Public Comment to NYSDEC re: City of Syracuse Use of EarthTec

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Statement of Support for SLA Position on City of Syracuse EarthTec Permit

Please check the box below to the left of the text to indicate that you support SLA's public comment to the NYSDEC

I support the Skaneateles Lake Association regarding the following statement: The Skaneateles Lake Association: • strongly opposes at this time the NYSDEC permitting the City of Syracuse the ability to introduce the algicide EarthTec into Skaneateles Lake. • requests that the NYSDEC postpones determination on the permit request until significant concerns outlined in this comment can be adequately addressed by the City of Syracuse, NYSDEC, EarthTec, and the appropriate scientific community. • requests that more information be provided regarding the selection of EarthTec and assessment of other alternatives if any. • has concerns about the risks associated with treating Microcystis cyanobacteria with a product such as EarthTec that could remain in the lake’s ecosystem over time. • requests more information from an entity such as the Environmental Protection Agency on the potential impacts on a water body from EarthTec • recommends that there is further investigation regarding what the impacts are to other similar bodies of water with similar application. • requests information on the long term risks and threats not only to humans, but also to how the application of EarthTec could impact the lake’s ecosystem. • recommends that there be more time for scientists familiar with Skaneateles Lake and Microcystis to confer with scientists at EarthTec to better understand potential impacts together before a determination is made to allow for the use of EarthTec. • recommends that the City of Syracuse provides more details regarding the treatment protocol of applications and monitoring operations. • requests that information is provided on how the treatment application is incorporated into a well-established and vetted emergency action plan. • recommends a continued assessment of the strategy of applying technologies like ultrasound and products such as EarthTec into the Woodland Reservoir as opposed to the open waters of Skaneateles Lake. • recommends that a baseline of copper in the existing sediment be established prior to any potential further introduction into Skaneateles Lake. • recommends that the NYSDEC provides other specific visual biological impact examples to look for beyond fish kills to trigger the cessation of the application of EarthTec. • recommends that there be a sufficient operations, maintenance, and monitoring plan associated with the proposed treatment system. • recommends a stronger response of enforcement from the NYSDEC, NYSDOH, and City of Syracuse regarding the greater need for more stringent protections in our watershed. • requests that the NYSDEC and the City of Syracuse to co-host an informational meeting for the public to have a venue to learn more on this issue and be given the opportunity to engage in a dialogue with experts and decision makers relative to the proposed permit application. • requests that the NYSDEC and City of Syracuse continue to invest in and expedite the development of more benign treatment technologies, products, and strategies in the management, mitigation, and prevention of Harmful Algal Blooms.

Additional comments

Please add any additional comments to the NYSDEC regarding the proposed permit fro the City of Syracuse to use EarthTec on Skaneateles Lake

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Public Comment on City of Syracuse SPDES Algicide Permit Application #7-3150-00112/00004

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