The Case for an Accessible Path for Vermont Lake Associations to Use ProcellaCOR to Control Invasive Milfoil

Supporters of Vermont Lakes and Ponds,

We’d like to inform you of the publication of the Federation of Vermont Lakes and Ponds white paper:

“The Case for an Accessible Path for Vermont Lake Associations to Use ProcellaCOR to Control Invasive Milfoil“.

As you may be aware, the Vermont legislature has created an Aquatic Nuisance Control Study Committee with the passing of Act 57 (H.31). From the Act 57 Committee’s website:

“The Aquatic Nuisance Control Study Committee was created to assess the environmental and public health effects of the use of pesticides, chemicals other than pesticides, biological controls, and other controls in comparison to the efficacy of their use in controlling aquatic nuisances recommendations regarding whether and when pesticides, chemicals other than pesticides, or biological controls should be used to control aquatic nuisances in Vermont in a report to the VT General Assembly on or before December 15, 2023.”

FOVLAP has been monitoring and attending the public meetings of the committee, and felt it was necessary to provide the committee with this paper to outline the need for continued access to regulated, safe, and effective use of herbicides as a tool to maintain control of Eurasian watermilfoil in infested waterbodies.

An increasing share of the burden of preserving Vermont’s lakes and ponds falls on the volunteer associations, who must address a host of challenges to ensure the protection and the long-term health of these vital Vermont aquatic resources. Currently, management of invasive milfoil is Vermont’s most pressing AIS problem. The current regulations governing this management provides a means to manage milfoil with a high but sustainable cost and with a bearable permitting burden.

Ongoing action is needed to care for and protect Vermont lakes and ponds from the threat of milfoil and other AIS. The Act 57 Study Group’s recommendations for changing herbicide use permit regulations should carefully consider the concerns of the volunteer organizations who are passionately devoting time and resources to milfoil management. The State of Vermont has the statutory responsibility to preserve the public waters of the state. This common goal leads to a vital partnership between the State and the associations. An effective partnership can improve lake health, avoid loss of lakeshore property values, and continue to attract the robust tourist economy that Vermont lakes and ponds provide.

There are numerous examples of lake associations in Vermont who, with the help of State and municipal funding along with their own fundraising efforts, have achieved effective control of milfoil with no evidence of serious harm to lake health – but only after using a permitted aquatic herbicide. The strength of this evidence compels us to argue that lake associations should continue to have access to the use of ProcellaCOR without unjustified new permitting burdens.

If the Act 57 Study Committee findings result in a delay or in significant changes to the permitting process that make the process yet more complex and burdensome, many milfoil infested lakes with active, successful, long term management programs could be negatively impacted, as they seek ANC permit renewals for ProcellaCOR. There would be similar negative impacts to those lakes that will, out of necessity, newly seek herbicide permits to control growing infestations.