Loading...
HomeMy WebLinkAboutSWP272000(20) STATg o� 0 4' 9 W � m �y'L 7889��1 STATE OF WASHINGTON DEPARTMENT OF HEALTH OFFICE OF ENVIRONMENTAL HEALTH AND SAFETY 243 Israel Road SE, Town Center 3 *P.O. Box 47825 Olympia, WA 98504-7825 TDD Relay Service (800) 833-6388 April 12, 2007 Mr. Allen Quynn City of Renton 1055 South Grady Way Renton, Washington 98057 Dear Mr. Quynn: RE: Coverage Under the Department of Health's Aquatic Mosquito Control National Pollutant Discharge Elimination System (NPDES) General Permit No. WAG-992000 The Washington tate Department of Health(DOH) received your application for authorization to proceed under the Aquatic Mosquito Control NPDES General Permit on April 6, 2007. The Department of Ecology issued coverage to the Department of Health under this permit effective April 12, 2007. This letter constitutes DOH's acceptance of your application and agreement for coverage to proce d under the Department of Health's General Permit coverage and authorizes you to proceed in carrying out the mosquito control activities specified in your application. This authorization is a ective on April 12, 2007. In order for this authorization to be valid, you must comply with all terms and conditions of the NPDES permit, including the best management practices and pro isions of the application and agreement for coverage. Retain this letter with your permit. It is the official record of permit coverage for your operations. Use your individu l user name and password, created through the SecureAccess Washington system (https://sec ureaccess.wa.gov/myAccess/saw/select.do), for reporting larvicide use at the end of the mosqui o control season. Your season's larvicide use records must be reported (to your SecureAccess Washington account) and received by DOH (signed hard copy version)no later than Febru 1 of the following year. Instructions for reporting larvicide use records are available at www. oh.wa.gov/ehp/ts/Zoo/WNV/Pennit.html. Changes to your online application regarding contact information, licensed pesticide applicator, anticipated larvicide use, or commercial pest control business contracted sites should be communicated to POH (Ben Hamilton, 360.236.3364 or benjamin.hamilton@doh.wa.gov) or Ecology(Kelly McLain, 360.407.6938 or kelm461@ecy.wa.gov) as they occur. The Department of Health or Ecology will then update your online application. ,a i�A Mr. Quynn April 12, 2007 Page 2 Best Management Practices Section S9 of the Aquatic Mosquito Control Permit requires that you either implement Ecology's Best Management Practices document or have your own Integrated Pest Management Plan approved by Ecology. Your coverage is contingent upon your implementation of the best management practices you have selected to use. Documentation of your Best Management Practices program should be available upon request by the Department of Ecology or DOH. Permit Fees The Department of Health has paid for the general permit fee. There is no additional cost to your organization. Department of Health and Ecology Assistance If you have questions after reviewing your permit coverage and have questions regarding the permit or this letter, please call 360.236.3364 or benjamin.hamilton@doh.wa.gov. Ecology's Kelly McLain, 360.407.6938 or kehn461 @ecy.wa.gov, can also provide assistance. Sincerely, Ben Hamilton, Health Services Consultant Zoonotic Disease Program Enclosures cc: Kelly McLain, Department of Ecology By certified mail ��E sT�rF F TDD RELAY SERVICE y 1-800-833-6388 < Ben Hamilton Health Services Consultant Zoonotic Disease Program Department of Health 360-236-3364 243 Israel Road,Tumwater Fax:360-236-2261 Mailing Address: Toll Free:888-586-9427 PO Box 47825 benjamin.hamilton@doh.wa.gov Olympia,WA 98504-7825 www.doh.wa.gov/ehp/ts/zoo.htm Recycle old O bottles, buckets `` t.e"A and cans. A Fix leaky faucets and sprinklers. Get rid of used tires { properly. Empty water from flower Washington State pot dishes. Depanment of Health DOH Pub 333-048 4/01 �►arvae Don't Give Mosquitoes A Chancel Mosquitoes need water to breed and grow. It doesn't take much water and it doesn't take much time. So,almost anything that will hold water for one week or more can produce these pests. Many places around your home may be causing mosquito problems. Get rid of places where water collects and mosquitoes won't have a chance! M05 nde puedo averiguar ma's ' ' OCCIDENTAL ? cQue es el virus cQuien esta en riesgo. sobre el virus del Nilo Occidental? del Nilo Occidental? El riesgo de contraer el virus del Nilo Salud Humana El virus del Nilo Occidental es una Occidental es muy bajo, sin embargo, Departamento de Salud enfermedad grave. Puede afectar a perso- cualquier persona se puede infectar. Las del Estado de Washington esabe www.doh.wa.gov/wnv nas, caballos, pajaros y a otros animales. personas mayores de 50 anos tienen Centros para el Control y Prevenci6n En 1999, el virus del Nilo Occidental el riesgo mas alto de contraer la de Enfermedadesusted apareci6 por primera vez en los Estados enfermedad gravemente. www.cdc.gov/ncidod/dvbid/westnile/index.htm Unidos en la ciudad de Nueva York. Desde Uso y seguridad de los repelentes de insectos esa vez, se ha propagado rapidamente por Centros para el Control y Prevenci6n to todo el pais. En 2002, se encontr6 el virus de Enfermedades por primera vez en los pajaros y caballos www.cdc.gov/ncidod/dvbid/westnile/qa/ en Washington. insect repellent.htm que Trabajadores en lugares al exterior 00 Centros para el Control y Prevenci6n de Enfermedades www.cdc.gov/niosh/westnileupd.html te esta Aves, equinos y otros ganados Departamento de Agricultura del Estado de Washington picando? www.wa.gov/agr/FoodAnimal/AnimalHealth/ Como se propaga? et uales son los sintomas? WNVdefault.htm Estado Departamento de Agricultura de los Estados Unidos Casi siempre el virus del Nilo Occidental Muchas personas infectadas con el virus r`* www.aphis.usda.gov/lpa/issues/wnv/wnv.html se propaga a las personas por la picadura del Nilo Occidental no se enferman. Lineal de information de un mosquito infectado, y a su vez, los Aproximadamente 1 de 5 personas Numero para el area de Olympia ,w 7 mosquitos se infectan despues de infectadas tiene sintomas leves, tales como 360-236-3980 , &` alimentarse de pajaros que portan el virus. fiebre, dolor de cabeza y dolor de cuerpo y Numero de llamadas gratuitas El virus del Nilo Occidental no se propaga menos personas a6n, aproximadamente 1 de Washington " 1-866-78VIRUS i ° ` por contacto directo con personas o de 150 infectadas tienen sintomas mas Numero de llamadas atuitas CDC :: animales infectados. A medida que raves. Los sintomas raves ueden incluir gr ( ) ,. q g g P 1-866-874-2646 sepamos mas sobre el virus del Nilo dolor de cabeza, fiebre alta, rigidez del / Occidental podremos descubrir otras vias cuello, estupor, desorientaci6n, temblores, flealth ton State Department ofde infecci6n. Para mayor informaci6n, convulsiones, debilidad muscular, paralisis } visite los sitios de salud de la red Internet y coma. Si usted tiene alguno de estos DOH Pub 333-052 5/2003 Spanish Parcialmente financlado por Los Centros para el Control que se indican al reverso. sintomas, p6ngase en contacto con su y Prevenci6n de Enfermedades del Departamento de Salud y Servicios Humans de los Estados Unidos. proveedor de salud. Para personas con discapacitadas,este documento se encuentra disponible en otros formatos,a solicitud. Por favor]lame al tel6fono 1-800-525-0127. • • R ZQue estan haciendo at Como puedo proteger a mi familia? ZQue debo hacer si encuentro respecto las instituciones de un pajaro muerto? salud ublica en el estado de No existe una vacuna humana para el virus del Nilo Occidental. El mejor modo de protegerse p Washington? es evitar los mosquitos. Tome las siguientes acciones para evitar las picaduras de mosquitos y El virus del Nilo Occidental infecta a reducir los lugares donde los mosquitos podriari crecer y reproducirse alrededor de su casa. ciertos pajaros salvajes. Los cuervos, Los departamentos de salud estatales y arrendajos, cornejas y urracas tienden a locales: enfermarse y morir con la infecci6n. Una • Controlan el virus del Nilo Occidental mayor cantidad de pajaros muertos podria Evite las picaduras de mosquitos No les de un hogar a los mosquitos ser un indicio de que el virus del Nilo atrapando e identificando mosquitos. f- Asegurese de que las ventanas y puertas r Vacie todo to que tenga agua estancada: Occidental esta en su comunidad. Usted • Rastrean la cantidad de informer de a pajaros muertos. tengan mallas milimetricas a prueba de llantas viejas,balder, cubiertas plasticas, puede yudar informando sobre corneasy insectos." Repare o cambie las mallas macetas y juguetes. otros pajaros muertos al programa de salud • Recolectan especies especificas de pajaros danadas. ambiental del departamento de salud local. muertos para pruebas r- Cambie el agua de las pilas para pajaros, Vea el directorio telef6nico en la secci6n de de laboratorio. t- Si es posible,permanezca en el interior fuentes, piscinas para ninos y bebederos Salud y Gobierno del Condado. Algunos • Notifican a los proveedores de salud para durante el anochecer y el crepusculo, que de animales, por to menos dos veces por pajaros muertos seran examinados para que busquen e informen sobre sintomas es cuando los mosquitos estan mas semana. controlar el virus del Nilo Occidental. en pacientes. activos. f- Recicle los envases no utilizados que Aunque no hay evidencia actual de que • Notifican a los veterinarios para que In Use camisas de mangas largas, pantalones podrian contener agua: tales como usted pueda contraer el virus del Nilo busquen e informen sobre caballos y largos y sombrero cuando vaya por botellas, latas y baldes. Occidental al manejar pajaros muertos, otros animales que tengan senales del lugares infestados de mosquitos,por evite el contacto con las manos virus del Nilo Occidental. e em to los bos ues o tierras humedas. r- Asegurese de que las canaletas de los l p q techos drenen adecuadamente y limpie desprotegidas. Use guantes o bolsas • Distribuyen informaci6n sobre el virus y plasticas dobles para poner al animal sobre c6mo controlar a los mosquitos. I- Use repelente contra mosquitos cuando las canaletas atascadas en la primavera y q muerto en la basura. sea necesario. Lea la etiqueta y siga las el otono. Estos esfuerzos estan destinados a instrucciones cuidadosamente.Tenga identificar el virus del Nilo Occidental cuidado especial al usar repelente en los r Repare ar que g exteriores y aspersores Kual es un repelente eficaz antes de que haya un brote. Los ninos. para reg que goteen. contra los mosquitos? funcionarios de salud publica alertaran Los repelentes que contienen DEET son los a las comunidades sobre las medidas que mas eficaces. Los productos con DEET tomaran para controlar al virus del Nilo GPuede afectar a mis mascotas el virus del Nilo Occidental? vienen en lociones, cremas, gels, aerosoles Occidental. y toallitas humedas. Vea la etiqueta para El virus del Nilo Occidental puede causar enfermedades graves en los caballos y los burros. ver el nombre quimico de DEET- Para la mayoria de los caballos no se enferman, aproximadamente 1 de 3 caballos que se Para ver las ultimas noticias sobre N, N-dietil-m-toluamida. enferme morira. Para proteger a sus caballos, pregunte a su veterinario sobre la vacuna para el virus del Nilo Occidental caballos contra el virus del Nilo Occidental. Siga los mismos pasos para reducir los lugares Los productos que contienen DEET se en Washington, visite donde los mosquitos puedan vivir y reproducirse cerca de los pastizales de caballos y graneros. deben utilizar en forma apropiada. Lea y www.doh.wa.gov/wnv Es raro que el virus del Nilo Occidental cause enfermedad en los perros, los gatos y otros siga las instrucciones de la etiqueta.Nunca. animales. use repelentes en exceso. YAWSM ' ' Do you now was b *it*ing You . Mosquitoes can carry viruses that cause serious illness. West Nile virus is one such virus. The risk of getting West Nile virus is low. People who are infected may have effects ranging from flu-like symptoms to paralysis. In extreme cases it can be fatal. Protect yourself. Take steps to avoid mosquitoes and to reduce the places where mosquitoes live and breed around your home. 4 +ft Avoid the Bite F Make sure windows and doors are "bug tight." Repair or replace screens. F Stay indoors at dawn and dusk, if possible, when mosquitoes are most active. F Wear a long sleeve shirt, long pants, and a hat when going into mosquito- infested areas, such as wetlands or woods. f Use mosquito repellent when neces- sary. Read the label and carefully follow the instructions. Take special care when using repellent on children. Don't Give Them a Home F Empty anything that holds standing water—old tires, buckets, plastic covers, flowerpots, and toys. r Change the water in your birdbaths, fountains, wading pools, and animal troughs at least twice a week. r Recycle unused containers that can collect water—bottles, cans, and buckets. F Make sure roof gutters drain properly; and clean clogged gutters in the spring and fall. F Fix leaky outdoor faucets and sprinklers. Washington State Department of Health DOH Pub 333-053 3/2003 For persons with disabilities,this document is available on request in other formats.Please call 1-800-525-0127. 1 1 1 Where can I find more What is West Nile virus? Who is at risk? on West Nile virus? West Nile virus is a serious illness that The risk of getting West Nile virus is Human Health can affect people, horses, birds, and very low, but anyone can become Washington State Department of Health other animals. In 1999, West Nile infected. People over 50 years of age www.doh.wa.gov/wnv Do u virus first appeared in the United have the highest risk of serious illness. Centers for Disease Control and Prevention YO www.cdc.gov/ncidod/dvbid/westnile/ States in New York City. Since that index.htm know time, it has spread rapidly throughout Insect Repellent Use and Safety the country. In 2002, the virus was Centers for Disease Control and Prevention found for the first time in birds and www.cdc.gov/ncidod/dvbid/westnile/qa/ what's horses in Washington. insect_repellent.htm Outdoor Workers Centers for Disease Control and Prevention www.cdc.gov/niosh/westnileupd.html Equines, Other Livestock, Poultry b *i t 61 n g Washington State Department of Agriculture agr.wa.gov/FoodAnimal/AnimalHealth/ OU0 Diseases/WestNileVirus/default.htm How is it spread? What are the symptoms? US Department of Agriculture www.aphis.usda.gov/lpa/issues/wnv/ ;; West Nile virus is almost always Most people who are infected with wnv.html spread to people by the bite of an West Nile virus will not get sick. Information Lines infected mosquito. Mosquitoes About 1 in 5 people infected will have Olympia Area become infected after feeding on birds mild symptoms such as fever, head- 360-236-3980 that carry the virus. West Nile virus is ache, and body aches. Even fewer, Washington State Toll-free 1-866 78VIRUS , not spread by direct contact with about 1 in 150 people infected, will CDC Toll-free("I'TI') infected people or animals. As we have more severe symptoms. Severe 1-866-874-2646 learn more about West Nile virus, we symptoms may include headache, may discover other routes of infec- high fever, neck stiffness, stupor, Washington State Department ot tion. For more information, visit the disorientation, tremors, convulsions,4 A Health health-related sites listed on the back muscle weakness, paralysis, and coma. DOH Pub 333-052 5/2004 Partially funded by of this brochure. If you have any of these symptoms, US Department of Health and Human Services Centers for Disease Control and Prevention contact your health care provider. For persons with disabilities,this document is available on request in other formats.Please call 1-800-525-0127. • • How can I protect my family? What are public health There is no human vaccine for West Nile virus.The best way to protect yourself is to avoid What should I do if I find agencies doing in mosquitoes.Take these steps to avoid mosquito bites and reduce the places where mosquitoes a dead bird? Washington state? live and breed around your home. West Nile virus infects certain wild birds. State and local health departments: Crows, jays, ravens, and magpies tend to • Monitor for West Nile virus by trap- Avoid Mosquito Bites Don't Give Mosquitoes a Home become sick and die from infection. ping and identifying mosquitoes. Increasing numbers of dead birds may be f Make sure windows and doors are f Empty anything that holds standing an indication of West Nile virus in your • Track the number of dead bird reports. community. You can help b reporting bug tight. Repair or replace screens. water—old tires, buckets, plastic tY p Y P g • Collect specific species of dead birds for laboratory testing. RR' covers, flowerpots, and toys. dead crows and other birds to your local Y g• Stay indoors at dawn and dusk, if health department, environmental • Notify health care providers to look for possible,when mosquitoes are most r Change the water in your birdbaths, health program. Look in the phone book and report symptoms in patients. active. fountains, wading pools, and animal under County Government—Health. • Notify veterinarians to look for and troughs at least twice a week. Certain dead birds will be tested to report horses and other animals with r Wear a long sleeve shirt, long pants, monitor for West Nile virus. signs of West Nile virus. and a hat when going into mosquito- r Recycle unused containers that can While there is no current evidence that • Distribute information on the virus infested areas, such as wetlands or collect water—bottles, cans, and you can get West Nile virus from han- and how to control mosquitoes. woods. buckets. dling dead birds, avoid bare-handed These efforts are designed to identify 9 Use mosquito repellent when neces- 9 Make sure roof gutters drain properly; contact. Use gloves or double plastic bags West Nile virus before an outbreak. sary. Read the label and carefully and clean clogged gutters in the spring to place the carcass in a garbage can. Public health officials will alert commu- follow the instructions.Take special and fall. nities about measures that they can take care when using repellent on children. What is an effective to control West Nile virus. F, Fix leaky outdoor faucets and mosquito UI repellent? sprinklers. Repellents that contain DEET are the most effective. DEET products come in Can West Nile virus affect my pets? lotions, creams, gels, sprays, and towelettes. Check the label for the For the latest on West Nile West Nile virus can cause serious illness in horses and donkeys.Though most horses do not chemical name for DEET: virus in Washington, visit get sick, about 1 in 3 horses that do get sick will die. To protect your horses ask your veterinar- N,N-diethyl-m-toluamide. WWW.doh.WQ.gov1wnv ian about the West Nile virus vaccine for horses. Follow the same steps as above to reduce Products containing DEET must be used places where mosquitoes live and breed near horse pastures and barns. It is rare that West Nile properly. Read and follow instructions virus will cause illness in dogs, cats, and other animals. on the label. Do not over use repellents. 1 1 ` ow to Use It Safe ty �s 7 Mosquito repAlen s hel t against '.mosquito bites at ma carry diseas such west Nile virus. ply repellent when you are outdoors an at risk for mosquito bites. Not all repellents are the same.The most effective ones contain DEET (N, N-diethyl-m-toluamide). Other repel- lents without DEET also protect against mosquito bites, but do not last as long. Choosing Repellents Choose a repellent that offers the best protection for the amount of time you will be outdoors. If you will be outdoors for several hours, use a product that has a higher concentration of the active ingredient. Read the product labels and compare.They often list the amount of time the product will last. Select a repellent that meets your needs. JMn- :tom l MI MT WA, Read the entire label care fully before using, and follow the directions. r When using repellents with DEET, avoid those with more than 15% DEET for children, and more than 30% DEET for adults. r Use just enough repellent to cover exposed skin or clothing. Don't apply repellent to skin that is under clothing. Heavy application is not needed. r Avoid putting repellents on cuts, wounds, or irritated skin. r Don't apply to eyes and mouth. When using sprays, don't spray directly on your face. Spray on your hands and then rub them carefully over your face. Don't allow young children to apply repellents to themselves. Have an adult ' do it for them. Keep repellents out of the reach of children. When putting repellent on a child, apply it to your own hands, then rub your hands on the child. Avoid the child's eyes and mouth. r Don't put repellent on a child's hands. Children tend to put their hands in their mouths and near their eyes. 1'- When you come back indoors, wash treated skin with soap and water. Wash treated clothing before wearing it again. If you think a repellent is causing a bad reaction,stop using it,wash the treated skin, and call your health care provider or Washington Poison Center at 1-800-222-1222. ' Washington State Department of Health DOH Pub 333-054 5/2003 For persons with disabilities,this document is available on request in other formats.Please call 1-800-525-0127. � 1 1 • • 1 sae usted *0 que te es a PLicando?e Los mosquitos pueden portar virus que causan enfermedades graves y el virus del Nilo Occidental es uno de ellos. El riesgo de adquirir el virus del Nilo Occidental es bajo. Las personas infectadas podrian tener efectos que oscilan entre los sintomas parecidos a la gripe hasta la paralisis. En casos extremos, podria ser fatal. Protejase. Tome acciones para protegerse de los mosquitos y reduzca los lugares alrededor de su casa donde los mosquitos pueden crecer y reproducirse. r } ht f 4 w r 77,,, Evite [as picaduras de mosquitos r Asegurese de que las ventanas y puertas tengan mallas milimetricas"a prueba de insectos."Repare o cambie las mallas danadas. Si es posible,permanezca en el interior durante el anochecer y el crepusculo,que es cuando los mosquitos estan mas activos. Use camisas de mangas largas,pantalones largos y sombrero cuando vaya por lugares infestados de mosquitos,por ejemplo los bosques o tierras humedas. r7 Use repelente contra mosquitos cuando sea necesario.Lea la etiqueta y siga las instrucciones cuidadosamente.Tenga cuidado especial al usar repelente en los ninos. No les de un hogar a los mosquitos r Vacie todo to que tenga agua estancada: llantas viejas,baldes,cubiertas plasticas, macetas y juguetes. r Cambie el agua de las pilas para pajaros, fuentes,piscinas para ninos y bebederos de animales,por to menos dos veces por semana. r77 Recicle los envases no utilizados que podrian contener agua:tales como botellas,latas y baldes. r°' Asegurese de que las canaletas de los techos drenen adecuadamente y limpie las canaletas atascadas en la primavera y el otono. r Repare los grifos exteriores y aspersores para regar que goteen. 0Washington State Department of PHealth DOH Pub 333-053 5/2003 Spanish Para personas con discapacitadas,este documento se encuentra disponible en otros formatos,a solicitud. Por favor!lame al teldono 1-500-525-0127. 1 1 1 FOR OFFICE USE ONLY Requestor's Number Date Received i,jowealth SW,Depnrtmml of Department of Health FORMS AND PUBLICATIONS REQUEST NOTE: This is your Shipping Label - Use complete street address (UPS will not deliver to a P.O. Box). Name/Requestor Telephone Date Name of Organization Internet E-mail Address Shipping Address 7 City State Zip Does Your Organization have a WIC Program? ❑ Yes ❑ No Forms or Publication Quantity Quantity Back No. Number Title Requested Shipped Order 1 333-047 Mosquito Problems Start at Home - Flyer (Eng) 2 333-048 Mosquito Problems Start at Home - Bookmark (Eng) 3 333-049 Mosquito Problems Start at Home - Poster (Eng) 4 333-052 Do You Know What's Biting You? - Brochure (Eng/Sp) s 333-053 Do You Know What's Biting you? - Stuffers (Eng/Sp) 6 333-054 Mosquito Repellant- Stuffer (Eng) 7 334-073 Fight the Bite - Inserts (Chinese) 8 334-073 Fight the Bite - Inserts (Russian) 9 334-073 Fight the Bite - Inserts (Khmer) 10 334-073 Fight the Bite - Inserts (Korean) 11 334-073 Fight the Bite - Inserts (Vietnamese) INSTRUCTIONS: Please put the publications and forms you are requesting in numerical order by the DOH number. ,Include both the form and pub number and the title. Order all items in each amounts. Your order will be filled to the nearest packaged amount. Requestor's name and telephone number must be filled in (in case we have questions about your order.) For orders that DO NOT involve a payment: Send this fully completed form to Department of Health, PO Box 47845, Olympia, WA 98504-7845. Faxed orders are accepted at (360) 664-2929. Telephone orders are not accepted. Do not re-order items that are back ordered. They will be sent to you as soon as new stock is available. For orders that include payment: Send this fully completed form and check to DOH Revenue Section, PO Box 1099, Olympia, WA 98507-1099. If you have any questions, please contact the DOH Warehouse at (360) 586-9046. DOH 740-018(Rev 4/2001) 0xsq1tito ro e ome Clean garden ponds and stock with fish. Recycle old bottles, Clean leaf buckets, and cans. clogged gutters. _ Adult Repair leaky faucets Get rid of used and sprinklers. tires properly. Eggs Pupae S 1 Larvae Keep water fresh. Drain Empty water from standing water from around flower pot dishes. stock troughs. Change water in Cover barrels birdbaths weekly. and buckets. DO I ,ivy Mosquitoes Oancel Mosquitoes need water to breed and grow. It doesn't take much water and it doesn't take much time. So, almost anything that will hold water for one week or more can produce these pests. Many places around your home may be causing mosquito problems. Get rid of places where water collects and mosquitoes won't have a chance! 4� IO)t['Pq) V S00111absoli O'ki t[Oa • • 140 Washington State Department of Prepared through funding provided by U.S.Department of Health&Human Services, �l�Hea l th Centers for Disease Control and Prevention Courtesy of North Carolina Department of Environmental and Natural Resources DOH Pub 333-047 4/01 For persons with disabilities,this document is available on request in other format: Please call 1-800-525-0127(TDD relay 1-800-833-6388) Best Management Practices for Mosquito Control Washington State Department of Ecology Water Quality Program W A S H I N 6 T 0 N STATE 0 E P A H T M E N T O F E C O L O G Y May 2004 Publication 03-10-023 revised ��a Printed on Recycled Paper Best Management Practices for Mosquito Control Washington State Department of Ecology Water Quality Program • May 2004 Publication 03-10-023 revised • For additional copies of this document contact: • Department of Ecology Publications Distribution Center P.O. Box 47600 Olympia, WA 98504-7600 Telephone: (360) 407-7472 Headquarters (Lacey) 360-407-6000 If you are speech or hearing impaired, call 711 or 1-800-833-6388 for TTY . 1 Regional Whatcom Pend San Jua Onicarl�. _ refill location Skagit Okanogan Islan _hIorlhwe Central Ferry Stevens 425-649-701� 5 7 d Clallam Snohomish Chelan • Jefferson g ,Bellevue Douglas Lincoln Spokane Grays -� King Eastern Harbor Kittitas Grant -339- 400 Plerce Adams Whitman rhurstott...,..__..s w._ st aciauth Yakkna Franklin Meld ` 60-407�` t0 shkiakum Yakima lumbi Benton Walla Cowlitz z kamania Walla Clark Kliddlat If you need this publication in an alternate format,please contact us at 360-407-6404. Call TTY(for the speech and hearing impaired) at 711 or 1-800-833-6388. • • Table of Contents Tableof Contents.................................................................................................................i Tables...................................................................................................................................ii Introduction ...........................................................................................................................1 Best Management Practices for Mosquito Control..............................................................3 I. Minimize Mosquito Breeding Sites and Utilize Personal Protective Measures.......... 3 H. Monitor Mosquito Populations and Disease.............................................................. 6 Ill. Establish Targeted Densities for Mosquito Populations .......................................... 11 1V. Mosquito Control Treatments................................................................................ 12 Appendix A: State Listed Species Restricted Areas.........................................................A-1 Appendix B: Insect Repellant Use and Safety..................................................................B-1 Appendix C: Response to Publlic Comments...................................................................C-1 • • Best Management Practices for Mosquito Control i Washington State Department of Ecology Tables Table 1. Disease Vector Mosquito Species Associated With Drainage Control Facilities ....9 Table 2. Potential Disease-Carrying Mosquitoes in Washington State ..............................10 Table 3. Permitted Insecticides Used For Mosquito Control...............................................16 Table 4. Insecticides Used for Adult Mosquito Control.......................................................19 • Page ii Best Management Practices for Mosquito Control Washington State Department of Ecology Introduction On April 10,2002,the Washington State Department of Ecology (Ecology) issued NPDES General Permit No.WAG-992000,covering mosquito control activities that discharge insecticides directly into surface waters of the state. Under the permit,the use of insecticides for mosquito control in water is allowed when the effects are temporary and confined to a specific location,though locations where insecticides are used may be widespread throughout the state. Applications of insecticides are subject to compliance with the Federal Insecticide, Fungicide,and Rodenticide Act (FIFRA) labels, the Washin<<ton Pesticide Control Act(1558 RCW),the Washington.Pesticide Application Act(17.21 RCW),the General Pesticide Rules(WAC 16-228� the Worker Protection Standard EVAC 16-233),a number of pesticide,and./or count--specific regulations, monitoring/reporting requirements,and approved best management practices (BMPs)that include integrated pest management options. When adopted by a mosquito control entity, these BMPs for Mosquito Control satisfy that NPDES Permit No. 992000,Condition S4 requirement. These Best Management Practices for Mosquito Control were developed through a collaborative effort of representatives from Washington and Oregon based mosquito control districts, Washington State counties,Washington State University,mosquito control insecticide industry and the state departments of Health,Agriculture,Fish and Wildlife,Transportation and Ecology. Our appreciation goes out to the many mosquito control experts and others who took the time to review the draft and offer their expertise and suggestions. • Mosquito control entities in Washington State that wish to develop their own BMPS may do so,but they must be approved by Ecology. An approvable integrated pest management(IPM)program for mosquitoes must involve natural resource scientists when planning control measures that could harm delicate ecosystems and include all the features of IPM as defined in Washington State law RCW 17.15.010(as adapted to mosquito management): 1) Minimize mosquito breeding and feeding sites. 2) Monitor mosquito populations and disease. 3) Establish the targeted densities of mosquito populations based on community factors of health,public safety,economic and aesthetic thresholds. 4) Treat mosquitoes to reduce populations below the targeted threshold using strategies that may include biological,cultural,mechanical,microbial,biochemical and chemical control methods and that consider human health,ecological impact,feasibility,and cost effectiveness. 5) Evaluate the effects and efficacy of pest treatments. • Best Management Practices for Mosquito Control Page 1 Washington State Department of Ecology • • Page 2 Best Management Practices for Mosquito Control Washington State Department of Ecology Best Management Practices for Mosquito Control I. Minimize Mosquito Breeding Sites and Utilize Personal Protective Measures Risk Assessment: Probability of outbreak in humans: Remote Action threshold: The presence or even the suspected presence of mosquitoes (any species)in an area identified for control efforts triggers minimization efforts in the early spring and summer. The mean development time from egg hatch to pupation takes 5 to 10 days at temperatures near 250 C (77'F)(Pratt and Moore,1993). However, "eggs of certain species can hatch in water as cold as 45' F" (L.ilja,2002,p. 24). Minimization actions are most effective in the early spring and continued through fall on an as-needed basis. Rationale: Minimizing man-made breeding sites in the targeted area of control and personal protection,especially for those with compromised immune systems,are the best defenses against getting bitten by mosquitoes,giving the best protection for the least cost. Minimum BMP Response: 1. Provide information to those in the area of control on eliminating artificially created mosquito breeding sites,use of biological controls(including bio-larvicides),use of repellents,and on protecting animals of concern. Local and state environmental health departments have a variety of informational brochures. See http://N�,ww.doh.wa.gov/ehj)/is/Zoo/WNV/`WNV.html for links. 2. Take appropriate minimization actions. • 3. If possible,obtain resources to enable effective responses. Minimization Actions Eliminate Artificial Breeding Sites around Homes and Offices ➢ Empty or turn over anything that holds standing water—old tires,buckets,wheelbarrows, plastic covers,and toys. Do not let water stagnate for more than seven days. ➢ Change water in birdbaths,fountains,wading pools,and animal troughs weekly. ➢ When practical,drill holes in the bottoms of containers that are left outdoors. ➢ Clean and chlorinate swimming pools that are not in use and be aware that mosquitoes can breed in the water that collects on swimming pool covers. ➢ Consider aerating ornamental pools and use landscaping to eliminate standing water; mosquitoes can potentially breed in any stagnant puddle that lasts more than four days. ➢ Recycle unused containers—bottles,cans,and buckets that may collect water. ➢ Make sure roof gutters drain properly,and clean clogged gutters in the spring and fall. ➢ Fix leaky outdoor faucets and sprinklers. ➢ Keep all ornamental shrubs and bushes trimmed and pruned to open them up to light and air flow.This will not only give mosquitoes fewer places to hide,but will promote growth and vigor in the plants. • Best Management Practices for Mosquito Control Page 3 Washington State Department of Ecology Use Appropriate Bio-controls i ➢ Stock water gardens that have no surface inlet or outlet with mosquito-eating fish(i.e., goldfish, mud minnow,stickleback,and perch). Tadpoles,dragonfly larvae,diving beetles,back swimmers,and front swimmers also prey on mosquito larvae. For more information,see http://,v�-,N-w.wdfw.wa.gov/factshts/westi-, iev,it-us.htni. Native vegetation and nest boxes can help attract mosquito-eating birds and bats.However, property owners should avoid introducing non-native fish or wildlife in an attempt to control mosquitoes.While it is permissible to release some fish commonly available in pet stores into small,contained backyard pools and ponds,non-native fish should not be released into open or partially contained waters that may occasionally flood into natural water bodies.Some non-native species,including so-called mosquito fish, Gambusia affinis, can be major pests when introduced outside their natural range. Gambusia are aggressive and have been known to feed on eggs,larvae and juvenile native fish and amphibians. Because of these negative impacts on native species, Gambusia is a regulated species in Washington State,and may not be introduced without a fish stocking permit issued by WDFW. ➢ Under WDFW policy,transfer/stocking permits may only be issued to organized mosquito control districts,the U.S. Army Corps of Engineers,and local or state health departments; permits may not be issued to private individuals. To protect the Olympic mud minnow,a state sensitive species, Gambusia stocking is prohibited in Clallam,Jefferson,Kitsap,Grays Harbor,Mason,Thurston, and portions of Lewis County that drain into the Chehalis river. For information on fish stocking permits contact the WDFW regional office in your area. • ➢ Selective bio-pesticides such as Bacillus thuringiensis israelensis (Bti),B. sphaericus or methoprene are very effective preemptive controls when applied in the spring to specific sources identified by surveys. Amplifying and bridge vector species should be targeted (also see p.11.). Personal Protective Measures ➢ Make sure window and door screens are"bug tight." Repair or replace if needed. ➢ Stay indoors at dawn and dusk when mosquitoes are the most active. ➢ Wear a long sleeve shirt,long pants and a hat when going into mosquito-infested areas such as wetlands or woods. ➢ Use mosquito repellant when necessary,and carefully follow directions on the label. For extensive repellent information from the Centers for Disease Control see Appendix B: Insect Repellent Use and Safety ➢ Areas frequented by the public,such as parks,zoos,outdoor concert areas,and wildlife reserves should consider making repellents available. Protect Animals of Concern ➢ To protect your horses and other equines,talk to your veterinarian about the West Nile virus vaccine.The vaccine requires two doses three to six weeks apart,and immunity may • Page 4 Best Management Practices for Mosquito Control Washington State Department of Ecology • not be achieved until up to six weeks after the second dose. An annual booster should be given a few weeks to a month prior to the start of the mosquito season in your area. ➢ Veterinarians should be consulted if you have concerns about your household pets or other animals. Repellents may be used in some instances. ➢ Thoroughly clean livestock watering troughs weekly. ➢ For more information see: http://w«-ur.aphis.Lisda.,aov/lpa/issues/wnv/prv.html and/or http://wNA Nv.cdc.gov/ncidod/'dvbid/west:iile/birds&-maininals.htni New Construction and Storm Drains As new facilities are being designed,consideration should be given to reducing mosquito habitat as much as possible. When considering a drainage or water treatment facility for mosquito control, the first consideration should be whether the problem could be reduced by physical modification or repair without compromising the facility's function. Physical modifications should be designed by an engineer and reviewed by the local government to insure they meet applicable design requirements. A possible design modification may include scarifying the pond bottom where it is no longer infiltrating as originally designed, providing slope to the bottom of the drainage facility or enhancing infiltration by some other method. Eliminating low spots that collect small • amounts of standing water and altering excessive overgrown vegetation may also be options. Alterations of slopes or repairs to a facility should not involve a reduction in the water retention or carrying capacity of the facility. As an example, soil should not be added to fill low spots. Instead, low spots should be graded flat such that the carrying capacity is not reduced. Sprinklers and Irrigation Systems Over-watering and poor irrigation practices are common producers of mosquitoes around the home,in parks,in irrigated fields,and on golf courses. Report standing water to appropriate maintenance personnel. ➢ Irrigated lands are among the highest producers of mosquito breeding sites in Washington State. High numbers of mosquitoes can develop in standing water as a result of flood irrigation. The actions below can help eliminate mosquito breeding sites by using physical controls (Colorado,2002;Pratt and Moore 1993). 1) Minimize standing water in fields so that it does not lie fallow for more than four days by improving drainage channels and grading. 2) Tail waters should not be allowed to accumulate for more than four days at the end of the field. 3) Keep excessive overgrown vegetation out of ditches to promote more rapid drainage,but retain ground cover to prevent soil loss. • Best Management Practices for Mosquito Control Page 5 Washington State Department of Ecology 4) Have ditches repaired to reduce seepage to the extent practicable(elevated water • tables can produce unintended standing water in fields). Modification or repairs to a ditch should not reduce the carrying capacity. 5) Minimize flood and rill irrigation practices to the extent practicable. 6) Avoid over-watering. Foster Healthy Wetlands Do NOT drain or fill wetlands. The chance of mosquito "outbreaks"increases in wetland and stream ecosystems that have been changed or tampered with. In disturbed systems,the predators of mosquito larvae are often excluded while the mosquitoes thrive. Thus,draining wetlands and removing greenbelts will not eliminate mosquitoes. In fact, such actions could actually increase the mosquito population if their natural predators are destroyed. The draining of wetlands will still leave behind many small puddles or wet depressions that are prime habitat for mosquitoes. Wetlands perform at least three classes of functions:hydrologic functions(i.e.,flood peak reduction, shoreline stabilization,or groundwater exchange),water quality improvement(sediment accretion, filtration or nutrient uptake),and food-chain support(structural and species diversity components of habitat for plants and animals,including threatened endangered and sensitive species). Many wetlands recharge ground water critical for local drinking water supplies and prevent streams from drying up during the summer. Given the critical functions wetlands perform,Ecology does not condone draining wetlands as a method for mosquito control. Since most predation on mosquitoes occurs when they are larvae,the best mosquito control is often to target the larvae,either by • fostering predators native to the area of control(amphibian larvae,aquatic salamanders,small fish) or by applying selective larvicides such as Bti. (Tom Hruby,Ecology Wetland Specialist,personal communication 2/26/03 and 1/16/04). II. Monitor Mosquito Populations and Disease Risk Assessment: Probability of outbreak in humans: Remote to low;areas with limited or sporadic WNV epizootic activity in birds and/or mosquitoes. Action Threshold. The presence of vector or nuisance mosquitoes suspected or confirmed in the area. Rationale. Base-line data on mosquito populations and mosquito-borne disease will help target educational efforts and are essential to control efforts,should they become necessary. Minimum BMP Response. Obtain and track avian mortality,human encephalitis/meningitis,and equine surveillance in the area of control. Further quantify epizootic activity by inventorying mosquito habitats,and trapping and testing for vector mosquitoes. Consider targeted insecticide control if surveillance indicates high potential for human risk to increase. Monitoring Strategies for Landowners of Private Property and Contracted Licensed Applicators ➢ Contact your local health department for information about birds,horses,and humans found to test positive for West Nile virus or other mosquito-borne diseases in your area of control. i Page 6 Best Management Practices for Mosquito Control Washington State Department of Ecology • ➢ Accurately map and identify rearing areas for mosquitoes,by species if possible. These are those sites for mosquito rearing that cannot be eliminated by following preventative measures such as container emptying,proper pond maintenance,and eliminating excess standing water by using appropriate irrigation BMPs. This is important because appropriate treatment measures are contingent on the habitat(species)encountered. The following northwest mosquito habitats and control issues have been identified in the Mosquito-Borne Response Plan developed by the Department of Health(Lilja,2002). Vectors in specific regions have not all been identified. Contact your local health department for the latest mosquito vector information. Floodwater.: Aedes vexans and Ochlerotatus sticticus develop in large numbers along the borders of the Columbia and other rivers and create important mosquito problems in this region. The larvae hatch in the spring or early summer when the streams overflow areas such as willow and cottonwood swales where the eggs have been laid. The eggs of these species are dormant when temperatures remain below 45-500 F. Partial dormancy of the eggs may continue until sometime in June so that only some of the eggs are hatched by floods occurring in April or May. In some seasons,the larger rivers may rise,recede,and rise again to cover the same egg beds and produce an additional hatch. In other seasons,two or three successive rises may occur,each of which is higher than the last. Females that emerge in the first hatch may lay eggs that will hatch in the second or third rises of the river. Most of the eggs are laid between the 10 and 20 foot levels,and some of the eggs that are not flooded during a series of low flood crest years remain viable for as • long as four years. Large Aedes vexans and Ochlerotatus sticticus breeding areas have been managed efficiently by controlling water levels above dams such as the Bonneville Dam. Dikes have prevented flooding in other areas. Clearing of brush has been of value in some locations. However,control of the major section of these types of breeding areas must often be accomplished with insecticide applications. Irrigation Water: Breeding places for several mosquito species are provided by irrigation water. Aedes dorsalis,A. vexans, Ochlerotatus melanimon,and Ochlerotatus nigromaculis are among the most important species that may develop when water is applied and stands for a week or ten days. Other species such as Culex tarsalis, Culiseta inornata, and Anopheles freeborni may also be produced. Tremendous numbers of mosquitoes breed in many areas where uncontrolled irrigation is practiced. Applications of insecticides are effective but are not substitutes for proper grading. Elimination of standing water is effective in preventing development of mosquitoes. Application of insecticides may be necessary for breeding places that cannot be drained. See Sprinklers and Irrigation Systems in Section I above. Tidal Waters: Aedes dorsalis is the only species that can breed in large numbers in both fresh and salt water in the Northwest. The larvae develop in some coastal areas where potholes are filled by the higher tides or where water levels fluctuate in permanent or semi-permanent pools. Leveling, drainage,or similar practices are effective in preventing breeding,but such areas must be properly maintained. Insecticide control may be necessary where these methods are inadequate or ineffective. Ochlerotatus togoi has also been found in coastal areas including San Juan,Island, Best Management Practices for Mosquito Control Page 7 Washington State Department of Ecology Skagit,Kitsap,and Mason counties. Larvae of this species have been found in pools of pure seawater along rocky shorelines. Snow Water: In many high mountain meadows and also at lower levels,mosquitoes breed in pools caused by snow melt. Development may require several weeks at higher elevations. Aedes communis,A. cinereus, Ochlerotatus hexodontus, O.fitchii,and O. increpitus are the most common species found in these locations. Usually there is only one generation per year,but the large numbers that may be produced are a severe annoyance to those who are working or seeking recreation in these areas. Elimination of breeding areas by drainage or maintenance of constant water levels is practical in some situations. Insecticide applications might have to be made by hand or by plane because of inaccessibility to heavy ground equipment. Permanent Waters,Ponds and Artificial Containers: The mosquitoes that lay their eggs on the water are usually found where water is present continuously during the season or at least for several days. Such locations include natural permanent ponds,including still waters along the borders of lakes and rivers sheltered from wave action and currents with some degree of vegetation,log ponds,tree holes,semi-permanent ponds and wetlands of various types,and artificial containers. Culex tarsalis, C.pipiens, C.peus,Anopheles freeborni,A. punctipennis, Culiseta incidens, and C. inornata are commonly found in such places. C. tarsalis and C.pipiens develop in large numbers in log ponds. C.pipiens also develops in large numbers in sewer drains,catch basins, and water left in artificial containers. Coquillettidia perturbans are found in permanent water in wetlands,swamps,and marshes that have emergent or floating vegetation. Insecticides are often used effectively to control most of these species,except those breeding in artificial containers that can be emptied. Larvae of C.perturbans are difficult to control because they are attached to the • roots of plants. Insecticide granules are sometimes applied,but eliminating host plants may be the most useful procedure to control this species. Consult with your local WDFW office before removing plants on WDFW-managed lands or in ecologically sensitive areas. Stormwater: In response to the anticipated arrival of West Nile virus in King County, King County Water and Land Resources developed recommendations for dealing with the mosquito control at County drainage facilities. The study(Whitworth,2002) identified the four basic habitats preferred by mosquitoes,the types of mosquitoes associated with the habitat type, and the WNV vector mosquito species that prefers each habitat type. Table 1 summarizes this information. • Page 8 Best Management Practices for Mosquito Control Washington State Department of Ecology Table 1. Disease Vector Mos uito Species Associated With Drainage Control Facilities Habitat Type Facility type Vector Species Permanent Water Year round wet ponds Anopheles punctipennis Larger Regional Ponds Wet Bioswales Marshes&Wetlands Wet Bioswales Aedes cinereus Some Regional Facilities Coquilietidia perturbans Temporary or Flood Water Temporary Wet Ponds Aedes vexans Dry Bioswales Culiseta inomata ReterrtkxVDetention Ponds Open Ditches Artificial Containers/Tree Holes Catch Basins Ochlerotatus japonicus Underground Tanks/Vaults Culex pipiens Discarded containers&Tires Culex tarsalis Udiseta inomata Table 2 summarizes biological information of vector mosquitoes found in Washington State. • • Best Management Practices for Mosquito Control Page 9 Washington State Department of Ecology Table 2. Potential Disease-Carrying Mosquitoes in Washington State is Day or Mosquito Night Range Generations Preferred Habitat Breeding Comments Species Biter per Year Aggress Does not One-eggs A woodland species: semi- Hatches in the early ive travel far hatch at permanent bogs & swamps, spring. Larvae found Aedes during from different wetlands, wet bioswales & among dense aquatic cinereus day 1habitat times floodwaters vegetation. Any temporary water body like ditches, puddles, Eggs may lie domant 3+ Day & containers, pools & yrs, hatches in ditches, Aedes vexans Night 20+ miles Many floodwater. still water. Prefers algae-laden, cool Springs and creeks pools on edges of slow connected to stormwater flowing rivers and Anopheles Stays near ponds, bioswales and streams. Has entirely uncti ennis Night habitat. One wetlands. dark palpi. One, but Strong hatchlings do Needs thick growth of fliers, not complete aquatic vegetation. Night- enters development Permanent marshes, Remains below the water often homes until the wetlands, temporary wet surface attached to roots Coquilletidia comes and lit following ponds, dry bioswales & and stems. Hatchlings erturbans to lights jareas. spring. o en ditches. emerge inspring. Found around water with high organic content, as in Proliferate in in artificial Usually catch basins & sewer containers. Lays eggs in migrates effuent ponds, tree holes, clusters of 50 to 400. only short artificial containers & Larval and pupal stages Culex i ien s Night distances. Many manholes. take 8 -10 days. Larvae develop from spring to fall in waters w/ Enters Any fresh water, artificial high organic material. buildings containers, & agricultural Eggs laid in rafts of 100 - Culex tarsalis Night after dark. Many and irrigated areas 150 & hatch Win 48 hrs. Breeds throughout spring and summer in cold Cold water- associated with water, females may glacial runoff and sunlit appear during warm waters, does not like hot winter breaks. Usually Culiseta Dawn & Stays near weather. Found at all feeds on livestock, not inornata Dusk Ihabitat. Many elevations. people. Artificial containers, catch Ochlerotatus Day& basins, undergound tanks Larvae are found in 'a onicus Night Not known Many and vaults & tree holes artifical containers. *New information has come in on Ochlerotatus canadensis that adults live for several months in woodland pools by melting snow or rain. They feed on a large range of mammals,birds,and reptiles. • Page 10 Best Management Practices for Mosquito Control Washington State Department of Ecology • Additional Monitoring for Public and Specialty Targeted Areas of Control ➢ Conduct ongoing mosquito larvae surveillance,including studying habitats by air,aerial photographs and topographic maps, and evaluating larval populations. ➢ Monitor and track data from mosquito traps,biting counts,complaints,and reports from the public. ➢ Keep seasonal records concurrent with weather data to predict mosquito larval occurrence and adult flights. ➢ Consider using sentinel chicken flocks for surveillance (See Centers for Disease Control and Prevention,Epidemic/Epizootic West Nile Virus in the United States: Guidelines for Surveillance,Prevention and Control,page 10, h!V://wvs—w,.cdc.,gov/ncidod/dvbid/westnile/resources/«`nv-g2idelines-aug-2003.pdf) ➢ Accurately map and identify rearing areas for mosquitoes. These would be those sites that cannot be eliminated by preventative measures such as emptying containers,proper pond maintenance,and eliminating excess standing water by using appropriate irrigation BMPs. These habitats can be identified by aerial photo assessments,topographic maps,and satellite imagery where available. This is important because appropriate treatment measures are contingent on the particular species that live in specific habitats. ➢ Agricultural site maps should include hay,pasture,circle irrigation,orchards,and rill irrigated field crops. An important land use that has caused problems to mosquito control districts in the past is flood irrigated pastures where the water stays on more than five to seven days. iNote: Detailed information on mosquito surveillance is available from Washington State Department of Health,available online at vk-A-.doh.iva.gov/ehl2/ts/Zoo/W,NV/WAArboviralRespPlan.pdf and ht!p://",w-w.doh.wa.gov/ehp/ts/Zoo/"WI\F\T/WestNileVir-usSurv.pdf III.Establish Targeted Densities for Mosquito Populations Risk Assessment: Probability of outbreak in humans: Remote to low;areas with confirmation of epizootic WNV in birds before August;a horse/human case,or sustained WNV activity in birds and/or mosquitoes. Action threshold: The presence(positive identification)of any vector mosquitoes in the area triggers activities to reduce their presence. Since people with compromised immune systems are likely to be the most vulnerable to mosquito-borne diseases,the areas of their exposure should be a priority. Rationale: Once vector mosquitoes have been positively identified in an area,control treatments are warranted,especially around high risk populations. If the cost of treatments is prohibitive, every effort should be made to educate those at risk of exposure about minimizing habitat and personal protection measures. BMP Minimum Response: Analyze disease activity data,i.e.,avian mortality,human encephalitis/meningitis,equine encephalitis and mosquito surveillance information in the area of control. Set targeted densities with special consideration being given for segments of the • Best Management Practices for Mosquito Control Page 11 Washington State Department of Ecology population most vulnerable to mosquito-borne diseases such as the elderly. If needed,enhance • human surveillance and activities to further quantify epizootic activity,such as mosquito trapping and testing. Establish Targeted Mosquito Densities for All Areas of Control To establish the targeted density of mosquito populations review information on incidences of avian mortality,human encephalitis/meningitis,and equine encephalitis for your area (the Department of Health or your local health department can provide this information). Conduct entomologic survey(inventory habitats and map mosquito populations). Using surveillance information and input from the people in the control area,establish the targeted density of mosquito populations based on the level of control desired by those in the area of control,public safety,and funding. ➢ Demarcate no-spray zones on maps. This may include areas such as schools,hospitals,fish farms,wildlife refuges,ecologically sensitive areas,the homes of individuals who are on chemically sensitive registers,and crops grown under a certified organic program. Other crop sites that do not have a tolerance for the mosquito control products used should also be listed. If the control entity is not a mosquito control district organized under RCW 17.28, then individual residences where the occupants do not want to be treated should be identified as no-spray zones. ➢ Individual homeowners and businesses determine targeted mosquito population densities based on the level of control desired and factors of risk and cost. Mosquito control agents must consult with their sponsors to determine targeted mosquito densities. ➢ Once the targeted density has been established,continue larvae surveys to find density response to habitat minimization efforts and need for larvicide treatments. IV. Mosquito Control Treatments Risk Assessment: Probability of outbreak in humans:Low to moderate Action Threshold: The positive identification of vector mosquitoes in the area may trigger activities to reduce their presence. Once minimization strategies have been taken,larvae surveys (i.e. dipping)can indicate the effectiveness of those efforts and the need for further action. General Permit Condition S4.2.0 states that the targeted density of larvae is 1 per three dips to commence larviciding unless vector mosquitoes are in the area and the probable breeding sites are inaccessible. This level is a minimum;mosquito control agents may want to set the targeted density at a higher level due to cost and risk factors. Rationale: Once vector mosquitoes have been positively identified in an area,control treatments are warranted. If the cost of treatments is prohibitive,every effort should be made to educate those at risk of exposure about minimizing breeding habitat and personal protection measures. Minimum BMP Response:Treat mosquitoes to reduce populations below the targeted threshold using strategies that consider biological,cultural,mechanical,and microbial,biochemical,chemical control methods. Evaluate methods for effectiveness of control,human health and ecological impacts,feasibility,and cost effectiveness. • Page 12 Best Management Practices for Mosquito Control Washington State Department of Ecology • Use an Integrated Pest Management (IPM) Approach for All Areas of Control Ideally,an IPM program considers all available control actions,including no action,and evaluates the interaction among various control practices,cultural practices,weather,and habitat structure. An ecologically-based IPM strategy relies heavily on natural mortality factors and seeks out control tactics that are compatible with or disrupts these factors as little as possible. When biological, biochemical or chemical treatment is needed,select treatments based on the species of mosquitoes found in larva pools,the age of larva,breeding habitat,density of larval populations and temperature. Pesticide applications shall not commence unless surveillance of a potential application site indicates a larva/pupa count of greater than 1 per 3 dips and the need to apply insecticides to control mosquito populations, or unless dead birds,infected horses,or adult mosquito surveys indicate the presence of vector mosquitoes when larvae counts cannot be made due to their inaccessibility. In these cases beginning control methods such as larviciding may be desirable or even necessary without the larvae dips. However,just because a dead bird is found which tests positive for WNV in an area does not mean that the vector mosquitoes are breeding in the nearest storm drain. Those in the business of controlling mosquitoes will have to know the breeding sites and species of vectors in the area to perform effective mosquito control. Natural resources biologists (e.g.,WDFW)must be notified of planned control measures whenever delicate(easily impacted)ecosystems could be harmed by mosquito control practices. Other resource management agencies(e.g.,National Marine Fisheries Service and U.S. Fish and Wildlife Service) should be consulted to determine when and where operations may harm ecosystems critical to threatened or endangered species,as well as appropriate treatments in these situations. Biological Controls Natural Waters: WDFW has several concerns with stocking biological mosquito predators in natural waters. Along with the introduction of non-native fish,the transfer of fish diseases from one location to another,even among native populations,can cause disease outbreaks. That is why all movement and stocking of fish requires a permit from WDFW,whether the fish are native or not. Due to the inability to test live fish without killing them,the transportation of fish from one watershed to another requires disease testing(usually on the adults at spawning,or by sacrificing a number of young fish)and verification that the remaining fish are reared on disease-free water. In addition,any non-native fish stocking currently needs to go through SEPA review prior to approval. The laws in Washington State are designed specifically to prevent this type of"Johnny Apple-seeding" from occurring. For more information,please contact your nearest Regional Office of the Department of Fish and Wildlife. Ponds or Impoundments with No Inlets or Outlets: Biological methods may include stocking species such as the Three-Spined Stickleback(Gasterosterous aculeatus)which is native to Washington State and known to be an effective predator of mosquitoes. Mud minnow,perch tadpoles,dragonfly larvae, diving beetles,back swimmers and front swimmers also prey on mosquito larvae. Guppies,goldfish,and other fish commonly sold in pet stores are exempt from permitting by Washington's Department of Fish and Wildlife(WDFW)and may be suitable for • smaller ponds with no inlet or outlet,horse troughs,and ornamental pools. However,before Best Management Practices for Mosquito Control Page 13 Washington State Department of Ecology planting any of these exempt fish,consult with WDFW. Some of these fish,such as goldfish,may • have severe ecological impacts on ponds and lakes. Mosquito Fish (Gambusia affinis)have been used for mosquito control in virtually every state because of the adult's ability to consume large amounts of mosquito larvae. These warm water fish rarely exceed 2.5 inches and prefer shallow water. They tend to flourish in almost any environment,including well discharges,cisterns,water tanks,potholes,rain barrels,and open septic tanks. Gambusia have been known to dramatically reduce and even eliminate mosquito larvae. WDFW suggests that the use of Gambusia be integrated into an overall mosquito control plan rather than used as an exclusive solution to mosquito abatement. Permits must be obtained from WDFW for use of Gambusia as a mosquito control measure. Microbial,Biochemical and Conventional Chemical Controls Applications of insecticides to water must be made by individuals licensed by the Washington State Department of Agriculture and permitted by the Department of Ecology's Water Quality Program. Information on WSDA license requirements is online at:http:/1pep.wsu.edu or call WSDA toll-free at(877)3014555.Permitting information is available from Ecology's website at www.ecy.wa.gov/programs/tiwq/pesticides/index.html or call (800)917-0043. Select product controls by comparing the species and targeted life stage of mosquitoes,the breeding habitat,density of larval populations,and temperature with the efficacy of the products,nontarget impacts,resistance management,and costs. For example,while Bacillus products are effective on early instars they do not control older larva. Methoprene can be used on older larval stages(i.e., pupa),and for situations where it is too late to use either Bacillus thuringiensis israelensis or Bacillus sphaericus,a monomolecular film might be used. Some Bacillus products do not have residual characteristics when temperatures are high,and larval populations can grow at the rate of an instar a day. In this situation the larva may be in the late third to fourth instar stage before an application of Bacillus can be made. Always consult product labels for specific information on efficacy and use. Product Material Safety Data Sheets(MSDS)provide additional information such as protocols or measures to be taken for accidental releases and other pertinent product information. The following is the approved list of larvicides that may be considered for mosquito control operations.Consult with federal,state and local agencies as needed. 1. Bacillus thuringiensis israelensis(Bti) 2. Bacillus sphaericus (H-5a5b) 3. Methoprene Granular,Liquid,Pellet,or Briquet(Restricted on state listed species sites -see Appendix A). 4. Monomolecular Surface Films (Restricted on state listed species sites-see Appendix A). 5. Paraffinic white mineral oil. Paraffinic white mineral oil is restricted on state listed species sites-see Appendix A and shall not be used in waters of the state unless: a.The mosquito problem is declared a public health risk;or • Page 14 Best Management Practices for Mosquito Control Washington State Department of Ecology • b.The other control agents would be or are known to be ineffective at a specific treatment site; and c.The water body is non-fish-bearing(when uncertain,consult Washington State Fish and Wildlife concerning fish and wildlife)and has no inlet or outlet. 6. Temephos may not be used in lakes,streams,wetlands or the littoral zone of water bodies. The use of temephos shall be allowed only in highly-polluted water(i.e. tire piles) or waters with high organic content(i.e.manure holding ponds and pastures with no surface water runoff),or under either of the two following conditions: a. As a result of consultation between the Departments of Agriculture and of Ecology in response to the development of pesticide resistance or ineffectiveness within a population of mosquitoes. When temephos is applied to areas draining to surface waters monitoring of persistence and residues are a condition of the approval. Temephos must be rotated with one or more of the approved alternatives with a different mode of action to minimize the development of resistance. b. As a result of consultation between the Department of Health and Department of Ecology in response to the development of a human health emergency as determined by the Washington State Department of Health. 7. Terrestrially applied insecticides are NOT regulated under federal or state water pollution control laws and are not subject to NPDES permit conditions or requirements. A variety of adulticides are regulated for use by WSDA in Washington State. Table 4 lists some of these products. However,in Washington State all applications of insecticides over water must be permitted under a Clean Water Act(NPDES) • permit. • Best Management Practices for Mosquito Control Page 15 Washington State Department of Ecology Table 3. Permitted Insecticides Used For Mosquito Larvae Control • Typical Active Label Use Application Method(s) Human Permit Target roducts Ingredient Rate and Persistence and Health Restrictions on Pests on 2003 cost Comments Restrictions Use" Label estimates Aquabac, (Bti)Bacillus 0.25 to 2 Hand sprayer, ground Not for None. Mosquito Bactimos, thuringiensis pints/acre sprayer or sprinkler potable larvae Vectobac and israelensis or up to 10 cans. water. Teknar Ibs/acre @ Effective 1 -30 days Minimal non- $24/gal. depending on dietary and Granules formulation. dermal risk to infants and $1.65/Ib Broad spectrum,except children. Coquilletidia VectoLex Bacillus 0.5 to 1.5 Granules are mixed with Not for None. Larval WDG sphaericus Ibs/acre water and sprayed. potable control in (H-5a5b) $4.65/lb Effective for 1-4 weeks, water. water with depending on the Essentially high organic species of mosquito nontoxic to content. larvae,weather,water humans. quality and exact form of the granules. Effective on Culex spp. Less effective against other species. Methoprene: Restricted on Altosid liquid 3-4 az./acre Use hand and ground Not for mosquito Active state listed specie *** s ra ers. potable larvae. ingredient is $226/gal p y water. Does sites—see a growth Effective for a few days not Appendix A. g unless specially pie hormone risks to mimic that formulated for slow human does not release. health. allow the It is not persistent mosquito because it degrades larvae to rapidly in water. mature. The briquettes are used in areas needed for ........ longer term residual Altosid pellets Methoprene 2.5-10 control such as ponded Ibs/acre areas of standing water, rsq 4/lb areas where flood waters may make it Altosid XR Methoprene riquette impossible to use Bti. .70 100-200 ft. Rates increase with deeper water. Alfosid Methoprene 1 briquette/ briquet $.90 @100 sq ft. Attosid XR-G is a sand formulation,good for pastures or marshes Altosid XR-G Methoprene 5-20 lbslac with thick vegetation. $8,48/Ib • Page 16 Best Management Practices for Mosquito Control Washington State Department of Ecology • Typical Active Label Use Application Method(s) Human Permit Target roducts Ingredient Rate and Persistence and Health Restrictions on Pests on 2003 cost Comments Restrictions Use*" Label estimates hand or b Sprayed y Monomolecul 0.2 to 1,0 Sp Okay for Restricted on Larval,pupal � Agnique MMF ar surface pal/acre remains active for ground equipment.Film 10-14 potable state listed specie and midge film water, sites-see control. Arosurf MSF Poty(oxy-f,2- @$30/ga1, days on floodwaters, livestock, Appendix A. ethanediyt)Al backyard brackish waters and Adult female pha- ponds.Susceptible to ponds,pool mosquitoes, isooctadecyt- wind breaking surface covers. hydroxy tension. Rendered ineffective at winds No risk to above 10 mph and in human very choppy water. health. Adult females are killed by entrapping and drowning when they contact the surface to la their eggs. Golden Bear Petroleum 3 to 5 Liquid formulations are No risk to May not be Larval and Oil distillate oils gal/acre sprayed by hand or human applied to fish- pupal gonide Oil prevent the ground equipment. health. bearing waters or control. larvae from $5-8/gal Persists for 12-15 on state listed obtaining hours,then evaporates. specie sites--see oxygen through the Less expense--kills Appendix A. surface film pupae stages Abate temephos 0.5 to 1.5 Sprayed liquid.Breaks Not for Highly restricted Mosquito • oz/acre down within a few days potable use-see permit larvae, $2 00/oz in standing water, water. condition 1A.5. midge, shallow ponds, Poses low punkie gnat, swamps,marshes,and risk to human and sandfly intertidal zones. health.High larvae in Temephos Is applied dosages,like non-potable most commonly by other OPs`, water. helicopter but can be can over- applied by backpack stimulate the sprayers,fixed-wing nervous aircraft,and right-of-way system, sprayers in either liquid causing or granular form. nausea, dizziness,& confusion. Malathion malathion 8 ozlacre, Labeled for use in Harmful by Can only be used Aphids, 8EC cost NA intermittent flooded swallowing, under an WaMqppers, areas,stagnant water inhalation or agreement gii pper and temporary rain skin contact. between Ecology s,spider pools. and Health in the mites, bugs, event of a beetles, disease outbreak. moths, worms,flies„.- mosquitoes,; &larvae *OPs are organophosphates **Restrictions can be waived in the event of a threat to human heath as determined by state and local health departments(see p. 16). ***EPA's 2001 Methoprene R.E.D.Fact Sheet states that methoprene"has activity against a variety of insect species,including horn flies,mosquitoes,beetles,tobacco moths,sciarid fly,fleas(eggs and larvae),fire ants,pharaoh ants,midge flies and Indian meal • moths." However,no effectiveness is claimed against these insects at the dose label rate for mosquito larvae control. Best Management Practices for Mosquito Control Page 17 Washington State Department of Ecology When Adulticides Fit into a Mosquito Control Plan • Terrestrially applied products are NOT regulated under federal or state water pollution control laws and are NOT subject to NPDES permit conditions or requirements when applied to terrestrial sites. However,adulticiding is often an integral component of an integrated pest management approach to mosquito control. In some instances,adulticiding can reduce or eliminate the need to heavily apply larvicides,can be used effectively with less environmental impact to non-targets,and can be cost- effective. Select triggers for the use of adulticide products:Some mosquito control districts recommend using light traps to monitor for mosquitoes. For example,Adams County MD recommends that counts of 8 to 12 mosquitoes caught in 12 hours or a 3 adult mosquito landing count per minute in a residential area triggers the need to adulticide (Thomas Haworth,personal communication, November 7,2003). Some applicators recommend adulticiding residential areas and upland areas where mosquitoes are migrating only when there is evidence of mosquito-borne epizootic activity at a level suggesting high risk of human infection. The following are examples of this type of evidence:high dead bird densities;high mosquito infection rates;multiple positive mosquito species including bridge vectors;horse or mammal cases indicating escalating epizootic transmission,including bridge vectors,horse or mammal cases,or a human case with evidence of epizootic activity. Reducing vector densities below transmission threshold usually requires multiple ULV applications. Therefore,triggers should take into account this latency effect so that human transmission is not proceeding prior to or during operations. This presupposes identifying • increasing human risk at least 2 weeks before human cases might present. Trigger design and implementation should reflect this need for preemptive adulticiding. BMPs for Adulticides: 1) Meteorological conditions: • Record wind speed and direction before spraying and be observant of all changes in direction and speed during the application. Use appropriate wind indicators. Gauges are highly recommended for ground applications and smoke for aerial applications. • For aerial applications,check temperature at different elevations to decide if there is an inversion. • Spray only when wind is away from sensitive sites. 2) Do not spray in winds over 10 mph. 3) Follow label buffers. The following table gives a sample of mosquito adulticides that may be used in terrestrial applications in Washington State. Labels are available from http://picol.cahe.wsu.edu/. • Page 18 Best Management Practices for Mosquito Control Washington State Department of Ecology Table 4. Common Insecticides Used for Adult Mosquito Control Typical Active Label Use Residual Products Ingredient Rate Use Cost Life Comments Biomist& Kontrol, Permanone ULV 4 Effective, 100 ft set- Aqua Reslin Permethrin oz/acre Adult Control $.24/oz 24 hours back from water. No set-backs to Pyrenone water. Approved for 25-5 Public crop and pasture Health ULV 1-4 applications. Insecticide Pyrethrin oz/acre Adult Control $1.20/oz 1 hour Expensive Has not performed well in some areas. ULV 4 No setbacks to Scourge Resmethin oz/acre Adult Control $.58/oz 1-4 hours water. Fyfanon ULV rates Very highly toxic to ULV Malathion Ivary Adult Control $.24/oz 24 hours nontargets. 0.0012 lb— Tested and used in 0.0036 lbs ai the NW. No water Anvil Sumithrin per acre Adult Control $.40/oz 1-4 hours precautions. Not • recommend No set-backs to ed for water. Approved for Dibrom, ground ULV crop and pasture Trumpet Naled use. Adult control applications. What Constitutes an Emergency or a Health Threat? Health emergencies and health threats are declared by local health departments in consultation with Washington State Department of Health. A health officer should consider demographics, population densities and species of mosquitoes,proximity of positive identifications of mosquito- borne disease,and local tolerances for pesticide applications and disease outbreaks when assessing risk. Permitted insecticides may be applied to waters as conditioned by their FIFRA labels(including methoprene in restricted areas) once an application has been submitted but before permit coverage is granted as a result of consultation between departments of Health and Ecology,in response to a human health emergency or threat as determined by the Washington State Department of Health. If an emergency is declared or a threat is determined,and mosquito control actions haven't already been taken,the responsible officials should immediately initiate actions to minin-dze mosquito breeding habitat and educate at risk populations about personal protection(see p.2);they should then begin conducting larval surveys and secure the funding,permits and licenses needed for applying insecticides. For practical purposes,once an outbreak is underway,larval surveys and • Best Management Practices for Mosquito Control Page 19 Washington State Department of Ecology other control and habitat minimization measures will have little immediate effect. At this point, • personal protective measures and large-scale adulticiding may provide the only means to reduce human/vector contact and further spread of the disease beyond those already infected. References Cited Colorado Mosquito Control,Inc. Online at: wwwr.comosquitocontrol.com/.Mood irrigation & mosquitoes.htm. Lilja,Jack. 2002. Mosquito-Borne Disease Response Plan, November 2002 Edition.Washington State Department of Health. Online at: www.doh.wa.gov/ O'Malley,Claudia C.1995. Seven Ways to a Successful Dipping Career. Wing Beats, vol. 6(4): 23-24. American Mosquito Control Association,www.mosquito.org/12ublications.html. Pratt,Harry D. and Moore,Chester G. 1993. Mosquitoes of Public Health Importance and Their Control. U.S. Department of Health and Human Services,Centers for Disease Control and Prevention,Self- study Course 3013-G:Vector-Borne Disease Control. Von Grey,Ed. 2002. Draft Appropriate Mosquito Management Strategies as a Response to West Nile Virus.Washington State Department of Agriculture. Whitworth,Terry.2002. Mosquito Management Policy for Residential Stormwater Ponds in King County, Washington. King County Department of Natural Recourses and Parks,Water and Land Recourses • Division. • Page 20 Best Management Practices for Mosquito Control Washington State Department of Ecology • Appendix A State Listed Species Restricted Areas Best Management Practices for Mosquito Control Page A-1 Washington State Department of Ecology • • Page A-2 Best Management Practices for Mosquito Control Washington State Department of Ecology Appendix A State Listed Species Restricted Areas Basis of Restrictions Ecology's Aquatic Mosquito Control National Pollutant Discharge Elimination System(NPDES)General Permit No.WAG-992000 Condition 54 3 states,"In developing the IPM plan,the permittee shall consult with local governments and state and federal agencies as needed." Ecology took the lead developing an IPM plan to assist many local governments and others performing mosquito control operations who were suddenly in the business of mosquito control due to the spread of the West Nile virus. As the permit required,Ecology consulted with the Department of Fish and Wildlife (WDFW)in spring 2003 during this process. As a result,the WDFW identified wildlife species that it considered most vulnerable to certain mosquito control larvacides,identified the primary areas occupied by these species,and requested that pesticide applications be restricted in these areas. These areas,along with areas identified as habitat for federal and state listed fish species were compiled into a document called Insert A and listed as areas where larvicides containing monomolecular surface films, methoprene,petroleum distillates,malathion and temephos were not allowed for use. Larvicides containing Bacillus thuringiensis israelensis(Bti)and Bacillus sphaericus (BS)were allowed for use due to their low toxicity to non-target species. Unfortunately,the recommendations for restrictions were given to Ecology after the mosquito • spray season had begun and in the interest of having a permit pathway in place for applicators for the 2003 spray season Ecology listed the recommendations as Insert A and opened them for public review after the season was over. The restrictions in Insert A have been considerably revised as a result of a more thorough review initiated the fall of 2003. Significantly,the restrictions on the use of methoprene in waters containing federal and state listed salmon have been lifted to allow monitoring for effects. The restrictions for state listed species that are still recommended by WDFW are listed here and a map of those areas is provided. Restrictions specific to larvicide active ingredients are also noted on Table 3. Criteria Used for the Restrictions The criteria WDFW used for denoting species as vulnerable were: 1) State species of concern(i.e.,listed as state endangered,threatened,sensitive,or candidate). 2) Current range and distribution of the species was highly localized. 3)The species inhabited freshwater wetlands during most of the mosquito control treatment period. Six species initially met those criteria:northern leopard frog(Rana pipiens),Oregon spotted frog(Rana pretiosa), western toad(Bufo boreas),western pond turtle (Clemmys marmorata),American white pelican(Pelecanus erythrorhynchos),and one butterfly,the Yuma skipper(Ochlodes yuma). WDFW identified areas occupied by the two extant populations of northern leopard frog;two extant western •Washington populations of Oregon spotted frog;western toad breeding ponds(for western Washington only);the Best Management Practices for Mosquito Control Page A-3 Washington State Department of Ecology three remaining western pond turtle populations;the single American white pelican breeding colony;and the o• known Washington Yuma skipper population. Based on the review of published literature,expert advice,and the vulnerability of these rare and endangered animals and their freshwater invertebrate food resources WDFW requested that if mosquito control is deemed necessary in the areas WDFW described in April 2003,that it be restricted to the use of Bacillus products. Aerial Applications An exception to the WDFW request regarding the use of certain larvicides was made for the single American white pelican breeding colony. The colony resides on islands and along the shores of the Columbia River,south of the confluence of the Snake River,in Walla and Benton counties. While bio-chemicals such as methoprene were not of concern for the pelican breeding colony,the method of aerial application was believed to be unacceptably disturbing for their successful breeding. It was agreed that aerial applications would not be made on the pelican breeding areas,whereas less obtrusive methods of mosquito control were acceptable near these sites. Discussions among several WDFW biologists found that aerial applications of larvicides disturbed work being done in a few wildlife refuge areas around the state. It was therefore agreed that operators making aerial applications over wildlife refuges should notify the appropriate regional WDFW office of their scheduled aerial applications at least 24 hours prior to spraying. The notification can be made by phone or fax. Area of Impact Only a few populations of northern leopard frog,Oregon spotted frog,western toad,western pond turtle,and • Yuma skipper remain in Washington. The total area occupied by these species in rivers,lakes,ponds,and wetlands is tiny,comprising of portions of 117 sections(<0.18% of Washington State). The areas identified for northern leopard frog(36 Sections)and western pond turtle (13 Sections)are owned or managed by WDFW. A prudent,risk-adverse approach is warranted with vulnerable threatened and endangered species. The following areas are restricted to the use of Bacillus thuringiensis israelensis(Bti)and Bacillus sphaericus(H-5a5b) only. Sections added January 22,2004 are in bold: 1) Grant County,north of Moses Lake,within the Crab Creek watershed:T21N R27E Sections 1,12,and 13;T21N R28E Sections 7,17,18,19,28,29,30,31,32,and 33. 2) Grant County,south and west of Moses Lake and south of Interstate-90,the northern portion of the Potholes:T19N R27E Sections 33,34,35,and 36;T19N R28E Sections 31 and 32,29,30;T18N R27E Sections 1,2,3,4,8,9,10,11,12,13,14,15,and 16,17,T18N R28E Sections 5,6,7,8,17,and 18. 3) Grant County,area within and near the Sun Lakes-Dry Falls State Park wetlands: T24N R27E and 28E. 4) Kitsap County:lakes,ponds,and wetlands located in T22N R1W Sections 1,2,10,11,and 12. 5) Klickitat County,west of the Klickitat River,all waters in T3N R12E Sections 28,29,32,and 33. 6) Mason County,on the Kitsap Peninsula:lakes,ponds,and wetlands located in T23N R2W Sections 11,12,13,14,15,22,and 23. 7) Pierce and Kitsap counties,Carney Lake,located in T22N R1W. • Page A-4 Best Management Practices for Mosquito Control Washington State Department of Ecology • 8) Pierce,Thurston,and Lewis counties,within the Nisqually River watershed:Alder Lake(or Alder Lake Reservoir),located in townships:T15N R4E and 5E. 9) Pierce County,south of Tacoma,Chambers Creek and associated waters in T20N R2E Sections 26 and 27. 10)Skamania County,east of Carson,all waters in T3N R8E Sections 23,24,25,26,and 36;T3N R9E Sections 30 and 31. 11)Thurston County,west of Yelm: lakes,ponds,and wetlands located in T17N R1E Sections 8,9, 16,and 21. 12)Thurston County,south of Olympia and east of Interstate-5,within the Black River watershed,the Beaver Creek drainage,located in T16N R2W Sections 9,10,11,and 12;T16N R1W Section 7. 13)Thurston County,south of Olympia and west of Interstate-5,within the Black River watershed:Black River proper from south of Black Lake to the Chehalis Riverconfluence,and the following tributaries,Stony Creek,Dempsey Creek,SalmonCreek,and Blooms Ditch. Legal description as follows for these sensitive areas: T17N R3W Sections 10,11,12,13,14,15,23,24, 25,35,and 36;T17N R2W Sections 7,18,19,and 30;T16N R3W Sections 2,11,14,19,20,21,22, 23,30,and31;T16N R4W Sections 25,26,27,31,32,33,34,35,and 36. • Best Management Practices for Mosquito Control Page A-5 Washington State Department of Ecology i 0.1 ----------------- eT .00 Ptsincled Wildlife ie fnwn*wWasNnglivifkg of Fish and Wildlife • Page A-6 Best Management Practices for Mosquito Control Washington State Department of Ecology i Appendix 6 Insect Repellent Use and Safety From the Center for Disease Control i Best Management Practices for Mosquito Control B-1 Washington State Department of Ecology • • B-2 Best Management Practices for Mosquito Control Washington State Department of Ecology i Appendix B Insect Repellent Use and Safety From the Center for Disease Control Q. Is DEET safe? A.Yes,products containing DEET are very safe when used according to the directions. Because DEET is so widely used,a great deal of testing has been done. When manufacturers seek registration with the U.S. Environmental Protection Agency(EPA)for products such as DEET, laboratory testing regarding both short-term and long-term health effects must be carried out. Over the long history of DEET use,very few confirmed incidents of toxic reactions to DEET have occurred when the product is used properly. (From the National Pesticide Information Center [NPIC],EPA re-registration eligibility decision. See comic.orst.edu/factsheets/DEETgen.pdf. Insect Repellents and Sunscreen Q. Can I use an insect repellent containing DEFT and sunscreen at the same time? • A.Yes. People can and should use both sunscreen and DEET when they are outdoors to protect their health. Follow the instructions on the package for proper application of each product. Apply sunscreen first,followed by repellant containing DEET. To protect from sun exposure and insect bites,you can also wear long sleeves and long pants. You can also apply insect repellent containing DEET or permethrin to your clothing,rather than directly to your skin. Q.Has CDC changed its recommendations for use of DEET and sunscreen? A. No. Based on available research,CDC believes it is safe to use both products at the same time. Follow the instructions on the package for proper application of each product. Apply sunscreen first,then insect repellent containing DEET,to be sure that each product works as specified. Q. Should I use a combination sunscreen/DEET-based insect repellent? A. Because the instructions for safe use of DEET and safe use of sunscreen are different,CDC does not recommend using products that combine DEET with sunscreen. In most situations,DEET does not need to be reapplied as frequently as sunscreen. DEET is very safe when applied correctly. The rare adverse reactions to DEET have generally occurred in situations where people do not follow the product instructions. Sunscreen often requires frequent reapplication,so using a combined product is not recommended. You do not need to reapply insect repellent every time you reapply sunscreen. Follow the instructions on the package for each product to get the best results. • Best Management Practices for Mosquito Control B-3 Washington State Department of Ecology Q.I heard about a study saying that there may be some type of interaction between repellents containing DEET and sunscreen.Is this true? A.There has been attention to a study concerning the chemicals in DEET and sunscreen presented at a scientific meeting.This is an in vitro study,which means that it is a laboratory study that did not include human or animal testing. The goal of the study was to examine absorption of these chemicals,and it did not evaluate or make conclusions about health effects related to this issue. The study authors stated that further evaluation of the interaction of these chemicals should be conducted. The study has not yet been published (as of July 2003). Evaluation by the EPA,which regulates products such as DEET,indicates that it is safe to use insect repellents containing DEET and sunscreen at the same time.CDC recommends using two separate products because sunscreen requires frequent applications while DEET should be used sparingly. Follow the directions on the package for each product,and consult your physician or pharmacist if you have questions.CDC's recommendations for the safe use of insect repellents on children and adults remain unchanged. Insect Repellent Use Q. Why should I use insect repellent? A. Insect repellents help people reduce their exposure to mosquito bites that may carry potentially serious viruses such as West Nile virus, and allow them to continue to play and work outdoors. Q. When should I use mosquito repellent? • A. Apply repellent when you are going to be outdoors and will be at risk for getting bitten by mosquitoes. Q. What time of day should I wear mosquito repellent? A. Many of the mosquitoes that carry the West Nile virus are especially likely to bite around dusk and dawn. If you are outdoors around these times of the day,it is important to apply repellent. In many parts of the country,there are mosquitoes that also bite during the day,and these mosquitoes have also been found to carry the West Nile virus. The safest decision is to apply repellent whenever you are outdoors. Q.How often should repellent be reapplied? A. Follow the directions on the product you are using in order to determine how frequently you need to reapply repellent. Sweating,perspiration or getting wet may mean that you need to re-apply repellent more frequently. If you are not being bitten,it is not necessary to re-apply repellent. Repellents containing a higher concentration of active ingredient(such as DEET) provide longer-lasting protection. Q. Should I wear repellent while I am indoors? A. Probably not. If mosquitoes are biting you while you are indoors,there are probably better ways to prevent these bites instead of wearing repellent all the time. Check window and door screens for holes that may be allowing mosquitoes inside. If your house or apartment does not have screens,a quick solution may be to staple or tack screening(available from a hardware • B4 Best Management Practices for Mosquito Control Washington State Department of Ecology • store) across the windows. In some areas community programs can help older citizens or others who need assistance. Q. How does mosquito repellent work? A. Female mosquitoes bite people and animals because they need the protein found in blood to help develop their eggs.Mosquitoes are attracted to people by skin odors and carbon dioxide from breath. Many repellents contain a chemical,N,N-diethyl-m-toluamide (DEET),which repels the mosquito,making the person unattractive for feeding. DEET does not kill mosquitoes;it just makes them unable to locate us. Repellents are effective only at short distances from the treated surface,so you may still see mosquitoes flying nearby. As long as you are not getting bitten,there is no reason to apply more DEET. Q. Which mosquito repellent works the best? A. The most effective repellents contain DEET(N,N-diethyl-m-toluamide),which is an ingredient used to repel pests like mosquitoes and ticks. DEET has been tested against a variety of biting insects and has been shown to be very effective. The more DEET a repellent contains the longer time it can protect you from mosquito bites. A higher percentage of DEET in a repellent does not mean that your protection is better—just that it will last longer. DEET concentrations higher than 50 percent do not increase the length of protection. Q. How does the percentage of DEET in a product relate to the amount of protection it gives? A. Based on a recent study: • A product containing 23.8 percent DEET provided an average of five hours of protection from mosquito bites. • A product containing 20 percent DEET provided almost four hours of protection • A product with 6.65 percent DEET provided almost two hours of protection • Products with 4.75 percent DEET and 2 percent soybean oil were both able to provide roughly one and a half hours of protection. Choose a repellent that provides protection for the amount of time that you will be outdoors. A higher percentage of DEET should be used if you will be outdoors for several hours while a lower percentage of DEET can be used if time outdoors will be limited. You can also re-apply a product if you are outdoors for a longer time than expected and start to be bitten by mosquitoes. (For more information,see Table 1:Fradin and Day,2002.See Publications page.) Q. Why does CDC recommend using DEET? A. DEET is the most effective and best-studied insect repellent available. (Fradin,1998). Studies using humans and mosquitoes report that only products containing DEET offer long- lasting protection after a single application.(Fradin and Day,2002.See Publications page.) Q. Are non-DEET repellents effective(e.g. Skin-So-Soft,plant-based repellents)? A. Some non-DEET repellent products which are intended to be applied directly to skin also provide some protection from mosquito bites. However,studies have suggested that other products do not offer the same level of protection,or that protection does not last as long as • products containing DEET. A soybean-oil-based product has been shown to provide protection Best Management Practices for Mosquito Control B-5 Washington State Department of Ecology for a period of time similar to a product with a low concentration of DEET(4.75%) (Fradin and • Day,2002.See Publications page.). People should choose a repellent that they will be likely to use consistently and that will provide sufficient protection for the amount of time that they will be spending outdoors. Product labels often indicate the length of time that protection that can be expected from a product. Persons who are concerned about using DEET may wish to consult their health care provider for advice. The National Pesticide Information Center (NPIC)can also provide information through a toll-free number,1-800-858-7378 or npic.orst.edu. Q. I'm confused.Which products contain"DEET"? A. Most insect repellents that are available in stores are labeled with the chemical name for DEET. Look for N,N-diethyl-m-toluamide or,sometimes,N,N-diethyy-3-methylbenamide. Choose a repellent that offers appropriate protection for the amount of time you will be outdoors. A higher percentage of DEET should be used if you will be outdoors for several hours while a lower percentage of DEET can be used if time outdoors will be limited. Using Repellents Safely Q. What are some general considerations to remember in order to use products containing DEET safely? A. Always follow the recommendations appearing on the product label. • Use enough repellent to cover exposed skin or clothing. Don't apply repellent to skin • that is under clothing. Heavy application is not necessary to achieve protection. • Do not apply repellent to cuts,wounds,or irritated skin. • After returning indoors,wash treated skin with soap and water. • Do not spray aerosol or pump products in enclosed areas. • Do not apply aerosol or pump products directly to your face. Spray your hands and then rub them carefully over the face,avoiding eyes and mouth. Q. How should products containing DEET be used on children? A. No definitive studies exist in the scientific literature about what concentration of DEET is safe for children. No serious illness has been linked to the use of DEET in children when used according the product recommendations. The American Academv of Pediatrics(AAP) Committee on Environmental Health has recently updated their recommendation for use of DEET products on children,citing: "Insect repellents containing DEET(N,N-diethyl-m- toluamide,also known as N,N-diethyl-3-methylbenzamide)with a concentration of 10 percent appear to be as safe as products with a concentration of 30 percent when used according to the directions on the product labels." The AAP and other experts suggest that it is acceptable to apply repellent with low concentrations of DEET to infants over two months old. Other guidelines cite that it is acceptable to use repellents containing DEET on children over two years of age. • B-6 Best Management Practices for Mosquito Control Washington State Department of Ecology Repellent products that do not contain DEET are not likely to offer the same degree of protection from mosquito bites as products containing DEET. Non-DEET repellents have not necessarily been as thoroughly studied as DEET,and may not be safer for use on children. Parents should choose the type and concentration of repellent to be used by taking into account the amount of time that a child will be outdoors,exposure to mosquitoes,and the risk of mosquito-transmitted disease in the area. Persons who are concerned about using DEET or other products on children may wish to consult their health care provider for advice. The National Pesticide Information Center(NPIC)can also provide information through a toll-free number,1-800-858-7378 or npic.orst.edu. Always follow the recommendations appearing on the product label when using repellent. • When using repellent on a child,apply it to your own hands and then rub them on your child. Avoid children's eyes and mouth and use it sparingly around their ears. • Do not apply repellent to children's hands. (Children may tend to put their hands in their mouths.) Do not allow young children to apply insect repellent to themselves;have an adult do it for them. Keep repellents out of reach of children. Do not apply repellent to skin under clothing. If repellent is applied to clothing,wash treated clothing before wearing again. Using repellents on the skin is not the only way to avoid mosquito bites. Children and adults • can wear clothing with long pants and long sleeves while outdoors. DEET or other repellents such as permethrin can also be applied to clothing(do not use permethrin on skin),as mosquitoes may bite through thin fabric. Mosquito netting can be used over infant carriers. Finally,it may be possible to reduce the number of mosquitoes in the area by getting rid of containers with standing water that provide breeding places for the mosquitoes. Q. Is DEET safe for pregnant or nursing women? A. There are no reported adverse events following use of repellents containing DEET in pregnant or breastfeeding women. Q. Are there any risks due to using repellents containing DEET? A. Use of these products may cause skin reactions in rare cases. If you suspect a reaction to this product,discontinue use,wash the treated skin,and call your local poison control center. There is a new national number to reach a Poison Control Center near you:1-800-222-1222. If you go to a doctor,take the product with you. Cases of serious reactions to products containing DEET have been related to misuse of the product,such as swallowing,using over broken skin,and using for multiple days without washing skin in between use,for example. Always follow the instructions on the product label. • Best Management Practices for Mosquito Control B-7 Washington State Department of Ecology More information . Q. Where can I get more information about repellents? A. For more information about using repellents safely please consult the EPA Web site: http://www.el2a.gov/pesticides/citizens/insectrL).htTn or consult the National Pesticide Information Center(NPIC),which is cooperatively sponsored by Oregon State University and the U.S.EPA. NPIC can be reached at:npic.orst.edu or 1-800-858-7378. • B-8 Best Management Practices for Mosquito Control Washington State Department of Ecology Appendix C Response to Public Comments Best Management Practices for Mosquito Control C-1 Washington State Department of Ecology • • • C-2 Best Management Practices for Mosquito Control Washington State Department of Ecology • AQUATIC MOSQUITO CONTROL GENERAL PERMIT RESPONSE TO COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD FOR GENERAL NPDES PERMIT WAG-992000 MODIFICATION AND THE BEST MANAGEMNT PRACTICES FOR MOSQUITO CONTROL This appendix contains Ecology's response to comments to the Mosquito Control General NPDES Permit WAG-992000 Modification and changes to the Best Management Practices for Mosquito Control (BMP)document received during a public review period from December 15,2003,to March 25,2004. Prior to the formal public review period the Departments of Health and Fish&Wildlife,many mosquito control districts,local governments,mosquito control product manufacturers and other interested parties worked with Ecology to revise the statewide permit and BMPs to make them more pertinent and usable for those conducting mosquito control efforts in the field. Meetings were held October 14 and 15 in Moses Lake,on October 21 in Lacey,and again on March 5 in Olympia,at the Washington State Department of Agriculture. As a result,Ecology received many informal comments and suggestions that were incorporated into the proposed modifications. Formal comments received during the public comment period pertain to wetlands,the use of methoprene and other mosquito control products,thresholds for larviciding(including preemptive methods of control),adulticiding,dipping requirements,suggestions for clarification,and other miscellaneous comments. Commenters 1. Joseph M. Conlon,American Mosquito Control Association 2. Karl Malamud-Roam,Ph.D.,Contra Costa Mosquito&Vector Control District,Concord,CA 3. Steve Foss and Wendy Sue Wheeler,Washington State Department of Agriculture 4. Ann Potter and Rocky Beach,Washington State Department of Fish&Wildlife 5. Tom Haworth,Adams County Mosquito Control District,WA 6. Kevin Shoemaker,Northwest Mosquito and Vector Control Association 7. Heather Hansen,Washington Friends of Farms and Forests 8. LaDell Yada,Washington State citizen 9. Lou Dooley,Environmental Health Director,Clark County Mosquito Control District 10. Doug Van Gundy,Wellmark International 11. William Meredith,Delaware Mosquito Control Section,Department of Fish and Wildlife 12. Wayne Switzer,Eden Advance Pest Technologies 13. Art G. Losey,Washington State Pest Control Association 14. William Peacock, City of Spokane • 15. Jim Thompson,Grant County Mosquito District#1 Best Management Practices for Mosquito Control C-3 Washington State Department of Ecology 16. Jim Tabor,WDFW • 17. Mike Young,Snohomish Health District 18. Gerald Campbell,Grant County Health District 19. Mark Newberg,Wellmark International 20. Benjamin Hamilton,Washington State Department of Health 21. David Ensunsa,Columbia Mosquito Control District 22. Dan Mathias,City of Everett Comments have been summarized and those commenting are referenced by the number given to them above. Where comments resulted in a change to either the BMP document or the permit,that change is noted. Wetlands Comment 1. The role of natural predation in the control of mosquitoes in the document and the webpage from which it is derived is somewhat overstated. Although there is a wealth of literature recording observations and extolling the importance of the Odonata as predators of diurnally active adult mosquitoes,this has not been supported by controlled field studies. While predation provides a worthy and welcome contribution to our integrated mosquito control efforts,it simply cannot provide the level of control needed when human lives are at stake This is certainly not meant to downplay the important part proper wetlands management plays in ecology and a fully-integrated mosquito management strategy,for the American Mosquito Control Association fully supports and endorses proper wetlands management. But I would caution against promulgating this as the sole means of mosquito control in areas where these wetlands are found. I would advise further caution against underestimating the potential magnitude of mosquito production even in natural,healthy wetlands. (1,11,12) Response to Comment 1. Mosquito "outbreaks" most often occur in destabilized wetland and stream ecosystems that have been changed or tampered with so that the predators of the larvae such as invertebrates, insects, and amphibians are excluded. Ecology does not suggest that predation is the only means of mosquito control for wetlands. While draining and/or filling wetlands are not approved methods, taking an integrated approach that targets mosquito larvae control, including bio-chemical control, is recommended in the BMPs. (Tom Hruby, Ecology Wetland Specialist, Personal Communication, IA6104) Methoprene Comment 2. This comment addresses the issue of restricting the use of methoprene in areas known to provide habitat for state threatened and endangered species during the mosquito spray season. There were divergent views on the proposed restrictions. One view suggests the restrictions are unnecessary, the other suggests precaution due to unknowns. Let it be noted that the WDFW restricted areas are the only conditions for methoprene in the Permit that are more stringent than the application conditions set by FIFRA labels. View 1. The 2001 USEPA document together with the 2003 USEPA research and the World Health Organization/FAO review state that methoprene will have minimal adverse effects on non-target species. The Fish and Wildlife letter pretty dramatically overstates the risks • C-4 Best Management Practices for Mosquito Control Washington State Department of Ecology associated with this product. Decisions should be made on sound science. Methoprene should be allowed in areas identified by WDFW to minimize the potential increase use of adulticides, which will likely result due to insufficient control of third and fourth instar larvae using Bacillus products only. (1,2,3,5,6,7,8,9,10,12,13,15,18,19,41) View 2.We [WDFW] appreciate Mr. VanGundy's [VanGundy represents Wellmark International,a manufacturer of methoprene products] explanation regarding the contents of the EPA RED documents.We notice that EPA does denote a level of amphibian toxicity from methoprene ("minimally toxic to amphibians"). In our October 13 letter,we state that research on methoprene and frog deformities is inconclusive. There are studies that have found developmental effects to amphibians when methoprene was applied at mosquito control treatment levels,and there are studies that have not observed this. We do not think it would be productive to engage in debate/rebuttal over all research on this matter. Because the body of research on this topic is not definitive we have chosen to use the precautionary principal when conserving state and endangered species.We did not feel that there was sufficient information to recommend that methoprene products be restricted other than in very localized areas where we have identified T&E species. Given that we are making recommendations for state threatened and endangered species,in very limited areas,and that other efficacious mosquito control products(Bacillus)are available,we continue to support our original recommendation on methoprene restriction. (4,16) Response to Comment 2. Aquatic Mosquito Control Permit No. WAG-992000, Section S4. Best Management Practices/Integrated Pest Management requires the preparation and implementation of an Integrated Pest Management •Plan (IPMP) by the permittee. Among other conditions, the section states, "in developing the IPM plan, the permittee shall consult with local governments and state and federal agencies as needed." The Permit Fact Sheet provides the following rationale for this condition: ...an IPM program considers all available control actions, including no action,and evaluates the interaction among various control practices, cultural practices, weather, and habitat structure. This approach thus uses a combination of resource management techniques to control mosquito populations with decisions based on surveillance. Fish and game specialists and natural resources biologists should be involved in planning control measures whenever delicate ecosystems could be impacted by mosquito control practices (p. 9). Ecology took the lead developing an IPM plan to assist local governments and others performing mosquito control operations who were suddenly in the business of mosquito control due to the spread of the West Nile virus. As the permit required, Ecology consulted with the Department of Fish and Wildlife (WDFW)in spring 2003 during this process. WDFW identified wildlife species that it considered most vulnerable to certain mosquito control larvacides, identified the primary areas occupied by these species, and requested that pesticide applications be restricted in these areas. Ecology also invited representatives from the industry to comment on the basis of the WDFW recommendations. An evaluation of the issue yields the following facts: 1. The criteria WDFW used for denoting species as vulnerable were appropriate. Only those listed as state endangered, threatened, sensitive, or candidate species that inhabited freshwater wetlands during most of the mosquito control treatment period were considered. Five species met the criteria:northern leopard frog(Rana pipiens), Oregon spotted frog(Rana pretiosa),western toad (Bufo boreas), western pond turtle (Clemmys marmorata), and one butterfly, the Yuma skipper(Ochlodes yuma). Best Management Practices for Mosquito Control C-5 Washington State Department of Ecology 2. _The total area occupied by these species in rivers, lakes, ponds, and wetlands is tiny, comprising of portions of 117 sections (<0.18% of Washington State). Many areas identified for northern leopard frog (36 Sections) and western pond turtle (13 Sections)are owned or managed by WDFW. 3. EPA's Methoprene Registration Eligibility Document (RED) is dated March 1991. This document has not been updated. A Fact Sheet for the RED was updated in 2001. The RED document states, "The Agency does have data, however, that show that methoprene is highly acutely toxic to estuarine invertebrates" (p. 12). The Fact Sheet for the RED document updates this assessment and describes the level of amphibian and fish toxicity from methoprene as "minimally toxic" but does not define what that means or explain if that is sufficiently protective for federally and state listed species of concern. The World Health Organization indicates methoprene is slightly toxic to fish but lists no data on amphibians. 4. Recent research on methoprene and frog deformities and developmental toxicity is inconclusive. For example, La Clair el al. (1998)found that methoprene breaks down quickly in sunlight and very low concentrations of the byproducts from degradation interfere with normal amphibian development. The La Clair study concluded "the addition of IpLIL of several of S-methoprene's degradaties to the environment of developing [amphibian]embryos resulted in juveniles with deformities similar to that found naturally." Ankley et al. (1998)found that UV light caused amphibian limb malformations whereas methoprene did not. The study further reported that concentrations of 500 ppb of methoprene caused mortality in amphibians. Degitz et al. (2003)was unable to reproduce the results of the La Clair study, but did determine that methoprene and its metabolites did not cause any adverse effects at rates < 1.25 ppm. These data are too disparate to be conclusive. Even though risk levels appear to be low, much uncertainty still exists with both the concentrations and the role methoprene and its metabolites play with the normal development of amphibians. 5. Levels of methoprene that may be found in the environment after mosquito control applications are also variable. Concentrations have ranged from 4 ppb at seven days post treatment from an Altosid 30-day briquette (Ross et al 1994) to 0.01 ppm from sustained-release formulations(Degitz et al.2003). Henrick, et.al. (2002)found 26 ppb s-methoprene in ponds treated with Altosid Liquid Larvicide (ALL)at day one, and 1 ppb at day seven. However, one of the metabolites, 7-methoxycitronellal acid, was found at 267 ppb at day 1 and 237 ppb at day 7. Notably, these levels do not represent multiple treatments or potential accumulation or any number of other factors, such as shade, wind, water flow, temperature, pH, turbidity, etc. that may affect concentrations of applications to the natural environment. 6. Several studies concluded that a dose-exposure connection between frog deformities and methoprene applications for mosquito control is unlikely and that correlations between locations of methoprene applications for mosquito operations and frog deformities have not been found (Henrick, et.al.2002,Johnson et.al. 2001, Ankley et al. 1998). 7. Larvicides containing Bacillus thuringiensis israelensis (Bti)and Bacillus sphaericus (BS)are allowed for use in these areas due to their extreme low toxicity to non-target species. 8. The restricted areas identified by WDFW may pose a threat to human health when used as breeding grounds by mosquito vectors due to the narrow window of effectiveness of Bacillus products. Ecology proposes to allow the use of methoprene in more than 99% of the state as conditioned by the federal FIFRA label but will continue to restrict the areas of application for methoprene as recommended by WDFW except in the event of a human health threat from mosquito-borne disease as determined by the State and local health departments. Mono- molecular films, oils and organophosphates are also restricted in these areas, but the restriction on the use of methoprene was questioned due to its low toxicity to non-targets and high selectivity for mosquito larvae. To aid future decisions regarding the use of methoprene Ecology will complete a SEPA checklist evaluation of the use of methoprene for mosquito control operations and initiate a monitoring strategy to document concentration levels of methoprene applications in relation to possible adverse effects to non-target species. Many individuals, including people • C-6 Best Management Practices for Mosquito Control Washington State Department of Ecology representing mosquito districts, local governments, Wellmark and WDFW have offered to review and/or assist with the monitoring strategy. We intend on taking advantage of these offers. The objective of the evaluation and monitoring plan will be to provide data on methoprene for decisions relevant to permit renewal by November 2006. Comment 3. Page 13 of the BMP under permitted pesticides for mosquito control: The chart should be corrected to show specifically listed pests for Altosid products. Under the heading"Target Pests on Label," the identified species in the chart for Altosid indicates a variety of pests. There are other methoprene labels that reflect these pests but for Altosid,mosquitoes are the only listed species. (10) Response to Comment 3. Agreed, the chart has been edited. However, EPA's 2001 Methoprene R.E.D. Fact Sheet states that methoprene "has activity against a variety of insect species, including horn flies, mosquitoes, beetles, tobacco moths, sciarid fly,fleas (eggs and larvae),fire ants,pharaoh ants, midge flies and Indian meal moths." This information has been noted as a footnote to the chart. Comment 4. The statement in Comment 2,that"We do not think it would be productive to engage in debate/rebuttal over all research on this matter [methoprene and amphibians]," is frankly stunning. I do not believe that I have ever seen a government entity express the thought that they do not want to review the scientific facts on a controversial issue. Given that Ecology's proposed alternatives to methoprene are frequently less effective in numerous circumstances,that resistance management through pesticide rotation is a cornerstone of modern IPM,and that USEPA and numerous other independent reviewers have found "minimal toxicity"or equivalent wording,the proposed prohibition should not occur without strong scientific evidence supporting it,and this has not been provided. (2) •Response to Comment 4. The comment referred to in the above statement, made by WDFW, was explained in the context: "Because the body of research on this topic is not definitive we have chosen to use the precautionary principal when conserving state and endangered species. We did not feel that there was sufficient information to recommend that methoprene products be restricted other than in very localized areas where we have identified T&E species. " They did review scientific facts, it was the lack of evidence regarding methoprene's toxicity that lead them to recommend the precautionary principle. Comment 5. The WSDA would like to inform Ecology that the Centers for Disease Control and Prevention, (CDC),recommends the alternation of biorational larvicides(Bti and Bs) and insect growth regulators (methoprene)annually or at longer intervals to prevent the development of insecticide resistance in vector populations. The WSDA recommends that the restriction of the use of Bti and Bs only in certain areas identified in the BMPs be amended by allowing some use of methoprene in rotation and in combination with the approved biorational larvicides so as to prevent the development of resistance to Bti and Bs. (3) Response to Comment 5. Since the restriction on the use of methoprene applies only in very select sites the rotation process recommended would not be precluded in 99% of the state. Further, in discussions with mosquito control operators around the state, we found that resistance to Bacillus products has not been found. Comment 6. The language allowing local jurisdictions to declare a health threat so they have access to methoprene is very unclear. This BMP gives no guidance as to how local boards of health are to be proactive in protecting the communities or what thresholds should be used to determine the potential for human health risks. Inconsistent mosquito control thresholds could result in water quality problems and people taking is illegal control measures into their own hands. (7,16,17) Best Management Practices for Mosquito Control C-7 Washington State Department of Ecology Response to Comment 6. Permit condition S1.4. restricts the use of methoprene in areas designated by Washington State Department of Fish and Wildlife except when a heath threat exists in those areas as determined by the State and local health departments. No health-based thresholds are stated in the BMPs or the permit. The Department of Health requested that health-based determinations be stated in general terms because the process and criteria used by local health jurisdictions to determine health threats is dependent on local conditions such as demographics,population densities and species of mosquitoes, proximity of positive identifications of mosquito-borne disease, tolerances for pesticide applications and tolerances for disease outbreaks. However, the language on page 16 of the BMP under the section, "What Constitutes an Emergency of Health Threat?"has been clarified. Comment 7. Page 3,paragraph 3. Regarding the statement in the BMP that methoprene is an endocrine disrupter,this statement is untrue and I would propose that this language be removed from the revised BUT. While endocrine disruption is becoming an area of concern,there are still ongoing discussions surrounding testing methodologies.Currently there is a lack of validated test systems. Methoprene does not disrupt the production of any glandular hormone within insects,other invertebrates,vertebrates or mammals. In insects it merely augments naturally occurring insect juvenile hormone(JH)at times in the insect life cycle where natural production of JH is at a minimum. An example would be during the molt from the last larval instar to the pupa or adult stage. I have included a more detailed commentary as Attachment 1. In mammalian systems,methoprene is broken down and excreted primarily through urine. (10) Response to Comment 7. Ecology agrees, the statement has been removed. Comment 8.There has been much discussion of the non-target effects of methoprene. As I outlined in my other correspondence,there exists a wide margin of safety to non-targets when methoprene is used according to label directions.There is no concern for accumulation of methoprene in the environment as it rapidly • degrades,further Henrick et al.2002,report that the degradation products of methoprene rapidly degrade as well,without accumulation. Methoprene can be used with confidence against mosquito larva but also provides for wide safety margins to non-targets. (10) Response to Comment 8. While there is no evidence that the use of methoprene for mosquito control will lead to amphibian malformations or other adverse effects to non-targets, the data are inconclusive. Scant monitoring has been done of methoprene applications for mosquito control in the natural environment. Ecology is initiating a monitoring strategy to document concentration levels of methoprene applications in the environment and will evaluate those levels in relation to possible adverse effects to non-target species. Comment 9. Page 18.There are some errors in the chart that need correction.The Altosid Liquid use rate should be changed to 3-4 ounces per acre instead of 2-20 pounds per acre.The 2-20 pound rate is incorrect for this formulation. The rate for Altosid XRG should be changed from 8-10 pounds to 5-20 pounds to reflect the label rate. In the target pest category there are a variety of pests listed for the Altosid products. While this list is inclusive of several product lines,it does not reflect the fact that the Altosid products are labeled only for mosquitoes. I would suggest that pricing be removed from the chart. Pricing is subject to change by time and location. Since the BMP is a document that will exist for some time,the pricing that is stated now in the BMP may not be indicative of a current price for future referrals to the BMP. (10) Response to Comment 9. The errors have been corrected. Prices, based on 2002 levels, will be retained only as a general guide for cost comparisons, one of the factors for consideration in an IPM plan. Comment 10. Methoprene's Impacts To Amphibians?—A few years ago,the U.S.Fish and Wildlife Service (USFWS)imposed a condition for methoprene's use on one of our two National Wildlife Refuges that • C-8 Best Management Practices for Mosquito Control Washington State Department of Ecology emethoprene not be applied over wetlands where the salinity was less than 5 ppt,done in what appeared (at least to us)to be an overly-zealous application of the precautionary principle,because of the service's supposed concerns about the impacts of methoprene upon the developmental stages of amphibians (which of course are found more typically in freshwater habitats than in salt marshes,hence the Service's 5 ppt demarcation). However,this restriction only lasted for one year in relation to our then questioning the USFWS's scientific foundations about their position—after further review of the scientific evidence,it then seemingly became apparent to the USFWS that there was no credible scientific evidence to link any amphibian developmental abnormalities or deformities seen in the field with exposures to methoprene associated with operational mosquito control, and this unnecessary restriction was rescinded. As I probably don't have to tell you or others in your state agency (if you're familiar with the scientific literature about these matters),several other much more probable causes of amphibian developmental abnormalities have now been scientifically identified (e.g.,parasitic infections,excessive UV light exposure,etc.)and been linked as the primary culprits for what has been observed for amphibian abnormalities,with any lingering connection here to the use of methoprene being an unwarranted,poorly-founded leap that serves little purpose(but wherever such claims still unfairly persist,then this bias certainly hinders the beneficial use of an important,environmentally- compatible mosquito control tool). (11) Response to Comment 10. We would be interested in any written assessment made by the USFWS on this matter. Thank you for your comments. Comment 11. Methoprene Use In Coastal Wetlands—As part of our statewide Integrated Pest Management (IPM)approach to mosquito control,we use methoprene(a juvenile growth-hormone mimic)as our frontline operational larvicide for salt marsh mosquito control,in spraying thousands of acres of Delaware's coastal wetlands with Altosid up to several times each summer(with our primarily using the A.L.L. 20% Concentrate formulation),including extensively using Altosid on Delaware's two National Wildlife Refuges.We find that Altosid gives us effective control achieved in practicable manner,and to the best of our knowledge does not have any unacceptable non-target impacts or environmental problems. Methoprene Use In Freshwater Wetlands—We also use methoprene for control of freshwater mosquitoes in stormwater management basins and constructed wetlands,often using some type of extended release formulation for this product in these settings,which similar to our salt marsh use also gives us effective control without any unacceptable side effects. (11) Response to Comment 11. Thank you for your comments on the use of methoprene. However, lacking any qualification on what is meant by "to the best of our knowledge"or "unacceptable side effects"we cannot make decisions on the use of methoprene based on these testimonials. Comment 12. [My] Only comment is on the BMP page eleven last paragraph,with the sentence that begins with"Methoprene can be used on older larval stages and for...to late to use either Bacillus or methoprene..." seems to say methoprene can be used when its too late to use methoprene??????? What gives? (14) Response to Comment 12. It was a typo. Thanks for catching it. The text has been corrected to read: Methoprene can be used on older larval stages (i.e.,pupa),and for situations where it is too late to use either Bacillus thuringiensis israelensis or Bacillus sphaericus, a monomolecular film might be used. Comment 13. Statement in the draft "Ecology proposes to continue to restrict the areas of application of •methoprene." But then ecology goes on to say, "they will initiate a monitoring strategy to document Best Management Practices for Mosquito Control C-9 Washington State Department of Ecology concentration levels and if necessary,levels of toxicity to non-target species." The objective of monitoring will • be to provide data on methoprene for permit renewal in 2006. Response:This monitoring,should it take place, SHOULD take place in the areas in question that are healthy frog environments now. Not some place that is already stressed for some other reason. And in monitoring the areas in question there will be records of methoprene application over the past years that will give some basis on where to start. And not take another twenty years in another location establishing a track record. And if monitoring is going to be done then it would seem that applications of methoprene should take place. Otherwise,what is going to be monitored? (15) Response to Comment 13. Comment noted. We will take your comments into consideration as we develop the monitoring plan. Comment 14. Calling your attention to the California draft fact sheet,written by the California State DOE, page 7,par 4, "USEPA has concluded that,used in mosquito control programs,methoprene does not pose unreasonable risks to wildlife or the environment." Now granted,each state can say and do whatever they want. And it is certain California has endangered species. But decisions being made in California are made on sound,current research. (15) Response to Comment 14. Decisions made in California are reviewed for relevancy to our program. Their control operations and monitoring results will be included in our SEPA evaluation. Comment 15. It was stated in the [WDFW] comments, "there are studies that have found developmental effects to amphibians when methoprene was applied at mosquito control treatment levels and there are studies that have not observed this." Response:Those studies that showed negative effects should be produced for review in this decision making process. And the studies must be the most current up to date studies. And not • studies that are old and have been disproved. At the meeting in Olympia on 5 March'04,industry presented, once again,the current facts on methoprene. With even newer studies done by OSU.And WSFW said, "we still have questions." When asked what are your questions the reply was, "we don't know." However,at least after three years WSFW and DOE are listening to the mosquito districts when they say,methoprene cannot be found or monitored for;only the effects can be monitored. (15) Response to Comment 15. See response to Comment 2. The SEPA evaluation and monitoring plan for methoprene have been proposed to clear up some of these ambiguities regarding the developmental toxicity of methoprene to non-target species. Comment 16. The most recent information is from Oregon,where ponds have been treated with methoprene and heavily monitored for the past several years. In over ten prior years of methoprene application and close inspection of populations,there has been no evidence of malformations. A recent discovery of infected snail populations,which harbor the deformity-causing trematodes,was a premonition of a deformity outbreak and further confirms that trematodes are to be strongly linked with these deformities,not methoprene. The newness of this information is encouraging and is a dose geographic example of how deformities in the amphibian population are not related to methoprene. This should be taken into consideration as the BMP is revised another time. (19) Response to Comment 16. Ecology would be interested in reviewing the Oregon studies. Please forward any contact information you may have. • C-10 Best Management Practices for Mosquito Control Washington State Department of Ecology Comment 17. If the proposed methoprene restriction is related to an absence of long-term testing and environmental impact studies,Wellmark requests to review the documentation that Washington is using for the long-term studies on other larvicide and adulticides products. (19) Response to Comment 17. Please see response to Comment 2. Comment 18. As mentioned in the meeting,many mosquito districts are influenced by decisions from other parts of the nation when it comes to restrictions on products. If the best management practices document continues to have restrictive language for methoprene,we will want a complete explanation for the decision so that other states can have a thorough understanding of Washington's position-how it is solely related to Washington State endangered species issues and not for the use of methoprene in general. (19) Response to Comment 18. Ecology's restriction of methoprene is solely related to Washington state endangered species issues and not for the use of methoprene in general. General use is not restricted beyond the FIFRA label. Preemptive use of biocides, including methoprene, is recommended in the BMP to minimize mosquito breeding sites and the need to use more toxic insecticides in the event of a disease outbreak. Further, Ecology did not assess the harm posed by methoprene to endangered species sufficient to warrant restricted use when a human health threat exists. Also see response to Comment 2. Comment 19. To date,the comments that we have reviewed and those that have been previously missing are overwhelmingly in methoprene's favor,submitted by professionals who have used the products for many, many years without environmental incident. Why is there no impact,reduction or deletion of the restriction language,or are these comments to be ignored? (19) OResponse to Comment 19. Our responses largely address those comments that are based in fact or law. The preponderance of users of a pesticide does not constitute its lack of adverse effects because oftentimes the causes of adverse effects and correlations are difficult and costly to determine. Also see response to Comment 2. Larvicide Preferences Comment 20. After reviewing the BMP I would like to state that I believe that many improvements have been made and it is now a more concise and user friendly guide. I commend you for taking out the larvicide hierarchy wording that was present before. I believe that there is still a preference indicated,but an effort has been made to clarify that a particular larvicide will not work best(or at all)in certain situations. (6,7,8,9,10, 13) Response to Comment 20. We agree. The language has been further clarified. Permit Condition S1.A.4 now reads: 4. Authorized pesticides are: ➢ Bacillus thuringiensis israelensis (Bti) ➢ Bacillus sphaericus (H-5a5b) ➢ Methoprene Granular, Liquid, Pellet, or Briquette. ➢ Monomolecular Surface Films ➢ Paraffinic white mineral oil. Paraffinic white mineral oil shall not be used in waters of the state unless: a. The mosquito problem is declared a public health risk,or b. The other control agents would be or are known to be ineffective at a specific treatment site,and • Best Management Practices for Mosquito Control C-11 Washington State Department of Ecology c. The water body is non-fish-bearing (consult Washington State Fish and Wildlife concerning fish and wildlife). *Use of methoprene is not restricted for use beyond the FIFRA label in more than 99% of the State. However, methoprene is restricted in areas designated by Washington State Department of Fish and Wildlife (see Appendix A) except when a health threat exists in those areas as determined by state and local health departments. Comment 21. I have a current label of Malathion 8 Spray produced by Wilbur-Ellis Co.with an EPA Reg. # 2935-83-ZA. The label states: "Mosquito Larvae: Apply 8 fluid ozs. per acre to standing water (intermittently flooded areas, stagnant water,temporary rain pools). Broadcast use only over intermittently flooded areas. Application may not be made around bodies of water where fish or shellfish are grown and/or harvested commercially." I am not saying that I want to use this all the time. I am not saying that I would use it at all. I did not use it as a larvicide this year,but it is registered and as long as it is,it should be left available to use at least in case of emergency without having to go through all the bureaucracy that can occur. The more products are available the more effective,including cost effective,we will be. (5,8,11,12,13) Response to Comment 21. Section S1, of the permit has been revised to allow the use of larvicides based on effectiveness and situation rather than just toxicity. According to Steve Foss, Pesticide Management section of WSDA, larvicides containing the active ingredients of malathion or temephos are not likely to be needed due to pesticide resistance or in cases of an emergency. However, larvicide products containing temephos are needed in areas with high organic content, such as wet manure fields and lagoons because the other larvicides permitted for use are often ineffective in these areas. In addition, manure fields and lagoons typically do not drain to surface waters. When surface waters are not affected monitoring will not be required. Malathion may be applied under . I an experimental use permit, so it remains in the tool box. Permit Condition S1,proposed modification: 5. Temephos may not be used in lakes, streams, or the littoral zone of water bodies or on state- listed specie sites listed in Appendix A of the BMPs, (Ecology publication 03-10-023). The use of temephos shall be allowed only in highly-polluted water(i.e. tire piles)or waters with high organic content(i.e.manure holding ponds and pastures with no surface water runoff), or under either of the two following conditions: a. As a result of consultation between the Departments of Agriculture and of Ecology in response to the development of pesticide resistance or ineffectiveness within a population of mosquitoes. When temephos is applied to areas draining to surface waters monitoring of persistence and residues are a condition of the approval. Temephos must be rotated with one or more of the approved alternatives with a different mode of action to minimize the development of resistance. b. As a result of consultation between the Department of Health and Department of Ecology in response to the development of a human health emergency as determined by the Washington State Department of Health. 6. Other pesticides may be applied in the context of a research and development effort under the jurisdiction of the Washington State Department of Agriculture through the issuance of a Washington State Experimental Use Permit. • C-12 Best Management Practices for Mosquito Control Washington State Department of Ecology Comment 22. In the Permit,Condition S4.A.2.The phase,"in the order of preference in which they should be considered" should be changed to, "may be considered." (7,8) Response to Comment 22. Agreed. The Permit now states: S4.A.2. The IPMP shall consider the approved list of pesticide-based controls found in Section S1. Comment 23. Page 9 of the Permit,Condition S4. A. 1.contains the phrase, "except in response to documented" should be replaced with"to minimize the". Resistance is very difficult to document. Resistance management is part of an effective IPM plan. (7,8) Response to Comment 23. Ecology met with WSDA over this language because resistance is difficult to document. The Permit language now states: S4.A.1. In the IPMP,pesticides that are effective in controlling the mosquito population and have the least adverse impacts to nontarget species shall be used except in response to documented development of resistance or in cases of ineffectiveness or in a declared public health emergency. Bio-controls Comment 24. Use of Appropriate Bio-controls (p. 2 of the BMP) states,"Stock water gardens that have no surface inlet or outlet with mosquito-eating fish(i.e., goldfish,mud minnow,stickleback,and perch). Tadpoles, dragonfly larvae,diving beetles,back swimmers,and front swimmers also prey on mosquito larvae. For more information,see htt2://�-vvw.wa.gov/wdf-*A,/factshts/­westiiilevii-tis.htni" *'This website has changed: http://`Nw-�v.wdfw.wa.gov/factshts/westrliievirus.htm,is the current site address. However, at this website,it only mentions birds and bats as natural predators for mosquitoes. I do not question the idea that the animals that you listed will feed upon mosquitoes(larvae or adult),but I think it is extremely misleading to imply that efficient control can be achieved with organisms like birds,bats, tadpoles,diving beetles,etc. More importantly,the website you are asking people to go does not appear to back up the limited claim for bird and bat control with any scientific evidence. (6) Response to Comment 24. Thank you for the updated link. Use of bio-controls may or may not yield sufficient control, efficacy was not meant to be implied. Of concern is that goldfish and other predacious bio-controls may escape into natural water bodies where they could become invasive or problematic. Comment 25. In mosquito control plans put together by several other states,pesticides are listed and identified as biopesticides or traditional chemical pesticides. The benefits and limitations of each product are described. The applicator is free to choose the best fit for the situation. The EPA classifies Bti, Bacillus sphaericus,and methoprene all as biopesticides,thus putting them in the same category. Washington is the only state that separates out methoprene.When deciding which control agent to use,it is important to consider efficacy. "Methoprene has consistently proved to be one of the most effective insect growth regulators against mosquitoes and is usually more efficacious than biological control agents" (Glare,1999). The presence of pollutants,salinity,organic and inorganic particles can all reduce the efficacy of Bti. According to the Center for Disease Control (CDC),two factors that contribute to the spread of West Nile Virus (WNV)include abundance of vectoring species of mosquitoes and wide spread irrigation. Washington has both. The proposed BMPs do not follow CDC guidelines for mosquito control. The CDC recommends the ofse of larvicides in targeted locations in risk category one. The proposed BMPs wait until risk category four to Best Management Practices for Mosquito Control C-13 Washington State Department of Ecology recommend larvicide use. By this stage,the CDC has already recommended increased larval control and • intensifying adult mosquito control. (7,3,6,8,11,12,13,19) Response to Comment 25. We agree that bio-chemicals like the bacteria Bti and the growth hormone methoprene should be included in this category. The following language has been added to this section (p. 3)of the BMP to encourage preemptive chemical bio-controls where predators alone may not be effective. Minimization Actions Use Appropriate Bio-Controls ➢ Selective bio-pesticides such as Bacillus thuringiensis israelensis (Bti), B. sphaericus or methoprene are very effective preemptive controls when applied in the spring to specific sources identified by surveys. Amplifying and bridge vector species should be targeted (also see p. 11.). Comment 26. Page 11: The title, "Chemical Controls" is misleading. Bti,Bacillus sphaericus,and methoprene are all classified by the EPA as biopesticides. The title should reflect that this section includes biopesticides,oils and traditional pesticides. (7,8) Response to Comment 26. Agreed, the title has been changed to, "Microbial, Biochemical and Conventional Chemical Controls." Comment 27. Preemptive treatments (larviciding known breeding sites early in the season)may reduce the need for adulticiding later. (1,7) • Response to Comment 27. Agreed, preemptive larviciding with bio-chemicals has been added as an option under the breeding site minimization actions. Adulticiding Comment 28. I believe that the section giving a BMP for adulticiding is misplaced. I am unclear as to your implication of adulticiding applications needing a NPDES permit(unless you mean when directly affecting water). Also,I feel that if you admit you don't have jurisdiction in terrestrial applications of adulticides,then indicated the Best Management Practices for them seems inappropriate. This should be left up to the organization that has direct jurisdiction. In addition,Ecology's BMP states that there should not be any adulticiding done unless there is a disease present. (5,6,9) Response to Comment 28. A large majority of workshop attendees (October 14&15 in Moses Lake and October 21 in Lacey) wanted the adulticiding section left intact because it is an integral component of their integrated pest management approach to mosquito control. Treatment triggers are left to the mosquito control operator or the organizations they work for to determine. The BMP states: "Select triggers for the use of adulticide products:Some mosquito control districts recommend using light traps to monitor for mosquitoes. For example, Adams County MD recommends that counts of 8 to 12 mosquitoes caught in 12 hours or a 3 adult mosquito landing count per minute in a residential area triggers the need to adulticide (Thomas Haworth,personal communication, November 7,2003). Some applicators recommend adulticiding residential areas and upland areas where mosquitoes are migrating only when there is evidence of mosquito-borne • C-14 Best Management Practices for Mosquito Control Washington State Department of Ecology epizootic activity at a level suggesting high risk of human infection. The following are examples of this type of evidence:high dead bird densities;high mosquito infection rates,multiple positive mosquito species including bridge vectors;horse or mammal cases indicating escalating epizootic transmission, including bridge vectors, horse or mammal cases, or a human case with evidence of epizootic activity(p. 21)." In some instances, adulticiding can reduce or eliminate the need to heavily apply larvicides, can be used effectively with less environmental impact to non-targets, and can be cost-effective. So for this best practices plan, some information on commonly used products and methods are appropriately included. However, since there have been objections to the inclusion of this section we will more clearly identify Ecology's regulatory jurisdiction in those sections. To be sure, Ecology has no intention of over-stepping its regulatory bounds. Comment 29. Page 13 of the BMP states,"Terrestrially applied insecticides are NOT regulated under federal or state water pollution control laws and are not subject to NPDES permit conditions or requirements. However,in Washington State applications of insecticides used for adult mosquito control, even if they are labeled for use over water, i.e., streams, wetlands, rivers, lakes, ditches, etc, must be permitted under a Clean Water Act (NPDES) permit." *Please clarify;I am assuming that the preceding sentence is referring to when adulticides are used on,in or directly above water. Is this the intent of your sentence or are you stating the regardless of use,an adulticide must have a NPDES permit? If the latter is true this seems to be in direct conflict with the first sentence of section 7. If the former is true then this should be made clear in the BMP. (6) Response to Comment 29. The only time adulticide applications would have to be permitted is when they are applied, directly or indirectly, to waters of the state. Ecology's Water Quality Program does not permit the application of pesticides that are applied to terrestrial sites. However, the italicized language has been removed because it was confusing and most likely not needed. ` Comment 30. BMP minimum response does not consider DOH and or CDC guidelines,which consider targeted adult mosquito control by stating,"...adulticiding based on surveillance is an extremely important part of any integrated mosquito management program. (11) Response to Comment 30. See Response to Comment 5 and 9. Also, the section that discusses adulticiding describes the various triggers that may be appropriate. Dipping Criteria Comment 31. Could you clarify the dipping criteria for larviciding storm water ponds?The 2003 permit said larvicides could be applied if greater than 0.3 larvae/pupae per dip are found.The 2004 BMPs says 1 larva per 3 dips is the larviciding threshold.The 2004 permit says that greater than 1 larva per 3 dips is the larviciding threshold.With last year's criteria 1 larvae per 3 dips meant we could larvicide. Do we now need 2 or more larvae per 4 dips to larvicide? (22) Response to Comment 31. Only 1 larva per 3 dips is needed. Comment 32. Could we state in the permit that entities that did control the year before based on their surveillance don't necessarily have to wait for mosquitoes to appear again the following season before using control measures in that water body. This question came up last year from King County,who identified their water bodies that needed control and wanted to continue that control without having to do the surveillance all over again. I'm getting questions such as "We found mosquito larvae last year in this pond,can we apply the Best Management Practices for Mosquito Control C-15 Washington State Department of Ecology mosquito dunks as a preventative measure this year without doing the dipping all over? Does the permit allow this?" (20) 0 Response to Comment 32. The permit requires mosquito dunks prior to treatment unless the site is inaccessible (see response to comment 33 below). Mosquito breeding sites may change and there is no need to use larvicides if no larvae are present. Comment 33. Page C-5-Other references use 1 per 3 dips rather than 0.3 per dip. (3,13) Response to 33. Agreed. Section S4.B of the permit now states: "Pesticide applications shall not commence unless surveillance of a potential application site indicates a larva/pupa count of greater than 1 per 3 dips, or unless dead birds, infected horses, or adult mosquito surveys indicate the presence of vector mosquitoes when larvae counts cannot be made due to their inaccessibility. In these cases larviciding may be desirable or even necessary without the larvae dips." Miscellaneous Clarifications Comment 34. The following clarifications are suggested: Page 1- Add-Applications of pesticides are also subject to the Washington Pesticide Control Act(15.58 RCM the Washington Pesticide Application Act(17.21 RCW),the General Pesticide Rules (WAC 16-228),the Worker Protection Standard MAC 16-233),a number of pesticide and/or counts,specific regulations. Page 3-The heading"Eliminate Mosquito Feeding Sites" does not correspond to bullets beneath the heading. Suggest different heading such as "Personal Protective Measures" Page 4-Clarify that the use of larvicides is one of the Minimum BMP Responses to Minimize Mosquito Breeding and use of adulticides. Page 5-Amend Risk Assessment:Probability of outbreak in humans: Remote to low;areas with limited or sporadic WNV epizootic activity in birds and/or mosquitoes. Page 10. IV. Mosquito Control Treatments Use larvicides at specific locations when WNV epizootic activity is found in birds and/or mosquitoes. Page 11 -Amend heading to Microbial,Biochemical and Conventional Chemical Controls. Bacillus thuringiensis israelensis (Bti)and Bacillus sphaericus (H-5a5b)are microbial pesticides. Methoprene is a biochemical pesticide. Monomolecular surface films,paraffinic white mineral oil,and temephos are conventional chemical pesticides. Page 12-Amend web page reference to guide of larvicide products. For a guide to larvicides see the WSDA website: http://wti-A,.kellysolutions.com/WA/shoLAMroductsbvpest2.asp?Pest_ID=IOAMA AC04. • C-16 Best Management Practices for Mosquito Control Washington State Department of Ecology Page 13-Clarify insecticides listed in table 3 are for larvae control and not adulticides. (3,13) Response to Comment 34: All the comments were accepted and changes made to the BMP document except the WSDA web site address. The WSDA web site was not included because larvicides not permitted for use under this permit may be listed there and it would be confusing to list products not permitted for use. Comment 35. Page 12 of the BMP states, "Fish and game specialists and natural resources biologists (WDFW) must be notified of planned control measures whenever delicate ecosystems could be harmed by mosquito control practices.... Could you please clarify how to determine a"delicate ecosystem?" Is this a legal description? Is this only WDFW land? Clarification would be helpful. (6) Response to Comment 35. "Delicate ecosystems"are those that can only survive under a narrow range of environmental conditions including light, salinity, temperature, water quality, and nutrients, and are extremely vulnerable to anthropogenie activities. An airplane flying over nesting grounds demonstrates this sensitivity. The phrase was not used as legal terminology, but as plain English. Comment 36. The fact that it takes 38 days to obtain a license and permit to undertake mosquito control activities would likely inhibit a community to address an emergency health issue... (11) Response to Comment 36. The vast majority of permitted entities in Washington come under the Department of Health's coverage by contracting with them. It takes about a seven-day turn around to do that, largely because of mailing time constrains. It's conceivable to have the turnaround time reduced to a day or two in a real emergency. •Comment 37. Education of the public in the areas of mosquito habitat reduction and personal protection in and of itself is not protecting the public from disease as is implied in the draft document (11) Response to Comment 37. Personal protection is the best precaution anyone can take to ensure minimal exposure to mosquito borne diseases. If a person tries to kill every mosquito in a two-mile square area they will probably not succeed and when they leave that area they are exposed to increased risk again. The best insurance anyone has against mosquito borne disease is to eliminate the chance of exposure in their direct personal space. This is why Appendix B, Insect Repellent Use and Safety from the Center for Disease Control has been added to the document. It is an excellent informational source. Comment 38. An important component of the CDC guidelines is to include monitoring for the disease as well as monitoring for mosquito populations. (11) Response to Comment 38. The Washington State Department of Health is the lead on monitoring for the disease. Section 11 of the BMP directs mosquito control agents to their local health departments for questions and issues related to monitoring for the disease. Comment 39. What is going to constitute monitoring? Record keeping or actual testing? Please clarify. (5) Response to Comment 39. When the permit was issued, monitoring was intended to examine persistence of the insecticides used in Washington State. Since persistence data for the larvicides allowed for use already exists,possible adverse affects to non-target organisms, rather than persistence, will be monitored. Additionally, the arrival of the West Nile virus in Washington State, has resulted in many local governments and others new to mosquito control practices applying larvicides during the spring and summer months. These new control operations will result in a sharp increase to the amount of larvicide being applied to waters. For these reasons, the monitoring requirement will be modified to Best Management Practices for Mosquito Control C-17 Washington State Department of Ecology only require reporting the type, location, and quantities of larvicides used. Ecology will use this information to prepare a plan to monitor for possible adverse affects in areas targeted by the reporting results. Comment 40. We treat hundreds if not thousands of small ponds through out the season,many of which are less than one acre. If we report those small ponds as <1 acre our rate per acre will all off. My district tries to record each treatment whether 10 acres or.03 acre. (5) Response to Comment 40. Reporting in tenths or hundredths of an acre is more accurate and can be done on the current reporting form. We allow permittees to also 'clump'the acreage they treat in an area so if they treat ten small ponds that are.10 acre each, they can report it as one acre. This works so long as the ponds all drain to the same receiving water. Comment 41. Comment to draft: By adding the WSDA RCWs and WACs it would seem that now mosquito control operations are under FIFRA and federal label requirements and NOT second level government rule making.There are so many levels of government that ALL requirements will be difficult for the home owner and layperson to sort out. (15) Response to Comment 41. Ecology must be responsive to Court decisions. However, we agree and have petitioned EPA several times to consider streamlining these requirements for the benefit of operators/applicators. Comment 42. How will the comments be handled in this process?It seems they are as much questions as comments. Because all that happens in this process is a response is given to comments with no action taken. (15) Response to Comment 42. The comments are reviewed for basis in fact or law. Where inaccuracies or deficiencies are • found, they are corrected. Comment 43. This is the second modification in less than one year on the permit,how often will changes be made in the future? (15) Response to Comment 43. This is the last modification that will be made prior to permit renewal. Comment 44. I suggest adding"ecologically sensitive areas" to demarcated no-spray zones on maps(p.11 of the BMP). (16) Response to Comment 44. Agreed. The language has been added to the section: "Demarcate no-spray zones on maps. This may include areas such as schools,hospitals,fish farms, wildlife refuges,ecologically sensitive areas,the homes of individuals who are on chemically sensitive registers,and crops grown under a certified organic program." Comment 45. C1,Number 3,may cover this,but it would be nice to have this language in more detail somewhere. Could we put what water bodies should have permit coverage? The "waters of the state"catchall works to a certain point,but there seems to be confusion over the water bodies (i.e. storm drains with an outlet)that could reach"waters of the state." I have instructed folks that if their water body has the potential to reach waters of the state,they need permit coverage. If"waters of the state"includes water bodies that have a potential to reach waters of the state,we should try to make this very clear. I'm still obviously a little confused... (20) C-18 Best Management Practices for Mosquito Control Washington State Department of Ecology Response to Comment 45. The Department of Ecology's Aquatic Mosquito Control permit covers mosquito control activities that discharge insecticides directly into surface waters of the state of Washington. All who conduct mosquito control activities in water for communities, districts and private landowners are required to obtain coverage. "Waters of the state" includes water bodies that have a potential to reach waters of the state. References cited: Ankley,G.T.,J.E. Tietge,D.L. DeFoe,K.M.Jensen,G.W. Holcombe,E.J. Durham, and S.A. Diamond. 1998. Effects of ultraviolet light and methoprene on survival and development of Rana Pipiens. Environmental Toxicology and Chemistry 17:2530-2542. Degitz,S.J.,E.J. Durham,J.E.Tietge,P.A. Kosian,G.W.Holcombe,and G.T.Ankley. 2003. Developmental toxicity of methoprene and several degradation products in Xenopus laevis.Aquatic Toxicology 64: 97-105. Henrick,C.A.,J.K. Ko,J. Burleson,G. Lindahl. D. VanGundy and J.Edge. 2002. Investigation of the relationship between s-methoprene and deformities in anurans.J. of Am.Mosq.Control Assoc. 18(3):214-221. Johnson,C. M.,L.B.Johnson,J.Murphy and V.Beasly,Evaluation of the potential effects of methoprene and Bti on anuran malformations in Wright County, MN. National Resources Research Institute,University of Mn. NRRI technical report no. NRRI/TR-2001/01 La Clair,J.J.,J.A. Bantle and J. Dumont. 1998. Photoproducts and metabolites of a common insect growth regulator produce developmental deformities in Xenopus.Environmental Science and Technology 32: 1453- 1461. Ross,D.H,D.Judy,B.Jacobson,R.Howell. 1994 Methoprene concentrations in freshwater microcosms treated with sustained-release Altosid formulations. J. of Am. Mosq.Assc. 10(2):202-210. I • Best Management Practices for Mosquito Control C-19 Washington State Department of Ecology II• PERMIT NO: WAG—992000 Issuance Date: March 7, 2007 Effective Date: April 7, 2007 Expiration Date: April 7, 2010 AQUATIC MOSQUITO CONTROL NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM STATE WASTE DISCHARGE GENERAL PERMIT State of Washington Department of Ecology Olympia, Washington 98504-7600 In compliance with the provisions of the State of Washington Water Pollution Control Law Chapter 90.48 Revised Code of Washington as amended And The Federal Water Pollution Control Act as amended (The Clean Water Act) Title 33 United States Code, Section 1251 et seq. Until this permit expires, is modified or revoked, Permittees that have properly obtained coverage by this permit are authorized to discharge to waters of the state in accordance with the special and general conditions that follow. David C. Peeler, Manager Water Quality Program Department of Ecology 3 TABLE OF CONTENTS SUMMARY OF PERMIT REPORT SUBMITTALS........................................................ 5 SPECIAL PERMIT CONDITIONS................................................................................... 6 S1. PERMIT COVERAGE................................................................................................ 6 A. Activities Covered Under This Permit...................................................................... 6 B. Activities Excluded From Coverage Under This Permit .......................................... 6 C. Geographic Area Covered......................................................................................... 7 S2. PERMIT APPLICATION REQUIREMENTS............................................................ 7 S3. COMPLIANCE WITH STANDARDS....................................................................... 7 A. Temporary Modification of the Water Quality Standards........................................ 7 S4. RESTRICTIONS ON THE APPLICATION OF PRODUCTS .................................. 8 A. Authorized Discharges............................................................................................ 8 B. Products Authorized for Use Under This Permit.................................................... 8 C. Experimental Use Permits..................................................................................... 10 D. Restrictions on the Use of Certain Pesticides Under this Permit.......................... 10 S5. PUBLIC NOTICIFICATION PROCEDURES......................................................... 11 A. Public Notice......................................................................................................... 11 B. Posting Requirements ........................................................................................... 11 S6. MONITORING REQUIREMENTS.......................................................................... 11 ST SAMPLING AND ANALYTICAL PROCEDURES ............................................... 12 S8. REPORTING AND RECORDKEEPING REQUIREMENTS................................. 12 S9. BEST MANAGEMENT PRACTICES/INTEGRATED PEST MANAGEMENT .. 13 S 10. COMPLIANCE SCHEDULE ................................................................................. 15 S l 1. CONDITIONAL APPROVAL FOR THE USE OF PRODUCTS NOT ............... 15 A. Product Approval.................................................................................................. 15 B. Public Notification Procedures............................................................................. 16 C. Approval of a New Product.................................................................................. 16 S12. APPENDICES........................................................................................................ 16 GENERALCONDITIONS .............................................................................................. 17 G1. DISCHARGE VIOLATIONS................................................................................... 17 4 G2. PROPER OPERATION AND MAINTENANCE.................................................... 17 G3. RIGHT OF ENTRY.................................................................................................. 17 G4. NOTIFICATION OF CHANGE IN COVERED ACTIVITIES............................... 18 G5. REVOCATION OF COVERAGE............................................................................ 18 G6. GENERAL PERMIT MODIFICATION OR REVOCATION................................ 19 G7. REPORTING A CAUSE FOR REVOCATION OF COVERAGE.......................... 19 G8. TRANSFER OF PERMIT COVERAGE.................................................................. 20 G9. TOXIC POLLUTANTS............................................................................................ 20 G10. OTHER REQUIREMENTS OF TITLE 40 CODE OF FEDERAL ...................... 20 G11. COMPLIANCE WITH OTHER LAWS AND STATUTES.................................. 20 G 12. ADDITIONAL MONITORING REQUIREMENTS............................................. 20 G13. REMOVED SUBSTANCES .................................................................................. 21 G14. SIGNATORY REQUIREMENTS.......................................................................... 21 G15. REQUESTS TO BE EXCLUDED FROM COVERAGE ..................................... 22 G16. APPEALS ............................................................................................................... 22 G17. DUTY TO REAPPLY ............................................................................................ 23 G18. TERMINATION OF INDIVIDUAL PERMITS.................................................... 23 G19. TERMINATION OF COVERAGE UPON ISSUANCE ....................................... 23 G20. ENFORCEMENT................................................................................................... 23 G21. SEVERABILITY.................................................................................................... 23 G22. PAYMENT OF FEES............................................................................................. 23 APPENDIX A-DEFINITIONS AND ACRONYMS ..................................................... 24 APPENDIX B-STATE LISTED SPECIES RESTRICTED USE AREAS ................... 25 5 SUMMARY OF PERMIT REPORT SUBMITTALS Refer to the Special and General Conditions of this permit for additional submittal requirements. Permit Section Submittal Frequency First Submittal Date S8 Annual Monitoring Report Annually February 1, 2008 S8 Annual Treatment Reports Annually February 1, 2008 S9 Noncompliance Notification As necessary G4 Permit Application for Substantive As necessary Changes to the Discharge G8 Notice of Permit Transfer As necessary G14 Notice of Change in Authorization As necessary G17 Application for Permit Renewal 1/permit cycle September 7, 2009 6 SPECIAL PERMIT CONDITIONS S1. PERMIT COVERAGE This permit revokes and replaces the Aquatic Mosquito Control General Permit (WAG-992000). This permit does not cover the control of adult mosquitoes using adulticides. A. Activities Covered Under This Permit All applicants of pesticide for control of pre-adult life stages of mosquitoes shall obtain coverage under this permit when the activity involves the direct discharge of pesticides into surface waters of the state of Washington. Mosquito districts and other pesticide applicators shall obtain coverage under this general permit to control pre- adult life stages of mosquitoes when applications are planned for any of the following: 1. Into water bodies that are contiguous with rivers or streams. 2. Into navigable waters of the state. 3. In other situations as determined by the Department of Ecology (Ecology). B. Activities Excluded From Coverage Under This Permit Applicators of pesticides need not obtain coverage under this permit for applications made to the following types of waterbodies: 1. Man-made detention or retention ponds designed specifically for wastewater or stormwater treatment that do not have an outlet to surface waters of the state, or ponds that are not likely to discharge during or for two weeks after treatment. 2. Any constructed water body* five acres or less in surface area with no discharge to other surface waters of the state during or for two weeks following treatment. 3. Upland farm ponds with no discharge to surface waters of the state. 4. Water bodies when the applicant conducts research covered under a state experimental use permit(less than one acre in size). Words in bold typeface are defined in Appendix A—Definitions and Acronyms 7 C. Geographic Area Covered This general permit covers aquatic mosquito control activities anywhere in the state of Washington. S2. PERMIT APPLICATION REQUIREMENTS A. Existing Permittees, existing mosquito control districts, and applicators with current mosquito control programs requesting coverage shall notify Ecology by submitting a completed application for coverage no later than 180 days prior to the expiration of the current permit. B. New Permittees, mosquito control districts, and applicators that propose to begin activities that will result in a discharge or potential discharge to waters of the state on or after the effective date of this general permit shall: 1. Notify Ecology by submitting a completed notice of intent [NOI] form at least 60 days prior to the planned activity that will result in the discharge to waters of the state. 2. Publish two times, each one week apart, in a local newspaper of general circulation a notice that an application for coverage has been made pursuant to Section 173-226-130(5) WAC. a. This notice shall specify that a thirty-day comment period exists prior to the issuance of permit coverage. b. At the end of the thirty-day comment period, Ecology will review all comments received prior to making a determination on whether to grant permit coverage. c. Ecology intends to notify new applicants by mail of their status concerning coverage under this permit. If the applicant does not receive notification of the coverage decision from Ecology, coverage under this permit will commence on the 6 1"day following Ecology's acceptance of a completed application form. S3. COMPLIANCE WITH STANDARDS A. Temporary Modification of the Water Quality Standards 1. WAC 173-201A-410 allows short-term modification of the criteria and classifications established by this regulation so long as certain conditions are met. Such activities must be conditioned, timed and restricted in a manner that will minimize water quality degradation to existing and characteristic uses. 8 2. This permit allows the application of products to control mosquito larvae only so long as the applicant meets all the terms and conditions of this permit, and the transitory water quality impact is limited to the vicinity of the product application and limited to the minimum time necessary to accomplish the desired aquatic mosquito control objectives. 3. The application of products authorized by this permit shall not cause long-term harm to the environment. 4. The Permittee shall ensure that the short-term water quality modification is limited to hours, days, or weeks for a specific pesticide application authorized under this permit. In the event that multiple treatments occur over the life of the permit, the total time of the short-term modification for all treatments shall not exceed one year. S4. RESTRICTIONS ON THE APPLICATION OF PRODUCTS A. Authorized Discharges 1. The Permittee shall ensure that all discharges and activities authorized by this permit are consistent with the terms and conditions of this permit. 2. The Permittee shall apply pesticide under this permit only for the control of pre- adult mosquitoes. 3. Beginning on the effective date of this permit, the permittee is authorized to discharge the aquatic pesticides that are listed in this permit into surface waters of the state, subject to compliance with the Federal Insecticide,Fungicide, Rodenticide Act (FIFRA) and the Washington Pesticide Control Act, and in consideration of integrated pest management options. 4. Ecology may order temporary suspension of permit conditions, with agreement of a state or local health officer, to protect public health. B. Products Authorized for Use Under This Permit 1. This permit allows application of the following listed pesticides that are labeled for use on aquatic sites and any other registered pesticides after they are approved through Ecology's approval process (see Section S11) if the Permittee applies the pesticide in compliance with all the terms and conditions of this permit: a. Bacillus sphaericus (H-5a5b) 9 b. Bacillus thuringiensis israelensis(Bti) c. Methoprene d. Monomolecular surface films e. Paraffinic white mineral oil. Paraffinic white mineral oil shall not be used in waters of the state unless: i. The Department of Health declares the mosquito problem a public health risk; or ii. The other control agents would be or are known to be ineffective at a specific treatment site and the water body is non-fish-bearing (consult Washington State Department of Fish and Wildlife). 2. The Permittee shall not apply temephos in lakes, streams, in the littoral zone of water bodies, or on state-listed species sites listed in Appendix B of this permit. The permit allows the use of temephos only: a. In highly polluted water(i.e., tire piles), or b. In waters with high organic content (i.e., manure holding ponds and pastures) with no surface water runoff, or c. In response to the development of pesticide resistance or ineffectiveness within a population of mosquitoes, as a result of consultation between Ecology and the Department of Agriculture (WSDA). i. If a permittee applies temephos to areas draining to surface waters, then the permittee shall monitor for persistence and residues. ii. The Permittee shall rotate the use of temephos with one or more of the approved alternatives with a different mode of action to minimize the development of resistance. d. In response to the development of a human health emergency as determined by the Washington State Department of Health (DOH) and after consultation between Ecology and DOH. 3. The Permittee may only apply malathion after consultation between Ecology and DOH and in response to the development of a human health emergency as determined by DOH. 10 C. Experimental Use Permits 1. The Permittee may apply other pesticides on a limited basis in the context of a research and development effort under the jurisdictions of the Environmental Protection Agency(EPA)and WSDA through the issuance of a Federal Experimental Use Permit. 2. Persons shall seek and obtain coverage under this general permit for any mosquito control projects conducted under a Federal Experimental Use Permit. 3. For projects of one acre or less in size, the applicant shall obtain coverage under a State Experimental Use Permit and coverage under this general permit is not required. D. Restrictions on the Use of Certain Pesticides Under this Permit 1. This permit restricts the use of methoprene, monomolecular surface film, Paraffinic white mineral oil, malathion, and temephos in the areas identified by the Washington Department of Fish and Wildlife (WDFW) in Appendix B of this permit. 2. The Permittee shall not apply methoprene, monomolecular surface film, Paraffinic white mineral oil, malathion, and temephos in the areas identified in Appendix B unless local and state health authorities discover and acknowledge a public health threat and issue an emergency health declaration. 3. If an emergency health declaration is issued,the following things must occur: a. Permittees shall consult with WDFW(Regional Wildlife Program Manager) during annual pre-control season planning. b. Permittees shall consult with WDFW during the control season when anticipating restricted pesticide use in these areas to affirm/update areas and define any areas of highest sensitivity. C. Permittees shall use Best Management Practices to minimize potential impacts and unnecessary applications of restricted use pesticides into water in restricted areas. (e.g. control to the extent possible with Bti and Bs before using restricted products, apply drift control methods, minimize application rates, use backpack application techniques when feasible, etc.) 11 S5. PUBLIC NOTICIFICATION PROCEDURES A. Public Notice 1. For expected applications of pesticides that have a water-use restriction (currently applies only to malathion, temephos, and Paraffinic white mineral oil), the Permittee shall publish a public notice in a local newspaper of general circulation (or nearest regional paper if a local newspaper does not exist). 2. The Permittee shall publish the public notice at least ten days prior to the first pesticide application of the season. This notice shall include: a. The pesticide(s)to be used and its active ingredient(s). b. The approximate date range of treatment. C. The approximate location(s) to be treated. d. The water use restrictions or precautions. e. The posting procedure. f. The names and telephone numbers of the applicator and the appropriate Ecology regional office. 3. The Permittee's notification to the public regarding mosquito control activities shall continue throughout the treatment season if pesticide applications occur. After the initial newspaper notice, notification may include a method other than notices in the newspaper, such as website posting or mailings. B. Posting Requirements 1. The Permittee shall post notices at all reasonable points of ingress and egress to the treatment areas when applying insecticides with water use restrictions to water bodies that are used for water supply, fish and shellfish harvesting, or water contact activities. 2. The Permittee need not post notices at sites that are not directly accessible to the public (i.e., catch basins, storm drains, utility and transportation vaults, etc.). S6. MONITORING REQUIREMENTS A. The Permittee shall meet the permit monitoring requirements by submitting complete larvicide application quantities as required in S&B. 12 B. If the Permittee chooses to monitor for efficacy or concentration, the Permittee shall follow sampling procedures outlined in ST S7. SAMPLING AND ANALYTICAL PROCEDURES A. EPA publishes laboratory analytical methods used by industries and municipalities to analyze the chemical and biological components of wastewater, drinking water, sediment, and other environmental samples that are required by EPA regulations under the authority of the Clean Water Act and the Safe Drinking Water Act. Most of these methods are published by EPA as regulations at 40 CFR Part 136 or in the latest revision of Standard Methods for the Examination of Water and Wastewater(APHA). The Permittee shall use an EPA method when conducting monitoring in compliance with this permit. B. With the exception of dipping, the Permittee shall ensure that all applicable monitoring data be prepared by a laboratory registered or accredited under the provisions of Chapter 173-50 WAC, Accreditation of Environmental Laboratories. Larvicide efficacy testing, larvae count research and analyses, and other related research are not considered monitoring for the purposes of this permit. S8. REPORTING AND RECORDKEEPING REQUIREMENTS The Permittee shall submit pesticide application information in accordance with the following conditions. The falsification of information submitted to Ecology shall constitute a violation of the terms and conditions of the permit. A. Annual Report 1. The Permittee shall submit reports summarizing pesticide applications by February 1st of each year. 2. These reports shall include: a. The name of the location treated (i.e., Sammamish Golf Club, City of Tacoma storm drain system, etc.). b. The chemical name, and c. The amount applied. 3. The Permittee shall sum the amount of each product applied at each site, identified location or system. 13 4. The Permittee shall submit this report electronically through Ecology's online data management system. B. Dip Records 1. For those treatments requiring dip samples to be taken, the Permittee shall record the: a. Date and place dipping occurred; b. The individual or contracted firm that performed the sampling or measurement; and c. The larvae counts of the dip sample. 2. The Permittee need not submit this information as part of the annual report, but shall make the information available upon request by Ecology. S9. BEST MANAGEMENT PRACTICES/INTEGRATED PEST MANAGEMENT A. Planning Options 1. The Permittee shall implement either: Ecology's Best Management Practices (BMP) document (Ecology publication#03-10-023), or an Integrated Pest Management Plan(IPMP)that has been approved by Ecology(See compliance schedule in S 10). The IPMP may include a decision tree outlining control options based on site and infestation conditions. 2. In the IPMP, the Permittee shall specify pesticides that are effective in controlling the mosquito population and have the least adverse impacts to non-target species, except: a. In response to documented development of resistance, b. In cases of effectiveness, or c. In a declared public health emergency. 3. The IPMP shall evaluate the approved list of pesticide-based control identified in S4.13.1, 2, and 3. 4. If developing an individual IPM plan, the Permittee shall consult with appropriate local, state, and federal agencies as necessary. 14 B. Open Accessible Areas 1. The Permittee shall not apply pesticide to open accessible areas unless the Permittee meets one of the following conditions: a. Surveillance of a potential application site indicates that at least one larvae/pupae is present in one of three dips; b. The Permittee has developed and obtained Ecology approval of a sampling protocol for large sites prior to treatment; or c. The application site is located either in or adjacent to a county in which mosquito, bird, animal, or human mosquito-borne disease cases are confirmed within the current treatment season. 2. In the event that larvae are found in an open accessible areas and the area is treated, the Permittee may continue larvicide treatments preemptively without dipping for the remainder of the treatment season. C. Water Supply, Conveyance,Drainage, or other Restricted Access Systems The Permittee shall not apply pesticides to regional water supply, conveyance, drainage, or other restricted access systems,unless one of the following occurs: 1. The Permittee has conducted representative sampling in the area and the sampling results indicate the presence of mosquito larvae; 2. The Permittee has developed and obtained Ecology approval of a sampling protocol for large sites prior to treatment or; 3. The application site is located either in or adjacent to a county in which mosquito, bird, animal, or human mosquito-borne disease cases are confirmed within the current treatment season or; 4. The treatment site is a catch basin, storm drain, utility or transportation vault, or 5. A public health emergency is declared by local and state health authorities. D. Spill Cleanup Requirements The Permittee shall immediately report all pesticide spills to state and local authorities, and immediately cease treatment at the spill location until the spill is contained and cleanup has occurred. 15 510. COMPLIANCE SCHEDULE A. The Permittee shall submit a copy of their developed IPMP (if this option is chosen) no later than February 1, 2008. B. The Permittee shall implement the IPMP for all aquatic pest control activities. C. If Ecology comments on the IPMP, the Permittee shall resubmit the IPMP with changes within six months of the receipt of comments. D. If Ecology requires the Permittee to resubmit the IPMP, and the planned treatment season has started, the Permittee may conduct treatments during the review period. 511. CONDITIONAL APPROVAL FOR THE USE OF PRODUCTS NOT SPECIFIED IN THE CURRENT PERMIT A. Product Approval This permit allows the use of products not specifically listed in S4.13 if the Permittee ensures that all of the following procedures are met prior to use: 1. Pesticides shall be approved for the specific use by EPA and/or WSDA. 2. Pesticides not specifically allowed for use under this permit shall undergo a risk assessment process prior to approval from Ecology. This risk assessment is an evaluation of the product, independent of the risk assessment performed by EPA during the registration process, and is intended to be more specific to Washington State concerns. The risk assessment shall: a. Be prepared by a qualified toxicologist. b. Include, at a minimum: i. Qualifications of the toxicologist(s)who prepared the risk assessment; ii. Verification that the product will meet the specified general conditions and prohibitions of this permit; iii. Information about human health effects from the product developed after the issuance of EPA's most recent risk assessment on the active ingredient; iv. A summary and assessment of the peer-reviewed literature concerning the product since the issuance of EPA's most recent risk assessment; 16 v. All available environmental and ecological information about the product and its environmental fate and effects; vi. Mitigation measures for the use of the product; and c. The Permittee shall submit the risk assessment and obtain Ecology's approval prior to use of the product. B. Public Notification Procedures After Ecology's approval of a risk assessment, Ecology will conduct public notification in the state register and make the notification available for posting on Ecology's website. The notice shall provide: 1. The chemical name and the brand name(s), 2. The expected uses of the product, 3. A summary of the expected environmental and human health effects, 4. Information about how to obtain copies of the risk assessment, and 5. Information about how to comment on the proposed use of the chemical within the 30-day comment period. 6. Comments submitted during this process should be submitted to: Aquatic Pesticide Specialist Department of Ecology, Water Quality Program P.O. Box 47600 Olympia, WA 98504-7600 C. Approval of a New Product 1. Based on any additional valid scientific information provided during the public comment period, Ecology may either grant, condition, or deny approval for the use of the new product. 2. Following approval, Ecology will modify this permit to condition the product's use. 512. APPENDICES The appendices are incorporated by reference into this permit and are subject to enforcement. 17 GENERAL CONDITIONS G1. DISCHARGE VIOLATIONS The Permittee shall be responsible for continuous compliance with the terms and conditions of this general permit. The Permittee shall be responsible for compliance with any order, directive, or penalty issued by Ecology. G2. PROPER OPERATION AND MAINTENANCE The Permittee shall at all times properly operate and maintain any facilities or systems of control to achieve compliance with the terms and conditions of the general permit. Where design criteria have been established,the Permittee shall not allow flows or waste loadings to exceed approved design criteria or approved revisions thereto. The permittee shall properly operate and maintain all application equipment to achieve compliance with the terms and conditions of the permit. The permittee shall not allow concentrations of the product(s)to exceed label or permit conditions. G3. RIGHT OF ENTRY The Permittee shall allow an authorized representative of Ecology, upon the presentation of credentials and such other documents as may be required by law, at reasonable times: A. To enter upon the permittee or sponsor's premises to which an effluent source (discharge) occurs or in which any records are required to be kept under the terms and conditions of this general permit; B. To have access to and to copy at reasonable costs, any records required to be kept under terms and conditions of the permit; C. To inspect any postings, monitoring equipment, or method of monitoring required in this general permit; and/or D. To sample any discharge of pollutants. If the sampling of influent or internal hatchery waters is necessary, the Permittee will be provided the opportunity to collect the required sample. 18 G4. NOTIFICATION OF CHANGE IN COVERED ACTIVITIES The Permittee shall submit a Change in Activities form to Ecology when a project activity changes significantly from what is currently listed on the permittees' application. G5. REVOCATION OF COVERAGE Pursuant to Chapter 43.21B RCW and Chapter 173-226 WAC, the Director may require any discharger authorized by this general permit to apply for and obtain coverage under an individual permit or another more specific and appropriate general permit. Cases where revocation of coverage may be required include,but are not limited to the following: A. Violation of any term or condition of this general permit. B. Obtaining coverage under this general permit by misrepresentation or failure to disclose fully all relevant facts. C. A change in any condition that requires either a temporary or permanent reduction or elimination of the permitted discharge. D. Failure or refusal of the Permittee to allow entry as required in RCW 90.48.090. E. A determination that the permitted activity endangers human health or the environment, or significantly contributes to water quality standards violations. F. Nonpayment of permit fees or penalties assessed pursuant to RCW 90.48.465 and Chapter 173-224 WAC. G. Failure of the Permittee to satisfy the public notice requirements of WAC 173-226-130(5), when applicable. Permittees who have their coverage revoked for cause according to WAC 173-226-240, as listed immediately above, may request temporary coverage under this permit during the time an individual permit is being developed,provided the request is made within 90 days from the time of revocation and is submitted along with a complete individual permit application form. 19 G6. GENERAL PERMIT MODIFICATION OR REVOCATION General permits may be modified, or revoked and reissued, in accordance with the provisions of Chapter 43.21B RCW and Chapter 173-226 WAC. Grounds for modification or revocation and reissuance include, but are not limited to, the following: A. When a change that occurs in the technology or practices for control or abatement of pollutants applicable to the category of dischargers covered under this general permit. B. When effluent limitation guidelines or standards are promulgated pursuant to the Federal Water Pollution Control Act or Chapter 90.48 RCW for the category of dischargers covered under this general permit. C. When a water quality management plan containing requirements applicable to the category of dischargers covered under this general permit is approved. D. When information is obtained, which indicates that cumulative effects on the environment from dischargers covered under this general permit are unacceptable. G7. REPORTING A CAUSE FOR REVOCATION OF COVERAGE A Permittee who knows or has reason to believe that any activity has occurred or will occur which would constitute cause for revocation under condition G6 or 40 CFR 122.62 shall report such information to Ecology so that a decision can be made on whether action to revoke coverage under this general permit will be required. Ecology may then require submission of a new Application for Coverage under this or another general permit or an application for an individual permit. Submission of a new application does not relieve the Permittee of the duty to comply with all the terms and conditions of the existing general permit until the new application for coverage has been approved. 20 G8. TRANSFER OF PERMIT COVERAGE Coverage under this general permit is automatically transferred to a new Permittee if- A. A written signed agreement between the old and new Permittee containing a specific date for transfer of permit responsibility and coverage is submitted to Ecology; and B. Ecology does not notify the old and new Permittee of its intent to revoke coverage under the general permit in which case the transfer is effective on the date specified in the written agreement between the old and new Permittee. G9. TOXIC POLLUTANTS The Permittee shall comply with effluent standards or prohibitions established under Section 307(a) of the Clean Water Act for toxic pollutants within the time provided in the regulations that establish those standards or prohibitions, even if this permit has not yet been modified to incorporate the requirement. G10. OTHER REQUIREMENTS OF TITLE 40 CODE OF FEDERAL REGULATIONS All other applicable requirements of 40 CFR 122.41 and 122.42 are incorporated in this general permit by reference. GI1. COMPLIANCE WITH OTHER LAWS AND STATUTES Nothing in the permit shall be construed as excusing the Permittee from compliance with any applicable federal, state, or local statutes, ordinances, or regulations. G12. ADDITIONAL MONITORING REQUIREMENTS Ecology may establish specific monitoring requirements in addition to those contained in this general permit by administrative order or permit modification. 21 G13. REMOVED SUBSTANCES Collected screenings, grit, solids, sludges, filter backwash, or other pollutants removed in the course of treatment or pollution control of wastewaters shall not be re-suspended or reintroduced to the final effluent stream for discharge to state waters. Such removed substances shall be lawfully disposed in an appropriate manner and shall comply with Chapter 173-303 WAC and Chapter 173-304 WAC. G14. SIGNATORY REQUIREMENTS All applications, reports, or information submitted to Ecology shall be signed and certified. A. All permit applications shall be signed by either a responsible corporate officer of at least the level of vice president of a corporation, a general partner of a partnership, the proprietor of a sole proprietorship or ranking elected official. For government entities, permit applications shall be signed by a manager or director, or their designee. B. All reports required by this permit and other information requested by Ecology shall be signed by a person described above or by a duly authorized representative of that person. A person is a duly authorized representative only if. 1. The authorization is made in writing by a person described above and submitted to Ecology. 2. The authorization specifies either an individual or a position having responsibility for the overall operation of a regulated facility, such as the position of plant manager, superintendent,position of equivalent responsibility, or an individual or position having overall responsibility for environmental matters. (A duly authorized representative may thus be either a named individual or any individual occupying a named position.) 3. For aquatic pesticide applications, the reports may be signed by either the sponsor or the applicator(s). C. Changes to authorization. If an authorization under paragraph 13.2. above is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, a new authorization satisfying the requirements of paragraph 13.2. above shall be submitted to Ecology prior to or together with any reports, information, or applications to be signed by an authorized representative. 22 D. Certification. Any person signing a document under this section shall make the following certification: "I certify under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiries of the person or persons who manage the system, or those persons directly responsible for gathering information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." G15. REQUESTS TO BE EXCLUDED FROM COVERAGE UNDER A GENERAL PERMIT Any discharger authorized by this general permit may request to be excluded from coverage under this general permit by applying for an individual permit. The discharger shall submit to the Director an application as described in WAC 173-220-040 or WAC 173-216-070, whichever is applicable, with reasons supporting the request. The Director shall either issue an individual permit or deny the request with a statement explaining the reason for the denial. G16. APPEALS A. The terms and conditions of this general permit, as they apply to the appropriate class of dischargers, are subject to appeal by any person within 30 days of issuance of this general permit, in accordance with Chapter 43.21B RCW, and Chapter 173-226 WAC. B. The terms and conditions of this general permit, as they apply to an individual discharger, are appealable in accordance with Chapter 43.2113 RCW within 30 days of the effective date of coverage of that discharger. Consideration of an appeal of general permit coverage of an individual discharger is limited to the general permit's applicability or nonapplicability to that individual discharger. C. The appeal of general permit coverage of an individual discharger does not affect any other dischargers covered under this general permit. If the terms and conditions of this general permit are found to be inapplicable to any individual discharger(s), the matter shall be remanded to Ecology for consideration of issuance of an individual permit or permits. 23 G17. DUTY TO REAPPLY Any Permittee receiving coverage for the length of this permit shall reapply for coverage under this general permit at least one hundred and eighty (180) days prior to the specified expiration date of this general permit. An expired general permit continues in force and effect until a new general permit is issued or until Ecology cancels it. Only those facilities that reapply for coverage are covered under the continued permit. G18. TERMINATION OF INDIVIDUAL PERMITS Any previously issued individual permit shall remain in effect until terminated in writing by Ecology, except that extension of an expired individual permit (pursuant to WAC 173-220-180(5)) shall terminate upon coverage under this general permit. G19. TERMINATION OF COVERAGE UPON ISSUANCE OF AN INDIVIDUAL PERMIT When an individual permit is issued to a discharger otherwise subject to this general permit, the coverage under this general permit for that Permittee is terminated on the effective date of the individual permit. G20. ENFORCEMENT Any violation of the terms and conditions of this general permit, the state Water Pollution Control Act, and the federal Clean Water Act, will be subject to the enforcement sanctions, direct and indirect, as provided for in WAC 173-226-250. G21. SEVERABILITY The provisions of this general permit are severable. If any provision of this general permit, or application of any provision of this general permit to any circumstance, is held invalid, the application of such provision to other circumstances and the remainder of this general permit shall not be affected thereby. G22. PAYMENT OF FEES The Permittee shall submit payment of fees associated with this permit as assessed by Ecology. 24 APPENDIX A - DEFINITIONS AND ACRONYMS All definitions listed below are for use in the context of this permit only. Adjacent: Something or someplace near, but not necessarily right next to something else. Applicant: The licensed pesticide applicator or any entity choosing to apply for permit coverage. Constructed water body:A human-made water body in an area that is not part of a previously existing watercourse, such as ponds, streams, wetlands, etc. Date range:A specific series of dates that anticipates the months of planned treatment. This is a planned range-it can be exceeded if public health concerns arise. Dipping: The act of scooping up a small amount of water and examining it for the presence/absence of mosquito larvae. Open accessible areas:Areas that are easily accessible by the public (e.g. wetlands, ponds, lakes, etc.) Qualified toxicologist:A person with a Ph.D in toxicology or in a health or ecological science with an emphasis in toxicology, or a person with a Master's degree in toxicology or a related science with an emphasis in toxicology, who is working in the field of toxicology. Representative sampling: In a large treatment area, the sites selected within that area that provide statistical significance (as determined by a statistician). Upland farm pond: Private farm ponds created from upland sites that did not incorporate natural water bodies (WAC 173-201A-260(3)f). Water supply, conveyance, drainage, or other restricted access systems: Restricted access areas that are accessible only through manholes or other means. Not readily accessible to the public (e.g. water, electrical or transportation vaults, storm drains, catch basins, etc.) Water-use restriction: This refers to any product labeled for restricted water use immediately after treatment(currently applies only to malathion, temephos, and Paraffinic white mineral oil). 25 APPENDIX B - STATE LISTED SPECIES RESTRICTED USE AREAS Criteria Used for the Restrictions The criteria WDFW used for denoting species as vulnerable were: 1) State species of concern (i.e., listed as state endangered, threatened, sensitive, or candidate). 2) Current range and distribution of the species was highly localized. 3) The species inhabited freshwater wetlands during most of the mosquito control treatment period. Six species initially met those criteria: northern leopard frog (Rana pipiens), Oregon spotted frog (Rana pretiosa), western toad(Bufo boreas), western pond turtle (Clemmys marmorata), American white pelican (Pelecanus erythrorhynchos), and one butterfly, the Yuma skipper(Ochlodes Yuma). WDFW identified areas occupied by the two extant populations of northern leopard frog; two extant western Washington populations of Oregon spotted frog; western toad breeding ponds (for western Washington only); the three remaining western pond turtle populations; the single American white pelican breeding colony; and the one known Washington Yuma skipper population. Based on the review of published literature, expert advice, and the vulnerability of these rare and endangered animals and their freshwater invertebrate food resources WDFW requested that if mosquito control is deemed necessary in the areas WDFW described in April 2003, that it be restricted to the use of Bacillus products. Aerial Applications An exception to the WDFW request regarding the use of certain larvicides was made for the single American white pelican breeding colony. The colony resides on islands and along the shores of the Columbia River, south of the confluence of the Snake River, in Walla and Benton counties. While bio- chemicals such as methoprene were not of concern for the pelican breeding colony, the method of aerial application was believed to be unacceptably disturbing for their successful breeding. It was agreed that aerial applications would not be made on the pelican breeding areas, whereas less obtrusive methods of mosquito control were acceptable near these sites. Discussions among several WDFW biologists found that aerial applications of larvicides disturbed work being done in a few wildlife refuge areas around the state. It was therefore agreed that operators making aerial applications over wildlife refuges should notify the appropriate regional WDFW office of their scheduled aerial applications at least 24 hours prior to spraying. The notification can be made by phone or fax. Area of Impact Only a few populations of northern leopard frog, Oregon spotted frog, western toad, western pond turtle, and Yuma skipper remain in Washington. The total area occupied by these species in rivers, lakes, ponds, and wetlands is tiny, comprising of portions of 117 sections (<O.18% of Washington State). The areas identified for northern leopard frog (36 Sections) and western pond turtle (13 Sections) are owned 26 or managed by WDFW. The Permittee shall take a prudent, risk-adverse with vulnerable threatened and endangered species. The following areas are restricted to the use of Bacillus thuringiensis israelensis (Bti) and Bacillus sphaericus (H-5a5b) an emergency health declaration is issued: 1) Grant County, north of Moses Lake,within the Crab Creek watershed: T21N R27E Sections 1, 12, and 13; T21N R28E Sections 7, 17, 18, 19, 28, 29, 30, 31, 32, and 33. 2) Grant County, south and west of Moses Lake and south of Interstate-90,the northern portion of the Potholes: T19N R27E Sections 33, 34, 35, and 36; T19N R28E Sections 31 and 32, 29,30; T18N R27E Sections 1, 2, 3, 4, 8, 9, 10, 11, 12, 13, 14, 15, and 16, 17; T18N R28E Sections 5, 6, 7, 8, 17, and 18. 3) Grant County, area within and near the Sun Lakes-Dry Falls State Park wetlands: T24N R27E and 28E. 4)Kitsap County: lakes, ponds, and wetlands located in T22N R I W Sections 1, 2, 10, 11, and 12. 5)Klickitat County,west of the Klickitat River, all waters in UN R12E Sections 28, 29, 32, and 33. 6) Mason County, on the Kitsap Peninsula: lakes, ponds, and wetlands located in T23N R2W Sections 11, 12, 13, 14, 15, 22, and 23. 7)Pierce and Kitsap counties, Carney Lake, located in T22N R1W. 8) Pierce, Thurston, and Lewis counties, within the Nisqually River watershed: Alder Lake (or Alder Lake Reservoir), located in townships: T15N R4E and 5E. 9)Pierce County, south of Tacoma, Chambers Creek and associated waters in T20N R2E Sections 26 and 27. 10) Skamania County, east of Carson, all waters in UN R8E Sections 23, 24, 25, 26, and 36; UN R9E Sections 30 and 31. 11)Thurston County, west of Yelm: lakes,ponds, and wetlands located in T 17N R1 E Sections 8, 9, 16, and 21. 12) Thurston County, south of Olympia and east of Interstate-5,within the Black River watershed,the Beaver Creek drainage, located in T16N R2W Sections 9, 10, 11, and 27 12; T16N R I W Section 7. 13) Thurston County, south of Olympia and west of Interstate-5,within the Black River watershed: Black River proper from south of Black Lake to the Chehalis Riverconfluence, and the following tributaries, Stony Creek, Dempsey Creek, SalmonCreek, and Blooms Ditch. Legal description as follows for these sensitive areas: T17N R3W Sections 10, 11, 12, 13, 14, 15, 23, 24, 25, 35, and 36; T17N R2W Sections 7, 18, 19, and 30; T16N R3W Sections 2, 11, 14, 19, 20, 21, 22, 23, 30, and31; T16N R4W Sections 25, 26, 27, 31, 32, 33, 34, 35, and 36. Addendum to Fact Sheet On November 21, 2006,the Environmental Protection Agency (EPA) issued a final rule entitled"Application of Pesticides to Waters of the United States in Accordance with FIFRA."This rule replaces a draft interpretive statement issued by EPA in 2003 concerning the use of pesticides in or around waters of the United States. The rule states that any pesticide meant for use in or near water that is applied in accordance with the EPA-issued FIFRA label, is not a pollutant under the Clean Water Act. Therefore such applications are not subject to NPDES permitting. The rule has now been appealed in 11 of the 12 federal circuit courts that are able to hear regulatory arguments. After EPA issued the rule, Ecology met with stakeholders to seek input on how Ecology should regulate use of aquatic pesticides. Ecology also provided the public with a three week comment period. Stakeholders affiliated with each of the seven affected permits (mosquito, noxious weeds, aquatic plants, irrigation, oyster growers, fish management, and invasive moth) sent comments to Ecology. The majority of comments requested that Ecology continue to issue joint NPDES/state permits to regulate aquatic pesticide applications. A pesticide applied to the water according to state law is a form of pollution. To apply a pesticide in the water, state law requires that the applicator obtain a short-term modification of the water quality standards from Ecology. Currently, the only legal vehicle for implementing that modification is a permit. State law only defines two types of permits for surface water discharges—National Pollutant Discharge Elimination System(federal) and State Waste Discharge (state). Until 2001, Ecology issued modifications using an administrative order. This process was challenged in court and is not a viable regulatory option at this time. Ecology decided that Washington will continue to use NPDES permits to control the use of aquatic pesticides in and around Washington state waters until the federal courts make a decision on the appeal of the EPA rule. These permits help the state protect human health and the environment by: • Ensuring pesticides with the lowest risk are used. • Reducing amounts of pesticides applied. • Tracking pesticide use. • Requiring public notifications and postings when waters are treated. • Monitoring levels of pesticides in the water after treatment. Ecology believes that these permits provide the best protection of water quality, human health, and the environment at this time. Ecology has taken steps to minimize the regulatory and administrative burden on permittees while ensuring that the permits comply with federal and state laws and court decisions. We will continue to follow the court proceedings surrounding the EPA rule and respond accordingly. Page 1 of 28 FACT SHEET FOR AQUATIC MOSQUITO CONTROL GENERAL NPDES PERMIT SA Fact Sheet For Aquatic Mosquito Control General NPDES Permit Page 2 of 28 TABLE OF CONTENTS Page SUMMARY....................................................................................................................................4 INTRODUCTION.......................................................................................................................... 5 BACKGROUNDINFORMATION............................................................................................... 6 MOSQUITOLIFE CYCLE............................................................................................................................7 PUBLICHEALTH IMPACTS.........................................................................................................................8 MANAGEMENT............................................................................................................................ 9 INTEGRATED PEST MANAGEMENT...........................................................................................................9 DESCRIPTION OF MOSQUITO CONTROL ACTIVITIES ..................................................... 10 MOSQUITOCONTROL PROGRAMS .......................................................................................................... 10 CRITERIA FOR COVERAGE UNDER THE GENERAL PERMIT.......................................................................11 BACILLUS THURINGIENSIS ISRAELENSIS(BTI): ...................................................................................... 11 BACILLUSSPHAERICUS:..........................................................................................................................12 METHOPRENE..........................................................................................................................................12 MONOMOLECULAR SURFACE FILMS ......................................................................................................13 LARVICIDALOILS....................................................................................................................................13 CHEMICAL LARVICIDES,ORGANOPHOSPHATES......................................................................................14 ENDANGEREDSPECIES........................................................................................................... 14 REGULATORY POLLUTION REDUCTION REQUIREMENTS............................................ 14 TECHNOLOGY BASED WATER QUALITY PROTECTION REQUIREMENTS ................................................15 WATER QUALITY BASED REQUIREMENTS..............................................................................................16 SEDIMENTQUALITY...............................................................................................................................17 SEPACOMPLIANCE................................................................................................................................17 RECEIVING WATER IDENTIFICATION......................................................................................................17 Eligibility and Geographical Area of Coverage.................................................................................18 BEST MANAGEMENT PRACTICES............................................................................................................18 OTHER PERMIT CONDITIONS................................................................................................ 19 MONITORING..........................................................................................................................................19 REPORTINGAND RECORDKEEPING.........................................................................................................19 LABACCREDITATION.............................................................................................................................19 SMALL BUSINESS ECONOMIC IMPACT ANALYSIS .............................................................................20 PERMIT MODIFICATIONS.........................................................................................................................20 WHEN COVERAGE IS EFFECTIVE............................................................................................................20 RESPONSIBILITY TO COMPLY WITH OTHER REQUIREMENTS.................................................................20 GENERALCONDITIONS...........................................................................................................................20 RECOMMENDATION FOR PERMIT ISSUANCE...........................................................................................21 APPENDIX A -- PUBLIC OPPORTUNITY TO COMMENT ................................................. 242 APPENDIXB -- GLOSSARY ..................................................................................................... 24 Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 3 OF 28 DEFINITIONS ...........................................................................................................................................24 APPENDIX C -- RESPONSE TO COMMENTS ........................................................................ 28 Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 4 OF 28 FACT SHEET FOR AQUATIC MOSQUITO CONTROL NPDES GENERAL PERMIT SUMMARY The State of Washington Department of Ecology(Department) has decided to issue a general permit for the application of pesticides to control mosquitoes in surface waters of the State of Washington. The use of pesticides is subject to the provisions of integrated pest management plans (IPMs). Monitoring is required in certain situations as determined by Ecology. Any short term toxicity to aquatic organisms is allowed under the terms of the permit and the water quality modification provisions to perform essential activities that protect public health. The proposed terms, limitations and conditions contained herein are tentative and may be subject to change, subsequent to public comments and testimony provided at public hearings. Activities not accepted under the general permit may be required to apply for an individual permit. Any application of pesticides to surface waters of the state requiring NPDES permit coverage that is not covered under either the general permit or an individual permit will be considered to be operating without a discharge permit and subject to potential enforcement action. In Headwaters, Inc. v. Talent Irrigation District, the Ninth Circuit Court held that applying an herbicide to navigable waters of the United States did not exempt the irrigation district from having to obtain an NPDES permit regardless of whether or not the irrigation district had applied the herbicide in accordance with the labeling requirements of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The EPA opened a public comment period in January 2005 on a proposed rule that would exempt the application of pesticides in aquatic settings from the Clean Water Act NPDES permitting requirements. However, the proposed rule has not been adopted. In September 2005, the Ninth Circuit Court issued its decision in Fairhurst vs. Hagener. The Fairhurst decision did not reverse the Talent decision, but did conclude that an NPDES permit is not required if a pesticide is intentionally applied to waters of the United States in accordance with a FIFRA label and with no residue or unintended effect. Neither the Court nor EPA has offered any guidance regarding what applications will result in no residue or unintended effect. Given the rulings from the Ninth Circuit Court and EPA's failure to finalize its proposed rule, most, if not all, aquatic applications of pesticides within the jurisdiction of the Ninth Circuit Court require NPDES permits. In February 2006, the Pollution Control Hearings Board (PCHB) issued a final order in case #05-101, Northwest Aquatic Ecosystems vs. Ecology, WTC. This case focused on a number of issues, one of which was whether or not an NPDES permit is required for the use of federally registered pesticides since the Ninth Circuit Court ruled in Fairhurst vs. Hagener. The Board ruled that: Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 5 OF 28 "Northwest Aquatic also renewed its summary judgment argument that the Board should rule NPDES permit coverage is not needed for the application of aquatic pesticides, when they are applied in accordance with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Northwest Aquatic bases this argument on the recent federal court decision in Fairhurst v. Hagener, 422 F.3d 1146 (9th Cir. 2005). The Board ruled on summary judgment that the Fairhurst decision does not provide a blanket exemption for the application of aquatic pesticides. Identified conditions must be met before a pesticide can be considered outside the category of a pollutant under the Clean Water Act. The pesticide must: (1)be applied for a beneficial purpose, (2) be applied in compliance with FIFRA, (3)produce no pesticide residue, and (4)produce no unintended effects. Fairhurst, 422 F.3d at 1150. Northwest Aquatic failed to provide any evidence specifically addressing how the use of diquat and endothall on the proposed sites would meet the four factors identified in Fairhurst. In the absence of such evidence,Fairhurst provides no basis for the Board to conclude a NPDES permit is not required for the proposed pesticide applications." INTRODUCTION This fact sheet is a companion document that provides the basis for issuance of the Aquatic Mosquito Control National Pollutant Discharge Elimination System(NPDES) State Waste Discharge General Permit. The Department of Ecology (Ecology) is proposing to issue this permit, which will allow discharge of wastes from aquatic pesticide applications to control mosquitoes in surface waters of the State of Washington,which are also waters of the United States, pursuant to the provisions of chapters 90.48, 90.52, and 90.54 Revised Code of Washington (RCW) and the Federal Water Pollution Control Act(FWPCA) as amended. This fact sheet explains the nature of the proposed discharges, Ecology's decisions on limiting the pollutants in the wastewater, and the regulatory and technical basis for these decisions. The Federal Clean Water Act (FCWA, 1972), and later modifications (1977, 1981, and 1987), established water quality goals for the navigable (surface) waters of the United States. One of the mechanisms for achieving the goals of the Clean Water Act is the National Pollutant Discharge Elimination System of permits (NPDES permits),which is administered by the Environmental Protection Agency (EPA). The EPA has delegated responsibility to administer the NPDES permit program to the State of Washington on the basis of Chapter 90.48 RCW which defines the Department of Ecology's authority and obligations in administering the wastewater discharge permit program. The establishment of a general permit for Aquatic Mosquito Control is appropriate due to the similar environmental fate specific to each permitted pesticide, the uniform discharge conditions to which all applications would be subject, the statewide scope of aquatic mosquito control, and the significant reduction of resources necessary for permit handling. However, individual permits will still be considered in those instances where a proposed activity requires more detailed guidance, or when an individual applicator so desires and Ecology approves. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 6 OF 28 The regulations adopted by the State include procedures for issuing general permits (Chapter 173-226 WAC), water quality criteria for surface waters (Chapters 173-201A WAC), and sediment management standards (Chapter 173-204 WAC). These regulations require that a permit be issued before discharge of wastes to waters of the state is allowed. The regulations also establish the basis for effluent limitations and other requirements which are to be included in the permit. One of the requirements (WAC 173-226-110) for issuing a general permit under the NPDES permit program is the preparation of a draft permit and an accompanying fact sheet. Public notice of the draft permit,public hearings, comment periods, and public notice of issuance are all required before the general permit is issued (WAC 173-226-130). The fact sheet and draft permit have been reviewed by representatives of the potential permittees and other members of a permit advisory group. Errors and omissions identified in this review have been corrected before going to public notice. After the public comment period has closed, Ecology will summarize the substantive comments and the response to each comment. The summary and response to comments will become part of the file on the permit and parties submitting comments will receive a copy of Ecology's response. The original fact sheet will not be revised after the public notice is published. Comments and the resultant changes to the permit will be summarized in Appendix C--Response to Comments. Y Larviciding with a backpack sprayer BACKGROUND INFORMATION A March 12, 2001 decision by the Ninth Circuit Court in Headwaters, Inc. v. Talent Irrigation District found that the applicator should have obtained coverage under a National Pollutant Discharge Elimination System (NPDES)permit prior to application of aquatic pesticides to an irrigation canal in Oregon. The canal discharged water into a creek where a fish kill occurred. The decision addressed residues and other products of aquatic pesticides. Headwaters, Inc. and Oregon Natural Resources Council filed a Clean Water Act citizen suit against the Talent Irrigation District (TID) for applying aquatic herbicide into a system of irrigation canals. Reversing a district court's opinion, the Ninth Circuit held that application of Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 7 OF 28 the pesticide in compliance with the labeling requirements of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) did not exempt TID from having to obtain a NPDES permit, and that the irrigation ditches were "waters of the United States" under the Clean Water Act. The Federal Insecticide, Fungicide, and Rodenticide Act of 1979 (FIFRA), as administered by the United States Environmental Protection Agency(EPA) and the Washington State Department of Agriculture, requires that all persons who apply pesticides classified as restricted use be certified according to the provisions of the act or that they work under the supervision of a certified applicator. Commercial and public applicators must demonstrate a practical knowledge of the principles and practices of pest control and safe use of pesticides, which will be accomplished by means of a "core" examination. In addition, applicators using or supervising the use of any restricted use pesticides purposefully applied to standing or running water(excluding applicators engaged in public health related activities) are required to pass an additional exam to demonstrate competency as described in the code of federal regulations as follows: "Aquatic applicators shall demonstrate practical knowledge of the secondary effects which can be caused by improper application rates, incorrect formulations, and faulty application of restricted pesticides used in this category. They shall demonstrate practical knowledge of various water use situations and the potential of downstream effects. Further,they must have practical knowledge concerning potential pesticide effects on plants, fish, birds, beneficial insects and other organisms which may be present in aquatic environments. Applicants in this category must demonstrate practical knowledge of the principles of limited area application." (40 CFR 171.4) Any person wishing to apply pesticides to waters of the state must either be licensed as an aquatic pesticide applicator by the Washington State Department of Agriculture, or operating under the supervision of a licensed applicator. For information on licensing requirements and testing,please visit hLtp://w4vw.a r wa.aov/PestFert/Licensiii E�; d/Licensing.htm. MOSQUITO LIFE CYCLE There are several species of mosquito that readily attack people, and some species are capable of transmitting microbial organisms that cause human diseases such as malaria and encephalitis. Mosquitoes from six genera are found in Washington and include Aedes, Anopheles, Culex, Culiseta, Coquilletidia, and Ochlerotatus. Mosquitoes are classified as Insects of the Diptera order. They undergo a complete metamorphosis, which involves four stages of development, egg, larva,pupa and adult. The first three stages occur in water, but the adult female is an active flying insect that feeds upon the blood of humans and/or animals. The female mosquito lays the eggs directly on water or on moist substrates that may later be flooded with water. The egg later hatches into the larva. This is the stage when most mosquito districts tend to focus control programs. During the larval stages it continues to feed and grow in size. The larvae go through four growth stages called instars. Once the larvae has developed to the fourth instar it stops feeding and pupates. This is a resting period. At this point the biological control (larvicide) no longer works as a control measure Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 8 OF 28 because it requires ingestion by the organism. Pupae can be killed by draining or emptying the water body, or using a monomolecular surface film or larvicidal oil. The larva transforms into the pupa where internal changes occur and the adult mosquito takes form. After a few hours to a few days in the pupal stage, the adult mosquito emerges from the water surface and seeks shelter in shady, moist areas. Adult mosquitoes must find shelter during the heat to avoid dehydration and most species are active during the hours from dusk to dawn. After a brief period of rest the adult female goes in search of a blood meal and the cycle continues. The time frame for this is highly variable anywhere from one to three weeks, depending on factors such as water temperature and food resources. The warmer the water the quicker the development will be. A very small amount of water in a container in warm weather can produce a batch of adult mosquitoes very quickly. Mosquito biology can follow two general scenarios. The first involves those species that lay their eggs in masses or rafts on the water's surface. Some of these species,which are found throughout the U.S., often lay their eggs in natural or artificial water-holding containers found in the domestic environment, or in naturally occurring pools. In summer the entire life cycle, from egg to adult, may be completed in a week or less. The second scenario involves Aedes mosquitoes that lay their eggs on moist soil or other substrates in areas that will be flooded with water later. After about two days, these eggs are ready to hatch, but if not flooded, can withstand drying for months and longer. In inland areas of the U.S. where these mosquitoes breed, heavy rains and flooding can produce millions of mosquitoes in a short time. Similar situations occur along coastal areas with mosquitoes adapted to salt marsh habitats. Some salt marsh mosquitoes are strong fliers and can sometimes travel up to 50 miles from the breeding site. PUBLIC HEALTH IMPACTS Female mosquitoes of nearly all species require blood from vertebrate animals to develop eggs, and many species bite people, pets, and livestock for this purpose. Mosquitoes are found throughout the world and many transmit pathogens which may cause disease. These diseases include mosquito-borne viral West Nile virus fever, encephalitis, dengue, yellow fever, malaria, and filariasis. Most of these diseases have been prominent as endemic or epidemic diseases in the United States in the past, but today, only the insect-borne (arboviral) encephalitides and West Nile virus fever occur annually and dengue occurs periodically in this country. The most important consequence of this is the transmission of microorganisms that cause diseases such as western equine encephalitis and St. Louis encephalitis. Both of these diseases can cause serious, sometimes fatal neurological ailments in people. (Western equine encephalitis virus also causes disease in horses.)Western equine encephalitis infections tend to be more serious in infants while St. Louis encephalitis can be a problem for older people. These viruses are normally infections of birds or small mammals. During such infections,the level of the virus may increase in these infected animals facilitating transmission to humans by Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 9 OF 28 mosquitoes. The West Nile virus, which can also cause encephalitis, was found in the northeastern United States for the first time in 1999, and is a good example of this mode of transmission. Over 20,000 human cases of West Nile virus have been reported in the U.S. Symptoms of human illness can range from mild flu-like symptoms to severe encephalitis, meningitis, or acute flaccid paralysis. Over 800 people have died from West Nile virus since its emergence here 7 years ago. Other pathogens transmitted by mosquitoes include a protozoan parasite which causes malaria, and Dirofilaria immitis, a parasitic roundworm and the causative agent of dog heartworm. Disease carrying mosquito species are found throughout the U.S., especially in urban areas and coastal or in inland areas where flooding of low lands frequently occurs. Even when no infectious diseases are transmitted by mosquitoes, they can be a health problem to people and livestock. Mosquito bites can result in secondary infections, allergic reactions, pain, irritation, redness, and itching. MANAGEMENT Mosquitoes are best managed on an area wide basis by public agencies that are either components of, or collaborating with, local health departments or are independent districts organized specifically for mosquito control. In Washington, there are approximately 16 mosquito control districts. Some are small and have responsibility for mosquito abatement in a few hundred square miles, while the activities of others may encompass one entire county or more. Mosquito control is accomplished by searching out mosquito larvae in standing water and treating the water with a material that kills the larvae. Many materials currently in use are biological in origin and are highly specific for mosquitoes, with little or no effect on other organisms. On occasion, mosquito abatement agencies may also apply chemical pesticides to kill adult mosquitoes,but ordinarily only when adult populations become so large that they cause extreme annoyance to many people or when the threat of disease transmission to people is high. Control of irrigation water in agricultural areas to avoid excess runoff is an important mosquito control method, but in recent years elimination of small bodies of water that can serve as wildlife habitat has ceased to be a mosquito control option because of habitat preservation concerns. INTEGRATED PEST MANAGEMENT Mosquito control activities are important to the public health, and responsibility for carrying out these programs rests with state and local governments, health departments, and vector or mosquito control districts. The federal government assists states in emergencies and provides training and consultation in vector and vector-borne disease problems when requested by the states. The current interests in ecology and environmental impact of mosquito control measures, and the increasing problems that have resulted from pesticide resistance emphasize the need for "integrated" pest management programs (IPM). IPM is an ecologically based strategy that relies heavily on natural mortality factors and seeks out control tactics that are compatible with or disrupt these factors as little as possible. IPM includes the use of pesticides, but only after Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 10 OF 28 monitoring of mosquito populations indicates a need. Ideally, an IPM program considers all available control actions, including no action, and evaluates the interaction among various control practices, cultural practices, weather, and habitat structure. This approach thus uses a combination of resource management techniques to control mosquito populations with decisions based on surveillance. Fish and game specialists and natural resources biologists should be involved in planning control measures whenever delicate ecosystems could be impacted by mosquito control practices. A good integrated pest management (IPM)program-- featuring monitoring for high mosquito populations and disease, resident education and action to maximize natural controls and minimize mosquito breeding sites, and larvaciding (killing immature mosquitoes) when necessary-- can control mosquitoes more effectively while reducing pesticide exposure to humans and the environment. Pesticides are dispersed in areas prone to mosquito larvae rather than being dispersed more widely, which has less environmental impact than adulticiding. The underlying philosophy of larval mosquito control is based on the fact that control is effective on concentrated, immobile and accessible larvae populations. This emphasis focuses on habitat management and controlling the immature stages before the mosquitoes emerge as adults. This policy reduces the need for widespread pesticide application in urban areas. DESCRIPTION OF MOSQUITO CONTROL ACTIVITIES MOSQUITO CONTROL PROGRAMS In response to these potential disease carrying pests, communities organized the earliest mosquito control programs in the eastern U.S. in the early 1900s. Eventually, other communities created similar programs throughout the country in areas where mosquito problems occurred and where citizens demanded action by local officials. Modern mosquito control programs in the U.S. are multifaceted and include surveillance, source reduction, and a variety of larval and adult mosquito control strategies. Surveillance methods include studying habitats by air, aerial photographs, and topographic maps, and evaluating larval populations. Mosquito control officials also monitor mosquito traps, and complaint reports from the public. Seasonal records are kept in concurrence with weather data to predict mosquito larval occurrence and adult flights. Many mosquito control programs and local health jurisdictions monitor mosquito-borne diseases by having wild birds, mosquito pools, and/or sentinel chickens tested for disease. Source reduction involves eliminating the habitat or modifying the aquatic habitat to prevent mosquitoes from breeding. This measure includes sanitation measures where artificial containers, including discarded automobile tires,which can become mosquito habitats, are collected and properly disposed. Habitat modification may also involve management of impounded water or open marshes to reduce production and survival of the flood water mosquitoes. If habitat modification is not feasible, biological control using fish may be possible. Mosquito control officials often apply biological or chemical larvicides, with selective action and moderate Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 11 OF 28 residual activity, to the aquatic habitats. To have the maximum impact on the mosquito population, larvicides are applied during those periods when immature stages are concentrated in the breeding sites and before the adult forms emerge and disperse. CRITERIA FOR COVERAGE UNDER THE GENERAL PERMIT Applicants for the general permit will be screened based on information in the application. Ecology will consider whether the applicant has a qualified licensed applicator on staff, familiarity with FIFRA and state requirements, and willingness to comply with any monitoring and/or IPM requirements. TABLE 1. PERMITTED PESTICIDES USED FOR MOSQUITO CONTROL Active Ingredient Use Bacillus sphaericus Control for first through third instar larvae.Higher rates are (H-5a5b) needed for late third and fourth instar larvae.Can have extended residual control even in highly organic aquatic environments. Bacillus thuringiensis Control for first,second,and third instar larvae. Higher rates are subsp.israelensis(Bti) needed for late third and fourth instar larvae. Methoprene First,second,third,and fourth instar larvae control. Monomolecular surface Larvae and pupae control.Okay for potable water. film POE isooctadecanol Petroleum and mineral Larvae and pupae control.State restricted use.Consult with based oil WDFW before using. Temephos State restricted use. Malathion State restricted use.Emergency use only. *For a guide to registered aquatic mosquito control products, go to the Washington State Department of Agriculture's Web page at ttttp:Uwww.kellvsolutions.com/ll'I/showproductsbypest2.asp?Pest ID=I0AJ112t4C04. BACILLUS THURINGIENSIS ISRAELENSIS (BTI): Bacillus thuringiensis subsp. israelensis (Bti) is a naturally occurring soil bacterium that can effectively kill mosquitoes during the larvae stage of development in water. Bti is an endospore-forming bacterium that is ingested by the actively feeding larvae. When the bacteria Bti encysts, it produces a protein crystal toxic to mosquito larvae. Once the bacteria have been ingested, the toxin disrupts the lining of the larvae's intestine causing it to stop eating and die. Bti is the primary material used for mosquito control because of its low toxicity to non-target species. Bti is highly pathogenic against Culcidae (mosquitoes) and Simuliidae (blackflies) and has some virulence against certain other Diptera, especially Chironomidae (midges). Bti is highly selective for the first through third instars of mosquito larvae. Bti has been extensively studied for effects on non-target organisms and environmental consequences of use with no reported adverse effects. It is not toxic to bees. According to several Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 12 OF 28 studies, when applied at field application rates, Bti has no reported effect on fish and amphibians. Several studies have found no effect on warm-blooded mammals. Labels indicate that direct contact with the products may cause mild eye or skin irritation. Bti products are available in liquid, pellet, granular, and briquette formulations. The type of Bti formulation influences the activity of the product. Generally Bti does not persist long after application, with toxicity persisting from 24 hours to over one month when the longer lasting formulations are used. Larval toxicity can depend on the species, its feeding activity and other possible factors such as UV light, water quality, pH, temperature, agitation, and sedimentation. Commercially available Bti strains are sold under several names, including Aquabac, Bactimos, Bonide Mosquito Beater "Plunks", Healthy Ponds, Sentry, Summit Bti Briquets, Teknar and Vectobac. A number of Bti products are available for residential use in water bodies, such as lined ornamental ponds, and are sold under various trade names such as Bayer Advanced Garden Mosquito Preventer, Beckett Skeeter Stopper, Mosquito Depth Charges, Mosquito Dunks, Mosquito Bits Quick-Kill, and Spectracide Mosquito Stop. BACILLUS SPHAERICUS: Bacillus sphaericus is a naturally occurring, spore-forming bacterium, which produces a protein endotoxin at the time of sporulation. The toxin is only active against the larval stage and must be ingested and digested before it becomes activated. B. sphaericus has the unique property of being able to control mosquito larvae in highly organic aquatic environments such as waste lagoons and storm water catch basins. B. sphaericus was first registered for the control of Culex mosquitoes but its uses have been expanded to include control of several Aedes, Anopheles, Ochlerotatus, Psorophora and Coquilettidia species. B. sphaericus is not acutely toxic to freshwater and saltwater invertebrates, honeybees, mayfly larvae, does not appear to be harmful to fish and other marine life, and is not toxic to birds on a sub chronic basis. In tests, B. sphaericus was not pathogenic, infective nor toxic in laboratory animals by the oral, dermal, pulmonary or intra-venous routes of exposure. In humans, mild skin and eye irritation can occur with direct contact Vectolex, the trade name for B. sphaericus, is available in corn cob granule,water dispersible granule, and water dispersible pouch formulations. B. sphaericus can offer up to six weeks of control in many habitats because the protoxins and spores can remain suspended in the water column for extended periods and due to the recycling of bacteria in dead larvae. Duration of control will depend upon habitat factors such as water depth, flushing, water chemistry and frequency of oviposition to maintain the recycling process. METHOPRENE Methoprene is a compound that mimics the action of an insect growth-regulating hormone and prevents the normal maturation of insect larvae. Unable to metamorphose, the mosquitoes die in the pupal stage. Methoprene is classified as a biochemical pesticide because it controls mosquito larvae by interfering with the insect's life cycle rather than through direct toxicity. Methoprene comes in numerous formulations and is sold under the product names Zoecon Altosid, Biosid, and Strike. Formulations labeled for residential use are sold under the names Pre-Strike and Vet-Kem. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 13 OF 28 Studies indicate that methoprene is of low toxicity and poses little risk to people when used according to label instructions. Methoprene was not shown to have any significant toxicological effects in the standard battery of toxicity studies used to assess human health effects. The pesticide has very low acute oral and inhalation toxicity potential and is not an eye or skin irritant. Methoprene is also of low acute dermal (skin) toxicity and is not a human skin sensitizer. In laboratory tests, the toxicity of methoprene to birds and fish is low, and it is nontoxic to bees. Field studies involving methoprene have shown that it has no lasting adverse effects on populations of invertebrates or other non-target aquatic organisms when used according to label instructions for mosquito control. Methoprene mosquito control products present minimal acute and chronic risk to freshwater fish, freshwater invertebrates, and estuarine species. Methoprene is not persistent in the environment. It degrades rapidly in water, being susceptible to transformation by sunlight and microorganisms. MONOMOLECULAR SURFACE FILMS Monomolecular surface film (MSF) is a non-petroleum surface oil that acts as a physicochemical agent by altering the mosquito's habitat. It belongs to the alcohol ethoxylate group of surfactants (products meant to increase product efficacy), which are used in detergent products. MSF disrupts the cohesive properties, which allow mosquitoes to use the water's surface as an interface for breeding. By making the surface "wetter," MSF in effect drowns mosquitoes. MSF kills larvae and pupae by making it impossible for them to keep their breathing tubes above the water's surface. Mosquitoes that require little or no surface contact for breathing, such as Coquillettidia species, require properly timed applications at surface contacting stages-the pupae to emerging adult-for maximum impact. Since MSF kills mosquitoes with a physical mechanism (rather than a toxic mechanism), it is not effective in habitats with persistent unidirectional winds of greater than ten miles per hour, or in areas with very choppy water. Some species such as the midge, and some arthropods that require attachment to the water surface have been shown to be affected. MSF is non-toxic to most non-target wildlife. According to EPA, MSF poses minimal risks to the environment when used as directed. The green tree frog progressed normally from tadpole to adult through several generations after being exposed to a constant film presence for six months. MSF is not a skin irritant, is only a mild eye irritant on prolonged or repeated contact, and is considered to be non-toxic by animal tests. As with all pesticides, direct contact should be avoided. The film persistence is dependent on temperature, water flow, amount of bacteria in the water, and the duration and strength of the wind following application. MSF typically persist on the water's surface for 5-22 days. LARVICIDAL OILS Oils, like films, are pesticides used to form a coating on top of water to drown larvae, pupae, and emerging adult mosquitoes. Oils are petroleum or mineral based and are typically used as a product of last resort for the control of mosquito pupae, since this stage does not feed but does require oxygen. Oils can persist for 12 to 15 hours and then evaporate within a few days. Larvicide oils, if misapplied, Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 14 OF 28 can be toxic to fish and other aquatic organisms. Studies have shown that aquatic invertebrates, amphibians, waterfowl, furbearers and fish may be deleteriously affected. Please consult with WDFW prior to using these products. CHEMICAL LARVICIDES (RESTRICTED OR EMERGENCY USE ONLY) The application of malathion and temephos,which are organophosphate pesticides, to water are restricted use larvicides under the Department of Ecology's aquatic mosquito control permit. Temephos is only allowed in highly polluted and high organic waters with no surface water runoff and may be used in response to the development of pest resistance or a public health emergency. Malathion may only be used for control of mosquito larvae under agreement between Ecology and DOH in response to a public health emergency. The primary application methods in aquatic mosquito larvae and pupa control are: 1. Hand application: Broadcast spreaders, backpack granulators and liquid sprayers are used to spread control materials either mounted on ATVs or carried by the applicator. 2.Aerial applications: Aerial applications normally use a conventional spray boom to improve coverage with the smaller volume of spray solution applied per acre. The spray produces a large droplet size at low pressure and low volume. The pilot monitors the flow rate to minimize pressure and controls drift additionally through application during lower air temperatures and low wind speed. ENDANGERED SPECIES EPA has implemented The Endangered Species Protection Program to identify all pesticides whose use may cause adverse impacts on threatened/endangered species and to implement mitigation measures that will mitigate identified adverse impacts. When an adverse impact is identified this program will require use restrictions to protect endangered/threatened species at the county level. These use restrictions will be specified on the product label or through the distribution of a county specific Endangered Species Protection Bulletin specified on the product label. REGULATORY POLLUTION REDUCTION REQUIREMENTS Federal and State regulations require that effluent limitations set forth in a NPDES permit must be either technology or water quality-based. Technology-based limitations are set by regulation or developed on a case-by-case basis (40 CFR 125.3, and Chapter 173-220 WAC). Water quality-based limitations are based upon compliance with the Surface Water Quality Standards (Chapter 173-201A WAC), Ground Water Standards (Chapter 173-200 WAC), Sediment Quality Standards (Chapter 173-204 WAC) or the National Toxics Rule (Federal Register, Volume 57, No. 246, Tuesday, December 22, 1992). The more stringent of these two limits must be chosen for each of the parameters of concern. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 15 OF 28 TECHNOLOGY BASED WATER QUALITY PROTECTION REQUIREMENTS Sections 301, 302, 306, and 307 of the FWPCA established discharge standards, prohibitions, and limits based on pollution control technologies. These technology-based limits are "best practical control technology" (BPT), "best available technology economically achievable" (BAT), and "best conventional pollutant control technology economically achievable" (BCT). Compliance with BPT/BATBCT may be established using a "best professional judgment" (BPJ) determination. The State has similar technology-based limits which are described as: "all known, available and reasonable methods of control,prevention, and treatment" (AKART)methods. AKART is referred to in State law under RCW 90.48.010, RCW 90.48.520, 90.52.040 and RCW 90.54.020. The Federal technology-based limits and AKART are similar but not equivalent. AKART: (1) may be established for an industrial category or on a case-by-case basis; (2)may be more stringent than Federal regulations; and (3) includes not only treatment, but also BMPs such as prevention and control methods (i.e. waste minimization, waste/source reduction, or reduction in total contaminant releases to the environment). Ecology and the Federal Environmental Protection Agency (EPA) concur that, historically, most discharge permits have determined AKART as equivalent to BPJ determinations. The pesticide application industry has been regulated by EPA under the terms of the Federal Insecticide, Fungicide, and Rodenticide Act, (FIFRA). The use of pesticides is regulated by label use requirements developed by the EPA. In developing label use requirements, EPA requires the pesticide manufacturer to register each pesticide,provide evidence that the pesticide will work as promised, and that unacceptable environmental harm will be minimized. The standards for environmental protection are different between the Clean Water Act and FIFRA. It is the intent of this general permit to authorize mosquito control in a manner that also complies with federal and other state requirements. All waste water discharge permits issued by Ecology must incorporate requirements to implement reasonable prevention, treatment and control of pollutants. The Washington Pesticide Control Act states that "the formulation, distribution, storage, transportation, and disposal of any pesticide and the dissemination of accurate scientific information as to the proper use, or nonuse, of any pesticide, is important and vital to the maintenance of a high level of public health and welfare both immediate and future, and is hereby declared to be a business affected with the public interest. The provisions of this chapter are enacted in the exercise of the police powers of the state for the purpose of protecting the immediate and future health and welfare of the people of the state." The pesticides allowed for use under this permit are regulated both by the state and by the federal government. Treatment of the pollutants addressed in this permit is difficult due to the diffuse nature and low concentrations that exist after the pesticides have become waste. The Talent decision established that aquatic pesticides become waste in the water after the pesticide has performed its intended action and the target organisms are controlled. Treatment of waters where pesticide residues Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 16 OF 28 threaten to cause unacceptable environmental harm may be needed in some situations, but not routinely. WATER QUALITY BASED REQUIREMENTS The mosquito control activities affect surface waters of the State. These waters are protected by chapter 173-201A WAC, Water Quality Standards for Surface Waters of the State of Washington. The purpose of these standards is to establish the highest quality of State waters, through the reduction or elimination of contaminant discharges to the waters of the State, consistent with: ■ public health; ■ public enjoyment; ■ the propagation and protection of fish, shellfish, and wildlife; and ■ existing and future beneficial uses. This purpose is reached, in part, by compliance with the limitations, terms and conditions of the General Permit. The mosquito control activities that discharge, directly or indirectly, to surface waters shall be required to meet the State water quality standards for Class A and Class AA surface waters as given in chapter 173-201A WAC. The characteristic beneficial uses of Class AA and A surface waters include,but are not limited to,the following: ■ domestic, industrial and agricultural water supply; ■ stock watering; ■ the spawning, rearing, migration and harvesting of fish; ■ the spawning, rearing and harvesting of shellfish; ■ wildlife habitat; ■ recreation (primary contact, sport fishing,boating, aesthetic enjoyment of nature); and ■ commerce and navigation. RCW 90.48.035 authorizes establishment of water quality standards for waters of the State. The State has implemented water quality standards in chapter 173-201A WAC. All waste discharge permits issued pursuant to NPDES or SWD regulations are conditioned in such a manner that all authorized discharges shall meet State water quality standards. Standards include an "antidegradation" policy which states that beneficial uses shall be protected. Ecology has deemed that, when properly applied and handled in accordance with the terms and conditions of the general permit, mosquito control activities will comply with State water quality standards, will maintain and protect the existing characteristic beneficial uses of the surface waters of the State, and will protect human health. New information regarding previously unknown environmental and human health risks may cause reopening of the general permit. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 17 OF 28 The short term water quality modification provisions of the permit will allow the discharges authorized by the general permit to cause a temporary diminishment of some beneficial uses while the water body is altered to protect public health and promote public enjoyment and quality of life. The short term modification will be short in that the actual impairment will be short lived, while the overall availability of authorization extends through the term of the permit. The integrated pest management plan to be developed as part of the Permittee's permit coverage satisfies the regulatory requirement for a long term plan that allows short term modifications to extend for five years. The activities authorized by this general permit do not have a reasonable potential to cause a violation of state water quality standards (WAC 173-201A) so long as the activities are allowed under the short term water quality modification. The water quality modification provides for an exception to meeting certain provisions of the state water quality standards, such as meeting all beneficial uses all the time. Activities covered under this permit are allocated a temporary zone of impact on beneficial uses, but the impact must be transient, and must allow for full restoration of water quality and protection of beneficial uses upon project completion. The conditions of this permit constitute the requirements of a short term water quality modification. Washington's water quality standards now include 91 numeric health-based criteria that must be considered in NPDES permits. These criteria were promulgated for the state by the U.S. EPA in its National Toxics Rule (Federal Register, Volume 57,No. 246, Tuesday, December 22, 1992). Ecology has determined that the applicant's discharge does not contain chemicals of concern based on existing data or knowledge. The discharge will be re-evaluated for impacts to human health at the next permit reissuance. SEDIMENT QUALITY Ecology has promulgated aquatic sediment standards (Chapter 173-204 WAC)to protect aquatic biota and human health. These standards state that Ecology may require Permittees to evaluate the potential for the discharge to cause a violation of applicable standards (WAC 173-204-400). Ecology has determined through a review of the discharger characteristics and effluent characteristics that this discharge has no reasonable potential to violate the Sediment Management Standards. SEPA COMPLIANCE Mosquito control activities have undergone numerous environmental impact evaluations. The use of pesticides are conditioned to mitigate environmental impacts of concern noted in these evaluations. The conditions of this permit should satisfy any water quality related SEPA concerns. RECEIVING WATER IDENTIFICATION Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 18 OF 28 Eligibility and Geographical Area of Coverage For the purposes of the general permit, the mosquito control activities for which the general permit is valid include surface waters of the entire State. Mosquito control activities are scattered throughout the state. Mosquito Control Districts (MCDare located in the following counties or areas: Adams County, Benton County, Camano Island, Clark County, Cowlitz County, Curlew (Ferry County), Franklin County, Grant County, Skamania County, Latah, Rosalia, Waverly, Tekoa(Spokane and Whitman County), Leavenworth (Chelan County), Columbia and Touchet- Lowden area(Walla Walla County), and Yakima County. Other areas may be treated by government or private operators. More MCDs may be formed and more places may be treated by contract or a government entity, especially in urban areas. This could occur rapidly if mosquito-borne diseases begin showing up in the state. Mosquito control districts and other pesticide applicators are required to be covered by the general permit for the following pre-adult life stage pesticide activities which occur in surface waters of the state: 1) Into waterbodies that are contiguous with rivers, creeks, and lakes, or 2) Into navigable waters, or 3) In other situations as determined by Ecology. Some mosquito larvacide applications are a low priority because of minimal environmental impact, particularly when compared with the desirability of mosquito control. These situations are derived in part from exclusions to the definition of"waters of the United States"in 33CFR Part 328.3. These include: 1) On land which is in agricultural use where the mosquito control is performed in inconsequential areas such as puddles, hoof prints, or intermittent wet areas, where treatment would have little or no environmental impact except to mosquito larvae, or 2) In man-made retention or detention ponds for wastewater or stormwater treatment. These situations are described so that Ecology and the mosquito control industry are not burdened by oversight and permit requirements in situations where a permit would add no additional environmental protection of beneficial uses. Ecology prefers to focus on the more significant water quality threats for permitting as opposed to the less significant ones that won't adversely affect water quality or related habitat. Much of the mosquito control work consists of applying larvacides in seasonal, isolated, and shallow ponds and agricultural land where no fish are present and the larvacide has no impact on wildlife other than mosquitoes. BEST MANAGEMENT PRACTICES Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 19 OF 28 The industry should continue to examine the possibility of alternatives to reduce the need for aquatic pesticides. Such methods include: 1) Applying pesticide only when mosquito larvae are present or expected to develop at a level that will constitute a nuisance or a public health threat. 2) Using the least intrusive method of pesticide application. 3) All errors in application and spills are reported to the proper authority. 4) No spraying of adult mosquitoes over surface waters of the state. 5) Informing the public of planned spray activities. 6) Public education efforts to reduce potential mosquito breeding habitat. 7) Choosing the most appropriate pesticide formulation according the Permittee's Ecology- approved Integrated Pest Management Plan. 8) Staff training in the proper application of pesticides and handling of spills. Labels specify some additional BMPs. An important goal of the first permit cycle is to reinforce the concept of reduction in pesticide residuals. A reduction in the discharge of pollutants to waters of the State can be achieved by using proper BMPs,which include integrated pest management and alternative pest control procedures. OTHER PERMIT CONDITIONS MONITORING Monitoring requirements for the purposes of this permit are met through annual reporting. There is currently no coordinated monitoring program for mosquito control, but any open accessible treatment areas must be dipped and show larvae present prior to treatment taking place, unless the product is specifically labeled for use prior to flooding, or as a pre-treatment tool. REPORTING AND RECORDKEEPING The conditions of Section 8 are based on the authority to specify any appropriate reporting and recordkeeping requirements to prevent and control waste discharges (WAC 173-226-090). LAB ACCREDITATION With the exception of certain parameters the permit requires all monitoring data to be prepared by a laboratory registered or accredited under the provisions of Chapter 173-50 WAC, Accreditation of Environmental Laboratories. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 20 OF 28 SMALL BUSINESS ECONOMIC IMPACT ANALYSIS The general permit requires compliance with federal and state laws and regulations and places no disproportionate burden on small business. The monitoring is met through annual reporting and meeting pesticide label requirements is already required under FIFRA. PERMIT MODIFICATIONS Ecology may modify this permit to impose new or modified numerical limitations, if necessary to meet Water Quality Standards for Surface Waters, Sediment Quality Standards, or Water Quality Standards for Ground Waters, based on new information obtained from sources such as inspections, effluent monitoring, or Department approved engineering reports. Ecology may also modify this permit as a result of new or amended state or federal regulations. WHEN COVERAGE IS EFFECTIVE Unless Ecology either responds in writing to any facility's Application for Coverage or obtains relevant written public comment, coverage under this general permit of such a facility will commence on the later of the following: • The sixtieth day following receipt by Ecology of a completed and approved Application for Coverage; • The thirty-first (3 l') day following the end of a thirty (30) day public comment period; or • The effective date of the general permit. If Ecology responds in writing to any facility's Application for Coverage or obtains relevant written public comment, coverage under this general permit of such a facility will not commence until Ecology is satisfied with the results obtained from written correspondence with the individual facility and/or the public commentor. RESPONSIBILITY TO COMPLY WITH OTHER REQUIREMENTS Ecology has established, and will enforce, limits and conditions expressed in the general permit for the discharge of wastes containing various pesticides registered for use by the EPA and the Washington State Department of Agriculture. These agencies will enforce the use, storage and disposal requirements expressed on pesticide labels. The Permittee must comply with both the pesticide label requirements and the general permit conditions. The general permit does not supersede or preempt Federal or State label requirements or any other applicable laws and regulations. General permit Condition G15 reminds the Permittee of this fact. GENERAL CONDITIONS General Conditions are based directly on State and Federal law and regulations and are included in all aquatic pesticide general permits. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 21 OF 28 RECOMMENDATION FOR PERMIT ISSUANCE The general permit meets all statutory requirements for authorizing a wastewater discharge, including those limitations and conditions believed necessary to control toxics,protect human health, aquatic life, and the beneficial uses of waters of the State of Washington. Ecology proposes that the general permit be issued for three (3)years. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 22 OF 28 APPENDIX A - PUBLIC OPPORTUNITY TO COMMENT PUBLIC COMMENT AND INFORMATION A Public Notice of Draft (PNOD) was published in the State Register on November 1, 2006. Two public hearings on the draft General Permit will be held: ■ On December 12, 2006 at the Department of Ecology headquarters in Olympia, and ■ On December 13, 2006 in the city of Pasco at Columbia Basin College A one hour workshop to explain proposed changes and answer questions will be held immediately preceding the hearings. Interested persons are invited to submit comments regarding the proposed re-issuance of this General Permit. Comments on the general permit may be delivered at the public hearings as either written or oral testimony. Written comments may also be submitted to the Ecology Office at the address below: Washington State Department of Ecology Water Quality Program Attention: Kelly McLain, Aquatic Pesticide Permits Manager PO Box 7600 Olympia, WA 98504-7600 All comments must be submitted by 5 p.m. on December 20, 2006 to be considered in the final permit determination. A responsiveness summary will be prepared and available for public review. It will be sent to all parties who submitted comments by the deadline. The proposed and final general permit, fact sheet, application form, and other related documents are on file and may be inspected and copied from Ecology WebPages: http://Nvww.ecy.wa.gov/prams/wq/herbicides%npdes develp.html and between the hours of 8:00 a.m. and 4:30 p.m. weekdays at the following Department locations: Washington State Department of Ecology Washington State Department of Ecology Central Regional Office Eastern Regional Office 15 West Yakima Avenue, Suite 200 North 4601 Monroe, Suite 202 Yakima, WA 98902 (509) 575-2807 Spokane, WA 99205 (509) 329- 3515 TDD (509) 454-7673 TDD (509) 458-2055 FAX (509) 575-2809 FAX (509)456-6175 Contact: Ray Latham Contact: Ken Merrill Washington State Department of Ecology Washington State Department of Ecology Northwest Regional Office Southwest Regional Office Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 23 OF 28 3190 - 160th Ave. SE PO Box 47775 Bellevue, WA 98008-5452 Olympia, WA 98504-7775 (425) 649-7288 (360) 407-7269 TDD (435) 649-4259 TDD (360) 407-6306 FAX (425)649-7098 FAX (360) 407-6305 Contact: Tricia Shoblom Contact: Deborah Cornett Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 24 OF 28 APPENDIX B -- GLOSSARY DEFINITIONS "Administrator" means the administrator of the EPA. "Antidegradation Policy" is as stated in WAC 173-201A-070. "Authorized representative" means: 1. If the entity is a corporation, the president, secretary, treasurer, or a vice-president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision-making functions for the corporation, or the manager of one or more manufacturing, production, or operation facilities, if authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures; 2. If the entity is a partnership or sole proprietorship, a general partner or proprietor, respectively; and 3. If the entity is a federal, state or local governmental facility, a director or the highest official appointed or designated to oversee the operation and performance of the activities of the government facility, or his/her designee. The individuals described in paragraphs 1 through 3, above, may designate another authorized representative if the authorization is in writing, the authorization specifies the individual or position responsible, and the written authorization is submitted to Ecology. "Best management practices (BMPs)" means schedules of activities,prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the pollution of waters of the State and their sediments. BMPs also include,but are not limited to, treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage. "Certified applicator" means any individual who is licensed as a commercial pesticide applicator, commercial pesticide operator, public operator,private-commercial applicator, demonstration and research applicator, or certified private applicator, or any other individual who is certified by the director to use or supervise the use of any pesticide which is classified by the EPA or the director as a restricted use pesticide. "Code of Federal Regulations (CFR)" means a codification of the general and permanent rules published in the Federal Register by the Executive departments and agencies of the Federal Government. Environmental regulations are in Title 40. "Conveyance" means a mechanism for transporting water or wastewater from one location to another location including, but not limited to,pipes, ditches, and channels. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 25 OF 28 "Department" means the Washington State Department of Ecology. "Detention" means the collection of water into a temporary storage device with the subsequent release of water either at a rate slower than the collection rate, or after a specified time period has passed since the time of collection. "Director" means the director of the Washington State Department of Ecology or his/her authorized representative. "Discharger" means an owner or operator of any "facility", "operation", or activity subject to regulation under Chapter 90.48 RCW. "Effluent limitation" means any restriction established by the local government, Ecology, and EPA on quantities, rates, and concentrations of chemical, physical, biological, and/or other effluent constituents which are discharged from point sources to any site including,but not limited to, waters of the state. "Environmental Protection Agency(EPA)" means the U.S. Environmental Protection Agency or, where appropriate, the term may also be used as a designation for a duly authorized official of said agency. "Erosion" means the wearing away of the land surface by movements of water, wind, ice, or other agents including, but not limited to, such geological processes as gravitational creep. "Existing operation" means an operation which commenced activities resulting in a discharge, or potential discharge, to waters of the state prior to the effective date of the general permit for which a request for coverage is made. "Facility" means the actual individual premises owned or operated by a "discharger" where process or industrial wastewater is discharged. "FWPCA" means the Federal Water Pollution Control Act(33 U.S.C. 1251 et seq.), as now or as it may be amended. "General permit" means a permit which covers multiple dischargers of a point source category within a designated geographical area, in lieu of individual permits being issued to each discharger. "Ground water" means any natural occurring water in a saturated zone or stratum beneath the surface or land or a surface water body. Hazardous waste" means those wastes designated by 40 CFR Part 261, and regulated by the EPA. "Individual permit" means a discharge permit for a single point source or a single facility. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 26 OF 28 "New operation" means an operation which commenced activities which result in a discharge, or a potential discharge, to waters of the state on or after the effective date of an applicable general permit. "NPDES" means the National Pollutant Discharge Elimination System under section 402 of FWPCA. "Operation" is synonymous with "facility". "Party" means an individual, firm, corporation, association,partnership, co-partnership, consortium, company,joint venture, commercial entity, industry, private corporation, port district, special purpose district, irrigation district, trust, estate, unit of local government, state government agency, federal government agency, Indian tribe, or any other legal entity whatsoever, or their legal representatives, agents, or assignee. "Permit" means an authorization, license, or equivalent control document issued by Ecology to implement Chapter 173-200 WAC, Chapter 173-216 WAC and/or Chapter 173-226 WAC. "Person" is synonymous with "party". "pH" means the logarithm of the reciprocal of the mass of hydrogen ions in grams per liter of solution. Neutral water, for example, has a pH value of 7 and a hydrogen-ion concentration of 10-7. pH is a measure of a substance's corrosivity (acidity or alkalinity). "Point source" means any discernible, confined and discrete conveyance including, but not limited to, any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container,rolling stock, concentrated animal feeding operation, or vessel or other floating craft, from which pollutants are or may be discharged. This term does not include return flows from irrigated agriculture. "Pollutant" means any substance discharged, if discharged directly, would alter the chemical, physical, thermal,biological, or radiological integrity of the waters of the state, or would be likely to create a nuisance or render such waters harmful, detrimental or injurious to the public health, safety or welfare, or to any legitimate beneficial use, or to any animal life, either terrestrial or aquatic. Pollutants include, but are not limited to, the following: dredged spoil, solid waste, incinerator residue, filter backwash, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt,pH, temperature, TSS, turbidity, color, BOD5, TDS, toxicity, odor and industrial, municipal, and agricultural waste. "Reasonable times" means at any time during normal business hours; hours during which production, treatment, or discharge occurs; or times when Ecology suspects occurrence of a violation. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 27 OF 28 "Regional administrator" means the regional administrator of Region X of the EPA or his/her authorized representative. "Retention" means the collection of water into a permanent storage device, with no subsequent release of water. "Shall" is mandatory. "Significant" is synonymous with "substantial". "Site" means the land or water area where any "facility", "operation", or "activity" is physically located or conducted, including any adjacent land used in connection with such facility, operation, or activity. "Site" also means the land or water area receiving any effluent discharged from any facility, operation, or activity. "State" means the State of Washington. "Substantial" means any difference in any parameter including, but not limited to, the following: monitoring result, process characteristic, permit term or condition; which Ecology considers to be of significant importance, value, degree, amount, or extent. "Surface waters of the state" means all waters defined as "waters of the United States" in 40 CFR 122.2 within the geographic boundaries of the state of Washington. This includes lakes, rivers, ponds, streams, inland waters, salt waters and all other surface waters and watercourses within the jurisdiction of the state of Washington. "Toxic amounts" means any amount, i.e., concentration or volume, of a pollutant which causes, or could potentially cause, the death of, or injury to, fish, animals, vegetation or other desirable resources of the state, or otherwise causes, or could potentially cause, a reduction in the quality of the state's waters below the standards set by Ecology or, if no standards have been set, causes significant degradation of water quality, thereby damaging the same. "Toxics" means those substances listed in the federal priority pollutant list and any other pollutant or combination of pollutants listed as toxic in regulations promulgated by the EPA under section 307 of the FWPCA (33 U.S.C. 1317 et seq.), or Ecology under Chapter 173-200 WAC, Chapter 173-201A WAC, or Chapter 173-204 WAC. "Unirrigated" means any lands having not been irrigated within 10 days prior to, or within 60 days after the application of any wastestream. "Waters of the state" means all waters defined as "surface waters of the state" and all waters defined as "waters of the state" in RCW 90.40.020. "Water quality" means the chemical, physical, biological characteristics of water, usually in respect to its suitability for a particular purpose. Fact Sheet For Aquatic Mosquito Control General NPDES Permit PAGE 28 OF 28 "Water quality standards" means the state of Washington's water quality standards for ground waters of the state (Chapter 173-200 WAC) and the state of Washington's water quality standards for surface waters of the state (Chapter 173-201A WAC). In the absence of other definitions as set forth herein, the definitions as set forth in 40 CFR Part 403.3 shall be used for circumstances concerning the discharge of wastes. Fact Sheet For Aquatic Mosquito Control General NPDES Permit AQUATIC MOSQUITO CONTROL GENERAL PERMIT FACTSHEET APPENDIX C —RESPONSE TO COMMENTS National Pollutant Discharge Elimination System (NPDES) and State Waste Discharge General Permit March 7, 2007 Introduction The Department of Ecology (Ecology)published the draft Aquatic Mosquito Control General Permit on November 1, 2006 for public comment. The public comment period ended at 5:OOpm on Wednesday, December 20, 2006. During the comment period, Ecology conducted two public hearings to provide background on the permit and take oral testimony. Ecology also took public comment via letter and email. Ecology considered all the comments in preparing the final permit. This Response to Comments documents Ecology's response to each commenter. The document is divided into four sections: General Comments, Specific Comments, Comments on the Fact Sheet, and Testimony Comments. This document becomes part of the permanent administrative record of issuance of the Aquatic Mosquito Control General Permit. Written comments were received on the draft permit from the following individuals or organizations: 1. Seattle Public Utilities 2. Benton County Mosquito Control District#1 3. Grant County Mosquito Control District#1 4. Washington State Department of Fish and Wildlife 5. Washington State Department of Transportation 6. Snohomish County Oral testimony was received from the following individuals at the public hearings; a transcript is available from Ecology upon request. December 13, 2006 Hearing in Pasco,Washington 1. Jim Thompson, Grant County Mosquito Control District#1 2. Ben Hamilton, Washington Department of Health 3. Kevin Shoemaker, Benton County Mosquito Control District#1 Comments General Comments on the Draft Permit Commenter#6 requests that in light on the new EPA rule on aquatic pesticides and the Clean Water Act, Ecology eliminate the need for both NPDES and state waste discharge permits when performing mosquito control activities. Response: Ecology reviewed the final rule issued by EPA on November 21, 2006, regarding EPA's interpretation that NPDES permits are not required for aquatic pesticide applications. This rule has now been appealed by both environmental groups and industry representatives. Cases are pending in 11 of the nation's 12 federal circuit courts eligible to hear regulatory issues. EPA specifically states that a pesticide applied in accordance with the FIFRA label is not a point source; therefore it cannot be regulated under the Clean Water Act. They do note, however, that there is most likely residue from these types of pesticide applications. The rule states that these residues are no longer point source pollutants, and Clean Water Act permitting is not required. A pesticide applied to the water according to state law is a form of pollution. To apply a pesticide in the water, state law requires that the applicator obtain a short- term modification of the water quality standards from Ecology. Currently, the only legal vehicle for implementing that modification is a permit. State law only defines two types of permits for surface water discharges—National Pollutant Discharge Elimination System(federal) and State Waste Discharge (state). Until 2001, Ecology issued modifications using an administrative order. This process was challenged in court and is not a viable regulatory option at this time. State law does not distinguish between point source and non-point sources of pollution. Washington State law requires that any substance put into the water that has the potential to alter the chemical,physical, or biological characteristics of a water body must obtain a permit prior to discharge. At this time, Ecology has determined that the best interests of the public and the environment are served by continuing to issue permits for mosquito control activities. These permits help the state protect human health and the environment by: • Ensuring pesticides with the lowest risk are used. • Reducing amounts of pesticides applied. • Tracking pesticide use. • Requiring public notifications and postings when waters are treated. • Monitoring levels of pesticides in the water after treatment. Commenters #2 and#3 request that the current NPDES and state waste discharge permit be changed into a state waste discharge permit only. Response: At this time, Ecology has decided to reissue this permit as a joint NPDES and state waste discharge general permit. Ecology will continue to watch the pending court cases related to the final rule issued by EPA on the use of aquatic pesticides. Commenter#2 requests that Ecology use some sort of tracking system for various drafts permits during the permit development process. They have seen problems in the past with new drafts coming out, and no indications of what, if anything, was changed or modified. Response: This comment refers to internal drafts of the permits that are provided to the external stakeholder group as a courtesy during the process. Each individual permit writer usually has their own tracking system for changes from one draft to another. Commenter#2 requests that Ecology provide a list of the "residues or unintended effects" when Bacillus thuringensis israelensis,Bacillus sphaericus, or methoprene are applied according to the FIFRA label. Response: The court cases and EPA have both used the terms "residues and unintended effects"without defining them, leaving Ecology in a place of uncertainty. At this time, Ecology does not intend to define residue or unintended effect. Ecology recognizes that there are residues and unintended effects when Bacillus thuringensis israelensis,Bacillus sphaericus, or methoprene are applied to water of the state. Commenter#4 (WDFW) has concerns about the use of methoprene in areas where state candidate or listed threatened or endangered species are found. WDFW requests that the restrictions on methoprene use in these areas be carried over from the expiring permit. They also request that if an emergency health declaration allows for methoprene use in these sensitive areas,the following BMP's be added to minimize its potential effects: ■Applicators will consult with WDFW(Regional Wildlife Program Manager) during annual pre control season planning and as needed in-season when anticipating methoprene application in restricted areas to affirm/update areas and define any areas of highest sensitivity. ■Applicator will use BMP's to minimize potential impacts and unnecessary entry of methoprene into waters in restricted areas. (e.g. control to the extent possible with Bti before using methoprene; use drift control methods, minimize application rates, use backpack application is areas of highest sensitivity, etc.) Response: Ecology agrees and has added language to reflect the requests of WDFW. Specific Permit Comments on the Draft Permit Condition S1. Permit Coverage Commenter#6 requests that Ecology delete Condition S 1.A.3 from the permit because it is unreasonably vague and unenforceable. If not deleted, they request that Ecology at least modify the condition to include parameters or criteria that Ecology would consider when determining what "other situations"may require coverage under the permit. Response: Ecology choose to include the statement"and other situations as approved by Ecology"because there may be extenuating circumstances not thought of at this time that would warrant permit coverage in the future. The permit language remains the same. Commenter#1 requests clarification of the language in S 1.B2 as it relates to larviciding ponds covered under already existing NPDES permits. Response: Ecology has removed S l.B.2 as it relates to larviciding man-made stormwater or wastewater detention or retention ponds covered by other NPDES permits. The main reason for removing this condition was the inclusion of a short- term modification of the water quality standards. The mosquito permit contains this modification, but the municipal stormwater permits do not contain this same language. There could possibly be legal issues if larvicides were applied without this modification language. S3. Compliance with Standards Commenter#6 requests that the language in S3 be rewritten to include language consistent with the language addressing short-term modifications in the Fact Sheet (pages 17-18). Response: Ecology does not believe that these two sections are drastically different. The language in the Fact Sheet explains in detail Ecology's legal basis for permit decisions. The short-term modification language included in the permit is the same as that found in other aquatic pesticide NPDES permits. This permit language has been challenged and upheld by the courts. Commenter#6 requests that the sentence in S3.A.3 stating that the "application of products authorized under this permit shall not cause long-term harm to the environment" be deleted. Response: One purpose of the permit is to protect the environment. Condition S3.A.3 helps fulfill that purpose. S4.Restrictions on the Application of Products Commenter#2 requests clarification on S4.B.e.2, and the requirements for consulting with WDFW. Specifically, is this a one time consultation or repeating event? How long does WDFW have to respond? Can sites be pre-approved? Would it be acceptable for WDFW to provide a list of sites where Paraffinic white mineral oil cannot be used and all other sites would be allowed? They also request the addition of an exemption from consultation for sites that are known to not have fish or are obviously uninhabitable for fish. Response: This consultation is intended to be a one time consultation between the permittee and WDFW. There has been no conversation with WDFW regarding the length of time they have to respond, or about the possibility of developing a list of sites where Paraffinic white mineral oil cannot be used. The language in S4.B.e.2 remains unchanged. Commenter#1 suggests adding a semi-colon at the end of the sentence in S4.C.3 and adding"coverage under this General Permit is not required." Response: Ecology agrees and has made these changes to S4.C.3. S5. Public Notification Procedures Commenter#6 requests that S5 "Public Notice" include an exemption from notice requirements in the event of a declared public emergency or public health threat. Response: Ecology agrees and has added language to S5 addressing this issue. Commenter#6 states that a sentence should be added up front to S5 explaining that it only applies to the use of products with water-use restrictions. Response: Ecology agrees and has added a sentence addressing this issue. Commenter#1 suggests rewriting S5.A.3 to read"The Permittee shall continue notification to the public regarding mosquito control activities throughout the treatment season if pesticide applications occur. After the initial newspaper notice,notification may include methods other than notices in the newspaper, such as website postings, mailings, or other measures." Response: Ecology agrees and has modified the language in S5.A.3 to match this. Commenter#6 requests that S5.A.3 be revised to read"The Permittee shall continue to notify the public regarding mosquito control activities throughout the treatment season if additional pesticide applications occur..." Response: Ecology agrees to this language change and has changed the permit to reflect that. S8.Reporting and Recordkeeping Requirements Commenter#1 suggests changing the language in S&A. from"City of Tacoma storm drain"to "City of Tacoma storm drain system." This would make it clear that Ecology does not require submittal of individual larvicide amounts for each catch basin, but instead requires total amounts used in all catch basins. Response: Ecology agrees and has modified the language as suggested. S9. Best Management Practices/Integrated Pest Management Commenter#6 requests that S9.A contain a reference to the compliance schedule for Integrated Pest Management Plan approval found in S 10. Response: Ecology agrees and has added language to make the connection between these sections. Commenter#1 suggests replacing "evaluate"with"consider use of in S9.A.2. Response: Ecology disagrees,believing that"evaluate" and"consider use of have different connotations in this instance. The language in S9.A.2 remains the same. Ecology believes an evaluation is necessary because each of these chemicals work slightly differently in the environment. Each one should be evaluated for potential use in a specific area of the state. Commenter#1 suggests adding "as necessary" at the end of the sentence in S9.A.3. Response: Ecology agrees and has added the suggested language to S9.A.3. S9.B.Commenter#5 suggests that "Open Accessible Areas" be rewritten to read, "During a mosquito season if larvae are found in an open accessible area and the site is treated, continued pre-emptive larviciding should be allowed without dipping for the remainder of that year." Response: Ecology has changed the language in S9.B. Commenter#1 requests that Ecology be more specific in S9.B.1 about the number of larvae needed in three dips prior to pesticide application. Response: Ecology agrees and has added the words "at least one" in front of larvae/pupae in S9.B.1. Commenter#6 states that for consistency, S9.0 should refer back to Special Condition S 1.B.2 that excludes from permit coverage man-made detention ponds for wastewater or stormwater treatment or control where those ponds are covered by a separate individual or general NPDES permit. This would include catch basins, storm drains, and vaults. Response: Ecology has removed the previous permit language exempting pesticide applications to man-made stormwater or waste water detention or retention ponds covered under other NPDES permits from needing this permit. The main reason for removing this condition was the inclusion of a short-term modification of the water quality standards. The mosquito permit contains this modification,but the municipal stormwater permits do not contain this same language. There could possibly be legal issues if larvicides were applied without this modification language. Commenter#1 requests that the language in S9.C.5 be changed to state that"A public health emergency is declared." Response: Ecology agrees and has changed S9.C.5 to reflect the comment above. S10. Compliance Schedule Commenter#1 requests that language be added to S 10 allowing for pesticide application when an Integrated Pest Management (IPM)plan has been resubmitted to Ecology for approval. Response: Ecology agrees and has added the following sentence: "If Ecology requires the Permittee to resubmit the IPMP, and the planned treatment season has started, treatments may occur during the review period." S11. Conditional Approval for the use of Products Commenter#1 suggests deleting"all available" in S11.A.2.b.v and adding the sentence: "Every effort should be made to include a broad range of available information." Response: Ecology disagrees and the language in this section remains unchanged. It is the intent of any risk assessment to include all available scientific information on the chemical. The intent of this language in the permit is that every effort will be made to include any available information. Changing the permit to read as suggested could allow for the selective inclusion of data,which defeats the entire purpose of the project. S12. Appendix Commenter#6 states that S 12 should not say Appendices but Appendix. Response: Ecology added a second appendix; therefore the comment no longer applies. Commenter#1 suggests that Appendix A, definition of"range"be changed to read"A specific series of dates that anticipates the months of planned treatment." Response: Ecology agrees and has made the suggested change. General Condition Comments Commenter#6 requests that"or sponsor's"be deleted from W.A. Response: Ecology left this language in because in certain circumstances,private commercial pesticide applicators are contracted to do work on someone else's property under this general permit. This gives Ecology access to the property of the "sponsor" of the treatment if necessary. Commenter#1 would like G4 to read"The Permittee shall submit a Change in Activities form to Ecology when a project activity changes significantly from activities described in the Permittee's permit application." Response: Comment noted. Commenter#6 requests that Condition G13 be deleted from this permit. Response: Federal law requires Condition G13 be included in the permit. Comments on Fact Sheet Commenter#1 requests that Ecology update the third paragraph of page 5 to reflect the issuance of the EPA rule on aquatic pesticides. Response: Ecology has added an addendum regarding the issuance of the EPA rule, and Ecology's current position. Page 10, Integrated Pest Management Commenter#1 requests that the first sentence be edited to read: "Mosquito control activities can be important to protect public health. Historically, mosquito and vector control districts, and some state and local governments and health departments nationwide have engaged in or helped to coordinate mosquito control activities." Response: Ecology does not make changes to the fact sheet after the permit has been sent out for public comment. Page 20, Monitoring Commenter#1 notes that this section does not reflect the exemptions from dipping open accessible areas. Suggest rewriting the sentence as follows: "There is currently no coordinated monitoring program for mosquito control but any open accessible treatment areas must be dipped and show larvae present prior to treatment taking place. Permittees are only exempted from this dipping requirement if they have implemented an Ecology- approved large site sampling protocol, the site is located in or adjacent to a county in which disease cases are suspected or confirmed within the current treatment season, or they are using a product specifically labeled for use prior to flooding, or as a pre- treatment tool." Response: Ecology does not make changes to the fact sheet after the permit has been sent out for public comment. Page 21, Responsibility to Comply with other Requirements There appears to be a typo in the last sentence. "G 15" should read"G 11." (Commenter#I) Response: Ecology does not make changes to the fact sheet after the permit has been sent out for public comment. Page 22, Recommendation for Permit Issuance In consideration of administrative workload and cost-effectiveness,we recommend a five-year permit term as opposed to the proposed reduction to a three-year term. The permit provides a generous allowance for the state to modify the permit if developments warrant such action. (Commenter#1) Response: Ecology is choosing to issue this permit on a three-year term rather than a five-year term or order to stagger the reissuance schedule of the general aquatic pesticide permits. Because the original permits were issued in 2002, they are currently set to expire at the same time every five years. By issuing this permit for three years rather than five, it makes it easier for Ecology to reissue the permits on time with current resources. Oral Testimony Testimony From Public Hearing in Pasco,Washington Jim Thompson, Grant County Mosquito Control District. I think that we should forgo the NPDES permits and go to a state permit. Response: At this time, Ecology has decided to reissue this permit as a joint P gY p J NPDES and state waste discharge general permit. Ecology will continue to watch the pending court cases related to the final rule issued by EPA on the use of aquatic pesticides. This is Ben Hamilton of the Washington State Department of Health. I'm assuming that we're still going to be operating either under a NPDES or a state permit. I'm hoping that if the Department of Health continues to be involved with permitting that we can try to streamline the application process for potential permittees. I hope that we can create a more user-friendly application system. This would make it easier for the users to apply and to report their annual records. Response: Ecology has developed a new online application and reporting system, which is more user-friendly and complies with the new streamlined permit requirements. Kevin Shoemaker, Benton County Mosquito Control. I would like to request that the wording for the posting requirements under section S.5 public notification procedures that was previously in draft two be added back in that reads quote "bodies that are used for water supply, fish, and shellfish harvesting or water contact activities" end quote. Response: Ecology agrees and this language was added to the permit. Mosquito General Permit - Print Page 1 of 2 lhla Application for Coverage Aquatic Mosquito Control General Permit Notice of Intent D A s N i R T T o N s r A T F To comply with the terms of the statewide general permit for discharges of aquatic OEPARTNENT OF PY 9 P 9 q E C 0 L 0 G y pesticides to control mosquito larvae to surface waters of the state Permit Number: COP I. Permittee Name of Entity: City of Renton Are you a commercial pest control business? F Yes f"' No II. Mailing and Contact Information Contact Name: Allen Quynn Quynn Mailing Address: 1055 S. Grady Way City: Renton ZIP: 98057 County: King E-Mail Address: aquynn@ci.renton.wa.us Daytime Phone: 425-430-7247 Cell Phone: III. Chemical Information Anticipated Larvicides to be Used Bacillus sphaericus IV. Regulatory Status Department of Agriculture Pesticide Applicator License number 374 Department of Agriculture Pesticide Applicator License expiration date 12/31/2007 F Licensee has a Public Health Pest Control, Aquatic Pest Control, or a Statewide category endorsement or will be supervised by someone with one of these endorsements. l 71' My renewal has been satisfied and will remain current. V. Spill Kit https://secureaccess.wa.gov/ecy/wgmosquito/PrintPermit.aspx 4/3/2007 Mosquito General Permit - Print Page 2 of 2 IDo you have a complete and up-to-date kit? F-I Yes r No I VI. Certification "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision. The information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." All label directions and requirements will be followed nless the Department of Ecology has further restrictions. Printed name of permittee Signature Date '�P 3 & Washington State use ONLY Permit Number Ecology Region Date Received Coverage Date https:Hsecureaccess.wa.gov/ecy/wgmosquito/PrintPermit.aspx 4/3/2007 4. Add a service to your account by scrolling down and selecting the"Apply"button for the Aquatic Mosquito Control Permit Application. A registration received screen will then appear thanking you for registering and letting you know an email will be sent approving or rejecting your registration. ty4-1tAJi WhtCh '. are submitted by oil transferring activities. F� Aquatic Mosquito Aquatic Mosquito Control Permit Application Control Permit none view AppN Application Registration Witkr '" the Electrurdc Product Recycling 5. You will receive an email indicating your access to the Aquatic Mosquito Control Permit Application has been approved. Log back into SecureAccess Washington at https://secureaccess.wa.gov/iiiyAccess/saw/select.do and your main page will indicate you have Services with Access to the permit application. Select the "Aquatic Mosquito Control Permit Application" link. A Access Secu reAccess R6M111%,% t. You are currently logged in as WQT*stur (ogou Services A service can be started by clicking on the service nam in the"Service with Access`area. Services with Access Agency Service Status Description Details Action e,5� Aquatic : Mosquito Department of Ecology Aquatic Mosau':to Control Permit Application active Control no description Click tv un,estisu __4 Permit 3, Application zi IS.,.ic.s with Access Pending si 6. Select the "Apply For A New Permit"button on the Aquatic Mosquito Control General Permit Notice of Intent Application page. Fill out the application and select the "Submit Application"button. Print application, sign, and mail to Department of Health kr0 9 ,.,t—a� pAC Attn: Ben Hamilton s4f? GOB, PO Box 47825 Olympia, WA 98504-7825 �d7 ' G W 3� 74ou 7. The Department of Health will review your application and mail an approval letter within 7 days. Instructions: Applying for the Aquatic Mosquito Control General Permit 1. Go to the SecureAccess Washington Web site at https://secureaccess.wa.gov. Select the"Register for SecureAccess Washington!" link under the First Time Users header. + a e wl,;Eta�o, Welcome to SecureAccess Washington Nome '. SecureAccess Washington is a single sign-on application gateway created by Washington State's Department of Information Services to simplify access to the growing list of government services aaessible via the Internet SeareAccess Washington agaves Internet access to multiple online government services mft the use of a unique single ' setf-generated User-ID and password.once signed in.users have the abil7chaiass"rd and register for access to various online government services. Returning Users First Time Users �oain to securv"c Ss! Regster.>ar Secu�eyccess wait, ,q_*c_:. PRIVACY NOTICE INFORMATION i jp Copyright 200a-2007->'Washington State Department of information Services-•Ag Rights Reserved 2. Fill in the registration information (record your username and password for your own personal records)and select the"Register" button. After submitting your information,you will receive an email confirmation in which you'll select the link asking you to activate your new account. Select the"login" link and enter your username and password to login into your account. 3. The first time you log in, you need to select"Add Service"under the My Account tab.After selecting "Add Service", select the"view available services" link in the Department of Ecology row. f You are currently togged in as kelm461 3oQ2Ct Add Service Select an agency below to see a list of services. Add Service Agency t rvices { U2partment of Ecology;. View avaitabie services Qepai tment of Labor and Industries We",available services if you have received a service code,enter it here to apply for access to a service. Service CodeAPP�/ Search for services based on kevwordts#. PRIVACY NOTICE INFORMATION copyright 2004-2007 Washington State Department of information Services--all Rights Reserved Allen Quynn - Mosquito Permit Reissued - New online application available Page 2 quito/mosquito_index.html. The new permit does abetter job at addressing the realities of aquatic mosquito control and allows more proactive control (i.e. don't have to dip catch basins, storm drains, etc.). The Department of Health has obtained this new permit and is again offering permit coverage (environmental checklist and cost free) to qualified entities who may need to perform aquatic mosquito control. Those who were covered under DOH's old permit are no longer covered under this re-issued permit. Municipalities, mosquito control districts, state agencies, commercial pest control businesses, and others who have water bodies that may require aquatic mosquito control are encourage to apply for coverage under DOH's permit. Another option: Many entities (home owners associations, school districts, private property owners, businesses, some cities, etc.)who contracted with a commercial pest control business to monitor/treat their water bodies found it beneficial to have the commercial control business obtain permit coverage on their behalf(thus removing themselves from the responsibilities of the permit and putting the responsibility on their contracted control business). The new online permit application has been greatly simplified, but to counter the efficiencies of the improved permit application, you must jump through the hoops of the super secure SecureAccess Washington. Apply for permit coverage through DOH by following these instructions: http://www.ecy.wa.gov/programs/wq/pesticides/permit documents/applicatio n_instructions.pdf All of the important links above can be found at DOH's permit page http://www.doh.wa.gov/ehp/ts/Zoo/WNV/Permit.htmi (if you're interested in bookmarking one mosquito permit-related page). Let me know if you have questions or need help with the online application. Thanks. Ben Hamilton Zoonotic Disease Program <http://www.doh.wa.gov/ehp/ts/ZOO.HTM> WA Department of Health <http://www.doh.wa.gov/> PO Box 47825 Olympia, WA 98504 (360)236-3364 Fax: (360)236-2261 Public Health -Always working for a safer and healthier Washington. > From: McLain, Kelly (ECY) > Sent: Wednesday, March 07, 2007 1:41 PM > To: Barrett, Tony (DOHi); Benner, Brian; Foss, Steve (AGR); > Hamilton, Benjamin (DOH); Hansen, Heather; Lacey, Lerry; Morrissey, > Barbara (DOH); Newberg, Mark; Peacock, William; Sager-Rosenthal, Ivy; > Shoemaker, Kevin; Storey, Angela; Strehle, Sheila; Switzer, Wayne; > Thompson, Jim; Tom Haworth; Wheeler, Wendy Sue (AGR); Whitworth, Terry > Cc: Winters, Nancy (ECY); Weaver, Duane (ECY); Peeler, Dave (ECY); > Shoblom, Tricia (ECY); Merrill, Kenneth R. (ECY); Latham, Ray(ECY); > Cornett, Deborah (ECY) > Subject: Mosquito Permit Reissued Allen Quynn - Don't forget to report mosquito larvicide records for 2007 Page 1 From: "Hamilton, Benjamin (DOH)" <Benjamin.Hamilton@doh.wa.gov> To: <dacker@bellevuewa.gov>, <bwbenner@fcmcd.org>, <upwindsailor@comcast.net>, <thaworth@gcpower.net>, <billw@gorge.net>, "White, Megan" <whitem@wsdot.wa.gov>, <paytonn@wsdot.wa.gov>, <fzenk@ci.lake-forest-park.wa.us>, <jimmi.maulding@mercergov.org>, <aquynn@ci.renton.wa.us>, <tjensen@ci.issaquah.wa.us>, <jdavis@ci.kent.wa.us>, <spoprocare@spoprocare.com>, <bpeacock@spokanecity.org>, <jleinbac@co.whatcom.wa.us>, <wmatthews@desmoineswa.gov>, <doug.jacobson@ci.bothell.wa.us>, <swarneke@orkin.com>, <dan.willott@metrokc.gov>, <cmcgauran@medina-wa.gov>, <ftaylor@co.pacific.wa.us>, <danielb@buriewa.gov>, <danri@chelanpud.org>, "Barrett, Tony (DOHi)" <TGBarret@co.lewis.wa.us>, <rosie@oregon potato.com>, <jackt@co.island.wa.ug> Date: 12/5/2007 8:38:05 AM Subject: Don't forget to report mosquito larvicide records for 2007 Hello, this is a friendly reminder to report your 2007 mosquito larvicide use records. A few of you (Adams Co MCD, Spokane ProCare, Chelan Co PUD) have already enter records into the online system, so if you've already completed that and put the report in the mail, please disregard this message. Your records are due to me before February 1, 2008. I'll be here through December to assist you with your reporting and Ecology's Kelly McLain (kelm461@ecy.wa.gov or 360-407-6938)will be available if you need help while I'm out for a few weeks in January. Below are the 6 steps for successful reporting! 1. Go to the SecureAccess Washington login page at https://secureaccess.wa.gov/myAccess/saw/select.do. Enter your User ID and Password to login. I can provide you your User ID if you've lost it-you can then retrieve your Password by clicking on the Forgot your password? link on the SecureAccess WA login page. Once you do login, it may prompt you to create a new password if you haven't accessed your account for some time (don't forget to write down your User ID and Password for next year's reporting). 2. Select the"Aquatic Mosquito Control Permit Application" link. 3. At the bottom of the page, select the"Submit Annual Report" button. 4. Fill out the reporting form by totaling up the amount of each larvicide used for the season and hitting the Add Data button to add the record to the Report List Summary on the bottom of the page. If you have no larvicide use information to report, select None Used in the larvicide and unit drop down boxes, enter 0 for the amount, and then Add Data. If your jurisdiction covers more than one county, you'll need to total up each larvicide product for each county (I think this only applies to WSDOT, Benton Co MCD and possibly the City of Bothell). If you are a commercial pest control business, you'll need to select each contracted site's name and total up the amount of larvicide used at each contracted site. ` Allen Quynn -Don't forget to report mosquito larvicide records for 2007 Page 2 5. Once all records are completely entered and showing up under the Report List Summary 6n the bottom, select Save and Submit Report to print out a hard copy. 6. Mail the signed hard copy to: WA Department of Health Attn: Ben Hamilton PO Box 47825 Olympia, WA 98504-7825 Let me know if you have questions. Thanks for getting this completed. Ben Hamilton Zoonotic Disease Program <http://www.doh.wa.gov/ehp/ts/ZOO.HTM> WA Department of Health <http://www.doh.wa.gov/> PO Box 47825 Olympia, WA 98504 (360) 236-3364 Fax: (360) 236-2261 Public Health -Always working for a safer and healthier Washington. CC: "McLain, Kelly (ECY)" <KELM461@ECY.WA.GOV>, "Tibbetts, Dorothy (DOH)" <Dorothy.Tibbetts@DOH.WA.GOV> 06/07/2007 08 :04 FAX 2538451133 WHITWORTH PEST SOLUTIONS fa001/001 CEIVEL '. Mosquito Management Day Sheet J U N 0 7 2007 CITY OF RENTON UTILITY SYS7,,- MS Year a Job Month�� Day (-e Person Making application/sampling 1 - yr) - c4TLicense# Terry Whitworth Applicator#374 Whitworth Pest Solutions 2533 Inter Avenue Puyallup, WA 98372 Product: Vectolex CG EPA# 73049-20 Time-Depart Shop A !PM Time Return to Shop PM -'• 15 Total time for billing N�S Billing Size Time Location Larval Product Total Rate/ Comments In/out count Name 1bs 1000 s ft Golf Course 40,000sgft ` -40 Hole#6 I A80`1G �OZr 5oZ �OUN� � VJOp,TI� EN1� Golf course 1�.Zp Golf Course About 1 acre -,2y Hole#7 �D 5 oz �Oe�Sr -h NUJ Golf course :0- Golf Course 40,000sgft o:7- Hole#9 P}PM 5 oz Golf course Q : ^" ''`- S o Z Golf Course 30,000sgft 91.3q Hole#18 5 oz v rnp�T�a fjok:n4 Golf course /0-r5 10 0 _ �� OtJ EAsi— Maintenance Pond NE 10 & 5 oz S►D Anacortes Maintenance Pond NE 26 Fr& 5 oz Lyons Maintenance 2 Tanks S 47" & 5 oz 36 sq ft each 102nd Ave Facilities 9 Tanks City Hall 5 oz 36 sq ft each 1055 S. Grady Way Post-it*Fax Note 7671 D"Eo pages► To From Co./Oop 1 _) C xt �. J 1°nonu II Pltono 1k Fax+! r _ FnK N AServer-1\data\\Dana\Mosquito hems\Mosquito Management Edited Day 5heet.doc 06/21/2007 08:02 FAX 2538451133 WHITWORTH PEST SOLUTIONS EIVEi Mosquito Management Day Sheet JM 2 1 2007 CITY OF RENTON Year a.0o`I- Month_ (� _ Day --). D Person Making application/sampling I—CVON 'bEGNr License # Terry Whitworth Applicator#374 Whitworth Pest Solutions 2533 Inter Avenue Puyallup, WA 98372 Product: Vectolex CG EPA# 73049-20 Time-Depart Shop On M Time Return to ShopM Total time for billing_gyp_fir' 14p;S L—FAVE M @p LEW o oj) lt)k o() Billing Size Time Location Larval Product ITotal Rate/ Comments in/out count Name lbs 1000 s ft Golf Course 40,000sgft 7,y Z Hole#6 C-45 5 oz F::o VNo wot:rrf Golf course $;t(o 4f3o�,E 1�_0z. 15"n ,e r-45r 5r.0- Golf Course About 1 acre '6-0,0 Hole#7 / 5 oz Golf course '.'-(3 l b2 Golf Course 40,000sgft $: t.l15 Hole#9 5 oz No!irr+ day r 510 Golf course , 1' / �jaZ Golf Course 30,000sgft ' (e Hole#18 5 oz Golf course o rJ d[lc►21� Maintenance Pond I 0: & 5 oz vlr )Tam too I (0, 4S Anacortes 1002, f1­`<*JE1 �=L�C—c�S Maintenance Pond !F 55 NE 26 $ � �oz 5 oz ' /5 L ons iJ�� Maintenance 2 Tanks j I ;�'7 S 47 & 5 oz 36 s ft each a.'-a 0 102'Ave NrN, 2 Oz Facilities 9 Tanks City Hall 5 oz 36 sq ft each 1055 S- I Grady Way -( 0)•S�G Post-it'Fax Note 7671 Dutu P�,9O5► To From i COMOP I Phone 0 'hone 11 _ 1 Fnx!f, \\Server-I�dataOana\Musquiro Items\Mosquito Management Edited Day Sheet.doc 07/05/2007 08 :21 FAX 2538451133 WHITWORTH PEST SOLUTIONS U 001/001 R'iECEIVEU '. Mosquito Management Day Sheet JUL 05 2007 CITY OF RENTON UTILITY SYSTL-'11S Year_moo o Month Day Person Making application/sampling LE Jc•N B mac.i+•� License# Terry Whitworth Applicator#374 Whitworth Pest Solutions 2533 Inter Avenue Puyallup, WA 98372 Product: Vectolex CG EPA# 73049-20 Time-Depart Shop c9 115a AM/PM Time Return to Shop_1 30 AM/PM / e r� I �.a��,� '7 : 3 o A Total time for billing r4 R s Billing Size Time Location Larval Product Total Rate/ Comments in/out count Name lbs 1000 s ft Golf Course 40,000sgft 7' 15 Hole#6 �Ekt oz 5 oz U'i=1—.�?P*T ,�r�; Golf course Golf Course About 1 acre 1­3 Hole#7 5 oz 5o,),.1 n E,,, urrl`RJ Golf course t.L14 1 192. WC:!- c f u a� Golf Course 40,000sgft �H� Hole#9 � r 5 oz Golf course : 0 7 z G01f Course 30,000sgft -. 13 Hole#18 S OZ �oVn7t� t�v �O�Ti� Golf course `'!S � S o�. Wz*, � Maintenance Pond io NE 101h& 5 oz Lp j S o r- f` tr7o�J 0 2_C.v Anacortes rNCAi_ pGL-5 L7rr PoIV0- Maintenance Pond r o= '� i NE 26 &D. i � 5 � � Lyons 0 5 oz ���� � P IN) CELL Maintenance 2 Tanks 0 : 4 5 S 47 & �� 5 oz 36 sQ ff each lA`OD 102nd Ave N Z OZ. Facilities 4151,- anks 0 ' o 0 City Hall 5 oz DEL 36 sq ft each 3v 1055 S. CV Grady Way SO Post-it""Fax Note 7671 a a ' Date POEIos► To From + Co./Dopt�I 6 f Phonic!I Phonn II _ _ Fax#r .— Fax it \\Scrver-1\dutu\Dans\Mosquito Items\Mosquito Management Edited Day Shcct.doc Mosquito Management Day Sheet Year �00 1 Month Day l Person Making application/sampling License#,_ (0-7(,015 Terry Whitworth Applicator#374 Whitworth Pest Solutions 2533 Inter Avenue Puyallup, WA 98372 Product: Vectolex CG EPA# 73049-20 Time-Depart Shop O M Time Return to Shop '.O V AM 3— VI Total time for billing I to Billing Size Time Location Larval Product Total Rate/ Comments in/out count Name IN 1000 s ft Golf Course 40,000sgft '61 Hole#6 SC57o Z 5 oz Golf course �N Golf Course About 1 acre ; 43 Hole#7OZ- 5 oz Golf course � 0 c7 Golf Course 40,000sgft cl :-04 Hole#9 5 oz Golf course - 1-6 D Oz. � Golf Course 30,000sgft %2 Hole#18 Golf course o ?j 10 Z, 5 oz Maintenance Pond t =1 S NE 10 & 5 oz � 0;LIO Anacortes CIS CH— Maintenance Pond 1)%1:51D NE 26` & �/ 5 oz :j patios gp 6 ( : i.O Lyons ATE R— Maintenance 2 Tanks l I: (AU S 47 1h& '5 oz 36 sq ft each I 102"d Ave Facilities 9 Tanks l 2.00 City Hall 1 S oz 36 sq ft each I rL:25 1055 S. V u Grady Way �S 0't \\Scrver•1\data\Dana\Mosquito Items\Mosquito Management Edited Day Shcet.doc 9OOIz001A SNOIIOl OS iS3d H180AIIHO, SELL9VB69Z XV3 3l Sl 300US0.40 08/03/2007 08: 18 FAX 2538451133 WHITWORTH PEST SOLUTIONS U 001/001 RECEIVE[ Mosquito Management Day Sheet AUG 0 3 2007 CITY OF RENTON UTILITY SYSTEMS Year 2 Oo Month Day Person Making application/sampling 0►-3 —License # (r,-1 _(os Terry Whitworth Applicator#374 ' Whitworth Pest Solutions 2533 Inter Avenue Puyallup, WA 98372 Product: Vectolex CG EPA# 73049-20 Time-Depart Shop Time Return to Shop 'X 12-;o1DAM12> R-R t 0 C Total time for billing 75 ��-_P,IJ E SQ k,�W009 � _ 30 tir j Billing Size Time Location Larval Product Total Rate/ Comments in/out count Name lbs 1000 s ft Golf Course 40,000sgft -4( Hole#6 lOvz 5 oz 'F-c>„,,z) (i�> Ooo_ t4 Golf course 57T Golf Course About 1 acre '0 1 Hole#7 5 oz Golf course - 2c7 1 oZ. Golf Course 40,000sgft Zj Hole#9 C;- 5 oz -f-2_v_rpnep Golf course C, 43 Golf Course 30,000sgft '5 ,4(v Hole#18 r 5 oz Gol,fcourse 5 � Oo2 as-c1�S R�-� S�DF 7 Maintenance Pond 1 a,2.o NE 10 & 5 oz 40 Anacortes �aZ T 4kis P�V_� Maintenance Pond 10,�145 NE 26 & 5 ,{ 5 oz A L,-T_-� ��r�F_ I! •'oo L ons 0 3 tN - ct-1 r t L Maintenance 2 Tanks 1 ;20 S 47h& n I r/2- 5 oz - 36 s ft each 1 9� 102°d Ave 1" Facilities 9 Tanks 1 45 City Hall 5 oz 36 sq ft each 10,o� 1055 S. tJ v ��— Grady Way Post-it'Fax(Vote 7671 Gate Paogos� To From Co./onp ,1 U f= G�u Phono it Phone it Pax 11, Fax# I a \\Servcr-I\data\Dana\Ivlosquito Iterns\Mosquito Management Sditcd Day Sheet.doc 08/16/2007 08 :46 FAX 2538451133 WHITWORTH PEST SOLUTIONS Z 001/001 RECEIVED Mosquito Management Day Sheet AUG 16 2007 CITY OF RENTON UTILITY SYSTEMS Year 4- Month _Day Person Making application/sampling— License# Terry Whitworth Applicator#374 Whitworth Pest Solutions 2533 Inter Avenue Puyallup, WA 98372 Product: Vectolex CG EPA# 73049-20 Time-Depart Shop 1� A M Time Return to Shop AM/pM -7:30 Total time for billing DP 45 Billing Size Time Location Larval Product Total Rate/ Comments In/out count Name lbs 1000 s ft Golf Course 40,000sgf1 7.45 Hole#6 Ste` 5 oz Golf course 'U I 50Z- Golf Course About 1 acre : 10 Hole#7 5 oz Golf course 3 DZ- }� � tr Golf Course 40,000sgft '. 3t Hole 009 5 oz zjz �pRT&+ Golf course g-.153 3 wS�o Golf Course 30,000sgft $:59 Hole#16 5 oz ez� fl rtlOty� D Golf course Z �J {�sT s�oC p� �b O Maintenance pond r I Z-x) NE 10 & 115 4��2 5 oz Anacortes Maintenance Pond 1/ :y5 NE 26 &, 5 oz I� Lyons Maintenance 2 Tanks 2'5 S 47"& �� 5 oz 36 s ft each I: I Q 102nd Ave Facilities 9 Tanks do City Hall `� 5 oz 36 sq ft each 10:5 1055 S. 1�j Grady Way ��• t.IS o� Post-tt"'Fax Noto 7671 onin poges� To '1 From co./Dcp�l,i \ Phone d Phone Fax N/ -� - 2 Fax II \\Scrvcr-1\daw\Dana\Mosquito itcros\Mosquito Management Editcd Day 5heei.doc Mosquito Management Day Sheet Year Month $ Day 2Q Person Making application/sampling License#_C217(95 Terry Whitworth Applicator#374 Whitworth Pest Solutions 2533 Inter Avenue Puyallup, WA 98372 Product: Vectolex CG EPA# 73049-20 Time-Depart Shop ') M Time Return to Shop N ' 0'-0 AN —7:3O Total time for billing Ce . —7;�;_ Billing Size Time Location Larval Product Total Rate/ Comments In/out count blame Ibs 1000 s ft Golf Course 40,000sgft 1.y15 Hole#6 3 -jC�E: c Oc z' 5 oz �a�17 Z Golf course B oG ��� sz_ C Golf Course About 1 acre L-YS Hole#7 ,� 1 oz 5 oz �v� T �snn o Golf course g S . ��t D� O� ND Golf Course 40,000sgft '6 y Z. Hole#9 5 oz Golf course o 5 0 Golf Course 30,000sgft Q' o, Hole#18 5 oz �� OL Golf course q.3 Z 5 0�. Maintenance Pond S NE 10 & po 5 oz VO`'"2� 1 L ', 10 Anacortes � htio.:'TL�J � Maintenance Pond LO �� ll'- NE 26` & � 2oz. 5 oz Jv<�i 5rr� A�aUF.J�' 11:;t,10 Lyons Maintenance 2 Tanks 1 2 I S 47 & 5 oz 36 sq ft each 12-. , 102"Ave 1�2 v- . Facilities 9 Tanks ko,00 City Hall 5 oz 36 sq ft each 1055 S. 25 l0 5 Grady Way jI t_q _ S f) 02 1 \\Server-1\data\Dana\Mo5quito items mosquito Managcmcnt Edited Day Sheet.doc S00/EO018 SNOIlN]OS 1S3d H180AIIHA EELL9VH99 %H3 2L SL 800Z/20/LO Mosquito Management Day Sheet Year ')'C>O Month a( Day 1 2 Person Making application/sampling License Terry Whitworth Applicator#374 Whitworth pest Solutions 2533 Inter Avenue Puyallup, WA 98372 Product: Vectolex CG EPA# 73049-20 Time-Depart Shop :dam AM/PM Time Return to Shop Z'cv -ANO—ND A eV--mltr- _tD I 7,,_,5Total time for billing Billing Size Time Location Larval Products Total hate/ Comments in/out count Name lbs 1000 s ft Golf Course 40,000sgfft 7�45 Hole#6 Golf course p5 Golf Course About 1 acre $ 0_+ Hole#7 5 oz Golf course p Golf Course 40,000sgft �,f Hole#9 5 oz Golf course 5 O Golf Course 30,000sgft G'7 Mole#18 5 oz Golfcourse 3Cj Maintenance Pond / :3 NE 10 & r 5 Oz D r�ct �1 02 Anacortes 5oz Maintenance Pond / :a8 NE 26` g 5 oz P 23 Lyons Maintenance 2 Tanks 2:00 S 470& N1 5 oz 36 sq ft each /2' 5 102"d Avez Facilities 9 Tanks /O:oc> City Hall A 5 oz 36 sq ft each ,ip i�E- 1055 S. — - Grady Way V Zo 1 \\Servcr-1\datu\Dana\Mosquito Items\Mosquito Monagcment Edited Day Sheot.doc �00/tr00fj SNOIIAIOS 1S3d H180AIIHA EEll9tr889Z xvd 8L El 800Z/80/l0 Mosquito Management Day Sheet Year Month Day Person Making application/sampling License # Terry Whitworth Applicator 43 74 Whitworth Pest Solutions 2533 Inter Avenue Puyallup, WA 98372 Product. 'Vectolex CG EPA# 73049-20 Time-Depart Shop (B 15 AM/PM Time Return to Shop0 AlV AP-e 1uG 61 r'n�4�u_�OrJ 1'4S Total time for billing 71�Pc�tz� n14 �0L '� ' ''�`"-- Billing Size Time Location Larval product Total Rate/ Comments in/out count Name lbs 1000 s ft Golf Course 40,000sgft Hole#6 , 5z'E___ Spz 5 oz Tee;\r7v'z--r-(_� Golf course Golf Course About 1 acre 2 3 Hole#7 r 5 oz S tDE Golf course Golf Course 40,000sgft r50 Hole#9 5 oz Golf course `�oZ._ Tit i-1T�P tJ• .���E Golf Course 30,000sgft .13 Hole#18 5 oz Golf course q;'33 �oL. T2E'��� ?J• SfDE Maintenance Pond 1D-40 NIE 10 & 5 oz 11' /V Anacortes T Maintenance Pond 11 20 NE 26"& 5 oz /.•25 L ons Maintenance 2 Tanks _ c'+ S 47 Eh& 5 oz 36 sq ft each .;t Zo 102"d Ave Facilities 9 Tanks City Hall 5 oz 36 sq ft each 1055 S. 202� Grady Way fn 2 B�7 `I \\5crvcr.1\dnta\Dona\Mosquito ltems\Mosquito Management Edited Day Shect.doc S00/90018 SNOIiAIDS 1S3d Hl'dOAITH18 EELL9vacgZ Xb'd EL EL 800Z/80/LO `SY O PLANNING/BUILDING/ PUBLIC WORKS DEPARTMENT �c4� M E M O R A N D U M DATE: July 17, 2007 TO: Kathy Keolker, Mayor FROM: Gregg Zimmerman, Administrator STAFF CONTACT: Ron Straka, Surface Water Utility Supervisor Allen Quynn, Surface Water Utility Engineer SUBJECT: Chris Clifford Trespassing Complaint Allen Quynn met Mr. Clifford at his home at 2720 Talbot Ave. S on Thursday, July 12, 2007, to discuss his concern regarding the City's mosquito treatment contractor, Whitworth Pest Solutions, Inc., being on his property without authorization. The contractor's treatment staff was also present at the meeting. Mr. Clifford stated that he heard the contractor operating gas powered spraying equipment on his property on the morning of July 5, 2007, and that he had not authorized the City's contractor to enter his property. The contractor's staff stated they were aware that they were not to enter either Mr. Clifford's property, or his neighbor's property to the north, to spray but did not think they had entered onto either property on the morning of July 5, 2007. To avoid any chance of the contractor inadvertently crossing onto either of the properties in the future, Mr. Clifford and the contractor's staff identified visual landmarks on an aerial map that could be used to assist the contractor with determining his location relative to the property lines. Mr. Clifford seemed satisfied with the response. Ref#55-2007 cc: Kevin Milosevich,Police Chief Lys Hornsby,Utility Systems Director April Alexander,Executive Secretary Tami Dauenhauer,Secretary Linda Moschetti,PBPW Administrative Secretary h:\file sys\swp-surface water projects\swp-27-surface water projects(cip)\27-2000 mosquito abatement program\2007 program\clifford complaint.doc\AQmd ' City of Renton West Nile Virus Phased Response Plan (Draft) Renton's West Nile Virus(WNV)Response Role: WNV is a public health issue and public health agencies are the experts. Renton's role is to support the federal, state, and local public health agencies in addressing this public health issue by supporting their surveillance program, supporting their education and outreach program(for Renton's citizens and City workers)and applying control measures(to reduce mosquito-breeding habitat& mosquito pools)to City-owned facilities and lands, consistent with public health alert levels and recommended response. Alert Definition Surveillance Response Education Response Control Response Level 0 Mosquito Inactivity No planned surveillance by the Prepare/update/order informational pieces Update West Nile Response Plan based on Period city. for treatment of private facilities,property, recommendation from the State and local health personal protection,website page, FAQs and departments. (November—March) media articles. Determine best control response strategy for treatment of Check with King County Department of city-owned stormwater management facilities based on Health(KC DOH)and Washington State census data,recommendations from state and local health Department of Health(DOH)for availability departments,other jurisdictions,and best available of updated information and materials. science. Make budget request for staff time to Based on set criteria established above,prepare for prepare and begin public outreach portion of larviciding of city-owned properties,which include the WNV Response Plan. following: • Ensure sufficient budget for larvicide treatment based on treatment strategy, • Identify possible private pest control operators, • Verify NPDES permit is valid for treatment period,and/or • Ensure sufficient number of licensed staff should city elect to larvicide in-house. Prepare/update survey of high-density elderly residential population areas and city-owned surface water facilities. CADocuments and Settings\aquynn\Local Settings\Temp\Renton WNV Response Plan Draft 2005.doc\AQ\tb\tp R E N T 0 N City of Renton West Nile Virus Phased Response Plan (Draft) Alert Definition Surveillance Response Education Response Control Response Level 1 Mosquito Activity Based on established control Inform city staff of recommended personal Initiate treatment of city stormwater facilities based on Period response criteria,the city will protection measures against mosquito bites established control response criteria. inventory and map mosquito through staff meetings and informational (April—October) habitat on city-owned memos. Inspect city properties and take action to minimize property(ies)(including mosquito-breeding habitats. No positive surveillance stormwater management facilities, Hold intra-departmental meetings to review findings in King County wetlands,and other water bodies) each responsible department's role(s)related It is assumed, at this time, that the city will follow the in the current calendar that may contain mosquito habitat. to WNV. Remind city departments to take following control response criteria under Alert Level 1: year(e.g.,no WNV steps to minimize mosquito habitat on city- positive birds or mosquito Based on established control owned lands within their control. • Monitor for larva and apply larvicide as pools and no WNV cases response criteria,conduct necessary to all city-owned stormwater ponds in humans or horses). mosquito surveillance of city Provide WNV information to city residents: (approximately 7 ponds). properties by larval dipping and • Inspect facilities on city right-of-way based on periodically report results to KC • Place articles in the Renton citizen complaints and known problem areas. DOH. Reporter. • Update and maintain the WNV • Larvicide will be applied based on a minimum Educate city employees(that p frequently work in the field)on web page on the city's website. larval count of 0.3 larva per dip. procedures for monitoring . Make KC DOH and DOH • Inspect city parks and facilities for the presence mosquito habitat and reporting brochures available at locations of mosquito larva and apply larvicide as dead birds. frequented by the public such as necessary. libraries,City Hall, Senior Center, Participate in discussions of the feasibility of forming Provide city residents with community events(Renton River mosquito control districts in King County. information on how to report dead Days)and the Community Center. birds to KC DOH. • Include WNV brochure with When feasible,submit live Finance's Utility Billing statement mosquito larva samples to Public mailing. Health for species identification. West Nile Virus materials will address issues relating to prevention,emphasizing City staff to keep informed on mosquito habitat reduction and personal WNV issues by attending regular protection against mosquito bites. KC DOH and DOH sponsored meetings. CA\Documents and Settings\aquynn\Local Settings\Temp\Renton WNV Response Plan Draft 2005.doc\AQ\tb\tp R E N T 0 N City of Renton West Nile Virus Phased Response Plan (Draft) Alert Definition Surveillance Response Education Response Control Response Level Provide designated city staff information/fact sheet on how to respond to citizen questions. Information/fact sheet will include responses to frequently asked questions. Contact known,private homeowner associations regarding larviciding their stormwater facilities. Providing information on contacting private pest control applicators,requirements for treatment,and obtain NPDES permitting, etc. Contact Neighborhood Associations regarding minimizing mosquito breeding habitat on private property. CADocuments and Settings\aquynn\Local Settings\Temp\Renton WNV Response Plan Draft 2005.doc\AQ\tb\tp RENTON City of Renton West Nile Virus Phased Response Plan (Draft) Alert Definition Surveillance Response Education Response Control Response Level Prepare/update list of Homeowners Associations with private storm water facilities. Designate Point of Contact for WNV(Surface Water: Allen Quynn,Parks: Terry Flatley,Facilities: Greg Stroh, and Shops: lt»t� M a rsty CADocuments and Settings\aquynn\Local Settings\Temp\Renton WNV Response Plan Draft 2005.doc\AQ\tb\tp R E N T 0 N City of Renton " �' ti`l"^ West Nile Virus 3I q a Phased Response Plan (Draft) Alert Definition Surveillance Response Education Response Control Response'' Level 2 Mosquito Activity Continue surveillance activities Continue public information activities Continue control response activities under Alert Level 1. Period described under Alert Level 1. described under Alert Level 1. Based on established control response criteria,monitor (April—October) Update city web page based on any new street drains/catch basin in proximity to vulnerable - information provided by state and local populations for mosquito production. Larvicide will be ' Areas with confirmed health departments. applied based on a minimum larval count of 0.3 larva per "V activity in wild dip. birds and/or mosquito Send KC DOH and DOH"Mosquito pools,but no positive Control Fact Sheet for Private Property It is assumed, at this time, that the city will follow the surveillance findings prior I Owners"to persons or organizations known following response control criteria under Alert Level 2: to August 1. to have potential mosquito breeding habitat, facilities,water features,and drainage • Inspect street drains and swale/ditches within'/o- (See Ale-rt L-evel 3-rf� systems. mile radius of the Senior Center and residential positive birds or areas with a high concentration of citizens over mosquitoes occur before 50 years of age. Apply larvicides if larval count August 1.) is 0.3 larva per dip(minimum). Continue to encourage owners of private stormwater management facilities to take the steps necessary to monitor and treat with larvicide as needed. CADocuments and Seuings\aquynn\Local Settings\Temp\Renton WNV Response Plan Draft 2005.doc\AQ\tb\tp RENTON City of Renton West Nile Virus Phased Response Plan (Draft) Alert Definition Surveillance Response Education Response Control Response Level 3 Mosquito Activity Continue surveillance activities Continue efforts described in Alert Level 2. Continue control response activities under Alert Level 2. Period described under Alert Level 2. Expand public information to include City It is assumed, at this time, that the city will follow the (April—October) Cable TV,and Renton Reporter following response control criteria under Alert Level 3: emphasizing personal protection, Initial confirmation of particularly for persons over age 50,as . Larvicide all catch basins and swale/ditches WNV positive bird resources allow. with standing water within ''/o-mile radius of collected before August 1, reported,positive WNV test surveillance and/or a horse or human Mail residents WNV additional findings in a bird,horse,or human. case; informational packets emphasizing personal protection and methods for minimizing The city may need to respond more aggressively by OR multiple positive mosquito habitat on private property. broadening treatment areas based on recommendation birds or mosquito pools in from the KC DOH and DOH. Additional treatment the absence of a horse or includes: human cases. • Larvicide all catch basins and swale/ditches with standing water within 1/4-mile radius of reported,positive WNV test surveillance findings in a bird,horse,or human,and/or apply larvicide based on a minimum larval count of 0.3 larva per dip. City staff to review criteria and plan for more widespread adult mosquito spraying efforts should the Alert Level increase to Level 4. It is assumed that the state and local department of health, in conjunction with Department of Ecology,will go through the environmental review process and obtain all necessary permits to allow adulticiding in accordance with state law. CADocuments and Settings\aquynn\Local Settings\Temp\Renton WNV Response Plan Draft 2005.doc\AQ\tb\tp R E N OT OT N City of Renton West Nile Virus Phased Response Plan (Draft) Alert Definition Surveillance Response Education Response Control Response Level 4 Mosquito Activity Continue surveillance activities Continue efforts described in Alert Level 3. Continue control response activities under Alert Level 3. Period described under Alert Level 3. Based on established control response criteria and strong (April—October) recommendation by the Health Department,the city will begin spraying of adult mosquitoes(adulticiding). Surveillance indicates high risk of multiple It is assumed, at this time, that the city will follow the human infections, an following response control criteria under Alert Level 4: escalating epizootic in horses and/or birds, • Apply adulticide within a'/2-mile radius of the abundant adult vectors, Senior Center,high concentration of people over and conditions favoring age 50 years of age and areas of positive"V continued trans-mission to infections reported in birds,horses,and humans humans. and/or apply larvicide based on a minimum KC DOH and/or DOH larval count of 0.3 larva per dip. may declare public health It is assumed that appropriate environmental review and emergency. permitting are completed prior to spraying. CADocuments and Settings\aquynn\Local Settings\Temp\Renton WNV Response Plan Draft 2005.doc\AQ\tb\tp ------------- REN70N . y o� CITY OF RENTON ♦ 4 T ♦ Planning/Building/PublicWorks Department Denis Law,Mayor Gregg Zimmerman P.E.,Administrator January 8, 2008 Ben Hamilton Zoonotic Disease Program Washington State Department of Health PO Box 47825 Olympia, WA 98504 SUBJECT: 2007 MOSQUITO LARVICIDE USE REPORT Dear Mr. Hamilton: Enclosed please find for your records,the City of Renton's 2007 Mosquito Larvicide Use Report as required under the NPDES Aquatic Mosquito Control Permit. Please call me at 425-430-7247, if you have any questions. Sincerely, Allen Quy/e'rUtility , Surface W Engineer Enclosure H:\File Sys\SWP-Surface Water Projects\SWP-27-Surface Water Projects(CIP)\27-2000 Mosquito Abatemen West Ni Virus\2007 WNVV007 larvicide report.doc\AQgd 1055 South Grady Way-Renton,Washington 98057 R E N T O N 9.This paper contains 50%recycled matenal,30%post consumer AHEAD OF T H F CURVE Mosquito General Permit - Annual Report Page 1 of 1 6k& Treatment Annual Report AQUATIC MOSQUITO CONTROL GENERAL PERMIT N'ASHINGT0N STATE o E P A H T N E N T o E To comply with the terms of the statewide general permit for discharges of aquatic pesticides to control mosquito E C O L O G Y larvae to surface waters of the state. Name of Entity: City of Renton Entity Name Larvicide Used Amount & Units County City of Renton Bacillus sphaericus 367.25 oz King I certify under penalty of law that this document and all attachments were prepared under my direction or supervision. The information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing vio0tions. Signature: %' Z, ' Date: E Printed name of permittee: �(�°vl LPL( https://secureaccess.wa.gov/ecy/wqmosquito/PrintReport.aspx 1/8/2008 •1" AO� - ;ZV - 3�S 1 Public Health ....................................................... Seattle & King County HEALTHY PEOPLE. HEALTHY COMMUNITIES. WEST N-ILE VIRUS Dorothy F.Teeter,MHA, Interim Director and Health Officer 2007 Season © Spring Training for . Municipalities SAVE the DATE: April 9, 2007 from 8:45 am - noon EVENT: 41h annual WNV Spring Training for Municipalities VENUE: Eastgate Public Health Clinic • 14350 SE Eastgate Way Bellevue, WA Phone: 206-296-4920 Join the SWAT team against WNV RSVP: Leah.Helms(a)metrokc.gov or 206-296-3998 ................................................................................................................................................, LINEUP State & local WNV surveillance ■ WNV update from WA State Dept of Health ■ NPDES permits for 2007 ■ Larviciding catch basins in the City of Seattle ■ 2007 Season: Mosquito control in King County ■ What happens if adult mosquito spraying is needed? ■ Pesticide Applicator's licensing requirements ■ Educational materials & resources ................................................................................................................................................: Environmental Health Services Division 999 Third Avenue, Suite 700 • Seattle,WA 98104-4039 City of Seattle O King County T(206)205-4394 F(206)296-0189• www.metrokc.gov/health �(�0) " O1Y, ljj�x(,k �1011,Vof Ron sires Ixu(tidve Wc6 SIT F�'/&I+T"�+f'.e is I ram. n F w WNV in Sacramento 2004 County Human Equine Bird Mosq. Sent. West Nile Virus Surveillance and I Pool Chicken Control in the Sac 3 84' 153 21 16 SYMVCD Yolo 1 1 26 0 0 David Brown, Manager Sacramento-Yolo Mosquito and State 331 102 840 408 166 Vector Control District Leader (LA) Riverside (LA) (LA) (LA) q l to' 68 S- i LI)22 dbrorun FIC79T+hx F.31TE', h of District Developed WNV Basic Level of Mosquito Response Plan Management Measures • Updated plan with Board of Directors January-March . Thresholds for adult control are 2005 »100 MMT/EVS per trap night • Utilized California Mosquito-Borne Virus Surveillance and Response Plan and CDC Plan »25 Light/Gravid per trap night • Five Levels of Control • Source reduction/water management » Level 1 -Basic Level » Level -Mosquito Pool/dead bird • Biological control » Level -Animal/Chicken • Larvicide(immature mosquito)control » Level 4 -Human case » Level -Epidemicconditions •Adulticide(mature mosquito)control in Rural/agricultural/open space areas • Education When Response Plan Triggered Sacramento-Yolo District - 1• Increase from Base Level lowers thresholds and • 14,000 identified increases levels of response larval Sites • Basic thresholds are reduced for response • —600,000 acres In 25(Magnet Trap-EVS) Agriculture/open » 10(Light trap-Gravid Trap) • When thresholds are triggered,Lab staff determines Space(44,000 acres A' scope of infections of rice) • Control operations maximize larval control • 40,000+of wetland/ » Immediate treatment of all larval sources wildlife habitat - Localized Treatment for adult control • Half urban/half rural - - • Immediate Press Releases to inform public WNV Mosquitoes of Concern 2005 Sequence of Events -Over 20 different species 2 species very efficient • By February, already at level 2 (Dead u Culex tarsalis Birds) ¢ -Agriculture -Natural Sources •Above Average Rainfall (Through June) -Urban • Followed by Above Average •Culex pipiens Flight Range -Urban sources Temperatures (record July ) Cx.pipiens—1 mile -Dairy/Rural Cx.tarsalis—5 miles Precipitation Records: Sacramento-Yolo Average Temperature Records at Counties 2000-2005 Sacramento-Yolo Counties,2000-2005 90 03 .. _._ R 80 0.25 _.... LL 70 u --.-2004 60 0.2 1 -41-2000-2004 3 50 .4 0.15 ! 2005 y 40 # _-... E 30 2004 0.1 / 12 20 2000.2004 n 1 10 2005 0.as 0 .. x° m -_.. �° c o` a` 10 P 5 ? O Months Months WNV positive and and negative mosquito pools in 2005 Sequence of Events June 2005:4+ve and 109-ve • July 8th infected mosquito pools 4E • July 15th infected Sentinel Chickens SS • July 21st report of human infection in Sacramento County is Media Announcements made June 2005 EVS tap sites • July 27th CCC hired to go door-to-door to ;P si,tiveWN,R,, inform residents of localized adult *P°`i'" g.iiveMV it,, control WNV positive and negative mosquito pools in July WNV positive and and negative mosquito pools in 2005: 70+ve and 310-ve August 2005: 53+ve and 503-ve N N W E r...,...o W+ S SS July 2005 EVS trap sites ' x.. August 2005 EVS trap sites ' N galive WNV sites . Negative WNV riles + Pos rive WNV sites " + P.11-WNV styes PositiveMegetive WNV sites • " ,}PosiliveMegaMe WNV sibs Y J Sacramento Mosquito Infection Rates (Late July-Early August) 20 r 5 15 D sviba on of dead birds repotted tom ,s. Sacramento and VUlo countless - January 1bN May 2005 Y `• 10 5 C"k.I'Ipir—, C.to rsal'is Ii.il N WE volo Govnl'y !!77 'ram ., • � w it Ytl ., �• D'etribut o i of dead bras reported horn y'rL 'c•. Distribution of dead birds reported from �i N Sacramento or ltl Vob Counties. Sacramento and Volo Counties: June 2005 ', July 2005 �•. , ,r G' R. Enhanced Larval Control in Performed Localized adult Entire Area mosquito control measures • Performed when dip counts exceed 0.1 larvae • Ground Rigs performed localized control • Bti/ Bs • Presentation to City Council in Target • Insect growth regulators Area »'Well,if it was really a problem, he would • Light film oils not have smiled" • 60,000+treatments to date in District • Quickly realized ground control would »10 additional Technicians (Swat Team) not adequately meet control objectives hired to perform control Aerial Adult Mosquito Control initiated Adulticiding • Decision made August 4 to treat 50,000 acres a� North of American River • 70,000 acres south to follow • Pyrethrin/PBO product selected . Material applied at 0.66 ounces per acre (0.0025lbs of pyrethrin) M • Anticipated start date " August 8 Adulticide Response Approval Process . When thresholds are i .,. • Addressed through Adoption of Plan met »Must be quick and definitive to be effective » Mosquito abundance »Prior planning a must »Virus activity —Public Outreach —Stakeholders —Contracts �I�.0 Methods and Materials in Methods and Materials in California California • Residual/Ultra Low Volume • Malathion ="Resistance" • Backpack,Vehicle • Naled = Category 1 Mounted and Airplane • Backpack G` »Trumpet » Parks,Resting Spots »DIfJrOm • Vehicle Mounted Residential • Pyrethrins= $1.00/acre » Parks Golf Courses • Pyrethroids= Longer Lasting than • Aircraft Pyrethrins » Large Areas Determining Efficacy . Immediate } n . » Caged Mosquitoes . Over-all » Pre-Post Trapping Dlstrlbubonof dead birds reported from I ry Sacramento and Yolo Counties: » Gravid vs.EVS auiyzoos ?e#-" Aerial Spraying zones in North and South , , it'S sale.,but 1)ublie fears`a " 4�t tiacl Sacramento Cnu tS C�11C( lta. .,� 1p�' *1. W. co le L\ tray is • taulted C S Held Town Hall Meetings Results Ranging from "Thank you",or • Significant reduction in mosquitoes in mild protest "Why are you not spraying us?" North Sacramento County 11 »reduction of 50%of adult Cx. tarsalis mosquito population based on trap counts + »Significant reduction of 33%of Cx.pipiens lug, population r • Post trap counts show a continued - reduction of mosquito population and N infection rate American Light Trap collection of Culex pipiens in American Light Trap collection of Culex tarsalis in Sacramento-Yolo Counties,2000-2005 Sacramento-Yolo Counties,2000-2005 412 ....... ..._:'� r� +i 2004 a 3'y t 2000-2004 f 1 10 - -2000-2004 I C 2005 0J2005 2.5 e 1 \y G 7 6 N 2 a N ° Y 1.5E g 4 0 `0 2 0 05 Zo )ate Fan �,at PQ6 0.4 )o° ) P`4' S-9 O<'t "o4 Od )ac Q°� �a4 PQ�`lad )Jp �J� PpA yaQ our, e,°� Oeo Months Months Bird Reporting Decline WNV Week of Onset WNV Symptomatic Infections and Positive Blood Donors nand died,Reported ro W-Novi—SruvC 1—.,Prapaa: by We k cf On SOS S.r,ar—caaty a,d c,lin.ra. Sacramento County 2006 10 r-swa.ain Cosh P/ 1� 35 -- Ps � _— enwwawaawarr r.:xroe. rave arm c.ws ermn. S ,v,�hy rP' mne mrzs—1.7-o]ne o,rz3 0„ W..Y E--V Oat. Effects of aerial spraying of pyrethrin inserticide on numbers of Odex moequitcee and their infection rates with WNV,in North Sacramento Qune-Oct 2005) - --- --------- Before Spraying After Spraying 20 15 10 ww ry S 5. 13 11• 6• 5 Oa:1 I .o.n mm o, ,.o,y o,n �• .,o o.o, :i,n, w : y_Nlunb—f moaqultoes/trap night - WNV Infection rate 11000 Temals mosquitoes 1VNV infection rates in Colex vnoaquitoea collected in North Sacramento before and Fluctuations of mosquito densities and their infection rates with WNV in Non. after aerial spraying with pyrethrin insecticide Sprayed areas in Sacramento and Y.I.Counties,during June-Oct 2005 E 3 ...... ......... ......... ... .......... ..16 i so After Spraying _ zs „ q i 40 �� 12 t? � 2 . o 30 Before Spraying 1s 6 20 E a E to os 8 2 . 3 a o o PJp1 9°vu pry Jo-Np 1p PJQ1 9°qe A°M1 pu�p c o cep J^� Jp0 Q5 19 1r,•) �^, 11• p' p , a O �i 3JJ y°� p°p r'Q pca,y t All baps 0-0O2 —Or _-W o i NVintechon refs tNn Spray areas n Sac Valo Comparison of number of mosquito vectors of West Nile Virus collected from North Sac Aerial Spraying zone and other Non Spray areas in Sacramento and Y.J.Counties Lessons Learned ch Aerial Spraying in North Sac:Aug 8-10 16 12 f . Ground Vehicles Generally more 10 accepted (Lie down in front of trucks) b 6 jam•••..�„_„� »Road Access/Obstacles 6 2 ' • Meteorology/Calibration Z • Perform When Infection rates are high p 1,.3J� ?J y°q yq° ,�� • Do not wait for human infections -- -•Sac Non Spray zone --*-North Sac Spray zone � �, Further Information Larval Slides •www.fightthebite.net Larviciding in Sacramento-Yolo District Known Larval Development Sites • "14,000"identified sites • "41"individuals responsible for larval : control . Partnerships with other agencies n (Maps,cleaning dates) Known Culex sites Natural Sources �� hs � 2 x�� Agricultural Sources Urban Sources f Program Adjustments '' E • Enhanced Public Education • Enhanced Larval Control in Response to Triggers »Dead Birds »Mosquito Pools »Equine Case »Human Case �^} ee jkprawt. fig. y, CATCH BASIN CRENN Lessons learned? Larviciding Costs • Altosid Products • Larviciding well • Weather conditions » Liquid=-$7.25/acre received by the » Rain » Briquets=-$2.75/each(90 days) Public • Irrigation » Pellets=0.68/each(25 days) 9 • Bti/Bs • Backyard sources » New sources » Bti Liquid=-$7.25 acre appear to be more of » Bs=$0.75/each(30 days) a problem • Oils • Larviciding alone will a Agnique-$33.00/acre(21 days)» Golden Bear-$7.00/acre Pupae Control not stop outbreak! Establishment and Funding for District formation Programs • Formed Pursuant to California Health and Safety Code »Division 3,Article 1,Chapter 2 -Petition -Resolution of Governing Body • Set forth the methods by which the district will be financed, including, but not limited to, special taxes, special benefit assessments, and fees Case Study Decision-Making Process • Sacramento-Yolo MVCD • Board adopts a Budget Prior to August 1 s'of each Fiscal Year which may include: » 2013 Square miles » Maintenance and operation » Bi County Agency » Employee compensation » Formed by Joint Resolution of Sacramento-Yolo » Capital outlay County Board of Supervisors in 1946 » Interest and redemption for indebtedness. • Governing Body Comprised of Appointed » Restricted reserve for public health emergencies. Representatives from County and » Restricted reserve for capital and asset preservation Incorporated Cities(currently 13 members) » Restricted reserve for contingencies. » Unallocated general reserve. District Board Developed Decision-Making, Funding, Etc... Mosquito Response Plan • Contingency fund developed • Updated plan with Board of Directors January-March 2005 • Funds appropriated from State • Utilized California Mosquito-Borne Virus Surveillance Emergency WNV Fund and Response Plan and CDC Plan . Five Levels of Control • Contracts for aerial services developed » Level -Basic Level prior to Season » Level -Mosquito Pool/dead bird » Level 3 -Animal/Chicken » Level 4 -Human case » Level 5 -Epidemic conditions S -� mvc � 9i�- was- 2b8Z Sacramento-Yolo Mosquito and Vector Control District West Nile Virus Outbreak 2005 Information Session March 27,2007 2:00 pm—4:30 pm Seattle Municipal Tower Room 1650 700 50'Avenue, Seattle (Building takes up entire block bounded by Columbia, S`h, Cherry and 6`h—enter at 5`h and Columbia, take second bank of elevators to 16`h floor and turn left) 2005 Sacramento outbreak overview(30 minutes) Larvicide response(15 minutes) • Funding • Application areas • Program adjustments during outbreak • Lessons learned Adulticide response(15 minutes) • Adulticide trigger(s) • Decision approval process • Funding • Methods, product • Tracking efficacy • Lessons learned Public/political reaction(30 minutes) • Public concerns,reaction during outbreak • Environmental community • Electeds relations • Communications adjustments during outbreak • Communications methods, any special notifications? • Communications partners • Public response one year later—any differences in perceptions or concerns? • What worked, what didn't Q&A(15 minutes) Outbreak planning tips for Seattle(15 minutes) • mosquito control • public information • electeds relations • health officials relations • anything else Q&A(30 minutes) Allen Quynn - REMINDER: WNV Info Session tomorrow afternoon Page 1 From: "Hopkins, Sharon" <Sharon.Hopkins@METROKC.GOV> To: "Alan Quynn" <Aquynn@ci.renton.wa.us>, "Allan Newbill" <allan@clydehill.org>, "Andy Loch" <andy.loch@ci.bothell.wa.us>, "Ben Parrish" <bparrish@ci.covington.wa.us>, "Bret Heath" <breth@ci.issaquah.wa.us>, "Brian Carson" <Bcarson@ci.seatac.wa.us>, "Carl Mueller" <carl@ci.carnation.wa.us>, "Carter Hawley" <Chawley@ci.ken more.wa.us>, "Charlotte Mackner" <Townofsky@att.net>, "Chris Searcy" <chrissearcy@ci.enumclaw.wa.us>, "City of Beaux Arts" <townhall@beauxarts-wa.gov>, "Dana Stahl POS" <stahl.d@portseattle.org>, "Daniel Bretzke" <danielb@ci.burien.wa.us>, "Daniel Smith" <daniel.smith@cityoffederalway.com>, "David Cline" <davidc@ci.burien.wa.us>, "David Delph " <ddelph@ci.covington.wa.us>, "Eric LaFrance" <elafrance@ci.sammamish.wa.us>, "Frank Zenk" <Fzenk@ci.lake-forest-park.wa.us>, "Gary Kennison" <Gary.ken nison@ci.maple-valley.wa.us>, "George Martinez" <Georgem@ci.north-bend.wa.us>, "Glen Baker" <Gbaker@cityofmilton.net>, "Jack McKenzie" <jackm@ci.hunts-point.wa.us>, "Jason Paulsen" <Bdcity@aol.com>, "Jean Lindsey" <Jeanl@ci.normandy-park.wa.us>, "Jefferson Davis" <Jdavis@ci.kent.wa.us>, "jerry shuster" <jshuster@ci.shoreline.wa.us>, "Jessica Williams" <jilliams@ci.shoreline.wa.us>, "Jesus Sanchez" <Jsanchez@ci.shoreline.wa.us>, "Jim Jaques" <Jjaques@cityofmilton.net>, "Jim Morrow" <Jmorrow@ci.tukwila.wa.us>, "Jimmi Maulding" <Jimmi.Maulding@mercergov.org>, "Joe Willis" <jwillis@medina-wa.gov>, "Jon Morrow" <jmorrow@ci.kirkland.wa.us>, "JWalsh" <Jwalsh@ci.pacific.wa.us>, "Kathy Joyner" <Kjoyner@ci.kirkland.wa.us>, "Kirk Holmes" <Kholmes@ci.snoqualmie.wa.us>, "Kristen McArthur" <kmcarthur@redmond.gov>, "Larry Howard" <Townhall@ci.yarrow-point.wa.us>, "Leah Helms" <leah.helms@metrokc.gov>, "Linda Wright" <LWright@desmoineswa.gov>, "Loren Reinhold" <Irein hold @desmoineswa.gov>, "Maiya, Andrews" <maiyaa@ci.newcastle.wa.us>, "Martin Nordby" <martin.nordby@cityoffederalway.com>, "Mike Fischer" <mike.fisher@duvallwa.gov>, "Mike Mactutis" <Mmactutis@ci.kent.wa.us>, "Pat Harris" <pharris@ci.bellevue.wa.us>, "Phyllis Varner" <pvarner@ci.bellevue.wa.us>, "Randy Bailey" <RandyB@CityofAlgona.com>, "Randy Holmes" <rholmes@ci.bellevue.wa.us>, "Schunke, Jim" <jschunke@ci.pacific.wa.us>, "Scott Schroeder" <Sschroeder@ci.kent.wa.us>, "Shana Kalenius" <shana.kalenius@ci.bothell.wa.us>, "Shannon Kelleher" <Shannon.Kelleher@seattle.gov>, "Sheila Strehle" <Sheila.Strehle@Seattle.Gov>, "Stacey, Rush" <srush@ci.kirkland.wa.us>, "Steve Leniszewski" <Steven.leniszewski@duvallwa.gov>, "Steve Osmeck" <Osmek.s@portseattle.org>, "Tim Carlaw" <Tcarlaw@ci.auburn.wa.us>, "Todd Jensen" <tjensen@ci.issaquah.wa.us>, "Tom Reber" <tomr@cityofalgona.com>, "Yosh Monzaki" <Yoshm@ci.woodinville.wa.us>, " Grandjean, Marcus " <Marcus.Grandjean@metrokc.gov>, "Acker, Dan" <DAcker@ci.bellevue.wa.us>, "Adams, Caren" <Caren.Adams@METROKC.GOV>, "Beleford, June" <June.Beleford@METROKC.GOV>, "Bradley, Lori" <Lori.Bradley@METROKC.GOV>, "Brady, Terry" <Terry.Brady@METRO KC.GOV>, "Brauner, JoMarie" <jomarie.brauner@doh.wa.gov>, "Brown, Kathy" <Kathy.Brown @METRO KC.GOV>, "Bucich, Paul" <paul.bucich@cityoffederalway.com>, "Dean, Timothy or Salvador Marez" <pwcrew@cityofalgona.com>, "Duchin, Jeff' <Jeff.Duchin@METROKC.GOV>, "Easterberg, Charles" <easterbg@u.washington.edu>, "Galbraith, Greg" <gregg@ci.issaquah.wa.us>, "Galvin, Dave" <Dave.Galvin@METROKC.GOV>, "Griffin, Leo" <Leo.Griffin@METROKC.GOV>, "Harding, Maurice B" <pharding@ci.bellevue.wa.us>, "Harris, Logan" <Logan.Harris@METROKC.GOV>, "Hillesland, Spence" <shillesland@ci.bellevue.wa.us>, "Hopkins, Sharon" <Sharon.Hopkins@METROKC.GOV>, "Hornsby, Lys" <Ihornsby@ci.renton.wa.us>, "Humes, Diane" <dhumes@ci.snoqualmie.wa.us>, "Johnson, Cathy" <Cathy.Johnson@METRO KC.GOV>, "Karasz, Hilary" <Hilary.Karasz@METROKC.GOV>, "Krank, Ken" <Ken.Krank@METROKC.GOV>, "Lewis, Jill" <jlewis@seattleschools.org>, "McGauran, Catey" <cmcgauran@medina-wa.gov>, "Ogershok, Rochelle" <Rochelle.Ogershok@METROKC.GOV>, "O'Leary, Joe" <JOleary@ci.bellevue.wa.us>, "Olson, Frank" <folson@desmoineswa.gov>, "Peacock, Ann" <Ann.Peacock@METROKC.GOV>, "Sanders, Jim" <jim.sanders@metrokc.gov> Date: 3/26/2007 8:34:06 AM Subject: REMINDER: WNV Info Session tomorrow afternoon WNV Partners- Just a reminder of the WNV Information Session tomorrow, Tuesday March 27th from 2:00 -4:30 pm. Program Manager Dave Brown and Public Information Officer Jennifer Benito from the Sacramento-Yolo Vector and Mosquioto Control District will be discussing their 2005 West Nile virus outbreak. This will be invaluable information for us as we Allen Quynn - REMINDER: WNV Info Session tomorrow afternoon Page 2 prepare for the upcoming WNV season. See the attached agenda for more details, and directions to the meeting location in the Seattle Municipal Tower Room 1650. See you there! Sharon «WNV Sacramento Agenda 3_27_07.doc>> Sharon G. Hopkins, DVM, MPH Public Health Veterinarian Environmental Health Services Division Public Health--Seattle & King County 999 3rd Avenue, Suite 700 Seattle, WA 98104 PH: 206-205-0495 FAX: 206-296-0189 sharon.hopkins@metrokc.gov Allen Quynn - Special WNV info session on 3/27/07 Page 1 From: "Hopkins, Sharon" <Sharon.Hopkins@METRO KC.GOV> To: " Grandjean, Marcus" <Marcus.Grandjean@metrokc.gov>, " Strehle, Sheila" <sheila.strehle@seattle.gov>, "Acker, Dan" <DAcker@ci.bellevue.wa.us>, "Adams, Caren" <Caren.Adams@METROKC.GOV>, "Beleford, June" <June.Beleford@METROKC.GOV>, "Bradley, Lori" <Lori.Bradley@METROKC.GOV>, "Brady, Terry" <Terry.Brady@METROKC.GOV>, "Brauner, JoMarie" <jomarie.brauner@doh.wa.gov>, "Bretzke, Daniel" <danielb@ci.burien.wa.us>, "Brown, Kathy" <Kathy.Brown @METRO KC.GOV>, "Bucich, Paul" <paul.bucich@cityoffederalway.com>, "Davis, Jefferson" <jdavis@ci.kent.wa.us>, "Dean, Timothy or Salvador Marez" <pwcrew@cityofalgona.com>, "Duchin, Jeff' <Jeff.Duch in@METROKC.GOV>, "Easterberg, Charles" <easterbg@u.washington.edu>, "Galbraith, Greg" <gregg@ci.issaquah.wa.us>, "Galvin, Dave" <Dave.Galvin@METROKC.GOV>, "Griffin, Leo" <Leo.Griffin @METROKC.GOV>, "Harding, Maurice B" <pharding@ci.bellevue.wa.us>, "Harris, Logan" <Logan.Harris@METRO KC.GOV>, "Hillesland, Spence" <shillesland@ci.bellevue.wa.us>, "Holmes, Kirk" <kholmes@ci.snoqualmie.wa.us>, "Hopkins, Sharon" <Sharon.Hopkins@METRO KC.GOV>, "Hornsby, Lys" <Ihornsby@ci.renton.wa.us>, "Humes, Diane" <dhumes@ci.snoqualmie.wa.us>, "Johnson, Cathy" <Cathy.Johnson@METROKC.GOV>, "Karasz, Hilary" <Hilary.Karasz@METROKC.GOV>, "Kelleher, Shannon" <Shannon.Kelleher@seattle.gov>, "Kennison, Gary" <gary.ken nison@ci.maple-valley.wa.us>, "Krank, Ken" <Ken.Krank@METROKC.GOV>, "LaFrance, Eric" <elafrance@ci.sammamish.wa.us>, "Lewis, Jill" <jlewis@seattleschools.org>, "Maulding, Jimmi" <Jimmi.Maulding@mercergov.org>, "McGauran, Catey" <cmcgauran@medina-wa.gov>, "Monzaki, Yoshiro" <yoshm@ci.woodinville.wa.us>, "Morrow, Jon" <jmorrow@ci.kirkland.wa.us>, "Ogershok, Rochelle" <Rochelle.Ogershok@METROKC.GOV>, "O'Leary, Joe" <JOleary@ci.bellevue.wa.us>, "Olson, Frank" <folson@desmoineswa.gov>, "Osmek, Steve" <osmek.s@portseattle.org>, "Peacock, Ann" <Ann.Peacock@METROKC.GOV>, "Quynn, Allen" <aquynn@ci.renton.wa.us>, "Reinhold, Loren" <]reinhold@desmoineswa.gov>, "Rush, Stacey" <srush@ci.kirkland.wa.us>, "Sanders, Jim" <jim.sanders@metrokc.gov>, "Sandin, Randy" <randy.sandin@metrokc.gov>, "Scherer, Jo" <joscherer@seattle.gov>, "Schroeder, Scott" <sschroeder@ci.kent.wa.us>, "Schunke, Jim" <jschunke@ci.pacific.wa.us>, "Sizemore, David" <David.Sizemore@METROKC.GOV>, "Skilton, Christopher" <Chris.Skilton@metrokc.gov>, "Smith, Dan" <daniel.smith@cityoffederalway.com>, "Sopher, Carrie" <sopherc@seattle.gov>, "Stahl, Dana" <stahl.d@portseattle.org>, "Stevens, Gary" <gstevens@ci.snoqualmie.wa.us>, "Sugg, Rick" <rick.sugg@seattle.gov>, "Swanson, Talon" <Talon.Swanson @METROKC.GOV>, "Thiede, Hanne" <hanne.thiede@metrokc.gov>, "Tibbetts, Dorothy" <dorothy.tibbetts@doh.wa.gov>, "Varner, Phyllis" <pvarner@ci.bellevue.wa.us>, "Walsh, Sue" <Sue.Walsh@metrokc.gov>, "Willott, Dan" <Dan.Willott@METROKC.GOV>, "Wu, Charles" <charles.wu@metrokc.gov>, "Zenk, Frank" <fzenk@ci.lake-forest-park.wa.us> Date: 3/7/2007 2:41:53 PM Subject: Special WNV info session on 3/27/07 Dear West Nile Virus partners-- On the afternoon of Tuesday March 27th we have a special opportunity to hear first-hand about the 2005 West Nile virus outbreak in northern California from front-line staff at the Sacramento-Yolo Mosquito & Vector Control District. The speakers will be Dave Brown, the Vector District's program manager, and Jennifer Benito, the District's Public Information Officer. Dave and Jennifer will give us an overview of the Sacramento-area WNV outbreak, discuss mosquito control including larvaciding and adult mosquito spraying; public concerns; political reactions; what worked and what didn't; and lessons learned. They will offer us outbreak planning tips for mosquito control, public information, and maintaing good working relationships with elected officials and public health. There will be plenty of time for questions and discussion. This will be invaluable information as we prepare for the upcoming WNV season in our area. Allen Quynn -Special WNV info session on 3/27/07 Page 2 For more about the the Sacramento-Yolo Mosquito&Vector Control District see their website at http://www.fightthebite.net/ The meeting will be held at the Seattle Municipal Tower(700 5th Ave S) in Room 1650 from 2 pm -4:30 pm on Tuesday March 27th. The Seattle Muni Tower is located in downtown Seattle between 5th and 6th Ave and Cherry and Columbia streets. Enter the building at 5th and Columbia and take the second bank of elevators to the 16th Floor and turn left. We thank the Shelia Strehle and the city of Seattle WNV team for sponsoring Dave and Jennifer's visit and arranging the meeting room. Hope to see everyone there. Sharon Sharon G. Hopkins, DVM, MPH Public Health Veterinarian Environmental Health Services Division Public Health--Seattle & King County 999 3rd Avenue, Suite 700 Seattle, WA 98104 PH: 206-205-0495 FAX: 206-296-0189 sharon.hopkins@metrokc.gov West Nile Virus (WNV) Phased Response Guidelines for Cities & Agencies in King County Public Health—Seattle & King County Contact: Dr. Sharon Hopkins,WNV program lead, (206)205-0495 or Sharon.Hopkins@metrokc.gov Aled Definition Surveillance Response Education Response Control Response Level O Winter(off season) -Analyze surveillance findings from previous -Evaluate effectiveness of educational materials -Evaluate mosquito surveillance and larvaciding No mosquito activity; season and outreach from previous season and update activities from previous year;update WNV plans for coming season Response plan approx Nov—Mar _Review and update mosquito and bird In King County surveillance plans for coming season and -Restock brochures and other educational -Develop control plans including capacity to secure materials,funding and other resources materials;check with Public Health for availability respond in the event a major WNV outbreak in the of new materials coming season requires extensive larval control efforts or adult mosquito spraying -Prepare for larvaciding of city properties by No risk of human obtaining NPDES permit through WA DOH WNV outbreak -Have designated staff obtain Pest Control Operator licensing,or contract with private pest control company to provide surveillance and larvaciding services during mosquito season Spring,summer& Inventory&map mosquito habitat -Inform city staff of recommended personal -Initiate source reduction of mosquito habitat at fall protection measures against mosquito bites via city-owned properties using principles of -Conduct mosquito surveillance at city Human Resources,city intranet sites,and staff integrated pest management No positive properties by larval dipping and periodically meetings;consider providing mosquito repellent surveillance findings report results to Public Health products to field staff -Encourage source reduction by homeowners, in King County in the businesses,and housing developments current calendar year -Field employees such as Parks or Utilities -Keep city Public Information Officer informed of (e.g.,no WNV crews should report dead bird sightings and WNV status and key public messages consistent -Respond to mosquito complaints from citizens positive birds or monitor mosquito habitat with local and state recommendations mosquito pools and -Consider use of larvacides at city facilities,water no WNV cases in -Encourage citizen reports of dead birds or -Provide public education and outreach on WNV features and drainage systems identified as humans or horses) significant mosquito problems to Public Health prevention emphasizing mosquito habitat having p g q g potential mosquito vector species and reduction and personal protection against where larval counts meet or exceed 1 larva per 3 -With assistance of Public Health,determine mosquito bites dips(or average of 0.3 larva per dip) associations between known mosquito vectors Examples of public outreach include: At Alert Level 1, larvaciding may be and habitat type • Establish or maintain WNV information limited to sources in proximity to on city web site with links to Public vulnerable populations such as senior Health WNV pages at housing,densities of population>50 www.metrokc.gov/health/westnile yrs of age,and outdoor venues used at • Encourage citizens to report dead bird dusk and evening hours sightings&mosquito activity -Review plans for control response to higher Alert • Insert WNV prevention Levels messages/brochures in utility statements,city newsletters,etc -Obtain supplies of larvacide,or have a plan for • Make WNV educational materials obtaining sufficient larvacide rapidly if needed Remote risk of available at community&senior centers, human outbreak parks,sports fields,festivals,and other -Attend WNV trainings sponsored by Public community events and gathering places Health or other organizations Alert Definition Surveillance Response Education Response Control Response Level Summer or fall -Continue activities of Alert Level 1 -Continue activities described in Alert Level 1 -Continue control activities in Alert Level 1 2 Areas with limited or -Conduct intensified surveillance in areas of -Update city web site emphasizing presence of -Monitor street drains/catch basin in proximity to sporadic WNV activity positive findings to identify possible sources& WNV in the area and prevention measures vulnerable populations for mosquito production in wild birds and/or mosquito species and apply larvacides if indicated mosquito pools -Increase public education emphasizing personal starting after -Expand surveillance in areas adjacent to protection,particularly for persons over 50 -Intensify mosquito habitat/source reduction and August 1 those with positive WNV surveillance findings larval control at facilities,water features,and -Provide personal protection information(and drainage systems in proximity to areas with (See Alert level 3 if -Assist Public Health in conducting live mosquito repellent products if feasible)to positive WNV surveillance findings positive birds or mosquito trapping and intensified larval homeless persons mosquitoes occur surveillance in areas with WNV positive birds -Provide information and/or support for appropriate before August 1 or mosquitoes -Prepare or update news articles for use by control responses by private agencies, or if there are human senior-oriented newsletters or other publications businesses,and organizations in the city with or equine cases) -Monitor maps produced by Public Health and encourage public education via local or mosquito habitat and/or facilities,water features indicating areas of WNV activity regional newspapers with attention to non-English- and drainage systems under their authority speaking residents(materials are available from Public Health) -Review or develop plans for adult mosquito control should it be determined,in consultation Low risk of -Send Public Health's"Mosquito Control Fact with Public Health,that this control step is human outbreak Sheet for Private Property Owners"to persons or necessary in limited locales organizations known to have potential mosquito breeding habitat,facilities,water features,and drainage systems Spring,summer or -Continue with surveillance activities Continue efforts described in Alert Level 2 -Intensity habitat reduction and larval control at 3 fall described in Alert Level 2 facilities,water features and drainage systems Keep city Public Information Officer informed and throughout the city Initial confirmation of ready to disseminate the public information that Larvaciding of street drains/catch a WNV positive bird will be needed if adult mosquito spraying is basins in proximity to vulnerable or mosquito pool undertaken populations may be necessary at this collected before alert level,based on the experience of August 1 -Expand public information to include TV,radio other US cities in past years and frequent newspaper reports emphasizing OR a confirmed personal protection,particularly for persons over -Intensify efforts to encourage and coordinate equine or human case 50,as resources allow appropriate control responses by private agencies, (even if no positive businesses,and organizations with mosquito birds or mosquito -Mobilize community group efforts for mosquito habitat,facilities,water features and drainage pools have been source reduction such as neighborhood clean up systems under their authority detected) days;provide prevention information at community festivals,health fairs and outdoor events -With direction and technical support from Public OR sustained high Health,be prepared to respond if Public Health levels of WNV -Encourage citizens and community partners to determines specific areas of high human risk and activity in birds or actively assist elderly or disabled residents with the need for limited,targeted adult mosquito mosquito pools in the source reduction,screening windows,screen spraying within your jurisdiction absence of equine or repairs,and use of mosquito repellents and other An example is spraying of a park the human cases protection day before an evening public event such as a outdoor concert Moderate risk of -Review criteria and plans for more wide-spread human outbreak adult mosquito spraying efforts should the Alert Level increase to Level 4 Alert Definition Surveillance Response Education Response Control Response Level Spring,summer or -Continue with surveillance activities -Intensify efforts described in previous alert levels -Continue intense larval control and habitat 4 fall described in Alert Level 3 with emphasis on reduction determining areas with significant populations -Engage local community leaders and Surveillance indicates of adult mosquitoes of vector species government officials to speak about WNV -With direction and technical support from Public a high risk of human Health,initiate on-going adult mosquito spraying infections,as shown -Enhance risk communications to public and program in high risk areas by indicators such as: owners of private facilities,water features and a)high dead bird drainage systems about adult mosquito spraying -In conjunction with state agencies or Public densities starting in Health,monitor effectiveness of spraying on target early summer;b) mosquito populations when adult spraying is done sustained high mosquito infection rates;c)multiple positive mosquito species;d)equine or mammal cases indicating escalating epizootic, e)a human case with high levels of bird,mosquito or equine infections;f) areas with early WNV activity that experienced epidemic conditions in past years High risk of human outbreak Spring,summer or rJ fall -Conduct surveillance to monitor effectiveness -Intensify public risk communication about adult Intensify adult mosquito spraying,repeating of mosquito spraying through trap counts and mosquito control spray applications until surveillance indicates Multiple confirmed infection rates of vector mosquito species adequate mosquito control human cases; -Consider distribution of mosquito repellent conditions favoring products at public events,especially those held in -If outbreak is widespread and covers multiple continued trans- the evening jurisdictions,coordinate spraying and control mission to people activities with neighboring counties and through (e.g.,persistent high -Emphasize urgency of personal protection the WA Dept of Health infection rates in against mosquito bites through community leaders mosquitoes,con- and the media;emphasize use of repellents at tinued avian mortality visible public events due to WNV) -Conduct active educational outreach and distribution of repellents in homeless,low-income Human outbreak and non-English speaking communities in progress -Consider distribution of door knob hangers in communities with high number of human cases Guidelines for a Phased Response to West Nile virus using surveillance data The phased response plan uses a range of surveillance data and the timing of the surveillance findings to guide community response to the threat of Public Health staff are responsible for compiling, mapping, and monitoring West Nile virus (WNV). The principal goal is to minimize the health impact of the range of WNV surveillance data (e.g., bird, mosquito, equine, and human WNV in our residents, as well as in domestic and zoo animals and in wildlife. cases) and determining the WNV Alert Level that guides the phased We have a limited (but increasing) understanding of the ecology and response. Public Health will keep municipalities and partner agencies epidemiology of arboviruses such as the West Nile virus in the US, so it is appraised of the current WNV Alert Level through e-mails to the WNV important to realize that predicting the arrival and intensity of WNV activity in Interagency Work Group and on the WNV website at any given area is difficult. It is also important to note that, while prevention http://www.metroke.gov/westnile. and control measures will aid in mitigating the effects of WNV in a community, it is unlikely that human infections can be entirely prevented. City officials are encouraged to seek consultation with Public Health—Seattle & King County in interpretation and application of these phased response Surveillance for WNV in dead birds (especially in crows,jays, and raptors) guidelines. We also encourage cities to join the Public Health-sponsored can be expected to provide the earliest warning of the arrival of West Nile WNV Interagency Work Group which meets periodically from spring through virus each season, therefore, residents and city governments are asked to fall and which keeps members informed of surveillance findings, assist Public Health in its dead bird reporting and testing program. recommendations, and educational resources through regular e-mail Surveillance for mosquito larva is another critical component which is used to communications. guide cost-effective mosquito control efforts; city governments are asked to monitor for mosquito larva in city-owned properties and report results to Dr. Sharon Hopkins of the Environmental Health Services Division is Public Public Health. Public Health also has programs for surveillance of WNV in Health's lead for the WNV Program and is available for questions and captured adult mosquitoes ("mosquito pool testing"), monitoring of WNV technical assistance. She can be contacted by e-mail testing performed by local blood centers, and for collecting reports of equine (Sharon.Hopkins(a)-metrokc.gov)or telephone (206-205-0495). Leah Helms and human cases of WNV. is the WNV Program Coordinator and can be reached at 206-296-3998 or Leah.Helms(a�metrokc.gov. The mailing address is 999 Third Avenue, Suite Cities should also be aware that new mosquito habitat is being created 700, Seattle, WA 98104. The FAX number is 206-296-0189. continually by housing developments, public and private construction projects, flooding, and land use changes. Periodic assessments should be We also encourage city officials to review the many WNV resources available undertaken to identify new mosquito habitat and implement surveillance if at our web site at http://www.metrokc.gov/health/westnile/. necessary. Public Health—Seattle &King County, WNV Program, updated 212612007 WNV Interagency Work Group Subcommittee on Mosquito Adulticiding and Related Issues February 26, 2007 Meeting Minutes Attendees: Dan Willott, KC-DNRP; Shannon Kelleher, SPU; Phyllis Varner, City of Bellevue; Sharon Hopkins, PHSKC WNV Lead; Leah Helms, PHSKC WNV Coordinator; Amy Eiden, King County Prosecuting Attorney's office; Dorothy Tibbets, DOH, Manager Zoonotic Disease Program; Cliff Weed, Manager WSDA Pesticide Compliance Program; Joel Kangiser, WSDA Pesticide Compliance; Wendy Sue Wheeler, WSDA Pesticide Registration; Liz Dykstra, DOH Zoonotic Disease Program; Ben Hamilton, DOH Zoonotic Disease Program; Jenee Colton, KC-DNRP; Total Attended: 13 The purpose of this work group is to research issues pertaining to adulticiding (adult mosquito spraying) and determine how adulticiding would be best accomplished if it were needed to control a significant West Nile virus outbreak in King County. I. Introductions and Announcements • Welcome to guest attendees from Washington State Department of Health (DOH) and Washington State Department of Agriculture Pesticide Program (WSDA) • Sacramento Yolo County WNV manager and PIO visit on March 27th at Key Tower hosted by the City of Seattle. There will be a morning session for City of Seattle Employees and an afternoon session will be open for the KC Interagency Work Group to attend. An announcement to the work group will go out when the plans are finalized. • WNV Spring Training for Municipalities April 9th at Eastgate PH Office • Public Health Pest'Control license training April 18 & 19 in Bellevue WA. Announcement was handed out at the meeting. • Status of the WNV letter to the Mayors and City Managers: Public Health now has a new director, Dr. David Fleming. The letter was delayed slightly to allow for the transition of the new director. The letter will also include the revised Phased Response Guidelines. Revisions will be discussed at today's meeting. Any suggestions and comments will be considered for the final draft to be included in the Mayor's letter. II. Follow-up on issues and Action Items identified at our January 8th meeting Questions from our last meeting: Is there an emergency SEPA for emergency control? What are the general permit requirements for Adulticiding? What are the federal and local laws regarding fish windows? Are we required to post and if so then where? TV, Website, newspaper. Can cities identify exclusionary areas? Other factors include bees, fisheries, organic farmers, parks, schools and child day cares. What are the laws for posting and spraying around these areas? Is there a Public Health exemption in RCW-Washington State Laws for pesticide application? What are the legal issues around Pesticide Sensitive Individuals list? If the state declares and emergency will funding from state sources be available to locals? Questions for DOH: What will DOH role be in a human outbreak situation? How will DOH assist in coordinating adult mosquito control? On County Level? On City Level? Update about the new NPDES permit. Pesticide Application Regulations for Mosquito Control (WSDA) 0 References: RCW 17.21, 15.58 and WAC 16.228 • Is there a Public Health exemption in RCW-Washington State Laws for pesticide application? o There may be exemptions in some situations. The jurisdictional Health Officer may be exempt_..County or city HD may be exempt. See RCW. 17.21 • What are the legal issues around Pesticide Sensitive Individuals list? Are we required to post and if so then where? TV, Website, newspaper. o There is no posting and notification required o There is an exemption for the posting for adulticiding for mosquitoes and gypsy moth for emergency and non-emergency spraying. (note: check with ecology regarding additional requirements that may need to be met) o Probably good PR to notify pesticide individuals, organic farms etc. • What about Bees? WSDA opinion is that it is a moot point if there are incidental bee kills to foraging bees. Issues arrive if they receive a complaint about negligence and label violation from the bee keeper. WSDA will investigate. If there is no indication that bee keepers are near by and no knowledge that bees are out foraging then there is no violation. Most adulticiding for mosquitoes will occur at twilight or dusk. Bees are,unlikely to be foraging at this time. Issue would be if hives were sprayed directly. • What about Organic Farmers? WSDA has list of registered farmers. Impossible to tell from this list exactly where the fields are. As, some fields may be in production and others may not. Organic farmers may not always contact WSDA. Many times WSDA is only able to provide the name of the farmer and the county where their farm is located. To avoid problems precautions should be taken to use the product per the label, notify known farmers in the area, applicator to pay attention to signs posted and refrain from spraying areas that are posted. o Casef•Example: WSDA, DOH and Ecology investigated a human exposure case in 2005 that was related to application of Malathion for adult mosquito control by a MCD. DOH determined that the human exposure was probable. EPA investigated the human exposure and determined that the product was applied according to the label and was not a label violation. Other statutes from WSDA applied in this situation. Negligence and faulty application were determined based on the testimony of the applicator that saw the sign and knew that there was an organic crop and sprayed anyway. The person also had an organic farm. Malathion residue was found on the crop. The farmer did not loose their certification however was not allowed to sell the crop. o Complaints: Complaints are investigated within 24-48 hours at the site of the complaint. Testimony of the complainant is taken along with evidence that may include residue samples, foliage, water, and clothing. Samples are sent to a lab in Yakima. The pesticide label and application methods are also examined. o RCW 43.05 enforcement: may result in a notice of correction. WSDA can not go to civil penalty without restrictions. Some enforcement qualifications include property damage greater than $1,000, bodily harm, and repeat offence. WSDA can issue a notice of intent to suspend. • May want to establish best management practices (BMP) prior to implementing a spray program. Benton County MCD developed BMP to shut off equipment if pedestrian goes by. If there is an issue action would be taken against the applicator and not the county/agency. • Urban areas vs. rural areas: King County includes many rural and densely populated urban areas. How would this information apply to the urban environment? o Expectations would be the same o WNV would not change the parameters • How would this apply if we have a cluster of WNV cases in a residential neighborhood and it is determined that spraying in these areas is needed? What about protests and injunctions? o Be prepared o Lots of publicity / Implement media campaign / 1800 # for calls about one event o Education and prevention messages to the community prior to spraying to boost support for the work o Protests may delay the spraying program o Injunctions may be used to stop spraying. Legal issues need to be prepared ahead of time to deal with this. Gypsy moth spraying saw and injunction. Legal issues were dealt with by Mary Toohey ( WSDA) • Direct Application & Drift of Pesticide o KC is looking at using a Pyrethirin or a Pyrethorid product o Know the label well as there may be subtle differences on enforceable language on similar products o Even if label is silent on issue it may default to faulty application and negligence if not careful (i.e. application near water bodies) o Summethrin, language on label allows for acceptable drift in some situations and near water bodies ■ Does not allow for direct application ■ Okay for intermittent flooding ■ No drift restrictions • Question for Ecology (Action Item) o For Gypsy Moth spraying of Bt near vegetation that was near water bodies a water quality variance was obtained from Ecology o Could this also apply for Mosquito Control in the event of WNV. • What about Parks and Public Places for Cities? o Cities can close parks in the event of PH emergency for WNV out break to spray • What about Private vs. Public Property? Concern that spraying will cross property lines. Chemical Trespass? o WSDA- No label restrictions, no laws, no rule prohibiting, and no violation. If they receive a complaint then they will investigate the application of the spraying event o Would this be chemical trespass in King County? (Action Item to Follow up for next meeting ) o WSDA- For gypsy moth there was a block but the court ruled that the state has the right to spray ■ Gypsy Moth had lots of advance notice. ■ WNV will have maybe a weeks notice. • Who will decide when and where spraying will occur? o Phyllis Varner (City of Bellevue) suggested that Public Health should determine when and where the spraying will occur. o Criteria for when and where adult spraying would occur should be developed. III. How will DOH assist in coordinating adult mosquito control? On County Level? On City Level? • State of emergency can be declared several ways. DOH can request State of Emergency from the Governors office. Can also be requested regionally by the counties. • Local jurisdictions have broad authority. • DOH is looking at the statues and will begin a policy discussion soon with their senior manager regarding WNV. • DOH is not required to do mosquito control. Law allows them to do it if there are funds for it. Currently there are no funds allocated. DOH will not plan to provide mosquito control. • If a State of Emergency is declared this may release some funds. o Most likely will be distributed circumstantially on a case by case basis o There are no funds in DOH budget for mosquito control unless an emergency is declared o If multiple counties need response DOH can help coordinate if requested o DOH may be able to set up a hotline and provide some risk communication education • King County may want to involve Washington Toxics and the Audubon Society from an early stage in the planning IV. NPDES Permit update — Ben Hamilton DOH • New permit will be in place by March 7th • DOH will acquire NPDES and offer to other agencies for mosquito control • No SEPA if'acquired though DOH • Online application should be more simplified • DOH will issue a new release announcing the new permit • Information about the new permit will be discussed at the April 9th Spring Training in Bellevue • What does this mean for catch basin treatment? o Dipping exemption for closed systems o No dipping before treating o Encourage pro-active treatments o Dip still required for open and accessible systems o A protocol can be established with Ecology on a case by case basis for an exemption to dip some but not all open systems. Plans must be submitted early. o WNV language in the new permit: If there is WNV in the same season then there is no dip requirement (closed systems) o If we have positive WNV then can ponds be treated proactively? • SPU — peak of larvae activity in catch basins are weeks 29-34 (Late July — August) • Are combined storm sewer systems waters of the state? o Should be treated as if they are even if language is vague V. Update on KC-DNRP Contract for Adulticiding — Dan Willott • DNRP will make a request for bids through county bid process • The contract will include no guarantee for work • They will review multiple vendors and price • Assume that there will be some sort of "start up allowance" should services be required • Will price backpack, truck and aerial applications • DNRP will choose the type of product to be used • Response time of vendor will be considered. Who can provide us the best response? • Vendors may be limited in our area. • May have to contract with a national chain • Vendor must provide proof of current and updated list that applicators are properly licensed with WSDA prior to spray activity • KC may want to develop BMP • WSDA would like to monitor the application for a non ag use inspection • Would like to have contract in place by July • Process should be streamlined for cities to "tag on" • May need to be under Health's contract for other cities to be able to use • There would be no state contract • DNRP will have a draft of Standard Operating Procedures (SOP) by April 9th meeting VI. Review of the WNV Phase Response Guidelines for Cities and Agencies in King County Dr. Sharon Hopkins and Group Discussion Copies of the 2005 ed. and 2007 ed. were passed around for the discussion VII. Changes to the Phased Response Guidelines • Addition of risk of a human WNV outbreak o Alert level 0 - no risk of human WNV outbreak o Alert level 1 — Remote risk of human WNV outbreak o Alert level 2 — Low risk of human out break o AlertAevel 3 — Moderate risk of human outbreak o Alert level 4 - High risk of human outbreak o Alert level 5 - Human outbreak in progress • Alert level 5 is a new alert level for 2007 plan o See plan for definition, surveillance response, education response, control response for the alert level 5 o Consistent with CDC guidelines for phased response alert levels • Some additions to the definitions of Alert level 2 and 3. • Public Health staff are responsible for compiling, mapping, and monitoring the range of WNV surveillance data and determining the WNV Alert Level that guides the phased response Group Discussion • DOH also issues alert levels. They may not centralize their alert levels for this year. • How long will Public Health (PH) take dead bird reports after we have positive birds? o PH as county divided into 5 regions. After we have positive surveillance in one area we will stop collecting birds there. This would free resources to concentrate on mosquito trapping. PH will continue to take the dead bird reports regardless of WNV positive surveillance. PH takes dead bird reports year round. • Definitions for alert level 2 and 3 need clarification. Language is confusing. Contains double negative. o Definition of Alert level 2 should be changed to say "After August 1" o Definition of Alert level 3 should be changed to say " Before August 1" • Control response for alert level 3 should include language to say "With direction and technical support from Public Health" to introduce the paragraph that describes response of adulticiding in specific, limited and targeted areas. • Control response for level 4 discusses "on-going adult mosquito spraying program in high risk areas. How often do you have to spray and how will this be monitored o In other areas that have sprayed for WNV they usually have to spray every 2-3 weeks. The goal is a quick reduction of adult mosquitoes and a drop in human cases. o Will be monitored by mosquito trapping pre and post spray. Vlll. Action Items for Next Meeting • Next meeting should be scheduled for the end of March • Update on status of DNRP contract for mosquito control • If we have positive WNV then can ponds be treated proactively? • Public vs. Private Property for adult mosquito control. • Define chemical trespass • Check with Ecology regarding variance / exemption for water bodies, fish windows for emergency mosquito control. References and Attachments for Items discussed at this meeting Updated Phased Response guidelines with changes and edits discussed at the meeting included. WNV Phased �sponse rev 02_26_ RCW 17.21 Washington Pesticide Application Act http://apps.leg.wa.gov/RCW/default.aspx?cite=17.21&full=true RCW 15.58 Washington Pesticide Control Act http://apps.leg.wa.gov/RCW/default.aspx?cite=15.58 WAC 16-228 General Pesticide Rules http://search.leg.wa.gov/pub/textsearchNiewRoot.asp?Action=HtmI&Item=1&X=301132055 &p=1 RCW 43.05 Technical Assistance Programs http://apps.leg.wa.gov/RCW/default.aspx?cite=43.05 West Nile Virus Interagency Workgroup Subcommittee on Mosquito Adulticiding & Related Issues 4th Meeting, March 29, 2007 1 :00 — 2:30 pm Eastgate Public Health Office AGENDA Announcements ■ WNV Spring Training for Municipalities April 9t" at Eastgate PH office ■ Public Health Pest Control license training April 18 &19 in Bellevue ■ Distribution of slides from Sacramento-Yolo MVCD talk on 3/27 Follow-up on issues and action items identified at previous meetings ■ Progress on DNPR contract for adulticiding (Dan Willott) ■ Legal issues around adulticiding adjacent to or over private property (Amy Eiden) New business ■ Follow up actions subsequent to visit by Sacramento-Yolo MVCD Manager and PIO ■ Is this group interested in promoting concept of vector control districts? • Determine date and action items for next meeting Public Health Seattle & King County HEALTHY PEOPLE. HEALTHY COMMUNITIES. West Nile Virus Response Plan West Nile virus (WNV) is spread by the bite of an infected mosquito. Since 1999, when the first U.S. outbreak occurred on the East coast, the virus has spread across the United States. WNV will present a considerable challenge, in part due to minimal historical data on mosquitoes in King County. In order to launch and sustain a science-based and appropriate response, data about mosquito habitats,breeding seasons, effective control mechanisms and other relevant information are required to tailor King County's response to our community. It is important that the King County WNV plan be flexible so that as more knowledge is gained on WNV we are able to formulate and modify appropriate responses. For background information on WNV see Appendix A. Links to additional information may be found in Appendix B. The plan has three main components—Education, Surveillance, and Control. Laws and regulation are also briefly addressed. The plan provides a science-based, regional framework to control WNV. While Public Health— Seattle & King County(Public Health) is the County lead for WNV response coordination, the plan addresses actions to be taken by other county agencies including the Departments of Natural Resources and Parks (DNRP), Transportation(KCDOT) and Development and Environmental Services (KCDES). For other jurisdictions and for private lands the plan provides suggested strategies. Education Public Health Education is the key Public Health strategy and role. We are developing messages both for the public as well as for partner agencies to distribute. When new WNV staff are hired, an education and outreach program will be developed. A media strategy is also planned. The key messages for the public address risk, habitat reduction, personal protection and mosquito avoidance. Community Outreach • Identify audiences (at-risk populations, Healthcare for the Homeless Network, shelters, soup kitchens, outdoor recreation stores, realtors, gardening stores and groups, etc.). Spring • Develop a distribution plan. Spring April 2003 1 • Respond to emails and phone calls from the public (Public Health is already receiving a large volume of emails from concerned residents). Send materials when requested. On-going • Visit each suburban city and drop off materials. Spring • Provide materials, outreach visits, presentations to major groups. Spring-fall • Work with cities to create WNV presentations for city personnel to deliver. Provide other information/be a resource.As needed. • Update WNV video. As needed • Update and add educational materials. On-going • PH Veterinarian: serve as departmental leader in a team facilitating activities related to WNV. Give presentations to appropriate audiences. Work with zoos. On-going • Develop guidance related to mosquito control for homeowners. On-going • Provide media response and messaging. On-going Pest Control Operators (PCOs) • Develop a list of contacts for internal use. Spring • Make available the latest information to PCOs. On-going • Identify capacity in the PCO industry to address anticipated control work needs. Spring • Supply PCOs with information to bring to consumers, act as PCO resource. Spring Medical Provider Education • Public Health's Communicable Disease Control, Epidemiology and Immunization section will develop educational materials and information for health care providers on recognition, reporting, diagnosis and management of WNV cases. On-going Internal Audience—King County Letter from Executive Sims to County employees regarding WNV and personal protection April • Continue to meet with County agency partners in a working group; advise on habitat reduction on county properties. On-going KCDNRP, KCDOT, DDES and Executive Services (KCES) These departments will have Public Health and other materials for distribution to staff and residents.As needed Surveillance Surveillance (larval, adult mosquito, bird/mammalian, and human)will be critical in the coming months. Larval surveillance is key for control work. Tracking adult mosquitoes may provide additional information about areas with mosquito infestation. Adult trapping allows easier identification. Bird surveillance provides information about arbovirus April 2003 2 activity, perhaps in geographically discrete areas. For a list of potential WNV mosquito vectors in King County, see Appendix C. Larval surveillance Public Health • Increase larval collection to more than 50 samples (last year's level) Spring/summer • Advise cities to do larval surveillance on their own properties, link them with the state DOH, who will provide training On-going • Work with Farm Management program on volunteer surveillance On-going • Enter data into GIS database As received • Analyze data from database to help predict where larval control work should be done On-going • Facilitate meetings between cities and state DOH to increase overall county larval surveillance Spring • Procure mosquito surveillance equipment. Spring KCDNRP and KCDOT • Staff may be asked to gather information on larva numbers captured at various King County-owned locations in the unincorporated areas of the County. Information will be gathered as part of a routine investigation of a mosquito complaint, during larval control efforts, during routine maintenance activities, or at the request of Public Health. Adult mosquito surveillance Public Health • Develop a database to receive new complaints and incorporate previous complaints. Data will be entered into the database for GIS mapping. In place mid-March • Adult trapping, driven by clusters of bird deaths or other data.As needed • Field visits to some complaints-- one-on-one property-owner education. Spring-Fall • Limited enforcement is possible through solid waste regulations. KCDNRP and KCDOT • Mosquito trapping surveillance may be carried out by County agencies or other entities at the request of the Public Health. As needed • Mosquito complaint calls will be summarized on a weekly or monthly basis. Information collected will include name, address, parcel number, and comments that will be sent to Public Health for inclusion in their tracking system. On-going Dead bird surveillance Public Health • Increase the number of dead crows collected (per state DOH resources). April 2003 3 • Focus on the collection of freshly dead birds (deceased less than 24 hours). Rapid detection and collection of dead birds provides quicker results for surveillance. • Administrative staff will enter dead crow reports into database for GIS mapping. As needed Human Surveillance Public Health • Public Health's Communicable Disease Control, Epidemiology and Immunization section will conduct surveillance for human cases of WNV among persons with compatible illness in accordance with Centers for Disease Control and Prevention and the Washington State Department of Health protocols. Health care providers in King County will be informed of the details of the surveillance system in late Spring. Control The intent of mosquito control is to address health issues related to mosquito borne diseases, in this case VVW. Public Health is not recommending that topical mosquito control be undertaken for nuisance control or aesthetic reasons. Public Health will continue to respond to mosquito nuisance complaints by providing information on owner- initiated mosquito control. King County's Integrated Pest Management policy is intended to limit the use of pesticides and encourage the least toxic agents, and low impact methods where possible. Accordingly, this plan does not recommend mosquito control in sensitive areas such as wetlands. Several methods of control are being considered, including reduction of artificial habitats and larvicidal agents to kill immature mosquitoes. Under extreme circumstances adulticides may be considered but since they are less effective, more toxic, and often require aerial spraying, adulticides are a last option. Larvicides, often in the form of briquettes or pellets, are applied to aquatic areas where mosquitoes lay eggs. Permits and licenses are required to apply larvicides to state waters (essentially any body of water that drains or connects to a natural water body). Public Health will not do any control work except for habitat reduction on its own properties. Public Health's main"control" function is to provide a scientific framework and advice to governmental and other entities for control work on their properties. Habitat reduction Public Health • Education. On-going. See Appendix F, "Basic Recommended Actions" for details. • Limited enforcement might be possible through solid waste regulations. • Field visits based on complaints -- one-on-one property-owner education. Spring-fall April 2003 4 KCDNRP, KCDOT and KCES • In addition to parks, King County government owns and maintains solid waste facilities, wastewater facilities, about 1400 storm water drainage facilities, 30,000 catch basins and many miles of roadside drainage ditches in unincorporated King County. As a major property owner, King County government's activities will address habitat reduction as described in Appendix F, "Basic Recommended Actions," habitat modification, potential facility modifications and repairs. 1. Habitat Modification Habitat modification ranges from removing potential small artificial habitat such as containers to changing the physical features of a facility. County agencies are responsible for managing any County owned or maintained property and will follow the same basic mosquito control measures being recommended to the public. See Appendix F for a list of typical recommended actions. 2. Physical Modifications or Repairs. The first consideration at any facility with artificial mosquito habitat should be whether it is practical for the problem to be reduced by physical modification or repair. See Appendix F for a description of these efforts. Larval Control Public Health • Public Health will offer advice but will not perform or pay for control work. County and other government property owners will be advised to examine and assess habitat for larva presence (especially catch basins, retention ponds, other bodies of water) and to possibly do larva control when larvae are present. Possible criteria for larviciding include: 1. proximity to housing 2. densities of populations over age 50 3. community concerns voiced 4. incidence of mammalian/bird cases. • Public Health has no legal authority to require jurisdictions to control habitat and conduct control work. Public Health will assess what each city/agency is doing. Spring fall • Public Health will not require private property to owners to apply larvacide,but will offer options and advice that can be used based on specific circumstances. On-going • Public Health will facilitate workshops for cities to understand county efforts, explain processes related to licensing and permitting. March -April • Public Health will evaluate larviciding efforts to assess efficacy of method. Winter 200312004 April 2003 5 KCDNRP, KCDOT, and KCES Aside from habitat reduction, two options for killing mosquitoes exist—natural (predator) control and artificial control. For information on the possible vector species found at various facilities, see Appendix D. 1. Natural Control • One long-term strategy is to introduce natural predators, which feed on mosquito larva. Any future decision to do this will be made in cooperation with the Washington Department of Fish and Wildlife (WDFW). See Appendix F for details. • Natural predators include amphibians, such as frogs or salamanders, and insects such as water beetles or dragonflies, birds, and bats. 2. Larvicidal Agents Any pesticide application to the waters of the state requires an NPDES permit prior to beginning any control actions. King County is applying for an extension of the Washington State Department of Health coverage under the existing Washington State Department of Ecology Mosquito Control NPDES permit which was issued in 2002. The KCDNRP's Water and Land Resources Division(WLRD) has reviewed the evidence available and is recommending that there is a benefit to providing early limited larvicide treatment at selected stormwater ponds. This recommendation is based on: 1) The recommendation by the State Department of Health; 2) Consultation with Public Health— Seattle &King County; 3) The results of the technical memo drafted by the WLRD Science Monitoring and Data Management Section"Ecological Assessment of three Larvicides for Mosquito Control in Stormwater Ponds (dated March 7, 2003); and 4) The results of 2002 stormwater pond study that indicated the presence of a primary vector species. • The best time to control mosquitoes is when they are in the larval stage. There are several products that can be used to control mosquito larva. Based on the information available for the ecological assessment, the preferred larval control agents to be used on County properties are: Bacillus thringiensis israelensis (Bti) and Bacillus sphaericus (Bs). Methoprene products, Monomolecular surface film (MMF), and Golden Bear Oil are products covered under the permit applied for by the State Health Department. Since methoprene impacts other aquatic insects and potentially some fish, its use by KCDNRP will be limited to extremely rare cases or a significant outbreak of the WNV. See Appendix E for a description of each larva control measure. • Facilities will be selected for potential treatment if they meet the following criteria: 1. There is water in the facility with mosquito larva present, or adult mosquitoes attempting to lay eggs. 2. The pond is adjacent to residential or commercial buildings. April 2003 6 3. The pond is located in an area of concern with regards to the number and density of residents over 50 years of age. 4. No natural predators are apparent or the mosquito population exceeds a minimum of 0.3 larvae per dip sample in spite of the existence of natural predators. 5. Habitat modification or natural controls are not practical or have not had a chance to take effect. Based on these criteria, KCDNRP will begin a larviciding program on selected stormwater ponds as needed throughout the mosquito season Similarly, a KCDOT program to larvicide its storm water ponds would be conducted as needed throughout the mosquito season. There are over 30,000 catch basins in the KCDOT road right-of-way located primarily throughout the urban unincorporated area. Treatment of all of these facilities would be cost prohibitive. Control activities for catch basins will be based on the criteria listed above. The preferred method of control at catch basins will be vactoring. Laws and Regulations There are no current BOH or other local regulations dealing with mosquitoes. Some enforcement of mosquito habitat minimization may be possible through solid waste code (i.e., where solid waste is the primary violation and mosquito habitat is also present). The King County Board of Health will review regulatory options in April. Budget Appendix I contains Public Health, DNRP, and DOT estimates of costs needed to implement this plan. Costs may increase as the season progresses and WNV related conditions change. April 2003 7 Appendix A West Nile virus background West Nile virus (WNV) is an arbovirus (arthropod borne virus) that is transmitted to birds and mammals through the bite of an infected insect, generally mosquitoes. Birds, especially those of the Corvid (crow) family frequently act as a host to the virus and can pass it back to an uninfected mosquito. Mammals do not appear to be able to transmit the virus back to mosquitoes. The majority of people and animals who acquire the virus have mild flu like symptoms that frequently go unnoticed. However, of those who do become symptomatic, a small percentage may develop a form of encephalitis, which can be fatal. West Nile Virus first appeared in the U.S. in 1999 in New York. Initially, it was diagnosed as St. Louis encephalitis. Prior to its introduction in the U.S., West Nile Virus has been present in Europe and Africa since its first discovery in 1937. WNV is related to St. Louis encephalitis, which has been present in the U.S. for decades. According to the U.S. Center for Disease Control, approximately 1 in 150 people infected develop a severe illness. The case counts for the U.S. since the introduction of the disease is: Year No. of States Clinical Cases Deaths 1999 4 62 7 2000 12+DC 21 2 2001 27+DC 66 9 2002* 44+DC 4161 277 The disease is also known to affect several hundred species of birds and mammals. Most notable are horses and corvid birds (crows,jays, etc.) * 2002 Case count as of 4-8-03 April 2003 8 Appendix B Additional resources More information on WNV and links to related web sites can be found through the following Internet links: Washington State Department of Health: http://www.doh.wa.gov/ehp/ts/Zoo/'vNNV/Vv'NV.html Washington State Department of Health WNV response plan: http://www.doh.wa.gov/ehp/ts/Zoo/WNV/WAArboviralRespPlan.pdf Public Health— Seattle &King County: http://www.metrokc.gov/health/westnile/ U.S. Center for Disease Control: http://www.cdc.gov/ncidod/dvbid/westnite/index.htm King County Department of Natural Resources and Parks http://dnr.metrokc.gov/dnradmin/press/2002/0916wnv.htm Environmental Risk Program at Cornell University: http://www.cfe.cornell.edu/ergp/WNV/ Information from EPA on insect repellent containing DEET http://www.epa.�,ov/pesticides/factsheets/chemicals/deet.htm April 2003 9 Appendix C Possible West Nile virus vector mosquitoes in King County To date, eight species of mosquitoes in King County have been associated with the West Nile Virus. Two of the eight species are considered to be the most likely vectors for WNV once it arrives in King County, these are culex pipiens and culex tarsalis. The other species have been associated with WNV positive tests, but may not be efficient carriers of the disease. Pending the results of additional research, King County control efforts will focus on the culex species. A brief description of each species follows and Appendix D shows the habitat types and the associated vector mosquitoes favoring each habitat. Knowing the preferred habit for each species of mosquito can help determine the best management strategy. The following information is taken primarily from Darsie and Ward(1981) and Meyer and Durso (1998). Culex pipiens, the "northern house mosquito', occurs in foul water with a high organic content, such as catch basins and stormwater ponds. It is a primary vector of St. Louis Encephalitis and has been implicated in the transmission of dog heartworm. Females feed at dusk or after dark, readily enter homes and prefer avian hosts, but will also feed on large mammals, including man. This species occurs throughout the northern United States and Washington. Culex tarsalis, the "western encephalitis mosquito', may be found in any standing fresh water, especially around agriculture. It is the most important vector of arborviruses in western North America. It prefers to feed on birds, but will also feed on large mammals and man after birds are done nesting. This species is widespread in North America and may be found at all elevations. It is an important encephalitis vector where that disease is present. Aedes vexans, the "inland floodwater mosquito', occurs in all types of floodwater situations, including roadside ditches and mud puddles, temporary pools formed by flooding in creek bottoms, and water pooling from irrigation. Eggs may lie dormant in soil 3 years or more, until the area becomes wet again. Some do not hatch until re-wetted several times. Adults are good fliers and capable of dispersing 5-15 miles from where they emerge. This species is likely present in many stormwater ponds, is a vicious day biter but rarely enters homes, and is widespread throughout North America. Aedes cinereus is a woodland species, usually found in permanent bogs and marshes. The larvae are secretive and tend to hide among aquatic vegetation or under leaves. Adults emerge primarily in early spring and are known as "ankle biters"because they tend to attack people around the lower legs. They are aggressive biters but often are not noticed because people are distracted by other species in their face. This species is widespread in North America, except in the and southwest. Anopheles punctipennis, the "woodland malaria mosquito', prefers algae-laden pools along the edges of slow moving streams and rivers. This species rarely enters homes, April 2003 10 tends to be a night biter, and attacks man outdoors in woodland or foothill situations. It is found throughout Washington State and is widespread throughout much of the U.S. and North to central British Columbia, Canada. It is likely to be found where springs or creeks are associated with stormwater ponds. Coquilletidia perturbans larvae occur in permanent marshes with emergent cattails and tulles. This species is unique because the larvae attach to roots and stems of aquatic vegetation and cannot be controlled with surface treatments like Bti or oils. Only products like methoprene are effective against this species. Adults are vicious biters and feed at dusk or after dark. This species has a single generation per year and is found throughout most of North America. Culiseta inornata, the "winter mosquito", is an unusually large mosquito that occurs in a variety of sunlit habitats including ponds, irrigation or glacial runoff, rain pools, salt marshes or even artificial containers. It is an early season species and does not like hot weather. This species is widespread in North America at all elevations. Ochlerotatus japonicus larvae are found primarily in artificial containers or tree holes. This species was first identified in New Jersey in 1998 and has now spread to thirteen other states and Quebec, Canada. All other states where it is found are in the northeastern United States; the only western record is from King County, Washington. April 2003 11 Appendix D Disease vector mosquito species associated with drainage control facilities Habitat Type Facility type Vector Species Permanent Water Year round wet ponds Anopheles punctipennis Larger Regional Ponds Culex pipiens Wet Bioswales Culex tarsalis Marshes&Wetlands Wet Bioswales Adedes cinereus Some Regional Facilities Coquilletidia preturbans Temporary or Flood Water Temporary Wet Ponds Adedes vexans Dry Bioswales Culiseta inornata Retention/Detention Ponds Culex pipiens Open Ditches Culex tarsalis Artificial Containers/Tree Holes Catch Basins Ochlerotatus japonicus Underground TanksNaults Culex pipiens Discarded containers&Tires Culex tarsalis Culiseta inornata April 2003 12 Appendix E Larvicidal control methods under consideration Bacillus thuringiensis israelensis (Bti) is a naturally occurring bacterium, which is used to disrupt the feeding abilities of aquatic fly larva. Bti is specific to fly larva and has little known impact on other species. In order for it to be effective the mosquito larva must ingest it, once the larva shifts to the pupae stage, Bti is no longer an effective control. Depending on the form of Bti used and water conditions, it has a residual life of 1 to 30 days. Bacillus sphaericus is also a naturally occurring bacterium, which disrupts the larva feeding abilities. Bs is best used in water with a high organic content. As with Bti, it is specific to fly larva and has little or no impact on other species. The residual life of Bs is 1 to 4 weeks. Methoprene is a chemical growth inhibitor,which prevents the mosquito larva from progressing to the adult stage. Since this chemical also may impact other insects and fish, it is not recommended for use where it will easily move into natural water bodies. Methoprene does not have to be ingested by the larva to be effective. Depending on the form of methoprene used, it has a residual life of 2 to 21 weeks. In a closed pond or a situation where there is little chance of outflow to natural water bodies, the long term version of methoprene may have a good cost/benefit ratio since it may be effective for most of a breeding season. This would reduce the need for staff to reapply pesticides through the summer months. Monomolecular surface film (MMF) is a pesticide that forms a thin layer on the water surface and makes it difficult for the mosquito larva to maintain its position at the water surface where it needs to be to breathe. In addition, adult mosquitoes trying to land on the water surface to lay eggs will become trapped in the water and drown. Although MMF has little impact on fish and other invertebrates, it will affect other insects that rely on a water surface tension. This is a reasonable method to use where a rapid impact is desired. It is not effective on the coquilletidia perturbans mosquito larvae that attach to cattails for breathing. This control agent is not suitable in windy conditions where the material will be dispersed by water movement. Golden Bear Oil is a light oil that can be sprayed onto the surface of the water. The thin layer of oil clogs the breathing tube and suffocates the larva and pupae . This is effective on both the larva and the pupae, but it also impacts other aquatic organisms. Use of Golden Bear Oil should be kept to a minimum. As with MMF, it is not suitable for windy conditions. April 2003 13 Appendix F Mosquito control measures 1. Basic recommended actions • Empty anything that holds standing water, such as old tires, buckets, plastic covers, and toys. • Change water in birdbaths, fountains, wading pools and animal troughs weekly. • Remove unused containers—bottles, cans, and buckets that may collect water. • Make sure roof gutters drain properly, and clean clogged gutters in the spring and fall. • Fix leaky outdoor faucets and sprinklers. 2. Habitat reduction/Physical modifications or repairs When considering a facility for mosquito control, the first consideration should be whether the problem could be reduced by physical modification. In general this is not going to be a practical alternative for drainage facilities. Most facilities serve water quality and flow control functions, with specific design features to enhance those functions. Modifications to the features may compromise the function. Physical modifications must be designed or reviewed by an engineer to insure they meet applicable design requirements. Possible design modifications may include changes to the flow rate, enabling the facility to drain sooner; eliminating low spots, which collect small amounts of standing water; or removing vegetation. Alternatively, if a pond can be deepened or made into a permanent wet pond, the conditions for natural predators may be enhanced. Repairs may include scarifying the pond bottom where it is no longer infiltrating as originally designed, reshaping the pond slopes to eliminate isolated pools of water, and cleaning the pond to remove inappropriate vegetation. Mosquitoes will use the lifting hole in the access covers for catchbasins, tanks, and vaults to get into the structure and either breed or shelter from the heat of the day. If possible they should be denied access by covering the hole with a"Tracy Patch", which is a piece of duct tape covering the hole. When the tape is removed to access the structure it should be replace with a fresh piece of tape. 3. Natural control options: The WDFW is investigating whether there are native minnows or fish that may be appropriate for introducing into ponds or wetlands which may not have a native population established. WFWD may also approve the use of gambusia(mosquito fish), which are a non-native species, but only in situations where they will not escape to natural waterways. April 2003 14 Appendix G Focusing the response Surveillance and control efforts will be prioritized based on indicators of the level of risk expected to be experienced by specific areas or locales. Indicators of increased risk include combinations of these factors: • The documented presence of West Nile virus (WNV) in an area or locale; • Concentrations of dead crows or birds that might indicate the presence of WNV prior to laboratory confirmation; • Concentrations of people over 50 years of age, the age group most vulnerable to WNV infection morbidity; • Concentrations of people whose circumstances increase their mosquito exposure (e.g. unsheltered homeless, outdoor activity participants such as play-field and park users and outdoor concert attendees); • Concentrations of complaints concerning adult mosquitoes or breeding habitat; • Proximity to shallow, still bodies of water that can provide mosquito breeding habitat; and • Other factors identified as knowledge of WNV evolves. Areas or locales will be ranked using the above risk-related indicators. Those ranked most highly will be the main focus of surveillance and potential control efforts. In addition to focused surveillance, geographically representative sampling of mosquito breeding habitat will be attempted in both urban/suburban and rural areas as county and external resources allow. Nonprofit organizations, such as equestrian groups, may be encouraged to assist with surveillance in rural communities. April 2003 17 5 rs 88992�07 � i y Renton 94 U3 23J59i 8 9 7 1 9 5 12 23059U5U 88 Neighborhood Detail Map/S to M p 16thl _r F -�ir- t i 0 1000 2000 f a I 1 : 12000 ` t � � x U a` -- v Pi6 IECT.LD=S ar . 4_x L�. > I } t ' i w.._ _. LEGEND f - r. F� r ( :t CITY OWNED f I AUTHORIZED r i VINEM PUBLIC ESMT. Note:TREATMENT WILL NOT BE APPLIED WITHIN 100' OF WATER. TREATMENTS WILL NOT BE PERFORMED NEAR HOMES.TREATMENT WILL ONLY BE DONE ON THE UPLAND AREA BETWEEN THE WETLAND EASTERN EDGE AND THE RESIDENTIAL AREAS.PROPERTY OWNER APPROVAL REQUIRED PRIOR TO TREATMENT ON PRIVATE PROPERTY. Mosquito Abatement Program (2007) M:\831MSTORM\MAPSlmosquito-abatmt\07treatemnt.dwg ;7rYk7i�'i7i7r'Y� riTiTi I/ i:xS.i'�i7�?7c}Ti) f'�ii�r i YId I !i 1'iWxTixS]r7f77 � r: IYk7itix7Jkf:3 �• >+ r1 r � WO LsS,�Jl.0.5�J1R1 � ..• = , nlF7c7jXir7i7i'k] t7�Y3C7'i�Ii7:1 ,� y 01 f: 99r r r � Xi1C!'iXi ��, • 889 M Giles' 1 y.�yy- :Tr 7:TrL•�Ji�j 1 r 1 ." (•TXXY O ' i MAP Legend '_I County Boundary Parks NB Neighborhood Business x Mountain Peaks Unincorporated KC Zoning - C0 -CornmunityBusiness Highways A•10 Agricultu rat.one DUparl0acres RD Regional Business f Forest Production District A 35 Agricultural.one DU pot 35acres O Office f Boundary F -Forest I•Ind uslnal Agricultural Production M Mineral Q 'Other District Boundary RA 2.5-Rural Area.one DU par5acres 2005 Color Aerial Photos Urban Growth Area Line RA 5•R u ral A roa.one D U per 5 acres RA•10-RuralAroa.one DU per 103cres Incorporated Area UR-Urban Reservc.ono DU par 5 acres Streets R,1 Residential.one DU per acre Nig R C Resident ol.a D U per acre Arterials; R 6 Residentlal.6 DU per acre Local R-8 Resident ol.8 D U per acre -- Lakes and Large Rivers LJ R 12-Residential.12 DU per acre ,Al Streams R18•Residential.18DU per acre DTribal Lands R•24 Residential.24DU peracre Parcels R 48 ResidentiaL38DU paracre (cont) The information included on this map has been compiled by King County staff from a variety of sources and is subject to change without notice.King County makes no representations or warranties,express or implied,as to accuracy,completeness,timeliness,or rights to the use of such information. This document is not intended for use as a survey product.King County shall not be liable for any general,special,indirect,incidental,or consequential a damages including,but not limited to,lost revenues or lost profits resulting from the use or misuse of the information contained on this map.Any sale of King County this map or information on this map is prohibited except by written permission of King County. Date:7/9/2007 Source:King County MAP-Property Information(http://www.metrokc.gov/GIS/iMAP) 0 -*0 Drainage Ditch Dist No 1 O Springbrook Creek y � y - O Lind Ave S u Lind Ave S Lind Av SW CD CIO N C r--� Valle Rd �+ - VaHeyRd ET71 -C� -T E Valle CD y Rd NE, CT) TT— Lt F r ew y Ile r �'ee wetlands -- y` r ; ' I V C . r _ T_ at c � ve 00 b rri e i 0 p 0 0/ LL L—,,eCT) - i rs 0 o 0 a 0