Possible effects on the Lake Bomoseen ecosystem

• ProcellaCOR EC mimics plant auxins that regulate growth. All plants could be impacted to some extent. There is no way of knowing how the rich plant life of Bomoseen (including several listed as Uncommon/Vulnerable on VT’s 2022 Natural Heritage Inventory of native plants) would be affected. We’d be experimenting on our lake.

• We’re told it’s safe for wildlife, but…From the EPA toxicity assessment:

  • “Neither reptiles nor amphibians are tested.”

  • “Only a few surrogate species for both freshwater fish and birds are used to represent all freshwater fish (2000+) and bird (680+) species in the U.S. For mammals, acute studies are usually limited to Norway rat or the house mouse.”

  • In the EPA report, benthic invertebrates (the base of aquatic food web prey) displayed chronic toxicity effects in sediment studies at all concentrations.

• There’s no way to control application area. Based on data from Midwestern lakes, ProcellaCOR EC can migrate out of the treatment area in levels high enough to kill milfoil and other plants hundreds of feet away.

• The Hubbardton end of the lake is an Audubon designated Important Bird Area of continental importance. This habitat (targeted for initial treatment) supports 166 species of birds, including several Threatened or Endangered species. They migrate & nest here, feeding on fish, frogs, invertebrates, tubers, & other aquatic vegetation.