In early 2022, the Lake Bomoseen Association applied for an ANC permit to use ProcellaCOR which resulted in misinformation being spread online and in newspaper commentaries.

To help combat this misinformation, and to provide fact-based information on ProcellaCOR, the Vermont Department of Environmental Conservation (DEC), published a document in October of 2022 entitled “Permitting Aquatic Herbicide Projects in Vermont”.

The Vermont DEC describes that the purpose of this document is to:

  1. Provide background information about DEC’s Aquatic Nuisance Control (ANC) permitting program, with a specific focus on aquatic herbicide projects;
  2. Identify some of the recent findings related to ProcellaCOR; and
  3. Provide a Q&A section on this topic reflecting common questions that DEC receives about our ANC permitting program

The document details Vermont statutes, the permitting application and technical review process, and the departments and agencies involved in the permitting process.

It also discusses key findings on ProcellaCOR EC, including:

  • a pre- and post-treatment statistical analysis of the aquatic plant survey data from Vermont treated waterbodies (showing increases in native plants, and decreases in milfoil)
  • an aquatic toxicity review memorandum performed by a Vermont DEC Environmental Scientist (concluding that “the potential for acute and chronic risks to fish, aquatic invertebrates, amphibians and other aquatic animals is considered low”)
  • a macroinvertebrate survey conducted by New York DEC, finding that “No significant changes to the macroinvertebrate community assemblage were observed when comparing survey results pre- and post-herbicide treatment.”
  • a review of ProcellaCOR’s confidential statement of formulation memorandum, performed by a Vermont State Toxicologist from the Vermont Department of Health concluding: “Based on a review of the confidential statement of formulation, it is reasonable to conclude that human exposure to the inert compounds contained in ProcellaCOR at the concentrations that would result under the conditions proposed by the applicants, is not likely to result in an increase in the level of concern for public health. Thus, the proposed treatment of Lake Bomoseen with ProcellaCOR is expected to result in negligible risk to public health, from both the active and inert compounds in ProcellaCOR.”)
  • an acknowledgement from the Vermont DEC’s Drinking Water & Groundwater Protection Division,“DWGWPD does not have concerns with the use of ProcellaCOR provided the conclusions from VDH have not changed and that treatment concentrations do not exceed 5 PDUs.”

Finally, the document contains 16 frequently asked questions posed to the Vermont DEC about these topics with their answers.

This document can be viewed here: Permitting Aquatic Herbicide Projects in Vermont

We also highly recommend reviewing this presentation by the Vermont DEC entitled “ANC Permitting 101” which goes into great detail about the permitting process.