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HomeMy WebLinkAboutAdditional Materials 5.22.2025 May 22, 2025 Massachusetts Division of Fisheries & Wildlife Natural Heritage & Endangered Species Program 1 Rabbit Hill Road Westborough, MA 01581 Yarmouth Conservation Commission 1146 Route 28 South Yarmouth, MA 02664 Re: Response to Request for Additional Information Applicant: Will Rubenstein, Camp Wingate Kirkland Project Location: Camp Wingate Kirkland, Elisha’s Pond NHESP File No.: 25-19462 MA DEP File No.: 83-2479 Heritage Hub ID: RC-93395 Dear Misty-Anne Marold and Jesse Leddick, In preparing our response to your request for additional information regarding the proposed vegetation management at Elisha’s Pond, we consulted with SePro (the manufacturer of Sonar products). While we were unable to obtain specific test results related to Plymouth gentian (Sabatia kennedyana) from SePro, we were able to obtain additional information from Massachusetts Department of Conservation and Recreation’s (DCR) Lakes and Ponds Program. We confirmed several ponds with conditions suitable for Plymouth gentian, that have recently been, and/or are currently being treated with fluridone. We analyzed the strategies for treating and monitoring those ponds and adapted our proposed management protocol to address concerns about potential impacts of fluridone, as well as hand-removal/raking activities on Plymouth gentian populations. Additionally, we conducted a visual survey of the littoral areas of Elisha’s pond on May 12, 2025. The data from this survey documents the current observed populations of Plymouth gentian at Elisha’s Pond, which will serve as a baseline for monitoring the species throughout and after management. Submit an Analysis of Fluridone Impacts to Plymouth Gentian: Based on available botanical surveys and herbicide application data, it is our understanding that fluridone has little to no adverse impact on the state-listed species Plymouth gentian when applied at low concentrations—specifically, at or below 5.0 ppb over the course of the growing season, with applications not exceeding a maximum of 20 ppb. Notably, Long Pond in Centerville, MA has been consistently treated with fluridone (Sonar) over at least the past ten years, indicating that Plymouth gentian persists through low-dose treatments of fluridone. The Comparison 2016 to 2020 table within the November 3, 2020 survey may suggest that fluridone impacts Plymouth gentian, as it shows a decline in five out of seven populations, with the establishment of one new population. However, a closer examination indicates that these declines are more strongly correlated with site disturbances rather than fluridone exposure. Documented disturbances include hydrological changes, shoreline alterations, and increased human activity—all of which are known to adversely affect shoreline species. The 2020 survey clearly notes that in areas with minimal to no anthropogenic disturbance, Plymouth gentian populations have persisted and, in some areas, have increased. The 2020 survey concludes within their Impact Analysis “that the herbicide treatments used to control the spread of Hydrilla at Long Pond is not having a negative effect on State-Listed species, nor on Sabatia kennedyana and Lachnanthes caroliniana populations documented in the pondshore community in the recent surveys.” This finding is reinforced within the Rare Plant Survey Report in 2022. It stated, “there was no evidence of negative impact in the appearance of the plants or plant parts found,” and indicates that shoreline disturbance from human activity appears to be the main cause of habitat disturbance along the waters edge. Product Information The proposed systemic herbicide is SonarOne / Sonar H4C, which are pelletized, slow-release formulations of fluridone. The revised application rate is consistent with concentrations used at Long Pond. SonarOne’s slow-release formulation minimizes the risk of acute exposure to non-target species when applied in controlled dosages while effectively targeting Hydrilla (Hydrilla verticillate), which is more sensitive to fluridone. While Sonar is proposed due to its selective action and low-dose, long-term efficacy, other methods, including alternative chemicals, were considered. However, these alternatives present higher risks of non-target damage or require more frequent applications, making fluridone the most suitable option under current site conditions. The alternatives were included in our original NOI filing, but are also summarized below with more specific reference to potential impact on Plymouth gentian and other native vegetation. Alternatives Assessment: Do Nothing: Not recommended If there are no efforts to remove Hydrilla from Elisha’s Pond, the existing population will continue to grow rapidly, effectively shading out populations of Plymouth gentian and other native vegetation that is submerged or partially submerged. Mechanical Harvesting/Hydro-raking: Not recommended Mechanical harvesting and Hydro-raking can be effective methods for controlling submerged aquatic plants. However, this approach is not recommended for managing Hydrilla in Elisha’s Pond. These methods can cause significant plant fragmentation, which would contribute to the spread of Hydrilla and allow it to further invade the waterbody. In addition to this, there is no boat ramp or suitable access point for launching this type of machinery in the pond, further limiting its feasibility. Suction Harvesting: Not recommended Suction harvesting can be an effective method for Hydrilla populations with low to moderate densities. This approach is somewhat non-selective especially in cases of high turbidity, as the Hydrilla grows amongst native vegetation, resulting in the removal and minimal fragmentation of both non-native and native vegetation. This approach is costly, requiring a filtering system to capture Hydrilla tubers and turions, providing means for divers to stay on course in turbid waters, other equipment and equipment features, and contractor mobilization. Water Level Drawdown: Not recommended Water level drawdown is a process where the water level is lowered by gravity, pumping, or siphoning. The water is held at a reduced level for a period of time, generally within the winter months. This is not a feasible control method for controlling Hydrilla in Elisha’s Pond. The pond does not have a water level control structure which would facilitate the drawdown of the water, and the lower water levels would negatively impact the populations of Plymouth gentian. Alternate Chemical Treatments: Besides fluridone, two alternate chemicals (diquat and endothall) are recommended in the Rapid Response Plan for Hydrilla in Massachusetts prepared for the Massachusetts Department of Conservation and Recreation. Diquat offers rapid treatment but is non-selective and has demonstrated higher toxicity to non-target aquatic plants. It also quickly absorbs to and is held by clay and peat – therefore is ineffective in muddy waters. It is not systemic, and therefore does not transfer to the roots and tubers of Hydrilla, making it ineffective in eradicating Hydrilla. It may negatively affect Plymouth gentian populations as much as, or more than, Hydrilla populations. Endothall is a contact herbicide often used to control Hydrilla. However, it is not systemic, and therefore does not transfer to the roots and tubers of Hydrilla, making it more effective in controlling, rather than eradicating Hydrilla. Other aquatic herbicides evaluated were Glyphosate and Imazopyr: Glyphosate is generally used in emergent settings and is less effective in submerged applications. It also has broader non-target risks than fluridone. Since Plymouth gentian is an emergent species and Hydrilla is submerged, it could be more negatively affected by glyphosate than Hydrilla. Imazapyr is not recommended for control of submersed aquatic species, and is a greater risk to non-target vegetation. The chemical doesn't break down as quickly as fluridone and persists for much longer in the environment. Submit Plan to Avoid Impacts during Manual Removal After chemical treatment(s), a substantial amount of dead plant material could accumulate within the pond which can reduce access to oxygen and sunlight for native flora and fauna in the pond and interfere with swimming and boating activity at Camp Wingate Kirkland and residential properties. This dead plant material may be removed through hand-harvesting, aided by rakes and nets, to prevent oxygen depletion of the pond. Raking will be limited to already disturbed areas such as the Swimming beach at Camp Wingate, in order to avoid disturbance of shoreline vegetation including observed populations of Plymouth gentian. The plant material will be bagged and taken to a transfer station, not a composting facility. We are also including a copy of our revised vegetation management protocol and NOI application narrative which includes more detailed information about vegetation monitoring strategies and our proposed lower levels of fluridone applications. If you should have any questions, please do not hesitate to contact us at (508) 477-1346 or email atanner@jenickstudio.com and nick@crawfordlm.com. Respectfully, Angela Tanner Landscape Architect, PLA, ASLA Crawford Land Management References State-Listed Species Habitat Assessment and Survey Plymouth Gentian (Sabatia kennedyana Fem.); Long Pond, Centerville MA. Submitted By: The Town of Barnstable; Dated: October 3, 2016 State-Listed Species Habitat Assessment and Survey Plymouth Gentian (Sabatia kennedyana Fem.), Redroot (Lachnanthes caroliniana), and Terete Arrowhead (Sagittaria teres), Long Pond, Centerville MA; Submitted By: The Town of Barnstable; Dated: November 3, 2020. Rare Plant Survey Report for Long Pond, Centerville MA; Submitted By: John Burns, Burns Environmental; Dated: October 15, 2022. UF/IFAS Center for Aquatic and Invasive Plants. (n.d.). Background on registered aquatic herbicides. University of Florida Institute of Food and Agricultural Sciences. https://plants.ifas.ufl.edu/control-methods/chemical-control/background-on-registered- aquatic-herbicides/ May 22, 2025 Massachusetts Division of Fisheries & Wildlife Natural Heritage & Endangered Species Program 1 Rabbit Hill Road Westborough, MA 01581 Yarmouth Conservation Commission 1146 Route 28 South Yarmouth, MA 02664 Re: Plymouth Gentian Population Survey Applicant: Will Rubenstein, Camp Wingate Kirkland Project Location: Camp Wingate Kirkland, Elisha’s Pond NHESP File No.: 25-19462 MA DEP File No.: 83-2479 Heritage Hub ID: RC-93395 Conducted on May 12, 2025 for Camp Wingate Kirkland by Crawford Land Management Species of Note - Plymouth Gentian (Sabatia kennedyana) Summary of Survey and Methodology On the date of the survey, the weather was mostly sunny with temperatures in the mid-60s. The shoreline of Elisha’s Pond was visually observed by canoe and by foot. The shoreline is partially developed with a few docks and swim beach areas and partially naturalized. The entire shoreline was visually observed, with special attention paid towards open sandy areas which provide a suitable habitat for Plymouth gentian. The majority of Plymouth gentian plants were found along the waters edge, however there were some occurrences above small inland banks and in water up to 30 cm in depth. At each location Plymouth gentian was observed, 10-foot plots were determined along the waters edge and population data was recorded using GPS software. A survey point was recorded within each plot, to collect species density (Dense, Moderate, Sparse, Trace) and categorized by growth stage (Basal, Vegetative). Survey Findings Plymouth gentian is present in multiple locations around Elisha’s Pond. The total population appears to be healthy and sustaining. Please see attached map titled Observed Plymouth Gentian along with representative photographs. One of the largest shoreline populations is noted to be along the eastern shoreline, north of Camp Wingate Kirkland’s established beach area. Each 10-foot plot contained a density of Trace to Sparse. Many basal rosettes and vegetative plants were visually observed (photos #1 - #4). This shoreline appears to remain relatively undisturbed. Along the southeast shoreline, abutting the parcel owned by the Town of Yarmouth, each 10- foot plot contained a density of Trace to Sparse. There were 2 specimens that still had seed heads from last fall. Many basal rosettes and vegetative plants were visually observed (photos #5 - #6). This shoreline appears to remain relatively undisturbed. Along the southern shoreline, mostly abutting private property to the west of the parcel owned by the Town of Yarmouth, each 10-foot plot contained a density of Trace to Sparse. Many basal rosettes and vegetative plants were visually observed (photo #7). The shoreline appears to be altered on an occasional to moderate basis. There is a very small stretch of existing shoreline to the immediate west of this population that has been significantly altered by human activity. Along the western shoreline, abutting private property, are two distinct locations of existing Plymouth gentian. Each 10-foot plot contained a density of Sparse to Moderate. Many basal rosettes and vegetative plants were visually observed (photos #8 - #15). The shoreline appears to be relatively undisturbed, at the time of survey. Along the northeast shoreline, each 10-foot plot contained a density of Trace to Sparse. Many basal rosettes and vegetative plants were visually observed (photos #16 - #18). There are more competing species within this area than in other areas. This shoreline appears to remain relatively undisturbed. No Plymouth gentian was observed in any other location of Elisha’s Pond. Factors that impeded growth of Plymouth gentian consisted of unsuitable habitat, dense populations of other existing native plants, as well as anthropogenic factors such as existing beach areas. Representative Photos Photo #1 Photo #2 Photo #3 Photo #4 Photo #5 Photo #6 Photo #7 Photo #8 Photo #9 Photo #10 Photo #11 Photo #12 Photo #13 Photo #14 Photo #15 Photo #16 Photo #17 Photo #18 W YarmouthRdC S X Tr a n s p o r tat i o n R a i l r o a d El i s h a P o n d D rW YarmouthRdPortsmouth T e r Elishas Pond El i s h a P o n d D r Maxar, Microsoft, Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, (c) OpenStreetMap contributors, and the GIS User Community 0 0.02 0.040.01 Miles ³ Legend Property Parcels Observed Plymouth Gentian 2025-05-12 ELISHA'S POND - OBSERVED PLYMOUTH GENTIAN DATE OF SURVEY: 05/12/2025 Elisha’s Pond Aquatic Vegetation Management Management Plan & Narrative 88 Route 6A, Suite 2B Sandwich MA 508.477.1346 info@crawfordlm.com WWW.CRAWFORDLM.COM PREPARED FOR Camp Wingate Kirkland 79 White Rock Road Yarmouth, MA 02675 DATE April 10, 2025 May 22, 2025 (Revision 1) 2 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN INTRODUCTION Elisha’s Pond is a 10.3 acre freshwater pond with a maximum depth of 20 feet located in Yarmouth, MA. The pond is a valuable resource to the shoreline residents, including the campers and staff of Camp Wingate Kirkland. The pond is primarily used for recreational activities involving swimming, the use of non-motorized watercraft, and wildlife viewing. Elisha’s Pond is within the Natural Heritage and Endangered Species Program’s (NHESP) mapped Priority Habitat and Estimated Habitat. CAMPCAMP WINGATEWINGATE SWIM AREASWIM AREA ELISHAS ELISHAS PONDPOND CAMP WINGATECAMP WINGATE ELISHAS POND RECREATIONAL AREAELISHAS POND RECREATIONAL AREA Great Pond: Yes (On State List) Surface Area: 10.3 Acres Max. Depth of Pond: 20’ 3 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN Native Aquatic Macrophyte Species Observed in March / May 2025 Common name Scientific name Common bladderwort Coontail (Hornwort) Hedge hyssop Low Water-milfoil Moss Pipewort Plymouth gentian Swamp loosestrife Watershield Yellow Pond Lily Utricularia vulgaris Ceratophyllum demersum Gratiola Myriophyllum humile Musci Eriocaulon aquaticum Sabatia kennedyana Decodon verticillatus Brasenia schreberi Nuphar lutea Non-Native Aquatic emergent botanic species observed in March / May 2025 None observed EXISTING CONDITIONS In recent years, the growth of hydrilla (Hydrilla verticillata) has become an increasing nuisance for Camp Wingate Kirkland’s staff and campers along with shoreline residents. Each year, campers have noticed the invasive plant encroaching into swimming areas, where it can have a significant impact on their experience. The hydrilla can create obstacles in the water, making recreational activities more difficult and less enjoyable. In some areas, swimmers may even get tangled in the aquatic plant, which not only disrupts activities, but also raises safety concerns. Approximately 5.3 acres of the pond is invaded, which represents about 51% of the total pond area (see diagram on page 4). Photos taken from Camp Wingate Kirkland’s swim area, March 2025. 4 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN PROPOSED AQUATIC VEGETATION MANAGEMENT APPROACH Management Description Hydrilla is a federally listed aquatic invasive species under the U.S. Code of Federal Regulations (Federal Noxious Weed). Currently, hydrilla is less widespread in New England than other regions of the country, so it is imperative to rapidly respond to identified populations. Hydrilla’s primary method of reproduction and spread occurs through production of tubers, turions, seeds and by fragmentation. Over time, through competition and shading, hydrilla can quickly become the dominant plant growing within an area. Dense populations of hydrilla can also promote excessive growth of cyanobacteria, potentially leading to harmful cyanobacteria blooms. The proposed plan for hydrilla management within Elisha’s Pond includes a combination of chemical and physical/mechanical methods. Based on the current density and growth habits of hydrilla, the use of a MDAR- and EPA-registered aquatic herbicide is warranted to control the population of hydrilla throughout the entire pond (DCR, Figure 3. Decision Tree for the Control of Hydrilla). The proposed chemical, fluridone, has been shown to be effective in controlling hydrilla populations throughout the northeastern United States, at doses that are low enough to allow most native plant species to recover and persist. It has been used in other Massachusetts freshwater ponds for hydrilla control, including Long Pond in Barnstable. Fluridone will be applied as specified on the product label, utilizing slow release pellets that are broadcast with a pelletized spreader. The applications will be done from a CLM Jon Boat launched from the Camp Wingate swimming area beach. Careful attention will be put towards safety measures, proper notification of chemical application timing, and ensuring a safe timeline for water-related recreational activities. The Jon boat will be thoroughly cleaned with hot water maintained at 104 degrees for at least 60 seconds on the entire surface area. The boat will be allowed to dry before the boat is transported off-site. (See General Prevention Procedure by the Stop Aquatic Hitchhikers! campaign) Any equipment used for vegetation removal or vegetation surveys will also be cleaned prior to transport from site. A maximum of three chemical treatments will occur, starting at the beginning of the growing season in May or June. Subsequent treatments will be performed following the product label specifications, paying special attention to the amount (ppb) of active ingredient that is applied. Testing the water for chemical levels, after each treatment, will also be performed following instructions depicted on the product label. Hydrilla populations will be assessed prior to scheduling chemical treatments to ensure that chemical treatment continues to be the best management practice. After chemical treatment(s), a substantial amount of dead plant material could accumulate within the pond. This dead plant material may be removed through hand-harvesting, aided by rakes and nets, to prevent oxygen depletion of the pond. Raking removals will be selective to only non-native/invasive aquatic species. Raking will be limited to already disturbed areas such as the Swimming beach at Camp Wingate, so as to avoid disturbance of shoreline vegetation including observed populations of Plymouth gentian (Sabatia kennedyana). The plant material will be bagged and taken to a transfer station, not a composting facility. 5 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN MONITORING METHODOLOGY: The pond will be monitored annually, both before and after treatments, to evaluate the effectiveness of fluridone on the hydrilla population. Monitoring will assess the tuber presence, plant growth, and overall density. Monitoring will also include an annual aquatic vegetation survey of the shoreline, including the state-listed Sabatia kennedyana (Plymouth Gentian), to evaluate potential non-target impacts of the treatment. Hydrilla Point-Intercept Survey Hydrilla monitoring will be performed annually at pre-determined survey points to ensure consistent data collection over time. The survey points were determined by overlaying a georeferenced 40m grid over basemap imagery of Elisha’s Pond in GIS and placing points for data collection at each vertex. (Refer to Monitoring Area Diagram for locations of pre-determined survey points). A handheld GPS unit will be utilized to ensure accurate field location for data collection. At each survey point, data collection will include water depth, hydrilla density, and biovolume. Hydrilla density will be quantified based on rake toss results and visual coverage estimates, following the Rake Toss Methodology, developed by the US Army Corps of Engineers and modified by Cornell University (Lord and Johnson 2006). The survey team will conduct a rake toss at each pre-determined survey point. The defined abundance scale will be used to categorize observations for each rake toss: Z = zero plants no plants on rake T = trace plants fingerful on rake S = sparse plants handful on rake M = medium plants rakeful of plants D = dense plants difficult to bring into boat Biovolume may be approximated using visual assessment and depth profiling, where appropriate. Aquatic plants will be identified using visual observation, and a throw rake, an underwater camera, and aerial drone photography. Photos will be taken at each pre-determined point to document vegetation and physical changes over time. Aquatic Macrophyte Survey The littoral zone (generally the portion of the pond that is less than 10-15 feet deep) will be surveyed annually to document aquatic vegetation (both native and non-native species). A survey team will visually monitor the littoral zone by boat (kayak or canoe) and by foot. The boat used for the survey will be provided by Camp Wingate Kirkland, and will remain on site in order to prevent the spread of hydrilla to other locations. Species population data will be collected for each aquatic plant observed. Plant species will be identified in the field using visual keys, any unknown species will be documented photographically and identified post- survey. Survey results will be mapped using either points (for individual plant occurences) or polygons (for plant community distributions). In other words, point data will be used for sparse or isolated individual plant occurences, while polygons will be used to document larger or contiguous plant beds. Plant density will be mapped following a pre-determined plant density classification, as described in the table below. Trace <1% Sparse 1-25% Moderate 26-60% Dense >60% 6 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN Metadata for all mapped features will include date, time, weather conditions, collector’s name, and any relevant field notes. Photo documentation of the pond shoreline will be collected, when feasible. Drone imagery will supplement field observations. Hydrilla Tuber Monitoring To monitor hydrilla tuber presence, core sediment samples will be obtained at pre-determined points within Designated Monitoring Areas 1 through 3. Five samples will be taken within each monitoring area for a total of 15 Tuber Samples. The deepest areas of the pond (Monitoring Area 4) will be ommitted from tuber sampling activity. Analysis of the core samples will be completed using a 4 cm-diameter metal mesh, o remove fine sediment. Remaining material will be examined for hydrilla tubers and turions. Any observed tubers/turions will be documented for the sampling site. Designated Monitoring Areas: Monitoring Area 1 Located within Camp Wingate Kirkland’s designated swim area, where the treatment and monitoring of hydrilla are of utmost concern due to its negative affects on camp recreational activities. Monitoring Area 2 Located within ‘The Cove’ which contains the most densely invaded portion of the pond. Monitoring Area 3 Located within the southern shoreline. Monitoring Area 4 Located roughly in the center of the pond to encompass monitoring within a deeper area of the pond. Monitoring Report At the end of each year, a monitoring report will be submitted to the commission in order to summarize the progress of the treatments, the health of native vegetation, and any recommended adjustments to management strategies. Refer to the Vegetation Management Protocol and Timeline for more detailed information on chemical treatment protocol, monitoring, and and timing. 7 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN Herbicide Information The proposed active ingredient for chemical treatment is Fluridone (Sonar™ or alternate). Fluridone is a systemic herbicide registered by the U.S. Environmental Protection Agency (USEPA) for use in water bodies and has been extensively used in various states for aquatic weed management, specifically for hydrilla. It was developed in the mid-1970s and approved for aquatic use in 1986. It inhibits the production of carotenoids, which gradually affects the plant’s ability to photosynthesize. Fluridone is most effective when hydrilla is actively growing, and it can take several weeks for results to show. Monitoring should be scheduled in a timely manner after each application to record results and assess whether an additional treatment and/or hand harvesting is recommended within the same year. It is difficult to manage hydrilla and treatment may never result in complete eradication. Research has shown initial treatments will not affect hydrilla seeds, turions, or tubers. Treatment must be repeated consistently and consecutively in following years in order to be effective. Monitoring reports will detail the level of hydrilla control and will recommend any changes to the management plan, if it becomes applicable. Testing the water for Fluridone levels, after each treatment, will follow instructions depicted on the product label. Water Use Restrictions The USEPA has established the following water use restrictions for fluridone-treated water, assuming that applications are applied as directed on the product label: - Drinking Water: No restrictions; treated water is safe for consumption immediately after application. - Swimming: No restrictions; swimming is safe immediately after application. - Fishing: No restrictions; fishing is safe immediately after application. - Livestock and Pet Consumption: No restrictions; animals can safely drink treated water immediately after application. - Food and Crop Irrigation: Wait at least 30 days after application before using treated water for irrigation. - Turf and Ornamental Irrigation: Wait at least 30 days after application before using treated water for irrigation. Impacts to Fish and Wildlife Studies show that fish do absorb fluridone but it does not bioaccumulate. Impacts of fluridone on fish are not of concern until concentrations reach 500ppb to over 8,000ppb (depending on species), well above the annual maximum dose allowed by the USEPA. Impacts to Non-Target Plants Impacts to native vegetation is expected to be minimal, as hydrilla is more sensitive to fluridone treatment compared to other native plant species. The proposed management will have a long-term beneficial effect on native vegetation. Hydrilla, if left untreated, will continue to grow and spread, effectively crowding out native plants. The large dense mats formed by hydrilla can significantly limit light penetration and oxygen exchange, further harming the health of native aquatic plants. Application Rates The pond level fluctuates based on factors such as rainfall, snowmelt, etc. During vegetation assessments, prior to scheduled chemical treatment, pond depth will be surveyed so that accurate application rates can be calculated. All chemicals applications will strictly adhere to the product label. 8 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN Alternatives to Chemical Management Mechanical / Physical Control Benthic Barriers: Not recommended for use throughout the entire areas of infestation The area of the hydrilla infestation is extensive, encompassing a significant portion of the pond. Given the existing conditions, the installation of benthic barriers is not considered a low-impact solution at this scale. These barriers would likely need to be installed and removed on an annual basis, leading to continuous disruption to the pond’s ecosystem, increasing the opportunity for hydrilla to spread through fragmentation, and requiring significant ongoing effort. Furthermore, if the benthic barriers were installed throughout the entire areas of infestation, it could result in deterimental impacts to invertebrates, native species, and other types of wildlife. While this method could reduce active growth, it would not fully inhibit hydrilla as the tubers would remain in the soil making eradication unlikely. Benthic Barriers: Not recommended in conjunction with chemical management Benthic barriers may be effective as a temporary solution in small, designated areas (i.e. Camp Wingate Kirkland’s swimming area) though they would interfere with chemical treatments aimed to control hydrilla. The barriers would block the systemic chemical from reaching the plant, slowing the overall effectiveness of the management strategy. The tubers would remain in the soil. Overall, this would be a costly approach that would require annual installation of the barriers, leading to continuous disruption to the pond’s ecosystem, increasing the opportunity for hydrilla to spread through fragmentation, and requiring significant ongoing effort. Hand-Pulling: Only recommended for shallow areas, in conjuction with chemical management Selective hand pulling is recommended (and is proposed) for the shallow areas of the pond, especially within Camp Wingate Kirkland’s designated swim area, after chemical treatment has been completed. This method will help remove excess dead hydrilla plant material. During hand- pulling, efforts will be taken to ensure that only the treated invasive hydrilla is removed, and all native vegetation remains undisturbed. Mechanical Harvesting/Hydro-raking: Not recommended Mechanical harvesting and Hydro-raking can be effective methods for controlling submerged aquatic plants. However, this approach is not recommended for managing hydrilla in Elisha’s Pond. These methods can cause significant plant fragmentation, which would contribute to the spread of hydrilla and allow it to further invade the waterbody. In addition to this, there is no boat ramp or suitable access point for launching this type of machinery in the pond, futher limiting its feasibility. Suction Harvesting: Not recommended Suction harvesting can be an effective method for hydrilla populations with low to moderate densities. This approach is somewhat non-selective especially in cases of high turbidity, as the hydrilla grows amongst native vegetation, resulting in the removal and minimal fragmentation of both non-native and native vegetation. This approach is costly, requiring a filtering system to capture hydrilla tubers and turions, providing means for divers to stay on course in turbid waters, other equipment and equipment features, and contractor mobilization. Water Level Drawdown: Not recommended Water level drawdown is a process where the water level is lowered by gravity, pumping, or siphoning. The water is held at a reduced level for a period of time, generally within the winter months. This is not a feasible control method for controlling hydrilla in Elisha’s Pond. The pond does not have a water level control structure which would facilitate the drawdown of the water. 9 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN Biological Control: Not recommended Sterile grass carp (Ctenopharyngodon idella) have been used in various aquatic management plans throughout the country to control the growth of aquatic macrophytes. However, the introduction of grass carp is not a feasible control method for Elisha’s Pond, as they are not approved for introduction or use in Massachusetts under current state regulations. Alternate Chemical Treatments: Not recommended, unless in conjunction with Fluridone According to the DCR Rapid Response Plan for Hydrilla verticillate in Massachusetts, two chemicals (Diquat or endothall) are recommended as alternatives to Fluridone. However, the response plan notes that both Diquat or Endothall are primarily used in localized areas, rather than throughout the entire water body. Elisha’s Pond has populations of hydrilla throughout the pond, rather than small, localized populations. It is also noted that typical use of those chemicals is to minimize spread of the plant, and eradication is not expected. Diquat and Endothall are selective contact herbicides that work by interfering with a plant’s respiration and photosynthesis systems, causing disruption to the plant cell membranes. Like Fluridone, they do not concentrate in animal tissue. However, unlike Fluridone, these herbicides only kill green vegetation that are in active growth. They are not systemic, and therefore do not transfer to and kill the roots. Because hydrilla tubers can lie dormant for many years, Diquat and Endothall are only effective in helping to prevent further spread of hydrilla, rather than reducing the population. Although the use of these herbicides are not recommended in lieu of Fluridone for this site, they may be effective, and are often recommended, as alternate chemicals to be used in conjunction with Fluridone, on a rotating basis in order to help prevent the invasive species from building up a tolerance or resistance to one specific herbicide. Do Nothing: Not recommended If there are no efforts to remove the hydrilla from Elisha’s Pond, the existing population will continue to grow rapidly, making it even more difficult to control in the future. The dense, mat forming growth habits of the species will have detrimental effects on the pond’s ecosystem by continuing to crowd out native vegetation, alter water chemistry, cause changes in dissolved oxygen levels, increase water temperatures, and reduce the ability of the pond’s ecosystem to support diversity of fish and other species that are dependent on native vegetation to thrive. In addition, the invasive vegetation will continue to negatively impact and endanger the current recreational activities on the pond such as swimming and non- motorized boating. Current and future recreational activities will exacerbate the spread of the invasive plant by causing significant plant fragmentation. Non-motorized boats and recreational equipment that are transported to other water bodies may hold plant debris that will then begin to spread beyond Elisha’s Pond. 10 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN MANAGEMENT ACTIVITY PROTOCOL AND TIMELINE All work is supervised/completed by a Certified Ecological Restoration Practitioner. All work is supervised/completed by an ISA Certified Arborist. All work is supervised/completed by a MA Certified Invasive Plant Management specialist. All herbicide treatments are completed by a MA licensed and insured pesticide applicator. All machine work is completed by a MA licensed and insured machine operator. Pre-Treatment Water Testing and Vegetation Survey (May-June) 1. Conduct comprehensive vegetation surveys of Elisha’s Pond to document pre-treatment conditions (Refer to Aquatic Macrophyte Survey & Hydrilla Point-Intercept Survey) 2. Samples of water to be collected from at least 2 points of the pond to establish a base line from which future treatment and testing can be measured. 3. Evaluate presence of hydrilla tubers at 3 sampling sites. 5 samples will be gathered at each point, for a total of 15 Tuber samples. (Refer to Hydrilla Tuber Monitoring) Initial Pond Treatment (May-June) 10’ avg depth 1. Mobilization of all personnel and equipment. 2. Purchase and delivery of all materials to complete the project. 3. Use of Sonar One or Sonar H4C at labeled application rates. The average depth of Elisha’s pond is estimated to be approximately 10’. 4. Sonar to be applied at 5-10 ppb (parts per billion), as recommended by DCR’s Hyrdilla Rapid Response Plan for Massachusetts, using a broadcast pelletized formula applied to the entire pond. This rate will allow multiple treatment to be performed in a single season. Sonar pellets are a controlled release formula vs Sonar SPR or Sonar Q which are “quick release and less targeted” and 5-10 ppb is the lowest end of the application spectrum. The total applied concentration of fluridone will not exceed 20 ppb annually. 5. Initial Sonar treatment to be performed from jon boat with electric motor (not to exceed 6 horsepower) calibrating a pelletized spreader to evenly distribute the treatment across the entire pond. 6. Access of the pond to be from Camp area carrying the boat down to the water and hauling it out upon completion. 7. Clean up of project area(s) after completion including cleaning of the jon boat following General Prevention Procedures for Stopping Aquatic Hitchhikers by ProtectYourWaters.net. Post-Treatment Water Testing 1. Two (2) weeks after performing the initial treatment, samples of water to be collected from at least 2 points of the pond to ensure the active ingredient is adequate and desirable treatment levels. 2. Water samples to be collected via canoe/kayak and/or paddleboard to access target areas. All samples will be kept on ice and sent in to the lab for analysis. NOTE: Final Second treatment amount is dependent on these results to ensure that we are getting the desired ppb in the pond for efficient Hydrilla treatment. 2nd Pond Treatment (June-July) 10’ avg depth 1. Mobilization of all personnel and equipment. 2. Purchase and delivery of all materials to complete the project. 3. Use of Sonar One or Sonar H4C at labeled application rates. The average depth of Elisha’s pond is estimated to be approximately 10’. 4. Sonar to be applied at approximately 3-5 ppb using a broadcast pelletized formula applied to the entire pond to maintain ppb. The total applied concentration of fluridone will not exceed 20 ppb annually. 11 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN 5. Sonar treatment to be performed from jon boat with electric motor (not to exceed 6 horsepower) calibrating a pelletized spreader to evenly distribute the treatment across the entire pond. 6. Access of the pond to be from Camp area carrying the boat down to the water and hauling it out upon completion. 7. Clean up of project area(s) after completion including cleaning of the jon boat following General Prevention Procedures for Stopping Aquatic Hitchhikers by ProtectYourWaters.net. Post-Treatment Water Testing 1. Two (2) weeks after performing the initial treatment, samples of water to be collected from at least 2 points of the pond to ensure the active ingredient is adequate and desirable treatment levels. 2. Water samples to be collected via canoe/kayak and/or paddleboard to access target areas. All samples will be kept on ice and sent in to the lab for analysis. NOTE: Second treatment amount is partially dependent on these results to ensure that we are getting the desired ppb in the pond for efficient Hydrilla treatment. 3rd Pond Treatment (Aug-Sept) 10’ avg depth 1. Mobilization of all personnel and equipment. 2. Purchase and delivery of all materials to complete the project. 3. Use of Sonar One or Sonar H4C at labeled application rates. The average depth of Elisha’s pond is estimated to be approximately 10’. 4. Sonar to be applied at 3-5 ppb using a broadcast pelletized formula applied to the entire pond to maintain desired ppb. The total applied concentration of fluridone will not exceed 20 ppb annually. 5. Sonar treatment to be performed from jon boat with electric motor (not to exceed 6 horsepower) calibrating a pelletized spreader to evenly distribute the treatment across the entire pond. 6. Access of the pond to be from Camp area carrying the boat down to the water and hauling it out upon completion. 7. Clean up of project area(s) after completion including cleaning of the jon boat following General Prevention Procedures for Stopping Aquatic Hitchhikers by ProtectYourWaters.net. Post-Treatment Water Testing and Vegetation Survey 1. Conduct comprehensive vegetation surveys of Elisha’s Pond to document pre-treatment conditions (Refer to Aquatic Macrophyte Survey & Hydrilla Point-Intercept Survey) 2. Samples of water to be collected from at least 2 points of the pond to establish a base line from which future treatment and testing can be measured. 3. Evaluate presence of hydrilla tubers at 3 sampling sites. 5 samples will be gathered at each point, for a total of 15 Tuber samples. (Refer to Hydrilla Tuber Monitoring) 4. Prepare and submit a monitoring report to the conservation commission with results of pre and post treatment hydrilla and native vegetation surveys. 12 CRAWFORD LAND MANAGEMENT | ELISHA’S POND AQUATIC VEGETATION MANAGEMENT PLAN RESOURCES Cayuga Lake Watershed Intermunicipal Organization. (2021). Cayuga Lake hydrilla management plan. https:// www.cayugalake.org/wp-content/uploads/Cayuga-Lake-Hydrilla-Management-Plan-2021-FINAL.pdf Cornell University Cooperative Extension. Fluridone FAQ. https://ccetompkins.org/environment/aquatic- invasives/hydrilla/management-options/herbicides/fluridone/fluridone-faq ENSR International. (2005). Fluridone ecological risk assessment: Final report (Paper 147). All U.S. Government Documents (Utah Regional Depository). https://digitalcommons.usu.edu/govdocs/147 Massachusetts Department of Agricultural Resources. Hydrilla [Fact sheet]. Massachusetts Introduced Pests Outreach Project. https://massnrc.org/pests/pestFAQsheets/hydrilla.html Massachusetts Executive Office of Energy and Environmental Affairs. 310 CMR 10.00: The Wetlands Protection Act. https://www.mass.gov/doc/310-cmr-1000-the-wetlands-protection-act/download Massachusetts Executive Office of Energy and Environmental Affairs. Hydrilla [Fact sheet]. https://www. mass.gov/doc/hydrilla-1/download Massachusetts Executive Office of Energy and Environmental Affairs. Hydrilla rapid response plan for Massachusetts. https://www.mass.gov/doc/hydrilla-rapid-response-plan-for-massachusetts/download National Library of Medicine. Fluridone [Chemical compound summary]. PubChem, National Center for Biotechnology Information. https://pubchem.ncbi.nlm.nih.gov/compound/Fluridone New York City Department of Environmental Protection. Hydrilla frequently asked questions. https://www. nyc.gov/assets/dep/downloads/pdf/environment/science-research/hydrilla-faqs.pdf SePRO Corporation. Sonar: An effective herbicide that poses negligible risk to human health and the environment. https://www.industrialvm.com/literature/sepro/sonar_risk_guide.pdf Texas A&M AgriLife Extension Service. Hydrilla. AquaPlant: A Pond Management Diagnostic Tool. https:// aquaplant.tamu.edu/management-options/hydrilla/ U.S. Army Corps of Engineers. Connecticut River Hydrilla. https://www.nae.usace.army.mil/Missions/ Projects-Topics/Connecticut-River-Hydrilla/ U.S. Environmental Protection Agency. Pesticide fact sheet: Fluridone. National Service Center for Environmental Publications. U.S. Fish and Wildlife Service. Rapid response plan for Hydrilla (Hydrilla verticillata) in Massachusetts. https://www.fws.gov/project/rapid-response-plan-hydrillahydrilla-verticillata-massachusetts Water Research Foundation. Chemical management of hydrilla for drinking water utilities. https://www. waterrf.org/research/projects/chemical-management-hydrilla-drinking-water-utilities Weston & Sampson. (2021). Water resources protection study [Prepared for the Town of Yarmouth, MA]. https://www.yarmouth.ma.us/DocumentCenter/View/17563/water-resources-protection-study-book?bidId= Wisconsin Department of Natural Resources. (2022, December). Fluridone chemical fact sheet. W YarmouthRdC S X Tr a n s p o r tat i o n R a i l r o a d El i s h a P o n d D rW YarmouthRdPortsmouth T e r Elishas Pond El i s h a P o n d D r Maxar, Microsoft, Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, (c) OpenStreetMap contributors, and the GIS User Community 0 0.02 0.040.01 Miles ³ Legend Property Parcels Aquatic Macrophyte Survey Area ELISHA'S POND - AQUATIC MACROPHYTE SURVEY AREA W YarmouthRdC S X Tr a n s p o r tat i o n R a i l r o a d El i s h a P o n d D rW YarmouthRdPortsmouth T e r Elishas Pond El i s h a P o n d D r 1 3 2 4 5 8 11 12 16 17 18 19 20 21 151413 9 10 76 Maxar, Microsoft, Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, (c) OpenStreetMap contributors, and the GIS User Community 0 0.02 0.040.01 Miles ³ Legend Property Parcels Hydrilla Survey Points ELISHA'S POND - HYDRILLA MONITORING POINTS General Prevention Procedures for Stopping Aquatic Hitchhikers: A must read for all recreational users Follow a general set of procedures every time you come in contact with any body of water. By doing so, you can protect your waters from harmful aquatic hitchhikers. Because you never know where a nuisance species has been introduced, but has yet to be discovered. There are hundreds of different harmful species ranging from plants, fish, amphibians, crustaceans, mollusks, diseases or pathogens. Some organisms are so small, you may not even realize they are hitching a ride with you. So, it is important to follow this general procedure every time you leave any body of water. HYDRILLA HAS BEEN FOUND IN THE DELAWARE & RARITAN CANAL! Please help us prevent the spread of this aggressive invasive plant! For more information, visit www.protectyourwaters.net Remove all visible mud, plants, fish/animals. Before leaving any body of water, it is important to examine all your equipment, boats, trailers, clothing, boots, buckets etc and:  Remove any visible plants, fish or animals.  Remove mud and dirt since it too may contain a hitchhiker.*  Remove even plant fragments as they may contain a hitchhiker.*  Do not transport any potential hitchhiker, even back to your home. Remove and leave them at the site you visited. *The larvae (immature form) of an animal can be so tiny that you cannot see it. However, it can live in mud, dirt, sand, and on plant fragments. Eliminate water from all equipment before transporting anywhere. Much of the recreational equipment used in water contains many spots where water can collect and potentially harbor these aquatic hitchhikers. Make sure that you:  Eliminate all water from every conceivable item before you leave the area you are visiting.  Remove water from motors, jet drives, live wells, boat hulls, scuba tanks and regulators, boots, waders, bait buckets, seaplane floats, swimming floats.  Once water is eliminated, follow the cleaning instructions listed below. Clean and dry anything that came in contact with the water. (boats, trailers, fishing equipment, dogs, boots, clothing, etc.). Basic procedures include:  Use hot (< 40° C or 104° F) or salt water to clean your equipment.  The following recipes are recommended for cleaning hard- to-treat equipment that cannot be exposed to hot water: o Dipping equipment into 100% vinegar for 20 minutes will kill harmful aquatic hitchhiker species. o A 1 % table salt solution for 24 hours can replace the vinegar dip. This table provides correct mixtures for the 1 % salt solution in water: Gallons of Water Cups of Salt 5 2/3 10 1 ¼ 25 3  Bleach: Bleach is a very effective disinfectant agent, but it is a caustic substance that can be corrosive to aluminum and other sensitive fishing and boating equipment. Soak or spray equipment for at least one minute with a 2% bleach solution (3 ounces of household bleach to 1 gallon of water).  A 1:10 dilution of Simple Green, or full strength Formula 409, Fantasitk, or other alkyl dimethyl benzyl ammonium chloride-containing cleaner can be used.  Household steam cleaners are a relatively inexpensive, yet effective disinfection option for boat owners.  If hot water is not available, spray equipment such as boats, motors, trailers, anchors, decoys, floats, nets, with high- pressure water.  DRY Equipment. If possible, allow for 5 days of drying time before entering new waters. 2006 Aquatic Plant Monitoring Guidelines As part of an enhanced aquatic pesticides review process implemented by the NYSDEC in 2005, applicants for the use of aquatic pesticides in some lakes may be required to develop aquatic plant management and monitoring plans. This will allow for a more consistent evaluation of these applications by NYSDEC permit review staff, and to build a more complete and defensible record on which to base permit application decisions. The criteria adopted in 2006 to trigger the development of these plans generally focus on waterbodies for which the NYSDEC requires an elevated level of protection and concern. These include waterbodies heavily used by the public for fishing, boating and other recreational activities, through access provided by New York State; waterbodies used for potable water; waterbodies in which rare, threatened, or endangered species can be found; and waterbodies identified by the NYSDEC as a priority for water resource protection and restoration, through inclusion on the state Priority Waterbody List compiled by the Division of Water. A master list of waterbodies meeting one or more of these criteria has been assembled by the NYSDEC and is provided on the NYSDEC’s Division of Solid and Hazardous Materials website. Instructions for developing aquatic plant management plans are found on the NYSDEC Bureau of Water Assessment and Management website as Appendix A of ‘A Primer on Aquatic Plant Management in New York State’. A direct link to this web site is http://www.dec.state.ny.us/website/dow/bwam/aquatic/ch6p4.pdf. Waterbodies on this list have been assigned standards for developing aquatic plant monitoring plans, based on a three tiered system. Tier III monitoring guidelines exceed those identified for Tier II and Tier I waterbodies. Tier II monitoring guidelines closely resemble those developed for Tier I waterbodies, but have been modified slightly to address specific concerns. This document provides instructions for developing an aquatic plant monitoring plan within the three tiered system. A general summary of the rake toss methodology is outlined, followed by a short summary of the monitoring guidelines for each tier. Examples of Aquatic Plant Monitoring forms for each tier are also included in this document. These guidelines were developed with the assistance of Paul Lord and Robert Johnson from Cornell University. For more information about these monitoring guidelines, please contact: Scott Kishbaugh, P.E. NYSDEC Division of Water 625 Broadway, 4th Floor Albany, NY 12233-3502 518-402-8282 (phone) 518-402-9029 (fax) sakishba@gw.dec.state.ny.us Summary of the Rake Toss Methodology Equipment: o Two metal rake heads (handles cut as close to head as possible) wired together o Woven nylon line, at least 40 feet Sampling Method: o Go to sample point and record GPS coordinates on Aquatic Plant Sampling form o Toss rake length of line o Retrieve rake slowly into boat o Estimate overall plant abundance using Cornell abundance scale (see abundance table below) o Remove plants from rake tines o Separate plants into individual piles corresponding to individual plant types (species) o Tier I: Estimate abundance of target and exotic species using Cornell abundance scale. Estimate abundance of all other plants (collectively) using same scale o Tier III: Estimate % abundance of all species using Cornell abundance scale o Record plant abundance on Aquatic Plant Sampling form o Make sure all plants are removed from tines of rake o Go to next sampling point and repeat process Cornell Plant Abundance Scale: Z = zero plants = no plants on rake T = trace plants = fingerful on rake S = sparse plants = handful on rake M = medium plants = rakeful of plants D = dense plants = difficult to bring into boat This methodology was adapted from the U.S. Army Corps of Engineers and further developed by Paul Lord and Bob Johnson from Cornell University. Pesticides Program Monitoring Requirements Tier I Lakes Method : Rake Toss- One Toss Per Site Frequency: One Sampling Event Pre-Application (preferably at time when target plant grows most extensively) One Sampling Event Post-Application (at time when target plant grows most extensively) Number of Lakes < 100 hectares: Larger of 15-50 Sites or 1 Site/hectare of Sampling Sites: Littoral Zone (portion of lake less than 10-15 feet deep) Lakes > 100 hectares: Larger of 30-50 Sites or 1 Site/hectare of Littoral Zone (portion of lake less than 10-15 feet deep) Site Locations : Equally Distributed Throughout Littoral Zone (preferably chosen from 100m x 100m grid overlay on map of lake) 50% of Sites in Treatment Area (spot treatment) Site Identification: GPS Coordinates, UTM NAD27 Preferred Site Mapping: Sites Labeled on USGS Topographic Maps Plant Identification: Target and Exotic Plants Identified to Species Level All Other Plants Listed as “Other” Plant Abundance : Quantified by Cornell/US Army Corps Abundance Scale: Z = no plants T = trace plants = fingerful on rake S = sparse plants = handful on rake M = medium plants = rakeful of plants D = dense plants = difficult to bring into boat Archiving: Digital photographs of Target and Exotic Plants Bookkeeping: Plant IDs and Abundance Listing in Table (preferably spreadsheet) Reporting: Annual Report- Summary of Methodology and Data Tables Report Due by December 31st of Treatment Year Example Tier I Aquatic Plant Survey Form Lake Name:Start Time:Description Starting Point:Station Sampling Date:End Time:Lat:Long:Description Exotics/Target Plants:Native and Other Plants:Station#Sample#Lat/ NAD27 ELong/ NAD27 NDepth (m)OverallPlantAbundanceEurasian watermilfoilwater chestnutcurlyleafedpondweedfanwortOther Target: Other Target: Other Target: 1 1 2 1 3 1 4 1 5 1 6 1 7 1 8 1 9 1 10 1 11 1 12 1 13 1 14 1 15 1 16 1 17 1 18 1 19 1 20 1 Abundance Values: Z = Zero; T = Trace (fingerful); S = Sparse (handful), M = Moderate (rakeful); D = Dense (too much to bring in boat) Additional Comments: 1 Sonar® H4C Aquatic Herbicide For management of aquatic vegetation in fresh water ponds, lakes, reservoirs (including inlets and tributaries), potable water sources, drainage canals, irrigation canals and rivers. Active Ingredient fluridone: 1-methyl-3-phenyl-5-[3-(trifluoromethyl)phenyl]- 4(1H)-pyridinone .................................................................................2.7% Other Ingredients. ........................................................................... 97.3% TOTAL ...............................................................................................100.0% Contains 0.027 lbs. active ingredient per pound. Keep Out of Reach of Children CAUTION/PRECAUCIÓN Si usted no entiende la etiqueta, busque a alguien para que se la explique a usted en detalle. (If you do not understand the label, find someone to explain it to you in detail.) Notice: Read the entire label before using. Use only according to label directions. Before buying or using this product, read Warranty Disclaimer and Misuse statements inside label booklet. If terms are unacceptable, return at once unopened. EPA Reg. No. 67690-61 FPL20190517 Sonar is a registered trademark of SePRO Corporation. SePRO Corporation 11550 North Meridian Street, Suite 600, Carmel, IN 46032, U.S.A. FIRST AID If swallowed • Call a poison control center or doctor immediately for treatment advice. • Have person sip a glass of water if able to swallow. • Do not induce vomiting unless told to do so by a poison control center or doctor. • Do not give anything by mouth to an unconscious person. If on skin or clothing • Take off contaminated clothing. • Rinse skin immediately with plenty of water for 15 to 20 minutes. • Call a poison control center or doctor for treatment advice. If inhaled • Move person to fresh air. • If person is not breathing, call 911 or an ambulance; then give artificial respiration, preferably mouth-to-mouth, if possible. • Call a poison control center or doctor for further treatment advice. If in eyes • Hold eye open and rinse slowly and gently with water for 15 to 20 minutes. Remove contact lenses, if present, after the first 5 minutes; then continue rinsing eye. • Call a poison control center for treatment advice. HOTLINE NUMBER Have the product container or label with you when calling a poison control center or doctor, or going for treatment. In case of emergency endangering health or the environment involving this product, call INFOTRAC at 1-800-535-5053. PRECAUTIONARY STATEMENTS HAZARDS TO HUMANS AND DOMESTIC ANIMALS Caution. Harmful if swallowed. Harmful if absorbed through skin. Harmful if inhaled. Causes moderate eye irritation. Avoid contact with eyes or clothing. Avoid breathing dust. Wear long sleeved shirt, long pants, shoes and socks. USER SAFETY RECOMMENDATIONS • Wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet. • Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. • Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing. ENGINEERING CONTROLS (AIRCRAFT) Aircraft pilots must use an enclosed cab that meets the definition listed in the WPS for agricultural pesticides [40 CFR 170.305]. ENVIRONMENTAL HAZARDS Follow use directions carefully so as to minimize adverse effects on non-target organisms. Trees and shrubs growing in water treated with this product may occasionally develop chlorosis. Do not apply in tidewater/ brackish water. Lowest rates should be used in shallow areas where the water depth is considerably less than the average depth of the entire treatment site, for example, shallow shoreline areas. Non-Target Organisms Advisory Statement Protect the forage and habitat of non-target organisms by following label directions intended to minimize spray drift. This product is toxic to plants and may adversely impact the forage and habitat of non-target organisms, including pollinators, in areas adjacent to the treated site. DIRECTIONS FOR USE It is a violation of Federal Law to use this product in a manner inconsistent with its labeling. Read all directions carefully before applying this product. PRODUCT INFORMATION This product is a selective systemic aquatic herbicide for management of aquatic vegetation in fresh water ponds, lakes, reservoirs (including inlets and tributaries), drainage canals, irrigation canals, and rivers. This product is a pelleted formulation containing 2.7% fluridone designed to provide enhanced numbers of pellets (greater coverage) in treated areas versus other Sonar pellet formulations at equivalent herbicide dosing. This higher density of pellets has the potential to improve herbicide contact with target vegetation in higher exchange treatment scenarios such as spot or small-partial application designs. This product is absorbed from water by plant shoots and from hydrosoil by the roots of aquatic vascular plants. It is important to maintain this product in contact with the target plants for as long as possible. Rapid water movement or any condition which results in rapid dilution of this product in treated water will reduce its effectiveness. In susceptible plants, this product inhibits the formation of carotene. In the absence of carotene, chlorophyll is rapidly degraded by sunlight. Herbicidal symptoms of this product appear in seven to ten days and appear as white (chlorotic) or pink growing points. Under optimum conditions, 30 to 90 days are required before the desired level of aquatic weed management is achieved with this product. Species susceptibility to this product may vary depending on time of year, stage of growth and water movement. For best results, apply this product prior to initiation of weed growth or when weeds begin active growth. Application to mature target plants may require an application rate at the higher end of the specified rate range and may take longer to control. This product is not corrosive to application equipment. The label provides recommendations on the use of a chemical analysis for the active ingredient. SePRO Corporation recommends the use of a High-Performance Liquid Chromatography (HPLC) for the determination of the active ingredient concentration in the water. Contact SePRO Corporation to incorporate this test, known as a FasTEST®, into your treatment program. Other proven chemical analyses for the active ingredient may also be used. The FasTEST is referenced in this label as the preferred method for the rapid determination of the concentration of the active ingredient in the water. Application rates are provided in pounds of product to achieve a desired concentration of the active ingredient in parts per billion (ppb). The maximum application rate or sum of all application rates is 90 ppb in ponds (< 10 Acres) and 150 ppb in lakes and reservoirs per annual growth cycle. This maximum concentration is the amount of product calculated as the target application rate, NOT determined by testing the concentrations of the active ingredient in the treated water. Weed Resistance Management For resistance management, Sonar H4C is a Group 12 herbicide. Any weed population may contain or develop plants naturally resistant to Sonar H4C and other Group 12 herbicides. The resistant biotypes may dominate the weed population if these herbicides are used repeatedly in the same area. Appropriate resistance management strategies should be followed. To delay herbicide resistance take one or more of the following steps: • Rotate the use of Sonar H4C or other Group 12 herbicides within a growing season or among growing seasons with different herbicide groups that control the same weeds. • Use tank mixtures with herbicides from a different group if such use is permitted; where information on resistance in target weed species is available, use the less resistance-prone partner at a rate that will control 2 the target weed(s) equally as well as the more resistance-prone partner. Consult your local extension service or pest control advisor if you are unsure as to which active ingredient is currently less prone to resistance. • Adopt an integrated weed-management program for herbicide use that includes scouting and uses historical information related to herbicide use and that considers mechanical control methods, cultural (e.g., timing to favor the desirable plants and not the weeds), biological (weed-competitive varieties) and other management practices. • Scout after herbicide application to monitor weed populations for early signs of resistance development. Indicators of possible herbicide resistance include: (1) failure to control a weed species normally controlled by the herbicide at the dose applied, especially if control is achieved on adjacent weeds; (2) a spreading patch of non-controlled plants of a particular weed species; (3) surviving plants mixed with controlled individuals of the same species. If resistance is suspected, prevent weed seed production in the affected area by an alternative herbicide from a different group or by a mechanical method. Prevent movement of resistant weed seeds to other areas by cleaning equipment. • If a weed pest population continues to progress after treatment with this product, discontinue use of this product, and switch to another management strategy or herbicide with a different mode of action, if available. • Contact your sales representative, pest control advisors, or local extension specialist for additional pesticide resistance-management and/ or integrated weed-management recommendations for specific types of plants and weed biotypes. Use Restrictions • Obtain Required Permits: Consult with appropriate state or local water authorities before applying this product. Permits may be required by state or local public agencies. • New York State: Application of this product is not permitted in waters less than two (2) feet deep, except as permitted under FIFRA Section 24(c), Special Local Need registration. • Hydroponic Farming: Do not use water from a Sonar-treated area for hydroponic farming unless one of the following has been verified for the relevant active water intake and its withdrawal of surface water: o A FasTEST has been run and the concentration in water at the intake is less than 1 ppb; or o A filtration or water treatment process following water intake has been verified analytically to reduce the concentration in potential irrigation water below 1 ppb. • Greenhouse and Nursery Plants: Do not use water from a Sonar-treated area for greenhouse and nursery irrigation unless one of the following has been verified for the relevant active water intake and its withdrawal of surface water: o For the irrigation of woody ornamental plants, a FasTEST has been run and the concentration at the intake is less than 5 ppb; or o For the irrigation of other greenhouse or nursery plants, the concentration is confirmed less than 1 ppb; or o A filtration or water treatment process following water intake has been verified analytically to reduce the concentration in potential irrigation water below either the 1 or 5 ppb levels cited above. • Water Use Restrictions Following Application (Days) Application Rate Drinking†Fishing Swimming Livestock/Pet Consumption Irrigation†† Maximum Rate (150 ppb) or less 0 0 0 0 See irrigation instructions below † Note below, under Potable Water Intakes, the information for application of this product within ¼ miles (1,320) feet of a functioning potable water intake. †† Note below, under Irrigation, specific time frames or fluridone concentrations that provide the widest safety margin for irrigating with fluridone treated water. • Potable Water Intakes: Concentrations of the active ingredient fluridone up to 150 ppb are allowed in potable water sources; however, in lakes and reservoirs or other sources of potable water, do not apply this product at application rates greater than 20 ppb within one- fourth (¼) mile (1,320 feet) of any functioning potable water intake. At application rates of up to 20 ppb, this product may be applied where functioning potable water intakes are present. NOTE: Existing potable water intakes which are no longer in use, such as those replaced by connections to potable water wells or a municipal water system, are not considered to be functioning potable water intakes. • Irrigation: For tobacco, tomatoes, peppers or other plants within the Solanaceae Family and newly seeded crops or newly seeded grasses such as overseeded golf course greens, do not use water treated with this product if concentrations are greater than 5 ppb. It is recommended that a SePRO Aquatic Specialist be consulted prior to commencing irrigation of these sites. When rotating crops, do not plant members of the Solanaceae family in land that has been previously irrigated with fluridone concentrations in excess of 5 ppb without consultation with a SePRO Aquatic Specialist. • Aircraft pilots must use an enclosed cab that meets the definition listed in the WPS for agricultural pesticides [40 CFR 170.305]. Use Precautions • Irrigation: Irrigation with water treated with this product may result in injury to the irrigated vegetation. Follow these precautions and inform those who irrigate from areas treated with this product of the irrigation time frames or FasTEST requirements presented in the table below. Follow these time frames and FasTEST recommendations to reduce the potential for injury to vegetation irrigated with water treated with this product. Greater potential for crop injury occurs where water treated with this product is applied to crops grown on low organic and sandy soils. Application Site Days After Application Established Tree Crops Established Row Crops/ Turf/Plants Newly Seeded Crops/ Seedbeds or Areas to be Planted Including Overseeded Golf Course Greens Ponds and Static Canals†7 30 FasTEST required Canals 7 7 FasTEST required Rivers 7 7 FasTEST required Lakes and Reservoirs††7 7 FasTEST required † For purposes of this product’s labeling, a pond is defined as a body of water 10 acres or less in size. A lake or reservoir is greater than 10 acres. †† In lakes and reservoirs where one-half or greater of the body of water is treated, use the pond and static canal irrigation precautions. Where the use of water treated with this product is desired for irrigating crops prior to the time frames established above, the use of a FasTEST is recommended to measure the concentration in the treated water. Where a FasTEST has determined that concentrations are less than 10 parts per billion, there are no irrigation precautions for irrigating established tree crops, established row crops or turf. PLANT CONTROL INFORMATION This product’s selectivity is dependent upon dosage, time of year, stage of growth, method of application, and water movement. The following categories, controlled, partially controlled, and not controlled are provided to describe expected efficacy under ideal treatment conditions using higher to maximum label rates. Use of lower rates will increase selectivity of some species listed as controlled or partially controlled. Additional aquatic plants may be controlled, partially controlled, or tolerant to this product. It is recommended to consult a SePRO Aquatic Specialist prior to application of this product to determine a plant’s susceptibility to it. Vascular Aquatic Plants Controlled Submersed Plants bladderwort (Utricularia spp.) common coontail (Ceratophyllum demersum)† common Elodea (Elodea canadensis)† egeria, Brazilian Elodea (Egeria densa) fanwort, Cabomba (Cabomba caroliniana) hydrilla (Hydrilla verticillata) naiad (Najas spp.)† pondweed (Potamogeton spp., except Illinois pondweed)† watermilfoil (Myriophyllum spp. except variable-leaf milfoil) Floating Plants azolla (Azolla spp.) duckweed (Lemna, Landoltia, and Spirodela spp.) Shoreline Grasses paragrass (Urochloa mutica) † Native plants that are often tolerant to fluridone at lower use rates. Please consult a SePRO Aquatic Specialist for appropriate use rates (not to exceed maximum labeled rates) when selective control of exotic species is desired. Vascular Aquatic Plants Partially Controlled Submersed Plants Illinois pondweed (Potamogeton illinoensis) limnophila (Limnophila sessiliflora) tapegrass, American eelgrass (Vallisneria americana) watermilfoil--variable-leaf (Myriophyllum heterophyllum) 3 Emersed Plants alligatorweed (Alternanthera philoxeroides) American lotus (Nelumbo lutea) cattail (Typha spp.) creeping waterprimrose (Ludwigia peploides) parrotfeather (Myriophyllum aquaticum) smartweed (Polygonum spp.) spatterdock (Nuphar luteum) spikerush (Eleocharis spp.) waterlily (Nymphaea spp.) waterpurslane (Ludwigia palustris) watershield (Brasenia schreberi) Floating Plants salvinia (Salvinia spp.) Shoreline Grasses barnyardgrass (Echinochloa crusgalli) giant cutgrass (Zizaniopsis miliacea) reed canarygrass (Philaris arundinaceae) southern watergrass (Hydrochloa caroliniensis) torpedograss (Panicum repens) Vascular Aquatic Plants Not Controlled Emersed Plants American frogsbit (Limnobium spongia) arrowhead (Sagittaria spp.) bacopa (Bacopa spp.) big floatingheart, banana lily (Nymphoides aquatica) bulrush (Scirpus spp.) pickerelweed, lanceleaf (Pontederia spp.) rush (Juncus spp.) water pennywort (Hydrocotyle spp.) Floating Plants floating waterhyacinth (Eichhornia crassipes) waterlettuce (Pistia stratiotes) Shoreline Grasses maidencane (Panicum hemitomon) NOTE: algae (chara, nitella, and filamentous species) are not controlled by this product. APPLICATION DIRECTIONS The aquatic plants present in the treatment site should be identified prior to application to determine their susceptibility to this product. It is important to determine the area (acres) to be treated and the average depth in order to select the proper application rate. Do not exceed the maximum labeled rate for a given treatment site per annual growth cycle. Application to Ponds This product may be applied to the entire surface area of a pond. For single applications, rates may be selected to provide 45 to 90 ppb to the treated water, although actual concentrations in treated water may be substantially lower at any point in time due to the slow-release formulation of this product. When treating for optimum selective control, lower rates may be applied for sensitive target species. Use the higher rate within the rate range where there is a dense weed mass, when treating more difficult to control species, and for ponds less than 5 acres in size with an average depth less than 4 feet. Application rates necessary to obtain these concentrations in treated water are shown in the following table. For additional application rate calculations, refer to the Application Rate Calculation—Ponds, Lakes and Reservoirs section of this label. Split or multiple applications may be used where dilution of treated water is anticipated; however, the sum of all applications should total 45 to 90 ppb and must not exceed a total of 90 ppb per annual growth cycle. Average Water Depth of Treatment Site (feet) Pounds of product per Treated Surface Acre 45 ppb 90 ppb 1 4.5 9 2 9 18 3 13.5 27 4 18 36 5 22.5 45 6 27 54 7 31.5 63 8 36 72 9 40.5 81 10 45 90 Application to Lakes and Reservoirs The following treatments may be used for treating both whole lakes or reservoirs and partial areas of lakes or reservoirs (bays, etc.). For best results in treating partial lakes and reservoirs, treatment areas should be a minimum of 5 acres in size. Treatment of areas smaller than 5 acres or treatment of narrow strips such as boat lanes or shorelines may not produce satisfactory results due to dilution by untreated water. Rate ranges are provided as a guide to include a wide range of environmental factors, such as target species, plant susceptibility, selectivity and other aquatic plant management objectives. Application rates and methods should be selected to meet the specific lake/reservoir aquatic plant management goals. Whole Lake or Reservoir Treatments (Limited or No Water Discharge) Single Application to Whole Lakes or Reservoirs Where single applications to whole lakes or reservoirs are desired, this product may be applied at an application rate not to exceed 90 ppb, and in a suggested range of 16 to 90 ppb. Application rates necessary to obtain these concentrations in treated water are shown in the following table. For additional application rate calculations, refer to the Application Rate Calculation—Ponds, Lakes and Reservoirs section of this label. Choose an application rate not to exceed 90 ppb to meet the aquatic plant management objective. Where greater plant selectivity is desired such as when controlling Eurasian watermilfoil and curlyleaf pondweed, an application rate lower in the rate range may be chosen. For other plant species, SePRO recommends contacting a SePRO Aquatic Specialist in determining when to choose application rates lower in the rate range to meet specific plant management goals. Use the higher rate within the rate range where there is a dense weed mass or when treating more difficult to control plant species or in the event of a heavy rainfall event where dilution has occurred. In these cases, a second application or more may be required; however, the sum of all applications must not exceed 150 ppb per annual growth cycle. Refer to the section of this label entitled, Split or Multiple Applications to Whole Lakes or Reservoirs, for guidelines and maximum rate allowed. Average Water Depth of Treatment Site (feet) Pounds of product Per Treated Surface Acre 16 ppb 90 ppb 1 1.6 9 2 3.2 18 3 4.8 27 4 6.4 36 5 8 45 6 9.6 54 7 11.2 63 8 12.8 72 9 14.4 81 10 16 90 11 17.6 99 12 19.2 108 13 20.8 117 14 22.4 126 15 24 135 16 25.6 144 17 27.2 153 18 28.8 162 19 30.4 171 20 32 180 Split or Multiple Applications to Whole Lakes or Reservoirs To meet certain plant management objectives, split or multiple applications may be desired in making whole lake treatments. Split or multiple application programs are desirable when the objective is to use the minimum effective dose and to maintain this lower dose for the sufficient time to ensure efficacy and enhance selectivity. Under these situations, use the lower rates within the rate range. In controlling Eurasian watermilfoil and curlyleaf pondweed and where greater plant selectivity is desired, an application rate lower in the rate range may be chosen. For other plant species, SePRO recommends contacting a SePRO Aquatic Specialist in determining when to choose application rates lower in the rate range to meet specific plant management goals. For split or repeated applications, the sum of all applications must not exceed 150 ppb per annual growth cycle. NOTE: In treating lakes or reservoirs that contain potable water intakes and when the application requires treating within ¼ mile of a potable water intake, no single application can exceed 20 ppb. Additionally, the sum of all applications must not exceed 150 ppb per annual growth cycle. 4 Partial Lake or Reservoir Treatments Where dilution of this product with untreated water is anticipated, such as in partial lake or reservoir treatments, split or multiple applications may be used to extend the contact time to the target plants. The application rate and use frequency of this product in a partial lake is highly dependent upon the treatment area. An application rate at the higher end of the specified rate range may be required and frequency of applications will vary depending upon the potential of untreated water diluting this product’s concentration in the treatment area. Use a rate at the higher end of the rate range where greater dilution with untreated water is anticipated. Application Sites Greater Than ¼ Mile from a Functioning Potable Water Intake For single applications, this product may be applied at rates not to exceed 150 ppb, and in a suggested range of 45 to 150 ppb. Split or multiple applications may be made; however, the sum of all applications must not exceed 150 ppb per annual growth cycle. Split applications should be conducted to maintain a sufficient concentration in the target area for a period of 45 days or longer. The use of a FasTEST is recommended to maintain the desired concentration in the target area over time. Application Sites within ¼ Mile of a Functioning Potable Water Intake In treatment areas that are within ¼ mile of a potable water intake, no single application can exceed 20 ppb. When utilizing split or repeated applications of this product for sites which contain a potable water intake, a FasTEST is required to determine the actual concentration in the water. Additionally, the sum of all applications must not exceed 150 ppb per annual growth cycle. Application Rate Calculation — Ponds, Lakes and Reservoirs The amount of product to be applied to provide the desired ppb concentration of active ingredient in treated water may be calculated as follows: Pounds of product required per treated acre = Average water depth of treatment site x Desired ppb concentration of active ingredient x 0.1 For example, the pounds per acre of product required to provide a concentration of 25 ppb of active ingredient in water with an average depth of 5 feet is calculated as follows: 5 x 25 x 0.1 = 12.5 pounds per treated surface acre. NOTE: Calculated rates may not exceed the maximum allowable rate in pounds per treated surface acre for the water depth listed in the application rate table for the site to be treated. Application to Drainage Canals, Irrigation Canals and Rivers Static Canals In static drainage and irrigation canals, this product may be applied at typical use rates of 37 to 74 pounds per surface acre. The maximum application rate or sum of all application rates must not exceed 150 ppb per annual growth cycle. Moving Water Canals and Rivers This product’s performance will be enhanced by restricting or reducing water flow. In slow moving bodies of water use an application technique that maintains a concentration of 10 to 40 ppb in the applied area for typically a minimum of 45 days. This product can be applied by split or multiple broadcast applications or by metering in the product to provide a uniform concentration of the herbicide based upon the flow pattern. The use of a FasTEST is recommended to maintain the desired concentration in the target area over time. Static or Moving Water Canals or Rivers Containing a Functioning Potable Water Intake In treating a static or moving water canal or river which contains a functioning potable water intake, applications of this product greater than 20 ppb must be made more than ¼ mile from a functioning potable water intake. Applications less than 20 ppb may be applied within ¼ mile from a functioning potable water intake; however, if applications of this product are made within ¼ mile from a functioning water intake, a FasTEST must be utilized to demonstrate that concentrations do not exceed 150 ppb at the potable water intake. Application Rate Calculation — Drainage Canals, Irrigation Canals and Rivers The amount of this product to be applied through a metering system to provide the desired ppb concentration of active ingredient in treated water may be calculated as follows: 1. Average flow rate (feet per second) x average width (ft.) x average depth (ft.) x 0.9 = CFS (cubic feet per second) 2. CFS x 1.98 = acre feet per day (water movement) 3. Acre feet per day x desired ppb x 0.1 = pounds product required per day. STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage or disposal. Pesticide Storage: Store in original container only. Do not store near feed or foodstuffs. In case of leak or spill, contain material and dispose as waste. Pesticide Disposal: Wastes resulting from use of this product may be used according to label directions or disposed of at an approved waste disposal facility. Container Handling Non-refillable Container. DO NOT reuse or refill this container. Completely empty container into application equipment, then offer for recycling if available or dispose of empty container in a sanitary landfill or by incineration, or by other procedures approved by state and local authorities. Warranty Disclaimer: SePRO Corporation warrants that this product conforms to the chemical description on the product label. Testing and research have also determined that this product is reasonably fit for the uses described on the product label. To the extent consistent with applicable law, SePRO Corporation makes no other express or implied warranty of fitness or merchantability nor any other express or implied warranty and any such warranties are expressly disclaimed. Misuse: Federal law prohibits the use of this product in a manner inconsistent with its label directions. To the extent consistent with applicable law, the buyer assumes responsibility for any adverse consequences if this product is not used according to its label directions. In no case shall SePRO Corporation be liable for any losses or damages resulting from the use, handling or application of this product in a manner inconsistent with its label. For additional important labeling information regarding SePRO Corporation’s Terms and Conditions of Use, Inherent Risks of Use and Limitation of Remedies, please visit http://seprolabels.com/terms or scan the image below. © Copyright 2020 SePRO Corporation Sonar and FasTEST are registered trademarks of SePRO Corporation SePRO Corporation 11550 North Meridian Street, Suite 600 Carmel, IN 46032, U.S.A.