Whereas, the Department of Natural Resources, pursuant to section 23.24, Wisconsin Statutes and Chapter NR 107, Wisconsin Administrative Code, is authorized to issue permits to riparian landowners for the management of nuisance-causing aquatic plants; and
Whereas, subsection NR 107.01, WAC, provides that “(c)hemical management shall be allowed in a manner consistent with sound ecosystem management and shall minimize the loss of ecological values in the waterbody”; and
Whereas, 2,4-D (2,4-dichloro-phenoxyacetic acid) is a systemic herbicide used in Wisconsin as a
terrestrial and aquatic weed-killer, primarily affecting broadleaf plants (1); and
Whereas, DNR has historically issued aquatic plant management permits authorizing 2,4-D for treatment of Eurasian watermilfoil (Myriophyllum spicatum), an invasive aquatic plant (1); and
Whereas, a University of Wisconsin-Madison laboratory research study concluded that the exposure of fathead minnow larvae to 2,4-D amine herbicide formulations at concentrations below USEPA -permitted application levels significantly decreased larval survival (2); and
Whereas, the study further provided that the application of 2,4-D at USEPA authorized concentrations in aquatic ecosystems likely would decrease fathead minnow larval survival and recruitment and similarly impact other native species (2); and
Whereas, a subsequent research project conducted by the DNR Office of Applied Science about the use of 2,4-D for chemical treatment of Eurasian watermilfoil in Lake Ellwood, Florence County provided evidence suggesting long-term 2,4-D treatments may negatively influence fish species such as northern pike, largemouth bass, bluegill and black crappies through both lethal and sublethal mechanisms (3); and
Whereas, there are alternative chemical and manual methods to manage nuisance aquatic plants including Eurasian watermilfoil.
Now Therefore Be It Resolved That, the Wisconsin Wildlife Federation at its Annual Meeting in Wisconsin Rapids on April 19th and 20th, 2024 requests the Department of Natural Resources cease issuing Chapter NR 107 permits authorizing the use of 2,4-D for aquatic plant management.
Submitted by the WWF Inland Fisheries Committee, Kendall Kamke, Chair
1. WDNR 2,4-D Chemical Fact Sheet—December, 2022 https://dnr.wisconsin.gov).
2. Dehnert GK, Freitas MB, DeQuattro ZA, Barry T, Karasov, WH. 2018. Effects of Low, Subchronic Exposure of 2,4-D Dichlorophenoxacetic Acid (2,4-D) and Commercial 2,4-D Formulations on Early Life Stages of Fathead Minnows (Pimephales promelas) Environmental Toxicology and Chemistry, Volume 37, Number 10—pps. 2550-2559.
3. Schleppenbach, B.T.; Matzke, G; Shaw, S.L.; Sass, G.G. Fish and Zooplankton Community Responses to the Cessation of Long-Term Invasive Eurasian Watermilfoil (Myriophyllum spicatum) Chemical Treatments in a North-Temperate, USA Lake. Fishes 2022 , 7, 165