Date: March 9, 2008

To: Wayland Conservation Commissioners

From: Ted Fiust

Subject: Proposed Aquatic Management Plan for Dudley Pond

Dear Conservation Commissioners:

I respectfully request that this letter be submitted and recorded as testimony in the upcoming hearing scheduled for March 13, 2008.

After seeing many of the emails and hearing the comments of the past weeks since the last Conservation Commissioners hearing about the use of fluridone in Dudley Pond in 2008, I felt compelled to add my own direct observations and thoughts about the current level of milfoil infestation. I emphasize that all my comments refer to the current level of milfoil infestation, and that I might suggest other methods than fluridone (trade name: Sonar) be used if the situation was different. As an abutter, diver, and aquatic biologist I have spent more time than anyone else in direct observation and research on the pond since 1995. I have been involved with every fluridone treatment except the first one in 1992. I have been involved with every diving effort, and I have been a part of every experiment done on the pond as an alternative to fluridone. I have served on every committee evaluating alternatives to fluridone since 1995.

My position is against the use of fluridone if reasonable alternatives exist. Given the current level of milfoil infestation, I believe fluridone to be the best method to employ this year. It is best for the pond and best for the sake of the community that uses the pond.

Milfoil density this summer will likely pose significant risk to the users of the pond and perhaps even to the pond’s animal inhabitants. Last summer pond residents said milfoil density was as bad as they had ever seen it. Therefore, since milfoil grows exponentially, this summer should be significantly worse. Water conditions may be degraded for aquatic inhabitants this summer, with potential for de-oxygenated water to cause undue stress on fish and invertebrates. Eutrophication will be accelerated. The pond abutters are angry. Property values are reduced. Boaters cannot use the pond. Fishermen are rarely seen on the pond. Swimmers may drown. Members of the Wayland Surface Water Quality Committee have several articles in their possession citing instances where drownings have occurred due to entanglement in milfoil. For these scientific, social, and political reasons, plus the economic incentive that it is the least costly and most likely to succeed method, I recommend fluridone be the method of choice to bring milfoil under control this year.

The Wayland Surface Water Quality Committee has stressed over and over that they have put a program in place making every effort to have this be the last time fluridone is put in the pond. Follow-up with monitoring and hand pulling at the earliest possible time should likely take care of the inevitable re-infestation.

Arguments against fluridone have focused on several misleading and misinformed perspectives. Below, I will address two egregious erroneous arguments for which I feel qualified to render an informed opinion based on either my direct experience working on the pond for 12 years, or based on my scientific background:

1. Erroneous statement Number 1: fluridone will “kill” the pond.

My direct observation is that fluridone has not had a significant adverse effect on non-target plants, fish, or invertebrates. I was present during the 1996, 1997 fall booster treatment, and the 1999, 2003 fluridone treatments. As a diver I performed many of the pre and post treatment plant surveys. As a hand pulling diver I have participated in hand pulling efforts every year that hand pulling was used as a control method. We did not hand pull during treatment years, except for the summer of 1997 prior to the fall treatment.

-Chlorosis of the water lilies did occur following some treatments. They came back.
-The fish populations subjectively appear fine. As a diver I regularly see bass, pickerel, black crappies, perch, bluegills, carp and catfish.
-Frogs, tadpoles, painted turtles and snapping turtles regularly appear.
-Invertebrates such as crayfish exist in good numbers. Leeches are also present.

Some predict excessive algae blooms. No significant algae blooms have threatened the pond in any year following previous fluridone treatments. Fluridone acts slowly over time to kill the plants. I have never observed any conditions that indicate the pond had less oxygen than needed to sustain the organisms in the pond. The dosage level during some treatments in the past has been at the targeted 12 ppb, although it has not been sustained for the targeted 120 days of the proposed 2008 application.

2. Erroneous statement number 2: Fluridone is a pesticide and carcinogen that should not be allowed in our drinking water:

References have been made to Rachel Carson’s Silent Spring, where organophosphate pesticides affect nervous system pathways in insects and humans alike. Fluridone’s mode of action is not the same. Fluridone is not a pesticide; it is an herbicide. Fluridone acts on a site that only exists in plants. With fluridone blocking the formation of carotenoid pigments (the yellow pigments in plants) that serve to protect the chlorophyll from ultraviolet photo-degradation, the plant’s “sunscreen” is removed, so to speak, and the plant gets fatal sunburn. The plant cannot make food for itself, and so dies a slow death. This means the water is not robbed of oxygen as might happen if a quick kill occurred. Animals do not make carotenoids, so we do not have a place where the chemical is likely to be active.

Further, the mode of action of fluridone is so effective on plants that the extremely low dose level of 10 to 20 ppb is enough. The USEPA has approved up to 150 ppb be allowed in water used for drinking. The proposed dose is 10 times less than that. Further, fluridone is specifically permitted for drinking water supplies, and application within a Zone II recharge area in Massachusetts, the designation for Dudley Pond. Even if any fluridone were to reach the nearest wells that are approximately 3000 feet from Dudley Pond, the dose would be assuredly less than 12 ppb due to photo-degradation in the pond and soil adsorption along the way. Those who indicate that repeated applications of fluridone may increase the level of fluridone reaching the wells fail to account for the goal of this 2008 proposal to be the last time fluridone is used in the pond.

Regarding fluridone being a carcinogen; no direct evidence has been found. Members of Surface Water Quality have done extensive research and have not been able to find in literature searches any reference to fluridone causing cancer.

We tried or evaluated every method suggested by any of the people submitting comments. They have been dismissed on economic grounds or have been tried and found not effective enough for the current level of milfoil infestation.

In conclusion, I stress that it is not intended that fluridone be used again and again. The 2008 proposal involves a follow-up management program that has previously not had the manpower or the dollars committed to see success. Our best previous effort was with the S319 Grant that involved weevil stocking. I hand pulled with other divers to the maximum dollars available under the grant and beyond, but it was not enough to keep the remaining milfoil from overtaking the pond again. The dosage level of the last fluridone treatment in 2003 was lower than the recommended level of 12 ppb and may have contributed to the abundant re-growth.

This time there is a plan to dose longer, monitor more strictly, start hand pulling earlier, and plan to spot treat as a last resort contingency should a milfoil re-growth area get out of hand. Please permit us to attempt to re-gain control of the milfoil one more time.


Ted Fiust
Aquatic Ecologist
42 Mathews Dr.
Wayland, MA