Aquatic Mosquito Control General Permit Public Comment

March 4, 2010 Mr. Jon Jennings Washington State Department of Ecology Water Quality Program P. O. Box 47600 Olympia, WA 98504 Dear Mr. Jennings, The Northwest Mosquito and Vector Control Association greatly values our long and productive relationship with mosquito control districts throughout Washington State and considers their active participation in EPA’s Pesticide Environmental Stewardship program as a tangible recognition of their commitment to protecting human health and the environment. With this long-standing collaboration in mind, and in light of the recent emergence of West Nile virus in Washington, I have to express my concerns with Washington State Department of Ecology’s draft NPDES permit for aquatic mosquito control. Adult mosquitoes, both vector and nuisance species, can potentially impact the health and economy of all Washingtonians. Mosquito control districts in Washington have a long and proud legacy of providing public health mosquito control operations that reduce these risks through an Integrated Pest Management (IPM) strategy. A key component of this IPM strategy is controlling adult nuisance species mosquitoes with adulticides by both air and ground. The proposed NPDES permit restrictions effectively eliminates the use of adulticides for the control of nuisance species mosquitoes by not authorizing the discharge of adulticides into “waters of the state”. It should be noted that many common ...