Aquatic Mosquito Control General Permit Public Comment

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March 16, 2010 Mr. Jon Jennings Aquatic Pesticides and CAFOs Water Quality program Washington State Department of Ecology P.O. Box 47600 Olympia, WA 98504 SUBJECT: Comments from Mosquito Control Districts Dear Mr. Jennings, Enclosed is a compilation of letters from Mosquito Control Districts of Washington State. Each District has a distinct geography and individual challenges, yet the ultimate goal is the same; to serve the citizens of the State of Washington by reducing mosquito populations. Thank you for the opportunity to comment on the Draft Aquatic Mosquito Control NPDES General Permit. We greatly appreciate the extra week that was granted by the Department of Ecology for additional public comment. We hope that you will carefully consider the comments made by the Mosquito Control Districts as you finalize the permit. We request the opportunity to meet with members of your department again in mid-April to discuss any changes that are to be made. A meeting place of Ellensburg was suggested at the hearing in Moses Lake. Washington has a long and successful history in mosquito control. The people have come to rely on our public services and our knowledgeable professionals. In the coming years as West Nile virus continues to spread throughout the state, and afterwards when the disease is endemic, it is increasingly important for Mosquito Control and Ecology to work together addressing the concerns of the citizens. Please feel ...

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We need Adulticide to Prevent Epidemics Washington State has had several outbreaks of mosquito transmitted disease. Malaria was even found in this state in the latter part of the 19th century and early part of the 20th. Before mosquito control district were established these diseases were a problem. In fact, the first mosquito control districts were established because of these diseases. If one infected person travels into an area with a large vector population we can have the same problem again. Reducing the mosquito population is the best way to insure that these diseases don‟t come back. Just because these diseases are no longer a problem here, is no reason to stop doing what has been most beneficial to eradicate these diseases in Washington State. After all we still vaccinate our children for those diseases that really are no longer a problem. You can‟t keep mosquito populations low enough with larvicide and habitat modification alone. In fact, large scale habitat modification is almost impossible these days and “mosquito fish” are not permitted in waters of Washington State. At some point each season every mosquito control district needs to use adulticide. Most districts use only ground based adulticide. We have developed our programs so that adulticiding is at a minimum but it is still needed; not only for mosquitoes when they are carrying disease, but when they are multiplying to such a point that they can become a threat to human health. After all, it just takes one person returning from Africa or Asia with a mosquito transmitted disease to start an epidemic. DOE must not prevent us from doing what we have always done to insure mosquito borne diseases are not readily transmitted in our state. The draft permit would essentially prevent us from doing any adult mosquito control until disease is well established. Waters of the state is defined too broadly. There is no way we can adulticide and still insure no residual is deposited in “waters of the state.” After disease is confirmed it is too late and this is entirely contrary to what health professionals have learned time and time again. Don’t wait until disease is confirmed. Keep mosquito populations low so that disease does not become established in the human population. We need all the tools available to do this. The following WA mosquito species are capable of transmitting or maintaining the following disease causing pathogens: Aedes vexans Canine heartworm, demonstrated laboratory transmission of Rift Valley fever Anopheles freeborni Malaria Anopheles punctipennis Canine heartworm Coquilletidia perturbans Eastern equine encephalitis Culex pipiens SLE, WNV Cx. tarsalis SLE, WNV, WEE Culiseta inornata WEE Ochlerotatus dorsalis WEE Oc. japonicus* Laboratory transmission of EEE, WNV and LaCrosse virus

Oc. melanimon WEE Oc. sierrensis Canine heartworm Oc. sticticus WEE, SLE Oc. togoi* Brugian and Bancroftian filariasis, Japanese encephalitis *Introduced, non-native species Documented mosquito borne diseases here in WA: we have had West Nile, WEE, and SLE as well as canine heartworm. What appears to have been malaria showed up in 1830 around Fort Vancouver, WA and the surrounding Willamette valley area. Malaria was reported in the mid to late 1800s/early 1900s in Oregon. The historical reports from WA appear to be primarily travel-related, esp. post WWII. Old Army reports suggest that malaria was present in South Central WA, although those cases may have been brought in by traveling troops. It can happen again. We must be allowed all our tools to insure public health is protected. Del Gilkerson Cowlitz County Mosquito Control

FRANKLIN COUNTY MOSQUITO CONTROL DISTRICT 2601 N. Capitol Ave. Pasco, Washington 99301 (509) 545-4083 Fax (509) 545-4839 www.fcmcd.org Monday, March 15, 2010 Subject: Comment on the WA State DOE NPDES Draft Permit statement: Page 10 - S5- B- 3 – The trigger for Mosquito Adulticide will be Alert Level 3 in the West Nile Outbreak Response Plan. Alert Level 3 is by definition “Moderate Risk of Human Outbreak”. “Sustained mosquito-borne virus activity in birds or mosquitoes in the absence of human infections”. Why waiting to reach Alert Level 3 before instituting Mosquito Adulticide measures is too late? First some background: What is the primary source that produces the mosquito species that are the primary vectors for transmitting mosquito-borne viruses to humans and other animals? That primary source is wetlands. Wetlands do have advantages but they also have disadvantages and those disadvantages put humans at risk. Wetlands provide the perfect habitat for the mosquito species that vector mosquito-borne viruses. These habitats provide relatively shallow still water, high concentrations of vegetation that provide cover from predators and an abundant food source with decomposing and new vegetation growth. In addition it provides an abundant source of hosts for the blood meal that female mosquitoes need for reproduction. The primary host in a wetland for these mosquito species blood meals is birds. It is the birds who are the continuing reservoirs for the mosquito-borne viruses West Nile virus, St. Louis encephalitis and Western Equine Encephalitis (WNv,SLE,WEE). These mosquito-borne viruses have effects to humans and animals that range from mild to very grave including loss of life. Summing up, wetlands do present a serious set of problems and a great deal of human risk involved. The best and most effective way to control/mitigate a problem is to control it at its source. To give you one example in The State of California: “California Wetlands Conservation Policy” Section VI- A and I will quote. “Address management and operations of wetlands- Recognizing that the responsibility for wetlands only begins with the acquisition or restoration, the State will work to provide adequate financial resources for wetlands management and operations including water source and delivery, mosquito abatement and vector control. The emphasis for these programs will be on State-owned wetlands.

The State also recognizes the responsibility public and private wetland owners have to their neighbors and will establish a model good neighbor policy to guide management of newly created, restored or enhanced”. The State of California recognizes the mosquito disease problem and its risks and has worked with Mosquito Abatement District’s to form the BEST MANAGEMENT PRACTICES FOR MOSQUITO CONTROL IN MANAGED WETLANDS. These BMP’s are habitat management practices, water, vegetation, and infrastructure maintenance activities used in the State to mitigate the mosquito/vector problems and their risks. Washington State: Washington State Wetland Policy makes no mention of mosquitoes, disease and the subsequent risk to humans they create. Since that is not in the policy the State of Washington have no mitigation policies to mitigate mosquito and disease problems and risk at the source. This is a grave oversight and needs to be addressed and instituted by the State... Back to the question- Why waiting to reach Alert Level 3 before instituting Mosquito Adulticide measures is too late? Both the EPA and CDC recommend and endorse applications of mosquito adulticides when surveillance indicates that mosquito larval control measures have proven inadequate to prevent imminent disease outbreaks. Wetlands produce the mosquito-borne disease vectors and here in Washington they are not managed and are congested with huge areas of dead and matted vegetation. This condition causes serious problems and risk. Mosquito Control District’s find that they cannot get the majority of their mosquito larvicide materials through the matted vegetation to kill mosquito larvae. Many times the District’s work to control mosquito larvae is inadequate leaving the District with the recourse of having to spray an insecticide to kill the adult mosquitoes that have emerged from the wetlands and other non-primary areas. Mosquito Control District’s public trust cannot allow or wait for vector mosquito species to complete their disease transmission cycle development. District’s must keep the adult mosquito population numbers reduced to a level that lowers the chance for the disease transmission cycle development to occur to keep humans and animals at the lowest amount of risk. Waiting for Alert Level 3 to be reached allows the disease transmission cycle to occur in substantial mosquito populations. Mosquito Control District’s must quickly reduce adult mosquito populations where and when they are found. Waiting means having large disease carrying mosquito populations and having to institute mosquito spraying over considerable geographical areas to control them. In summation waiting for level 3 to occur before spraying insecticide for adult mosquitoes involves public risk that is unacceptable and indefensible in light of the facts. Sincerely Brian W. Benner Brian W. Benner, Director

Smaller Districts and Reaching Alert Level 3 Requiring an alert level 3 before adulticiding is even considered is a frightening scenario to imagine to a small district. Smaller districts may lack the tools to track the progression of disease spread in mosquito populations. A Mosquito Control Districts main concern is for the public health. With the permit as written you are eliminating an important tool in our ability to minimize public health risks from mosquito diseases; A Permittee that is an organized mosquito control district (chapter 17.28 RCW) may use adulticides to control vector mosquitoes provided it: conducts mosquito surveillance, mosquito disease testing, monitors other disease indicators (such as dead birds, equine disease cases, or human health cases) and follows available DOH vector control guidance (e.g. the West Nile Outbreak Response Plan where the trigger for adulticiding is Alert Level 3). Mosquito disease testing is an important part of a mosquito control program. Many smaller districts such as mine lack the personnel, equipment, and funding to fully establish a disease surveillance and testing program. We rely on State and local health jurisdictions for help with disease testing services. With the current state of the economy help is not as readily available as it once was. Not all mosquito control districts have the ability to quickly and easily establish that a mosquito-borne disease has in fact established itself in the local mosquito or bird population. These are usually the first indicators of a mosquito-borne disease presence. Although I am able to identify the species of mosquitoes in my traps I cannot determine if they are carrying a disease or not; several species of mosquitoes in Washington are vectors for a mixture of mosquito-borne diseases. With a lack of funding at the State Health Department I am only able to send two species for testing. There is also a lag time in test results; I’m afraid that by the time we are finding positive mosquito pools it would be too late to react with adulticide. People and horses would already have been infected; the only way we are going to realize we are at a level 3 is when we start seeing people and horses with the disease. In my district we don’t own any adulticiding spray or fog equipment; we will either rely on outside vendors or county personnel to perform spray or fog applications of adulticide. Without the testing equipment needed for early detection of disease in the mosquito population a preemptive and rapid response will not be easy. We will have to react only after people and horses have become ill and the public health threat is beyond proactive control. Perhaps the Department of Ecology will offer Grants or other funding to help mosquito control districts purchase the needed equipment to adhere to permit guidelines. Please rethink this part of the permit so that we will have the ability to react and treat mosquitoes with adulticides if needed before people become ill. Jay Lawrence District Manager Camano Island Mosquito Control District cimcd@wavecable.com 360 387-8705

Allow Us to do What We Have Always Done to Safeguard Public Health Mosquito Control Districts are asking the DOE to reword the permit in such a way that we can continue providing service to our taxpayers as we have in the past. Most of the districts have been in existence for decades and over this time have developed programs that rely heavily on larviciding but also use adulticides to respond when the public is overwhelmed by adult mosquitoes. No matter how hard we try, larvicide alone will not solve the whole problem. I‟m sure the use of adulticides in the state has drastically decreased over time as the industry changes, but a well run integrated pest management program will always need adulticides at some point during the season. The Mosquito Control Districts are professional programs with highly trained staff that respect the environment and always follow all labeled rules and guide lines. If the permit stands as drafted we will be forced to stop all adulticiding until disease is proved to be persistent in the environment. This will be too late for the health of citizens of the state. Additionally the lack of adulticide for control of nuisance mosquitoes will severely affect the quality of life and business economy in many parts of our state. Our attorney, Pat Brock, has written to you informing you that “It is my opinion that if the draft language becomes final, it will be necessary that the Districts cease all applications targeting adult nuisance mosquitoes.” Adulticides are use routinely all over the country and have been used for many, many decades. I am unaware of any incidents where professionals, using adulticides as directed by the label and in accordance with the policies we have in place in our districts have cause harm to the environment. To my knowledge no other state will put such restrictions on the use of adulticides as this draft permit does. Our mosquito control districts strictly follow the regulations imposed on us by the Washington State Department of Agriculture, The Washington State Pest Control Act, and by the manufacture‟s FIFRA approved label. We watch the wind speed and direction to prevent any drift over rivers, lakes and streams thought to be fish bearing. But even with these procedures it is impossible to comply with the draft permit and continue to use adulticide in our programs. The problem is in the definition of “Waters of the State” and the distinction between nuisance and vector mosquitoes. If the wording in the permit is changed as follows we will be able to continue to provide mosquito control as we have in the past. S5. ADULTICIDE USE 1. The Permittee is authorized to discharge incidental amounts of adulticides and their residues to surface waters of the state during mosquito control season. The Permittee must limit incidental deposition to the extent possible by strictly adhering to label directions. Adulticides may not be used in Appendix B areas unless WDFW and Ecology approve the use.

2. The mosquito control period, April 1 to October 31 of the same year, is the only time incidental discharge is authorized. The Permittee may request an extension of this period in writing from Ecology if natural population control (die-off) after October 31 is not expected. 3. Mosquito Control Districts A Permittee that is an organized mosquito control district (chapter 17.28 RCW) may use adulticides to control mosquitoes provided it is just one part of an Integrated Pest Management program that also includes larval control and breeding source reduction and conducts mosquito surveillance, mosquito disease testing, and monitors other disease indicators (such as dead birds, equine disease cases, or human health cases) 4. Areas without a Mosquito Control District A Permittee that is not part of an organized mosquito control district (chapter 17.28 RCW) may use adulticides to control mosquitoes provided DOH makes the determination that adulticiding for mosquito control is necessary to protect public health due to an overriding public health concern. In conclusion, we are not asking DOE to give us permission to do more then we have in the past. We are just asking DOE to reword the permit so that we can continue to work as we always have. If DOE believes we should change the way we operate and stop all adulticiding until we reach DOH Alert Level 3 we request that you give us the reasoning behind this and present us with evidence of where we have cause environmental problems in the past. Del Gilkerson Cowlitz County Mosquito Control

Comments to the draft Washington State “Aquatic mosquito control national pollutant discharge elimination system state waste discharge general permit “ I have recently reviewed the online version of the draft NPDES permit for mosquito control. During this review I was unable to locate a citation under allowable active ingredients for mosquito adulticides for the active ingredient etofenprox. This oversight is understandable since Etofenprox, under the trade name Zenivex E 20, is new to mosquito control. Zenivex was first presented to mosquito control in 2009. Etofenprox is a pyrethroid ether, and as such, the chemistry is different than that of conventional pyrethroids. The Etofenprox molecule contains only carbon, hydrogen, and oxygen and does not contain side chains associated with some traditional pyrethroids that can cause skin sensitivity and respiratory irritation. Etofenprox has an extremely low avian and mammalian toxicity profile, rat oral LD50 value is >42,880 mg/kg, which is significantly lower than items commonly found in the household such as aspirin and caffeine. The EPA has given etofenprox a reduced risk classification. The formulation of etofenprox is also unique among formulated pyrethroid mosquito adulticides. The Zenivex E20 product does not contain the synergist piperonyl butoxide (PBO) that is included in other pyrethroid mosquito products. Etofenprox controls mosquitoes at low application rates and as such the formula does not require PBO to control mosquitoes. This lack of PBO reduces the environmental load for PBO. Zenivex E20 is currently registered with the State of Washington. Zenivex (etofenprox) offers the mosquito abatement districts in Washington State a reduced risk tool for use in the fight against disease carrying mosquitoes. I urge you to correct the oversight and place etofenprox among the mosquito adulticide choices that are listed in the draft permit. Doug VanGundy Director Central Life Sciences 12111 Ford Rd Dallas, Texas 75234

ADAMS COUNTY MOSQUITO CONTROL DISTRICT The Subject: Use Only ULV for Adulticiding Dear Jon Jennings, This has to be a very hard task to rewrite this NPDES permit. One can only assume that those that are proposing some of these new ideas do not understand the total concept of what we do in mosquito control. I would like to comment of the use of only ULV for Adulticiding. Some mosquito control districts have large areas and very populated cities and towns where the only way to control the adult mosquitoes is to fly thousands of acres at a time. Once disease is present in an area some of the applicators come to fly at least 15,000 to 20,000 acres a night. To do a good job and to stop the spread of disease they will apply adulticides for two to three consecutive nights barring good weather. I do not have any big populated areas. My biggest town is 8,000 people. That may not be many people, but they are just as important because they are tax payers. The areas that I most usually fly will range from 50 to 250 acres. These major applicators will not come in and fly these small areas. In order for me to do my adult control measures, we use a conventional spray system. It uses more water and more pressure to get the drops smaller for adult control. It may not be quite as good, but it gets the job done and uses less product in the long run because I do not spray as many acres. Naled or Dibrom 8 is labeled for this use and it does a good job. If you read the label you will see that there are many vegetables and food crops on the label and they use a much higher rate of application than I am using for adult mosquito control. Each mosquito district has special or different conditions tailored for their own areas. That’s why we have BMP’s and you are making it very difficult for us to do our job when the only way is your way and not the one that will fit our own needs. Please reconsider and allow us to use the methods that work the best for each of our areas as long as the products are registered by EPA and we follow the label. Many areas that have standing water are not fish bearing nor does the water go any where. It should not only be important to protect the environment, but also to protect the Health of those that live and recreate in each of our areas. Thank you for your consideration in this matter. Tom Haworth, Manager PO Box 262 Othello, WA 99344

March 15, 2010 Comments to Washington State Department of Ecology concerning the NPDES Draft Permit; Clarification for the definition of “Waters of the State” Definition of Waters of the State Waters of the state are referred to many times throughout the AQUATIC MOSQUITO CONTROL NPDES PERMIT DRAFT and the FACT SHEET. Definitions of Waters of the State are very vague and I would like to submit the following comments and questions. In the “Draft Aquatic Mosquito Control General Permit Fact Sheet” page 29 paragraph titled “Geographic Area Covered” describes surface waters of the state; “Ecology defines surface waters of the state as “lakes, rivers, ponds, streams, inland waters, salt waters, wetlands, and all other surface waters and water courses within the jurisdiction of the state of Washington (90.48.020 RCW, 173-201A-020 and 173-226-030 WAC).” A definition is also given in the Glossary of the Fact Sheet; “Waters of The State: All surface and ground waters in Washington State as defined by chapter 90.48.020 RCW, 173-201A-020 WAC and 173-226-030 WAC including any future amendments of state law. Also includes drainages to waters of the state.” The Glossary definition of ground water is; “Ground Water: means any naturally occurring water in a saturated zone of stratum beneath the surface of land or a surface water body.” I think most people know a basic definition of what lakes, rivers, ponds, streams, and salt waters are. However the terms inland waters, wetlands, and all other surface waters and water courses seems to indicate that any and all water is considered to be waters of the state even ground water “beneath the surface of land or a surface water body” according to your definition. I would like a better description, definition, and clarification of these terms; inland waters, wetlands, and all other surface waters and water courses. The issues I am concerned with about the adulticide restrictions relating to waters of the state are the restrictions this draft permit puts on nuisance adult mosquito control as well as the restrictions to vector mosquito control. You claim the permit does not restrict the use of adulticide for any mosquitoes as long as it doesn’t inadvertently enter Waters of The State. Spray or fog drift is a function of the adulticides used in mosquito control and “waters of the state” are everywhere. I don’t know where you would find an area in Washington that adulticide would ever be legal. Especially in Western Washington, you would be hard-pressed to find an area where there aren’t any Waters of the State. The definitions and restrictions you describe in the NPDES documents will leave anyone performing adult mosquito control at risk for potential lawsuits.