SOURCE:
June 20, 2024
Re: Moratorium on ProcellaCOR Permitting Pending PFAS and Human Health and Ecological Impact Concerns
Dear Adirondack Park Agency Executive Director Barbara Rice,
The undersigned are writing to express our deep concern regarding the recently disclosed Minnesota Department of Agriculture (MDA) information on per- and polyfluoroalkyl substances (PFAS) within pesticides, including florpyrauxifen-benzyl which is the active chemical ingredient in ProcellaCOR EC and SE. As the Adirondack Park Agency is aware, ProcellaCOR EC is the less concentrated form of ProcellaCOR SE, both of which are manufactured by the SePRO Corporation, the former of which has been recently approved for use in several lakes in the Adirondacks.
Partners call on the Adirondack Park Agency to place a moratorium on the issuance of additional permits until further science can be reviewed and conducted to assess the impacts ProcellaCOR will have on the Adirondack waters that Park-residents and New York depend on for clean water.
ProcellaCOR is part of a new class of plant growth hormones called synthetic auxins, which mimic plant hormones, that have been engineered to be absorbed by target species such as Eurasian watermilfoil (EWM). It differs from other herbicides because it causes the plant to undergo an accelerated rate of growth by elongating a plant’s cells. This process eventually kills the plant rather than more traditional herbicides, which poison a plant. ProcellaCOR was registered by the US Environmental Protection Agency (EPA) in 2018 as a Group 4 herbicide.
In 2022, the EPA removed 12 chemicals found to contain PFAS from their list of registered inert ingredients, which merely are all ingredients that are not the active ingredient in a given pesticide and does not mean they are non-toxic, approved for use in nonfood pesticide products. None of the 12 chemicals were reported as currently being used in pesticides as inert ingredients, though the EPA removed them to “prevent the introduction of these PFAS into pesticide formulations without additional EPA review.” In addition, nine new PFAS were listed last year and seven new PFAS were listed in January of this year. This demonstrates a rapidly emerging public health crisis that merits further research before any additional ProcellaCOR permits are approved and are able to pose irreversible harm to our water, wildlife, and to human health.
PFAS are colloquially known as “forever chemicals” given their long-term persistence in the environment. PFAS are defined as “a class of fluorinated chemicals containing at least one fully fluorinated carbon atom” per the 2019 National Defense Act, Department of Environmental Conservation (DEC), and the MDA definitions. The MDA expands the PFAS interpretation of a “fully fluorinated carbon” to also describe unsaturated carbon bonds such as one fluorine atom on a benzene ring, which ProcellaCOR exhibits. While this is not congruent with the current EPA interpretation from US law, which does not clarify whether carbon atoms must be saturated or part of an alkyl chain, it is consistent with emerging literature for a framework by which pharmaceuticals may be determined to contain PFAS1. A 2023 EPA explainer flyer warns, “The more we learn about PFAS chemicals, the more we learn that certain PFAS can cause health risks even at very low levels. This is why anything we can do to reduce PFAS in water, soil, and air, can have a meaningful impact on health.”
We recognize the addition of testing concentrations at or near lake bottom depths post-treatment to assess that concentrations are below recommended levels. However, this is not enough as impacts beyond target areas require further study when wind and water carry the herbicide outside of the application area and have impacts to native plant communities2. There is also concern for bioaccumulation as the chemical is fat soluble and can persist in the environment for longer than claimed because they bind to microplastics, which are present in Adirondack waters.
Given these concerns and the unknown nature of its potential threats to environmental and human health, the undersigned call for a moratorium on issuing any new permits for ProcellaCOR and other possible PFAS-containing aquatic pesticides until more comprehensive information is available.
We urge the APA to reinforce long-term lake management plans containing a history of active management, assess site suitability, and protect wetlands more rigorously through approaches that include hand harvesting or DASH before and after treatment when applying herbicides.
The current lack of in situ research is troubling and merits a long-term mesocosm-to-field study encompassing benthic aquatic invertebrates, native plant species, and aquatic predators. The mesocosm study must include hydrodynamic processes and lake characteristics to ascertain the impacts of ProcellaCOR and its degradates on the ecology of aquatic systems in a more holistic sense. These assessments must address bioaccumulation, food webs and predator/prey relationships, changes to foraging behaviors, and shifts in food availability. This type of study shows the importance of chemicals studied in their natural ecological contexts and can illuminate altered trophic cascades that may drive biodiversity loss4. The undersigned groups request that the APA address these concerns at an upcoming presentation to the board on ProcellaCOR.
As federal guidelines and listings change, agencies in states such as Minnesota and Maine are taking the lead as protectors of waters and health, and New York must follow suit. Invasive species such as Eurasian water milfoil are threats to our waterways, but forever chemicals pose a threat to all.
Sincerely,
Raul J. Aguirre, Executive Director, Adirondack Council
Adrienne Esposito, Executive Director, Citizens Campaign for the Environment
Tracy Frisch, Chair, Clean Air Action Network of Glens Falls
Bobbi Wilding, MS, Executive Director, Clean+Healthy
Dr. John E. Kelly III, Chair, Lake George Association
Chris Navitsky, PE, Lake George Waterkeeper
Kathleen A. Curtis, LPN, Founder and President, Moms for a Nontoxic New York
Caitlin Ferrante, Conservation Program Manager, Sierra Club Atlantic Chapter
