This comment was submitted to the NYS DEC as part of an Environmental Assessment process for the ongoing application of Glyphosate (the cative ingredient in the herbicide Roundup) over a 40 acre parcel of the Piermont Marsh, south of the Tappan Zee Bridge on the Hudson River in Rockland County, NY.

February 28, 2018

NYS DEC
PO Box 315
Slaatsburg, NY 12580
hrnerr@dec.ny.gov

To Whom It May Concern:

We at NY4Whales are writing as representative of the staff, volunteers and membership of NY4Whales/NY4Wildlife, a 501(c)(3) cetacean and wildlife-advocacy organization operating out of Yonkers, NY. Thank you for the opportunity to comment on the proposed application of Glyphosate on a parcel of the Piermont Marsh in Rockland County, NY. We are requesting that procedures under NEPA and the SEQRA process be followed and a full Environmental Impact Statement be provided for the public, to facilitate a proper and competent analysis of the proposed activities. We find the Draft Plan is inadequate and fails to provide basic information needed to assess the project’s value.

OMISSIONS

What is the exact formulation of the Glyphosate solution to be used in the Piermont Marsh? Why was this left out of the Draft Plan?

What is the specific amount of tonnage of the Glyphosate solution that will be applied? Why was this left out of the Draft Plan?

What is the amount of tonnage that will be applied annually for the “long term maintenance” plan after the approximately 10 year initial applications?

What is the cumulative effect of years of Glyphosate application and long term maintenance on the Piermont Marsh and its community? Why was this omitted from the Draft Plan?

How does the DEC compute the length of “long term maintenance”; given the proclivity of the plant and its robust growth? The DEC hints at annual application essentially forever, which cannot be justified.

ENVIRONMENTAL TOXIN, CARCINOGENIC

Remarkably, the DEC stands by an unsupportable assertion that Glyphosate does little or no harm to humans or the environment. The chemical is the active ingredient in Monsanto’s Roundup, no stranger to controversy over its toxicity. However, in light of the fact that the International Agency for Research on Cancer (IARC) and the World Health Organization (WHO) have determined that Glyphosate is “potentially carcinogenic”, this chemical, in any of its dangerous formulations, does not belong in the Piermont Marsh.

On Friday, March 20, [2015,] the IARC released a statement that glyphosate, malathion and diazinon (also an insecticide) are classified as “probably carcinogenic to humans.”…
Glyphosate, on the other hand, is one of the key ingredients in the herbicide Roundup, which is produced by Monsanto, the largest seed company in the world. The chemical is widely used to get rid of unwanted weeds across the world. The IARC reported that it may be carcinogenic to humans.
“The IARC Working Group that conducted the evaluation considered the significant findings from the US EPA report and several more recent positive results in concluding that there is sufficient evidence of carcinogenicity in experimental animals,” stated the IARC. (Passary, Sumit. “Malathion Can Kill Insects And Glyphosate Can Kill Weeds But They Can Also Give You Cancer: WHO.” TECH TIMES, March, 2015. http://www.techtimes.com/articles/41293/20150321/malathion-can-kill-insects-and-glyphosate-can-kill-weeds-but-they-can-also-give-you-cancer-who.htm)

INERT INGREDIENTS NOT REVEALED WILL EXACERBATE TOXICITY

A French research team of molecular biologists from the University of Caen has discovered that the toxic effects of Glyphosate-based pesticides, including Roundup, are dependent and multiplied by compounds included in the formulas.

The new findings intensify a debate about so-called “inerts” — the solvents, preservatives, surfactants and other substances that manufacturers add to pesticides. Nearly 4,000 inert ingredients are approved for use by the U.S. Environmental Protection Agency….
The research team suspects that Roundup might cause pregnancy problems by interfering with hormone production, possibly leading to abnormal fetal development, low birth weights or miscarriages….
Last month, an environmental group petitioned Argentina’s Supreme Court, seeking a temporary ban on glyphosate use after an Argentine scientist and local activists reported a high incidence of birth defects and cancers in people living near crop-spraying areas. Scientists there also linked genetic malformations in amphibians to glysophate. In addition, last year in Sweden, a scientific team found that exposure is a risk factor for people developing non-Hodgkin lymphoma.
Inert ingredients are often less scrutinized than active pest-killing ingredients. (Crystal Gammon. Weed –Whacking Herbicide Deadly to Human Cells. Scientific American. June, 2009. https://www.scientificamerican.com/article/weed-whacking-herbicide-p/)

            It doesn’t take much to understand that Glyphosate formulations are a detriment to marine organisms, insect life, birds, fish, small mammals and those that feed on them. Given the at risk species (critically endangered, endangered or vulnerable) cited by the DEC as present in the marsh, Glyphosate formulations, especially ones that the NYS DEC has not clarified, should be adjudicated illegal and barred from use at the Piermont Marsh as they can not be proven to “do no harm”.

PESTICIDE DRIFT

However, given the community concerns about potential herbicide exposure, DEC and OPRHP will establish an herbicide monitoring and data sharing program to evaluate and document herbicide use and evaluate whether herbicide moves beyond the treatment areas. The program will be developed in close consultation with local representatives, marsh managers, and pesticide regulators. The monitoring will evaluate herbicide levels prior to, during, and after treatment using best available techniques. Information will be posted on a publicly accessible website as soon as analyses are completed. (DEC. DRAFT PIERMONT MARSH RESERVE MANAGEMENT PLAN December 2017. https://www.dec.ny.gov/docs/remediation_hudson_pdf/hrnerrpiermontplan.pdf)

In other words, AFTER the pesticide has inevitably and predictably drifted out of the target area, the public will be given that information and the amount of drift analyzed. That may be well and good, but how does learning about the drift after the fact help ecosystems, the wildlife and people in the community? During intense weather events, and even through normal tidal and wave action, drift can be extensive; contamination of non-target areas by this product and the unknown pesticide adjuvants which have been shown to be as deadly or worse than the Glyphosate itself will occur. Posting drift information of this potentially carcinogenic formula will be no comfort, and is no solution. This statement shows that it lacks common sense reasoning from a government agency that should not have the power to apply a detrimental chemical to this sensitive and beloved marsh area.

LONG TERM EFFECTS

Cumulative effects of the years of application is not addressed in the Draft Plan, nor is it certain just how many years the Glyphosate application will take place. Because of the plant’s robust growth and potential for the development of Glyphosate-resistance, it is most likely that eradication efforts will continue annually in perpetuity, or until sea level rise overcomes even the ability of Phragmites to survive.

Although the plan’s horizon is ten years, it establishes a monitoring and adaptive management approach to support marsh resilience and conservation over the long term. (https://www.dec.ny.gov/docs/remediation_hudson_pdf/hrnerrpiermontplan.pdf)

Exposing the community to an endless cycle of Glyphosate application is not acceptable, and is an admission that the DEC doesn’t expect the Glyphosate to work!

SECRET FORMULATION

There is no exact data showing the formulation of the planned Glyphosate. It is critical to examine the exact ingredients in light of recent studies connecting the Glyphosate’s inert ingredients with the death of human tissue, adverse effects on amphibians, marine organisms and more. In fact, in some studies, the inert ingredients are being found more harmful than the actual chemical. Without an analysis of the actual ingredients it is impossible to predict harm or no harm to the environment or the nearby village and residents.

Phragmites will be controlled with a combination of three techniques: 1) a limited ground-based application of a registered herbicide (an aquatic glyphosate formulation) and non-ionic surfactant (an additive that helps the herbicide coat and penetrate the leaf surface);… The herbicide, applied at a dilute concentration, is absorbed and carried into underground plant parts, and disrupts a specific pathway for amino acid synthesis that is unique to plants and not present in animals. (Ibid.)

The NYS DEC [EPA] states it is conducting reviews periodically to reevaluate the safety of Glyphosate. If the EPA is admitting it is not sure that Glyphosate is safe, how can the NYS DEC assume that Glyphosate is safe, in unknown formulation and tonnage amounts, being applied to an environmentally sensitive tidal marsh of the Hudson River?

The Phragmites stands have replaced native plants in the marsh, but also now, as in other areas where Phragmites have established, support their own ecosystem. The Draft Plan does not consider the established ecosystem and what is thriving there, only to say that native species have been replaced.

ECOSYSTEM SERVICES PROVIDED BY PHRAGMITES

One researcher, Erik Kiviat, found important ecosystem services in stands of Phragmites, in 13 states; the study area included the Hudson River marshes. Results were published by the National Institutes of Health.

Many ecologists and wetland managers in the USA and Canada have considered P. australis as a weed with little value to the native biota or human society (Meyerson et al. 2000, 2002; Kiviat 2010). Occasionally, ecologists have expressed the contrary view that reedbeds provide important habitat and other ecosystem services (e.g. Kane 2001b; Weis and Weis 2003). Here I show that Phragmites provides important ecosystem services, among which is support for common and rare elements of biodiversity including many species of native plants and animals. These habitat functions of Phragmites are linked to distinctive characteristics of the plant and are generally similar to habitat functions of Phragmites in the Old World. I also propose a new approach to managing Phragmites to optimize its habitat functions, potential harvest for products and other ecosystem services. It is important to present a detailed summary of habitat functions to create an accurate context for further research and management decisions. (Kiviat, Erik. Ecosystem services of Phragmites in North America with emphasis on habitat functions. Annals of Botany Company. February, 2013. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4104640/)

Kiviat describes in detail the remarkable number of habitat and non-habitat ecosystem services provided by Phragmites. For food, Phragmites can provide seed and sugar; for fuel, fuel pellets and potentially fuel bricks, methane and other fuels; building materials including roof thatch, fencing, and even insulation. They are used for dried flower arrangements, decorations, fishing poles, building and stabilizing soils, carbon sequestration, evapotranspirative “air conditioning” and important removal of contaminants from water or soil. They can dewater sewage sludge, and removal harmful nitrogen and phosphorus from partially treated sewage, and provide stabilization and habitat development on inactive coal slurry impoundments. Phragmites stands are nest sites for bees, areas rich in primary production, nutrient processing, and provide a maintenance-free spontaneous vegetation cover on urban and derelict lands. Phragmites act as a screen between industrial and residential areas and as a ceremonial prop, Phragmites were used by Native Americans, including the Navajo and other southwerstern states, as well as during the Jewish festival of Sukkot. (Ibid. Table 1.)

Kiviat echoes knowledge that Pragmites provide beneficial ecosystem service to marsh soils, in addition to facilitating waste treatment, even as a food source for wildlife:

Phragmites builds and stabilizes tidal marsh soils, and stores carbon in litter and soils more effectively than Spartina spp. (Windham and Lathrop 1999; Rooth and Stevenson 2000; K. V. R. Schäfer, Rutgers University, Newark, NJ, pers. comm.). Thus Phragmites may protect tidal marshes from erosion associated with sea-level rise, as well as helping to mitigate global climate change. Soil building by Phragmites in tidal marshes appears to reduce micro-relief of the marsh surface and eliminate small pools used as a refuge at low tide by Fundulus (killifish) and other small nekton (Dibble and Meyerson 2012)…. (Ibid.)

WASTE TREATMENT
Clearly, the most important direct use of Phragmites in North America is in constructed systems for dewatering sludge from sewage treatment plants (e.g. Burgoon et al. 1997), and less frequently for removing nutrients from partially treated sewage (e.g. Gersberg et al. 1986). There are probably thousands of sludge-drying beds of variable size in the USA, and these are cost-effective and conserve energy that would otherwise be used in heat-drying of sludge. The high rates of transpiration of Phragmites and its ability to tolerate salt, metals and other pollutants make Phragmites suitable for drying sludge, and the efficient uptake of nutrients makes it suitable for polishing partially treated wastewater. Phragmites has also been used experimentally to dewater dredged material (Stout 1977)….

PHRAGMITES AS FOOD
Various insects feed on Phragmites (Balme 2000; Tewksbury et al., 2002; Lambert 2005; E. Kiviat, unpubl. data); many of these are believed to be non-native (Balme 2000). However, most studies of Phragmites insects have been in the eastern states and there are probably many insects associated with western Phragmites that remain to be documented. Insects include endophagous stem-feeders, leaf chewers, sap suckers, gall makers and a rhizome feeder. Usually, insect feeding does not cause significant damage; Balme (2000) found the greater wainscot moth Rhizedra lutosa causing minor damage in Rhode Island. On one occasion I found larvae of Simyra insularis (Noctuidae; Henry’s marsh moth), a native, generalist feeder, heavily grazing Phragmites leaf blades where it grew sparsely among Calamagrostis canadensis (bluejoint grass), but not in the adjoining dense Phragmites stands (Fig. ​(Fig.77)….

The non-native sap-feeding Chaetococcus phragmitis (reed scale) that is sessile beneath lower leaf sheaths may be widespread and abundant, at least in Old World Phragmites. Krause et al. (1997) found late-winter biomass of adults as high as 1 g dw m⁻² in a freshwater tidal marsh on the Hudson River. I have frequently seen songbirds opening leaf sheaths and consuming the scale insects, especially in winter, in the northeastern states. Birds also commonly peck holes in Phragmites internodes and eat insects living within.

Hyalopterus pruni (mealy plum aphid) is widespread and abundant in North America (Balme 2000; Lambert 2005). This aphid alternates generations between Phragmites in summer and Prunus spp. (cherries, etc.) in winter; it is a pest of prune (Prunus domestica) orchards in California (Latham and Mills 2012). Although birds apparently do not feed on mealy plum aphid, Coccinellidae (lady beetles) are often present and presumably feed on the aphids.

Ondatra zibethicus (common muskrat) is the most important native vertebrate consumer of Phragmites. Muskrats feed on young shoots and rhizomes, and also cut mature culms for lodge construction. Several studies in different regions of North America have found Phragmites ranking from high to low among other plant species in the muskrat diet (Bellrose 1950; Paradiso 1969). Muskrats may use Phragmites intensively, depending on the availability of more ‘preferred’ foods such as Typha (cattail) and Scirpus (bulrush; Butler 1940; McCabe 1982). For example, Butler (1940) listed Phragmites as the fourth of 13 plant taxa in the muskrat diet in Manitoba; McCabe (1982) found Phragmites a close second to Scirpus in Utah; Phragmites was an important summer food in the north-central states (Errington 1941); in Maryland tidal marshes Typha and Scirpus were most important but Phragmites was ‘a favourite food, grows in beds of limited distribution, in which muskrats are always found’ (Smith 1938);…

Muskrats may be abundant in habitats where Phragmites is highly dominant, as at times and places in the New Jersey Meadowlands (E. Kiviat, unpubl. data). Castor canadensis (American beaver) also uses Phragmites for construction and perhaps eats it as well, but possibly less so than the muskrat.

Sylvilagus spp. (cottontail rabbits) at times cut many Phragmites shoots for food (Balme 2000; E. Kiviat, unpubl. data). Balme (2000) found extensive clipping of culms by Sylvilagus floridanus (eastern cottontail) in experimental Phragmites plots in Rhode Island. I found extensive clipping by S. floridanus at a lakeside wet meadow in Rockland County, New York, in 2011. In 2006 I observed much use of Phragmites stands (clipping of culms, shelter) by S. cf. audubonii (desert cottontail) in the Southwest. Domestic livestock (horses, cattle, goats, sheep) graze Phragmites, especially young shoots in spring, and have caused Phragmites declines in some cases (Kiviat and Hamilton 2001). Spatial patterns of reedbeds in relation to fences of livestock pastures in New York suggest that livestock inhibition of Phragmites is common. Odocoileus virginianus (white-tailed deer) may graze Phragmites in Louisiana but it is not a major food (Self et al. 1975). Branta canadensis (Canada goose) grazes Phragmites leaf blades, especially in urban marshes of the New York City area, but does not seem to do much damage (E. Kiviat, unpubl. data). Chen caerulescens (snow goose) feeds on Phragmites rhizomes in Gulf Coast marshes (Glazener 1946)….

Dead Phragmites material (litter, detritus) provides food as well. Fungi and other microbes growing on decomposing wetland plants support detritivorous invertebrates (Gulis et al. 2006) and provide the basis for wetland food webs that are often more important than those based on herbivory. Most of the macroinvertebrates found in reedbed litter and soil (see Table ​Table3)3) are probably deriving nutrition from dead Phragmites and associated microbes. Food webs based on Phragmites detritus, alone or as a significant portion of mixtures with other carbon sources, can support important fish populations (Wainwright et al.2000; Weinstein et al. 2000) and therefore higher-order consumers that presumably include certain invertebrates, turtles, snakes, many kinds of birds, and mammals. [Emphasis added.] (Ibid.)

Kiviat disputes claims that Phragmites stands crowd out or smother all other plants within the centers:

Frequent associates in reedbed interiors include Peltandra virginica (arrow arum) and Impatiens capensis (orange jewelweed) in fresh water, and Atriplex prostrata (A. patula var. hastata; orache) in brackish water. Occasional individuals of larger woody or suffrutescent species such as Sambucus nigra ssp. canadensis (common elderberry), Ailanthus altissima (tree-of-heaven), or Hibiscus moscheutos (swamp rose mallow) may also occur; in some cases these plants may have been present before reedbed development….

[INSERT PHOTO HERE]

Other plants associated with reedbeds. Left: Hibiscus moscheutos (swamp rose mallow), a common large suffrutescent associate of Old World P. australis in East Coast tidal marshes and formerly tidal marshes. Upper right: mosses beneath sparse Old World P. australis on freshwater tidal shore, Hudson River. Lower right: Cardamine longii (Long’s bittercress), a rare plant, beneath sparse Old World P. australison the freshwater tidal shore, Hudson River. Photographs by Erik Kiviat. (ibid.)

Reedbeds can be dense, with Phragmites highly dominant, or sparse with other species admixed. For example, in September 2000, I found 18 species of associated vascular plants (three herbaceous and one woody vines, two shrubs, two suffrutescent herbs, two ferns, and eight other herbs) in the interior of a reedbed that had been harvested annually and occasionally burned in the New Jersey Meadowlands (E. Kiviat, unpubl. data). These associated species were sparse and occurred just outside the most recently harvested area. Reedbeds that are sparse, deeply flooded, or subject to high hydrodynamic energy (e.g. shorelines of open tidal waters) may support a greater diversity of vascular plants in edges. The occurrence of rare vascular plants and mosses in the interiors or edges of reedbeds under some circumstances suggests that Phragmites is facilitating the associated species by ameliorating harsh environmental conditions. [Emphasis added.] Some of the cases I have observed are in relatively high-energy (wave-washed) tidal shores where sparse reedbeds appeared to be physically sheltering smaller plants of other species or maintaining favourable substrates against wave erosion. At Jamaica Bay Wildlife Refuge in New York City, Platanthera lacera (ragged fringed orchid), a regionally rare species, was found beneath mixed upland stands of Phragmites and Betula populifolia (grey birch), and nowhere else (D. Taft, U.S. National Park Service, New York, NY, pers. comm.). On the Hudson River, three rare native species, Limosella subulata (mudwort) and Lilaeopsis chinensis (eastern lilaeopsis) in brackish tidal wetlands, and Cardamine longii (Long’s bittercress) in fresh-tidal wetlands, occur in reedbed edges where the Phragmites may be facilitating these small plants by providing physical shelter, stabilizing the sediments, or oxygenating the soil (the last phenomenon was suggested as a process by which Phragmites facilitated plants less tolerant to soil hypoxia; Callaway 1995). [Emphasis added.]

Vines, both woody and herbaceous species, use Phragmites for support. Vines are especially frequent and sometimes constitute considerable phytomass at the upland edges of reedbeds and on channel banks where the substrate may be slightly higher. Cuscuta (dodder) occasionally parasitizes Phragmites; all other vines are non-parasitic. Certain robust woody vines that ordinarily use woody plants or permanent structures such as fences for support evidently are able to reach from old overwintered Phragmites culms to new shoots of the current year. I have documented >30 species of vines, half native and half non-native, using Phragmites as the host (E. Kiviat, unpubl. data). Vines modify reedbed architecture and provide additional food resources for animals.

Diverse mosses and a few liverworts occur beneath reedbed edges and interiors on soil or culm bases (Barbour and Kiviat 2007; G. Stevens, Hudsonia, Annandale, NY, pers. comm.; E. Kiviat, unpubl. data). Bryophytes appear to be more abundant and diverse beneath Phragmites where it grows sparsely and the substrate is wet but not long-flooded. A rare species in New York, the moss Philonotis muhlenbergii, was found beneath Phragmites on a Hudson River island (Barbour and Kiviat 2007). Algae colonize the lower portions of culms. Epiphyton (algae, particularly diatoms) was similar in Phragmites and Typha in an Ohio marsh (Back 2010). (Ibid.)

Like the marshes in this study, the Piermont Marsh likely hold all these and more. The dazzling number of species and the manner of their coexistence in the marsh, amidst Phragmites betrays the human sensibility as bereft and lacking understanding. These stands should not be destroyed at all, as they provide so much, and we have yet to understand. Kiviat continues with even more ecosystem services provided by Phragmites.

Reedbeds may retain ice and remain cooler than their surroundings in spring (Meyerson et al.2000). The resulting cool microclimate may inhibit some biota. Possibly some of these cool reedbeds shelter species near their southern range limits that require cool habitats.

The greater height of Phragmites compared with other wetland herbs is a resource for certain species. Although the nests of Ammodramus maritimus (seaside sparrow) were placed low in native graminoids in Massachusetts, the birds most often sang from Phragmites or a shrub [Iva frutescens (marsh-elder); Marshall and Reinert 1990]. Phragmites located at higher substrate elevations in or near marshes, and perhaps the robust nature of the reedbed itself, can provide shelter from higher than normal tides or floods, as evidenced by nesting Larus atricilla (laughing gull) in New Jersey (Burger and Shisler 1980).

Particular features of reedbeds attract birds in many instances. Anatinae (dabbling ducks) loafed on cattle-trampled reedbeds at the Delta Marshes, Manitoba (Sowls 1955). Small, reed-bordered channels were used by ducks during bad weather in the New Jersey Meadowlands [R. Kane, New Jersey Audubon Society (retired), Bernardsville, NJ, pers. comm.]. Reedbeds, especially those with standing water, attract large numbers of roosting songbirds, as reported in published studies and qualitative observations (Table ​(Table2);2); in one example, there was a peak of 40 000 Dolichonyx oryzivorus (bobolink; Iliff and Lovitch 2007). In the Delta Marshes of Manitoba, where native Phragmites is a dominant species, Circus cyaneus (northern harrier) nested in the edges between Phragmites and Scholochloa festucacea (whitetop grass). Phragmites was the most abundant plant in the vicinity of five nests (Hecht 1951).

Few data are available regarding Phragmites support of amphibians and reptiles, although various species have been found in reedbeds (Table ​(Table2).2). Under certain circumstances, reptiles appear to be using reedbeds for overwintering or thermoregulation (E. Kiviat, unpubl. data). Storeria dekayi dekayi (northern brown snake) individuals have been found beneath small piles of recently cut Phragmites culms in a non-tidal marsh restoration site in New York City (V. Ruzicka, Randall’s Island Park Alliance, New York, NY, pers. comm.).

Notable are findings that Phragmites provide nesting materials for small mammals, including the muskrat and beaver. Phragmites also provide a buffer between human activities and the ecosystem wildlife; mitigating noise and visual disturbances.

PHRAGMITES AS NEST MATERIAL
Many birds use Phragmites culm, leaf, or inflorescence material in their nests. Common muskrat and American beaver use culm and rhizome material in lodge construction.

PHRAGMITES AS A BUFFER
The tall, dense, resilient masses of Phragmites often provide a buffer between human activities or cattle grazing and wetland wildlife (Ward 1942; Buchsbaum 1991). Phragmites screens out some of the noise and visual disturbances. Dense woody thickets can provide the same function, although reedbeds often occur at marsh edges in urban areas and other places that lack dense shrubs or trees. Reedbeds also buffer other organisms from winds. (Ibid.)

Some birds actually seek out Phragmites for nesting:

Relatively much is known about bird use of Phragmites, although this information is distributed unevenly by taxon, season, geographic region, and habitat (Table ​(Table5).5). In some cases, birds appear to actively select Phragmites habitat. Examples include Sterna hirundo (common tern) nesting in offshore reedbeds in Lake Poygan, Wisconsin (L. Bodensteiner, Western Washington University, USA, unpubl. data), Oxyura jamaicensis (ruddy duck) and Fulica americana (American coot) nesting only in reedbeds in New Jersey (Kane 2001a, b), and flocks of Hirundinidae (swallows), Icteridae (blackbirds), and other songbirds roosting in reedbeds in a freshwater tidal marsh on the Hudson River (Kiviat and Talmage 2006). (Ibid.)

This study showed how many species will use the reedbeds for one function, such as insect foraging, and an adjacent habitat for another type of activity, such as nesting. Removing one habitat, the Phragmites, will place these species at risk.

HABITAT COMBINATIONS
Mobile animals, such as birds, many mammals, and strongly flying insects, commonly use combinations of habitats to acquire all the resources they need. A reedbed can support one type of activity by a species while an adjacent or nearby alternate habitat can support another type of activity. In Marshlands Sanctuary (New York), Rallus longirostris (clapper rail) nested in a narrow fringe of Phragmites at the upland edge of a brackish tidal marsh, and foraged in the adjacent S. alterniflora at a slightly lower elevation in the marsh (A. Beal, Westchester County Department of Parks, Recreation and Conservation (retired), Ardsley, NY, pers. comm.). In marshes of the Hudson River and the New Jersey Meadowlands, larvae of Poanes viator (broad-winged skipper, a butterfly) feed on Phragmites leaves in the reedbeds, and the adults fly out of the reedbeds to feed on flower nectar of L. salicaria (purple loosestrife), Nepeta cataria (catnip), and other plants. (Ibid.)

Kiviat found that more than 75 native species of birds were breeding in dense Phragmites; such findings begs restraint when planning the destruction of Phragmites. More study is sorely needed.

Of 17 studies of breeding birds in reedbeds compared with an alternate habitat (Table ​(Table5),5), there were about 16 instances of species that were more abundant in Phragmites, and about 36 instances of species more abundant in the alternate habitat (these tallies include some duplication of species among studies). Of six studies of non-breeding birds, there were about 13 instances of species that were more abundant in reedbeds and three instances of species more abundant in the alternate habitat. These numbers suggest that reedbeds offer more functions to non-breeding birds (e.g. cover for roosting and escape from predators), but the fact that >75 species of North American birds have been reported to be breeding in Phragmites-dominated habitat (some examples in Table ​Table2)2) indicates the need for a broader range of studies. Meyer’s (2003) study of birds in Phragmites, Typha, and marsh meadow at a Lake Erie site in Ontario indicated the complexity of Phragmites–bird relationships, which varied by habitat, stand edge compared with interior, season, and bird species. At a large and longstanding rookery on Pea Patch Island in Delaware Bay (Parsons 2003), two species of long-legged wading birds nested only in upland shrubs and trees, four species nested in that woody vegetation as well as in Phragmites marsh, and one species nested only in reedbeds. Of the four species that nested in both habitats, one had greater egg and nestling productivity in the reedbeds and one had greater productivity in the woody vegetation. Although alternate habitats may be better for more species, there are many cases where reedbeds are better for a particular species.

No bird that breeds in the U.S. or Canada is known to depend wholly on Phragmites, although certain birds breed only in Phragmites marshes in particular regions (e.g. Fulica americana and Oxyura jamaicensis in New Jersey (Kane 2001a, b). (Ibid.)

Phragmites stands in the Piermont Marsh no doubt provide examples of the richness of biodiversity that is evident through these studies. Removing the Phragmites will adversely impact the wildlife – everything from arthropods and marine organisms to the large predator birds and ungulates that calls it their home.

Kiviat further photo-documented a variety of flora-biota within the Phragmites reedbeds in our area:

[INSERT PHOTO HERE]

“Variation in the reedbed habitat. Upper left: interspersion of Typha and Old World Phragmites in a brackish tidal marsh, Hudson River. Upper right: Old World Phragmites stand with the vines Mikania scandens (climbing hempweed) and Ampelopsis brevipedunculata(porcelainberry), New Jersey Meadowlands. Lower right: dense Old World Phragmites with small pool, New Jersey Meadowlands. Lower left: native Phragmites stand with an admixture of other plants, a marsh on Lake Ontario, New York. Photographs by Erik Kiviat.” (Ibid.)

Kiviat explains how so many species are driven to Phragmites for their survival:

REEDBED CHARACTERISTICS AND HABITAT FUNCTIONS
What makes a reedbed attractive to other organisms? The tall, dense masses of leafy culms where Phragmites is more highly dominant provide shelter from weather and predators to arthropods, small birds, and other small organisms, but may be too dense or shady for small plants or larger animals. However, large birds such as Circus cyaneus (northern harrier), Ardeidae (herons) and Threskiornithidae (ibises) can roost or nest on top of reedbeds with some degree of culm lodging. Large animals, such as O. virginianus(white-tailed deer), are sometimes able to break trails through dense reedbeds. Other Phragmitescharacteristics that shape its habitat functions include mats of lodged culms that animals rest on or under, hollow internodes of broken dead culms that shelter spiders, and the soil-stabilizing ability that apparently attracts Castor canadensis and O. zibethicus to build lodges. Some organisms are associated with high-biomass reedbeds whereas others are associated with low-biomass (sparse, short or fragmented) reedbeds.

The more we learn about how reedbed characteristics are beneficial or detrimental to particular species, the better we can manage Phragmites for particular biodiversity goals. (Ibid.)

NESTING BOXES
Now that we understand the diversity of species that make use of Phragmites as a function of their survival, for the prey insects the stands harbor, as nesting sites, as shelter or security from predators, we should appreciate ecosystem and wildlife adaptations made to accommodate and use the species.

Where is the logic in providing nesting boxes to lure birds to a site that will be rife with toxic poisons? Wildlife don’t recognize boundaries as off limits. They will continue to use the Phragmites as they have in the past, and pay with their lives. The use of Glyphosate in this rich conglomerate of life is unacceptable.

For many bird species, the availability of nesting sites is a limiting factor. Where natural nesting sites are in short supply, artificial nest boxes and platforms can provide birds with an alternative. While they cannot fully replace natural nesting sites, artificial nesting structures can enhance wildlife habitat and increase bird densities and diversity. To that end, an osprey nesting platform and nest boxes for purple martins (Progne subis) and tree swallows (Tachycineta bicolor) will be erected at various locations within the Reserve. Nest boxes will be mapped and monitored to ensure their use by target species. Monitoring is a critical part of a nest box program to avoid promoting the proliferation of non-native species and ensure that boxes are maintained in good condition. (DEC)

In an area being doused with Glyphosate – which will impact the prey insects, fish, amphibians, and small mammals of raptors and songbirds – why erect nest boxes? We know that most species make use of the various ecosystems for specific functions, for ex., finches may pick off insects and gather nesting material from the Phragmites stands, then nesting in adjacent trees. Luring these birds to the area with boxes near the poisoned Phragmites is simply leading them to their deaths.

Where Phragmites is mixed with native vegetation, herbicide will be applied by a certified pesticide applicator, or someone working under their direct supervision, using a low-volume spot treatment method (e.g., backpack spraying, stem injection, etc.). In areas where Phragmites is dominant, herbicide will be applied by a certified pesticide applicator, or someone working under their direct supervision, using a sprayer on a small amphibious vehicle that is capable of driving across the marsh surface. The treatment area will be mowed during the winter following herbicide application to mulch the dead plant material and accelerate the establishment and growth of native plant species. In the years following the initial treatment, low-level maintenance spraying will likely be necessary to address any remaining Phragmites or incipient invasions. (Ibid.)

If herbicide is applied selectively in mixed native and non-native communities, it is certain that native plants will be destroyed as well. In fact, it is unlikely that the entire 40 acres of marsh ecosystem and beyond will not be severely impacted, as the non-proven-safe Glyphosate formula can not be analyzed given the data by the DEC.

In addition to providing habitat for rare plants and animals, Piermont Marsh performs many critical ecosystem services, including production and transport of nutrients and organic matter, removal of nutrients and contaminants, reduction of wave energy during storms, storage of flood water, and trapping of sediment.

Instead of killing Phragmites, the DEC could just as effectively facilitate the use of these Phragmites as waste treatment, for example, providing an annual crop to specific Hudson River towns to treat sewage sludge, or to the industry that can manufacture building products or ornamental materials. Instead of maiming the habitat of the marsh with unnatural chemicals of dubious safety, why not plant the vine Cuscuta (dodder), which parasitizes Phragmites?

The NYS DEC has a long history of undertaking projects that don’t meet the approval or wishes of taxpayers. Why ignore the Piermont community, those most impacted, removing from them the democratic processes that allow them to determine the fate of their community and its resources?

More discussion, and a full Environmental Impact Statement process under SEQRA must be undertaken to answer these questions, to provide the public with the warranted information needed to better address this plan, and to alleviate very real concerns that reckless and hyper-vigilant actions to destroy Phragmites stands will destroy the Marsh itself. To do less would be irresponsible and a denial of the “Precautionary Principle”.

In fact, the project portends to be an exercise in futility with a perpetual annual application of “likely carcinogen” to the marsh to beat down a plant that will not be the loser; a procedure that will add to the detriment of the marsh, generate the ire of residents and call into question the reasoning and ability of the NYS DEC to act competently during any “management” procedure. When a cancer cluster is created in Piermont, the DEC will be the first to take the blame. This is all unnecessary. Let’s face it: Phragmites are here to stay. The wildlife of the marsh have accepted it, and are happily using the plant for survival. Leaving well enough alone, and forbidding any application of Glyphosate is the best way to proceed.

Sincerely,
Taffy Williams, President