DPA 2002 Weed Committee Report

DPA Weed Committee Findings: A Summary of Eurasian Milfoil Control Technologies For the Dudley Pond Association Bob Smith, Acting President Oct.13, 2002 Committee Chair: Lili Griffin

Weed Committee Project Goals • Conservation Commission's mandate to look at non-chemical alternatives, a DPA Weed Committee was formed to examine all the available alternatives again (chemical and non-chemical) at the request of the acting president, Bob Smith. Mandate is 2 years from April 2002 - 2004.

• Ultimate goal of project - Update and research ALL available milfoil abatement technologies and present results to DPA. • Provide a unified recommendation to Conservation Commission of how the DPA wants to proceed regarding abatement.

Description • The project looked at the costs and benefits of milfoil abatement alternatives. A 10-year timeline was used for comparing costs. • Weed Committee was formed in July. Met on July 10&29, Sept. 19,26,Oct. 1&10. Unpaid group of ten volunteers.

Members were...

Chair: Lili Griffin Members: Ted Fiust, Sherry Fiust, Lili Griffin, Jackson Madnick, Elizabeth Newton, Grace Olin, Arlene Pollak, Elliot Pollak, Karen Lowery

Other Reasons for a Weed Committee?

• To track new regulatory trends which have an impact on Dudley Pond - We need to keep up with legal and regulatory winds of change. Health risks of herbicides, evolving technology improvements, and community input require ongoing study.

• To work as a liaison to many Community Entities who need to be involved in decision process • To educate the community. Another independent entity. (i.e., Risks are typically not communicated to public by people who provide those services. Balanced approach needed.)

• To act as an information source - Keeper of history and Lessons learned from past activities.

Who needs to be involved in decision-making process?

• On October 27, a vote by DPA residents will gauge where we are as a community. We need to bridge all concerns and come up with Mutually Agreeable Approaches that satisfy the following: ▫ Wayland Conservation Commission ▫ Residents with private drinking water wells ▫ Surface Water Quality Committee ▫ Wayland Water Department ▫ Mass. Dept. of Environmental Management ▫ Mass. Wildlife and Fisheries

How this Study Differs from Past Studies • This study updates information since the last study done in 1996.

• This study looks at multiple technology solutions. Past Studies looked at single technology solutions.

• This study uses a 10-year timeline to compare costs and for comparison of alternatives.

Why a 10-Year Plan? • Provides a more reliable basis for comparing alternatives - Long-term vs. Short-term value can be evaluated. • A 10-year plan will allow us to do needed economic forecasting and planning.

10-Year ofat Dudley Milfoil Mgmt.

10-Year HistoryHistory of Milfoil Management Pond, Wayland, MA Year

1992

1993

1994

1995

S

1996 S

1997 1998

1999

F(4)

S(2)

2000 2001 2002

Herbicide $17,000

$18,500 $0.00

$30,000

HandPulling $6,775(5) $28,025(6)

/Hydroraking NoAction



$8,000



(3)

(1). – 1980-1996 average chemical is $10,000 (included curly leaf). Milfoil discovered in Fall 1991.

(2). – Two treatments in Spring, continuous concentration of over 7 ppb.

(3) – Fungus infection due to weakened milfoil.

(4) - 1997 was a free partial outlet cove treatment.

(5) - Hydro-raking (6) - Hand-pulling



Sources of Past Funding DPA Wayland SWQC

49% SWQC

State Funding

26 % State Funding

26% DPA Funding Past Funding Sources for Weed Abatement Costs (1992-2002) Funding Sources DPA Wayland SWQC State Funding

Sum % $ 27,700 26% $ 52,600 49% $ 28,000 26% $ 108,300 100%

Avg. Annual 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 $ 2,770 $ 8,000 $ 200 $ 3,500 $ 6,000 $ 10,000 $ 5,260 $ 9,000 $ 6,575 $ 14,525 $ 12,500 $ 10,000 $ 2,800 $ 10,000 $ 10,000 $ 8,000 $ 10,830 $ 17,000 $ $ 6,775 $ 28,025 $ 18,500 $ $$ 30,000 $ $$ 8,000

Reliability of Future Funding Sources Changing policy positions on the frequency of herbicide usage in ponds affects our ability to get grants. After 10 years, still have a milfoil problem.

Innovation will be rewarded and encouraged.

• Wayland Conservation Commission • Wayland SWQC

• State Dept. of Environmental Management ALSO, other competing entities with more political pull may drain existing resources •Lake Cochituate now has a milfoil problem!

Information Collected for each Milfoil Control Technology Research information outline: 1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

Description of Control Alternative Effectiveness/Reliability (years) Advantages Disadvantages Equivalent Annual Costs Permit/Regulatory Requirements Appropriateness to Dudley Pond Needs Implementability Past Performance at Dudley Pond List of Experts/Points of Contact List of other New England Pond Sites that have used Control Technology Report was prepared titled.. “Research of Eurasian Milfoil Control Alternatives for DPA2002�

Description, Cont‟d Alternatives were grouped into 4 Main Categories...

•

Physical Controls

•

Mechanical Controls

•

Biological Controls

•

Chemical Controls

Initial list of Milfoil abatement options were taken from a December 1998, Washington State Dept. of Ecology, Lake Leland Integrated Aquatic Plant Management Plan. Other available alternatives added later as research progressed.

18 Potential 10-Year Alternatives ALT. No. 1A 1B 1C 2A 2B 2C 2D 2E 2F 3A 3B 4A 4B 4C 5A 5B 5C 6

DESCRIPTION Every 3rd Year Herbicide Application Every 4th year Herbicide Application with Volunteer Hand-Pulling Every 4th year Herbicide Application w/Paid Divers for Hand-Pulling 7 ft. Draw down Knockdown with Herbicide and 7 ft. Draw down 7 ft. Draw down and Suction Harvester Dredging Only Bottom Barrier Only Knockdown w/Herbicide and Bottom Barrier Contact Herbicide with Weevils Contact Herbicide with Sterile Carp Mechanical Harvester Rotovation Suction Harvester Organica Clean-Flo Greener Pastures No-Action

Alternatives are a Mix of Herbicide and Non-Herbicide Approaches • • • •

1 No-Action alternative for the purpose of comparison.

1 Herbicide-only approach 11 Non-herbicide approaches.

5 Combined Herbicide w/non-toxic approaches. Of these... ▫ 3 involved one herbicide (e.g. knockdown) application at year 1 of 10 year plan to create a smaller infestation that can be managed by other non-toxic approaches. ▫ 2 cycled herbicide w/ hand-pulling options (paid and volunteer divers) every 4th year over 10 year period. (minimizing applications and extending periods between applications by the usage of non-toxic approaches.

Alternatives Ranking Criteria • Cost Affordability - (5 = Lowest Cost, 1=Higher Cost • Environmental Impact - (5 = Low impact, 1= High impact.

• Effectiveness - (5=Very Effective, 1=Least Effective • Sustainability - (5=Most Sustainable, 1=Least Sustainable.

List of 9 of 18 Readily Available Alternatives • Readily Available - Are those that could be ranked using ranking criteria - not requiring a feasibility study, demo pilot, and currently legal in State of MA.) ALT. No. 1A 1B 1C 2D 2E 2F 4A 4B 6

DESCRIPTION Every 3rd Year Herbicide Application Every 4th year Herbicide Application with Volunteer Hand-Pulling Every 4th year Herbicide Application w/Paid Divers for Hand-Pulling Dredging Only Bottom Barrier Only Knockdown w/Herbicide and Bottom Barrier Mechanical Harvester Rotovation No-Action

STATUS         

What were “Readily Available” Alternatives?

• Herbicide Alternatives with or without HandPulling • Mechanical Harvester type Alternatives • Bottom Barrier Alternatives • Dredging Alternatives • No-Action Alternative • NO Biological Control or Clarifier or Drawdown Alternatives in this mix.

List of 9 of 18 NOT Readily Available Alternatives • NOT Readily Available - Those that could NOT be ranked using ranking criteria - They REQUIRE a feasibility study, demo pilot, or not currently legal in State of MA.) ALT. No. 2A 2B 2C 3A 3B 4C 5A 5B 5C

DESCRIPTION 7 ft. Draw down Knockdown with Herbicide and 7 ft. Draw down 7 ft. Draw down and Suction Harvester Contact Herbicide with Weevils Sterile Carp Suction Harvester Organica Clean-Flo Greener Pastures

STATUS Needs Feasibility Study Needs Feasibility Study Needs Feasibility Study Needs Pilot Test Not Permitted in MA. Not Permitted in MA Needs Research on Effect.

Needs Research on Effect.

Needs Research on Effect.

What made them NOT “Readily Available”?

Alternatives w/potential that could NOT be ranked

• Greener Pastures, Organica, and Clean-Flo needed additional research on their effectiveness.

• The weevils alternative requires a pilot test to determine if effective (ecology-specific).

• The Sterile Carp and Suction Harvester alternatives are not yet permitted or under review for use in Massachusetts.

Cost Ranking Factor Alt. No. Potential Future Alternatives 6 3B 3A 2A 2B 5C 1A 1B 1C 5A 2C 2F 5C 4A 4B 4C 2E 2D

No-Action Sterile Carp Contact Herbicide w/Weevils Draw down - 7 feet Herbicide w/ 7ft. Draw down Greener Pastures Herbicide Only, Every 3rd Year Herbicide w/Volunteer Diver Hand-Pulling Herbicide w/Paid Divers Hand-Pulling Organica Draw down - 7 feet w/Suction Harvester Herbicide w/Bottom Barrier Clean-Flo Mechanical Harvester Rotovation Suction Harvester Bottom Barrier Only Dredging Only

Cost Rank Est. Avg. Annual 5=Good,1=Poor 10-Yr. Costs Costs 5 5 5 5 5 5 5 4 3 3 3 2 1 1 1 1 1 1

$0 $29,500 $72,000 $90,000 $106,000 $120,000 $120,000 $154,000 $195,000 $210,000 $301,000 $285,000 $500,000 $500,000 $500,000 $500,000 $1,500,000 $2,250,000

$0 $2,950 $7,200 $9,000 $10,600 $12,000 $12,000 $15,400 $19,500 $21,000 $30,100 $28,500 $50,000 $50,000 $50,000 $50,000 $150,000 $225,000

Top 3 Cost-Effective Alternatives 10-Year Totals • No-Action• Sterile Carp• Contact Herbicide w/Weevils-

$0 $29,500 $72,000

Sustainability Ranking Factor Alt. No. Potential Future Alternatives 2D 2F 2E 6 1A 1B 1C 4A 4B 5C 2A 2B 2C 3A 3B 4C 5A 5C

Dredging Only Herbicide w/Bottom Barrier Bottom Barrier Only No-Action Herbicide Only, Every 3rd Year Herbicide w/Volunteer Diver Hand-Pulling Herbicide w/Paid Divers Hand-Pulling Mechanical Harvester Rotovation Greener Pastures Draw down - 7 feet Herbicide w/7ft. Draw down Draw down -7 feet w/Suction Harvester Contact Herbicide w/Weevils Sterile Carp Suction Harvester Organica Clean-Flo

Sustainability 5=Good,1=Poor 3.0 2.0 1.5 1.0 1.0 1.0 1.0 1.0 1.0 ? ? ? ? ? ? ? ? ?

Comments Removes source of nutrients for many years Barrier lasts for 5 years or more Barrier lasts for 5 years or more Scored Same as No-Action Scored Same as No-Action Scored Same as No-Action Scored Same as No-Action Scored Same as No-Action Scored Same as No-Action Needs Research on Sustainability Needs Feasibility Study Needs Feasibility Study Needs Feasibility Study Needs Pilot Study - Sustainable for 10 years to eternity Not Permitted in MA to Date - Sustainable for 5 years Not Permitted in MA to Date Needs Research on Sustainability Needs Research on Sustainability

Top 3 Sustainable Alternatives 10-Year Totals • Dredging Only• Herbicide w/Bottom Barrier • Bottom Barrier Only -

$2.25M $285K $1.5M

Effectiveness Ranking Factor Alt. No. Potential Future Alternatives 2D 1A 1C 1B 2F 2E 4A 4B 6 5C 2A 2B 2C 3A 3B 4C 5A 5C

Dredging Only Herbicide Only, Every 3rd Year Herbicide w/Paid Divers Hand-Pulling Herbicide w/Volunteer Diver Hand-Pulling Herbicide w/Bottom Barrier Bottom Barrier Only Mechanical Harvester Rotovation No-Action Greener Pastures Draw down - 7 feet Herbicide w/7ft. Draw down Draw down - 7 feet w/Suction Harvester Contact Herbicide w/Weevils Sterile Carp Suction Harvester Organica Clean-Flo

Effectiveness 5=Good,1=Poor 4.0 3.0 3.0 2.0 2.0 1.5 1.0 1.0 0.0 ? ? ? ? ? ? ? ? ?

Comments Removes source of nutrients for many years Proven Effective Hand-Pulling is effective on small infest.

Volunteer Divers less effective than paid Bottom Barriers difficult to maintain Bottom Barriers difficult to maintain Requires continuous effort Requires continuous effort Least Effective - Do Nothing Needs Research on Effectiveness Needs Feasibility Study Needs Feasibility Study Needs Feasibility Study Needs Pilot Study - Past Experience may be flawed Not Permitted in MA to Date - Highly Effective Not Permitted in MA to Date - 6x's more efficient Needs Research on Effectiveness - Needs backing up Needs Research on Effectiveness - Stowe/Hudson pilot

Top 3 Most Effective Alternatives 10-Year Totals • Dredging• Herbicide Only, Every 3rd Year• Herbicide w/Paid Divers Hand-Pulling-

$2.25M $120K $195K

Environ. ImpactEnviron.

Ranking Factor Impact Alt. No. Potential Future Alternatives 6 1B 1C 1A 4A 2D 2E 2F 4B 5C 2A 2B 2C 3A 3B 4C 5A 5C

No-Action Herbicide w/Volunteer Diver Hand-Pulling Herbicide w/Paid Divers Hand-Pulling Herbicide Only, Every 3rd Year Mechanical Harvester Dredging Only Bottom Barrier Only Herbicide w/Bottom Barrier Rotovation Greener Pastures Draw down - 7 feet Herbicide w/7ft. Draw down Draw down - 7 feet w/Suction Harvester Contact Herbicide w/Weevils Sterile Carp Suction Harvester Organica Clean-Flo

5=Good,1=Poor 4.0 3.5 3.5 3.0 2.0 1.0 1.0 1.0 1.0 ? ? ? ? ? ? ? ? ?

Comments Non-toxic approach, little disruption Minimal-toxic approach, little disruption Minimal-toxic approach, little disruption Assumes least toxic herbicide used, little disruption Non-toxic, Only affects surface of pond Short-term impacts are high, drain pond. Long-term low Affects fish, macrophytes, other species of plants Affects fish, macrophytes, other species of plants Stirs up sediments, non-selective Needs Research on Environ. Impacts Needs Feasibility Study of Environ. Impacts Needs Feasibility Study of Environ. Impacts Needs Feasibility Study of Environ. Impacts Non-toxic, Very low environmental impacts Non-toxic, Very low environmental impacts Not Permitted in MA to Date Needs Research on Environ. Impacts Needs Research on Environ. Impacts

Top 3 Low Environ. Impact Alternatives 10-Year Totals • No-Action

$0

• Herbicide w/Volunteer Diver Hand-Pulling

$154K

• Herbicide w/Paid Divers Hand-Pulling

$195K

All Ranking Factors

Alt. No. Potential Future Alternatives 6 No-Action 1A Herbicide Only, Every 3rd Year 1B Herbicide w/Volunteer Diver Hand-Pulling 1C Herbicide w/Paid Divers Hand-Pulling 2D Dredging 2E Bottom Barrier Only 2F Herbicide w/Bottom Barrier 4A Mechanical Harvester 4B Rotovation 3A Contact Herbicide w/Weevils 3B Contact Herbicide with Sterile Carp 4C Suction Harvester 5A Organica 5C Clean-Flo 1D Greener Pastures 2A Draw down - 10 feet 2B Herbicide w/6ft. Draw down 2C Draw down - 6 feet w/Suction Harvester

10-Yr. Costs $0 $120,000 $154,000 $195,000 $2,250,000 $1,500,000 $285,000 $500,000 $500,000 $80,000 $56,000 $500,000 $210,000 $500,000 $120,000 $90,000 $118,000 $233,000

With Cost 9 12 10.5 10.5 9 4.5 6 5 4 ? ? ? ? ? ? ? ? ?

Final Results of Ranking of 9 Standing Alternatives

• Using all ranking factors, 10-year cost, sustainability, environmental impact and effectiveness. The highest scores came from the following: ▫ Herbicide only, Every 3rd year. ▫ Herbicide every 4th year w/Volunteer Hand-Pulling in out years ▫ Herbicide every 4th year w/Paid Hand-Pulling in out years.

ALT 1A -Herbicide Only Every 3rd Year rd

Alternative 1A - Every 3 Year Herbicide Application Herbicide







$30,000

$0

$0

2003

2004

2005

NoAction Annual Costs Year









$30,000

$0

$0

2006

2007

2008







$30,000

$0

$0

2009

2010

2011

$30,000 x4 

$0 x 5

$30,000

$0

$120,000

2012

2013

10-Yr Total

Advantages - Effective for large infestations. Minimizes herbicide applications to every 3 years.

Disadvantages - Regrowth occurs in short-term and may have negative impact to human health and the environment in long-term.

Cost Basis - 1999 Herbicide application with two treatments in Spring, continuous conc. > 7 ppb. Frequency is acceptable based on 10-year history.

ALT 1B -Herbicide Every 4th Year w/

Volunteer Hand-Pulling Alternative 1B – Every 4th year Herbicide Application with Volunteer Hand-Pulling Herbicide

 





$30,000

$8,000

$8,000

$8000

2003

2004

2005

2006

HandPulling Annual Costs Year



 





$30,000

$8,000

$8000

$8000

2007

2008

2009

2010

$30,000x3 



$8,000x8

$30,000

$8,000

$8000

$154,000

2011

2012

2013

10-Yr Total

Advantages - Effective for large infestations. Minimizes herbicide applications to every 4 years. Pulls community together. Scuba clubs interested in participating at this time.

Disadvantages - Regrowth occurs in short-term and may have negative impact to human health and the environment in long-term. Manpower intensive but proven to be feasible for small infestations. Historical usage has been after two years of no-action resulting in limited effectiveness due to massive regrowth.

Cost Basis - 2002 Costs for Volunteer Hand-Pulling, 1999 herbicide costs from 10-year history.

ALT 1C -Herbicide Every 4th Year w/

Paid Diver Hand-Pulling th

Alternative 1C – Every 4 year Herbicide Application w/Paid Divers for Hand-Pulling Herbicide









$30,000

$8,000

$10,000

$12,000

2003

2004

2005

2006

HandPulling Annual Costs Year











$30,000

$8,000

$10,000

$12,000

2007

2008

2009

2010

$30,000 x3 



$105,000

$30,000

$8,000

$10,000

$195,000

2011

2012

2013

10-Yr Total

Advantages - Effective for large infestations. Minimizes herbicide applications to every 4 years by use of paid divers. Paid divers are more effective than volunteer diver teams Disadvantages - Regrowth occurs in short-term and may have negative impact to human health and the environment in long-term. Manpower intensive but proven to be feasible for small infestations. Historical usage has been after two years of no-action resulting in limited effectiveness due to massive regrowth.

Cost Basis - $40/hr x 7 hrs/day per diver x 3 divers x 5 days = $4,000, 2 weeks, 3, weeks, then 3 weeks again cycle.

What have we learned from this process?

•All readily available alternatives are not long-term alternatives.

•Sustainable cheaper alternatives require R&D, feasibility or pilot testing.

•Cost is a VERY limiting factor in selecting alternatives.

For instance, dredging scored highest when cost is not a factor.

•We need to take some risks and allocate a certain amount of our budget to R&D if we want to have sustainable alternatives!!!

Why Should We have an R&D Budget?

• R&D alternatives are cheaper than herbicide  Carp is half the cost of the herbicide alternatives (10-yr).  Weevils is 2/3 the cost of the herbicide alternatives (10-yr).  Drawdown is 2/3rd the cost of herbicide alternatives (10-yr)

• Carp is legal in the state of Connecticut. It is not legal in MA but may be in 2004 if Mass. DEM study allows. There are examples of successful sites at Green Lake IL, Silver Lake WA, Green LakeSeattle WA. (See handout).

• The weevil has been successful at Lake Mansfield - Mansfield VT, Lower Goose Pond - Berkshire MA, Houghton Lake -MI Weevil needs a $7000 pilot test. (See handout).

• Drawdown has been successful at Indian Lake- Worcester MA, East Lake Waushacum - Sterling MA, Lake Singleton - Sutton MA, Otis Lake Cape Cod, MA, Lake Spencer- Spencer MA

R&D ALT 3B - Sterile Carp Alternative 3B - Sterile Carp Sterile Carp

 ($14,500) 

No-Action Annual Costs Year

 ($7,000)

$14,500 2003







$2000 $2000 $2000 $2000 2004

2005

2006

2007

$7,000 2008

See Cost Basis 









$0 x 9

$0

$0

$0

$0

$0

$29,500

2012

2013

2009 2010 2011

Advantages - In long-term most economical in out years beyond study timeframe.

Disadvantages - Not permitted in Massachusetts at this time. Next year should have Mass. Study complete to determine if will allow usage.

Cost Basis - 15 carp per acre x 30 acres x $10 each. = $4500 +shipping and consulting ($10,000), Need to introduce more carp after 5 years (Estimate based on not full replacement but 50% of prior add rate).

10-Yr Total

R&D ALT 3A -Contact Herbicide w/Weevils Alternative 3A - Contact Herbicide with Weevils Contact Herbicide

Weevils Middfoil ™

 ($10,000)  ($7,000)

$10,000 x1  ($30,000) 

NoAction Annual Costs Year

 ($20,000)

$57,000 













$0 x 8

$17,000

$30,000

$0

$20,000

$0

$0

$0

$0

$0

$0

$0

$67,000

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

10-Yr Total

Advantages - If test pilot is successful, is a long-term solution. Nontoxic alternative in long-term.

Disadvantages - Needs a test pilot to determine if will thrive. Could lose a year requiring a switch to another alternative if not successful.

Cost Basis - Contact herbicides are 1/3 cost of systemic herbicides. Contact herbicide instead of systemic so can maintain healthy milfoil (Bob Hartzel w/Geosyntec Consultants 978-263-9588). $1/bug, Application rates based on typical rates applied at other ponds of similar size. If timed correctly, may be able to cut costs to $0.50/bug.

R&D ALT 2B - Herbicide w/ 7 ft. Draw down Alternative 2B - Knockdown with Systemic Herbicide and 7 ft. Draw down Herbicide

 ($30,000)

$30,000 x1  ($72,000)

7 ft Draw down



NoAction Annual Costs Year

 ($1,000)

 ($1,000) 

 ($1,000) 

 ($1,000) 

$72,000x1 $1000x4 

$0x6

$30,000

$72,000

$0

$1000

$0

$1000

$0

$1000

$0

$1000

$0

$106,000 $34,000(1)

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

10-Yr Total

(1) If initial upfront costs funded by state (20% Matching Grant).

Advantages - Nontoxic alternative. Allows for cleaning and raking of pond during draw down.

Disadvantages – Not readily available, needs a feasibility study.

Cost Basis - Two estimates. One from Bay State Environmental at $80,000 and another from Mass Dams and Safety Office of $72,000. Other year costs of $1000 are based on some costs associated with monitoring draw down. Herbicide Costs based on 1999 costs.

6 - Ft. Drawdown

8 - Ft. Drawdown

Weed Committee Recommendations • Herbicide treatment in Spring 2003.

• Form a Grant Writing Committee • Reconvene Weed Committee in Spring – meet every month at a minimum.

• Actively pursue funds, grants, revenue to R&D alternatives.

Summary of Current Status

• We have a large infestation of milfoil.

• After 10 years of management it has not been abated. Spent $108,300 to date.

• It appears that readily available alternatives do not provide long-term management.

• Available funding will decrease in future unless we actively pursue other sources.

• We need to manage the Dudley Pond with herbicides every 3 years but, in the interim, use available funds for R&D options so that sustainable long-term solutions are possible.

Update on Aquatic Herbicides - Nov. „02 •

Rodeo/Pondmaster TM (Glyphosphate) - Recently in the news as being a potential endocrine disrupter (lab results and worker studies).

•

New Herbicide under Experimental Use Permit - 2,4,D being phased out and replaced with Renovate TM (Triclopyr) which is less mobile in the environment than 2,4,D was. Triclopyr is less soluble than Sonar and is preferrable because less likely to have off-site impacts to groundwater quality but will cost more than Sonar.

•

Nautique TM (elemental copper) is cheaper than Sonar TM (Fluridone) but would need to be used 2x’s because is a contact herbicide (not systemic). Also, is non-toxic if have sufficient alkalinity in Dudley Pond. Need to get alkalinity information.

•

Trying to resolve facts behind Sonar’s risks which is causing anxiety by certain community members - initiating a FOIA w/EPA to get information on independent study done on Sonar

by Dynamic, Corp. Was it the inerts that caused carcinogenity, teratogenity, etc. in Dynamic Corp. and was formulation changed?

•

Looking for alternatives to reduce the costs of herbicide applications, so that have funds to explore other alternatives. Landscaping companies, applicators from New York, Connecticut, or New Jersey?