments • Write Problem Statement -safety of waters, spreading to neighboring lakes, Goal is to eradiate non- native and noxious weeds and reintroduce native plants. Include undeveloped lake area in King County ■ Keep sign in sheets/agendas/time logs Other contacts: Dan Smith, City of Federal Way: Public Works, Surface Water Lake Management District. Discussion on weeds: results of King County dive survey: Native water lilies -shaped like ace of spades and stand up on waters surface. There are not many patches of these on North Lake. More fragrant non-native lilies Eurasian Milfoil-big puffy -leaflets -fluorescent bright. Northern is native-darker/olive green. Milfoil is everywhere in the lake. Early season for milfoil probably due to weather conditions Native Pond weed. Important Notes: Removing the lilies may increase milfoil. Lilies shade milfoil from sunlight/growth HPA Hydraulic Permit Approval is needed for hand pulling of weeds North Lake IAVMP - Appendix A A-7 Monetary matches with Weyerhaeuser for match and budget timing. Weyerhaeuser may continue funding lake management Next meetings: Steering Committee May 24"' Steering Committee June 14t` with Beth Cullen Watershed meeting June 28th North Lake IAVMP - Appendix A A-8 5/24/04 Steering Committee Meeting Attendees: Wendy Honey, Julie Cleary, Debra Hansen, Tom Jovanovich, Chuck Gibson (6:30pm-8:OOpm 90 minutes) • Discuss planning and assign problem statement and lake history. • Who are our contact? o Long time residents Objective to have draft completed by next meeting. All committee members assigned a section to write. Circulate by email and each committee member will review and provide feedback. Next meeting: June 10 with Steering Committee members and Beth Cullen North Lake IAVMP - Appendix A A-9 6/28/2004 Meeting Agenda Welcome -Neighbors Guests- Detrich and Glenda Jones, North Lake Residents Beth Cullen, Water Quality Planner, Lake Stewardship Program King County Water and Land Resources Mark Braverman, Site Forestry Manager for Weyerhaeuser Belinda Bowman, General Manager, Whitworth Pest Solutions Dan Smith, City of Federal Way Introduce Committee Members: Wendy Honey, Debra Hanson, Julie Cleary, Tom Jovanovich, Chuck Gibson Objective: To update the community on the Small Change Grant, water lilly eradication efforts currently taking place, and introduce IAVMP — Speaker Wendy Honey Small Change for a Big Difference Grant from King County Department of Natural Resources and Parks: North Lake Photo presentation: Whitworth Pest Solutions: update on 6/17 spray of Fragrant Water Lilies: Belinda Bowman Introduce IAVMP, Integrated Aquatic Vegetation Management Plan: IAVMP PowerPoint presentation: Beth Cullen Open floor for discussion and questions. Close meeting / Collect Letter of Support from each household attending North Lake IAVMP - Appendix A A- 10 6/28/2004 Meeting Agenda (Speaker. Notes: Wendy Honey) Welcome -Neighbors Guests - Dietrich and Glenda Jones, North Lake Residents Beth Cullen, Water Quality Planner, Lake Stewardship Program King County Water and Land Resources Mark Braverman, Site Forestry Manager for Weyerhaeuser Belinda Bowman, General Manager, Whitworth Pest Solutions Dan Smith, City of Federal Way Introduce Committee Members: Wendy Honey, Debra Hanson, Julie Cleary, Unable to attend: Tom Jovanovich, Chuck Gibson Objective: To update the community on the Small Change Grant, water lily eradication efforts currently taking place, and introduce IAVMP — Speaker Wendy Honey In June we received approval on the Small Change for a Big Difference Grant from King County Department of Natural Resources and Parks. This grant was for $2000.00 and allowed funding for the first stage of fragrant water lily eradication that took place on June 17, and 181h. This first stage seems to be a successful start as many of the fragrant water lilies are beginning to die. As this continues to happen, they may sink to the bottom and it is possible that some masses of them may rise and float. If they float onto your shoreline and it is more thank you can handle for cleaning up to recycle or compost, please contact a member of the Steering Committee and we will organize a work party to assist. We may need follow-up treatments as we get into the later summer months. In order to schedule future funding of this project, we need to determine the financial support. There is approximately $360.00 left from the grant funds, and we would need to ask residents to assist in funding. We can still use the Weyerhaeuser permit for future treatments, even if they are not in conjunction. It is important to mention that the Native Lilies were not sprayed as part of the eradication. The contractor was very careful not to spray these lilies and they will remain as part of the native habitat. North Lake PowerPoint presentation: Wendy Honey, photos of the lake during the water lily eradication efforts June Ie, June 17t', and June 24"'. Whitworth Pest Solutions: update on 6/17 spray of Fragrant Water Lilies: Belinda Bowman Our next step: Introduce IAVMP, Integrated Aquatic Vegetation Management Plan: The grant application the Steering Committee is currently drafting. This grant is from the State Department of Ecology. The due date for the grant application is October 2004 for funding eradication project to begin in 2005. (Include request for matching funds both in kind and monetary) We are considering the first 3 years to be the most costly and are hoping to receive $100.00 per household in order to meet our match funds. We do need ongoing financial support from the homeowners as at some point, when funding has run out, we will be self funding to keep our lake free of the weeds that today infest the shoreline and water surface. We also'receive credit for in kind North Lake IAVMP - Appendix A A- 11 matches of time such as monitoring progress. To date the Steering committee has dedicated in excess of 100 hours to these projects. If you are working with any Steering Committee member on any project efforts, it is important that all time is logged for credit IAVMP PowerPoint presentation: Beth Cullen Open floor for discussion and questions. Close meeting with thanks and support / Collect Letter of Support from each household attending North Lake IAVMP - Appendix A 12 A- 7/26/04 Steering Committee Meeting Agenda Attendees: Tom Jovanovich, Julie Cleary, Debra Hansen, Chuck Gibson, Wendy Honey, Beth Cullen Informational discussion on herbicides to consider: o Approximately 3-5 acres of milfoil 0 24D-higher toxicity -not for use in Salmon bearing streams Approx. Cost $600.00 per acre o Triclopere-less toxic -new approved approx. cost $1000.00 per acre -spot treat shallows o Map out Eurasian milfoil o Glysophate considered for Purple Loosestrife and yellow flag iris o Consider herbicide treatments matched with diver hand pulling o Discuss fabric barrier at the boat launch. Annual housekeeping o Need to set up lake patrol • Discuss further work on IAVMP application o How are we doing? On target! ■ Update on lake management fund o Need to get this account established. It was determined to request $50.00 from each lakeside resident. If we are able to collect 80% that would cover this year's expenses as well as a seed account for next year. ■ Discuss next RODEO application o To be applied by Whitworth Pest Solutions end of Aug or by Mid September. Approx. const $750.00 plus tax • Other items as needed: o Continue drafting IAVMP and working on application. o Get account established through NLIC treasurer, Simone ■ Next meeting after the first of September. North Lake IAVMP - Appendix A A- 13 9/02/04 Steering Committee Meeting Attendees: Wendy Honey, Debra Hansen, Julie Cleary, Chuck Gibson (6:30pm-8:00pm 90minutes) Items to discuss: • Review our notes/comments on the draft IAVMP • Review and discuss the application document (Wendy is still working on this) o Draft answers and discuss format to use • Review the attachments for the IAVMP o Letter of support and signatures o Meeting agendas and notes o Correspondence from the Dept. of Fisheries (Larry T. is to be mailing this to Wendy) regarding Rotenone restoration of North Lake in 1950's-1970's o Community feedback (ANY?) Non reported Next step is to forward completed draft to Beth Cullen at King County with completed application, attachments, and disc of pictures of North Lake, history, and 2004 lily eradication progress. This will be sent by 9/04/2004. Next meeting to be determined North Lake IAVMP - Appendix A A- 14 APPENDIX B Appendix B contains a copy of the Letter of Support distributed at the watershed -wide community meeting. Prior to distributing the letter and the signature sheets at the end of the watershed -wide meeting on June 28, 2004, King County staff and the Steering Committee members presented full details of the proposed treatment strategy and answered questions from those present at the meeting. In addition to signatures of support gathered at the end of the meeting, several Steering Committee members took sheets with them so they could explain the proposal to their neighbors and have them sign if they supported the proposal. There are 54 signatures in support of the proposed treatment plan presented in detail at the watershed -wide meeting and summarized in the Letter.of Support. North Lake IAVMP — Appendix B B-1 North Lake Noxious Weed Project Letter of Community Support June 28, 2004 By signing this letter, we, the members of the North Lake community, agree ❖ that Eurasian watermilfoil and other listed noxious aquatic weeds present a serious threat to the natural beauty, ecological integrity, and safe recreational activities on Spring Lake. ❖ that controlling the noxious weeds is an immediate priority and that ongoing monitoring and control should be a continuing priority into the future ❖ that community -based funding will be necessary to maintain a milfoil-free lake after initial eradication efforts ❖ that the proposed treatment strategy outlined below is reasonable but may be altered by experts at the Department of Ecology to achieve the greatest likelihood of success Recommended "Treatment Initial Treatment (Year 1) Treat infested areas with 2, 4 D or triclopyr Diver hand -pulling Install bottom barrier at boat ramp Community education — milfoil ID and survey methods training Year 2 Diver surveys Triclopyr/ 2,4-D for spot control as necessary Diver hand -pulling and dredging as necessary Bottom barrier maintenance Continued community education Ongoing management Continued community education Community survey Diver survey Diver hand -pulling as necessary Bottom barrier maintenance North Lake IAVMP — Appendix B B-2 APPENDIX C Appendix C contains product labels from aquatic herbicide formulations that are included in the proposed treatment plan for aquatic noxious weeds at North Lake. These include the labels for two aquatic glyphosate products (Rodeo and Aquamaster), one granular 2,4-D BEE product (Navigate), and one liquid 2,4-D DMA product (DMA*4IVM). AquaKleen is essentially the same formulations as Navigate by a different manufacturer. A liquid formulation of triclopyr (Renovate 3) is also included as possible treatment for Eurasian watermilfoil. North Lake IAVMP — Appendix C C-1 APPENDIX D Appendix D contains some historical documents regarding work done on North Lake over the years. The Rotenone records were requested from the Washington State Department of Fish and Wildlife, documenting application since 1950. Records of King County Noxious Weed Control Galerucella beetle release forms for purple loosestrife control. This appendix concludes with the herbicide application notices from the Whitworth Pest Solutions distributed to the lakeside residents in the summer of 2004 for fragrant water lily control work. North Lake IAVMP — Appendix D D-1