Comment submitted by Dr. Steven R. Booth, Wilapa Bay Grays Harbor Oyster Grower Association

Although the Willapa Bay / Grays Harbor Oyster Growers Association recognizes that carbaryl may no longer be necessary for the certain uses described here, we wish to remind the producers and sellers of carbaryl, as well as the general public, that the pesticide remains an important and safe pest management tactic for many crops. For example, in the past 60 years the density and distributions of two species of burrowing shrimp have increased greatly in Willapa Bay and Grays Harbor of Washington State, likely due to a loss of seasonal freshwater influx since the damning of the Columbia River and a decrease in key predators. Burrowing shrimp live in and soften the mud, causing shellfish and other members of the benthic community to sink and die. We have investigated a myriad of chemical, mechanical, and biological alternatives, but carbaryl remains the only tool that can effectively remove the shrimp from selected commercial ground with minimal and transitory impact to other organisms. Without the use of carbaryl, this local industry would be greatly damaged and hundreds of jobs would be lost. High quality shellfish products depend on high quality water and both would likely decline without the vigilant oversight provided by the shellfish growers.