ID Contact ID Section Title Section Number Comment Comment Source

8 Meredith, Bill 1.0 ‐ Coverage Under This Permit General Are there county‐level bulletins for threatened or

endangered species? Meeting

9 Dwinell, Steve 1.0 ‐ Coverage Under This Permit 1.0

Will EPA be adding additional use patterns?  Such as

pesticides in aquaculture? Is there a way to have

aquatic weed control through a generic permit for

pesticides?

Meeting

10 Dwinell, Steve 1.0 ‐ Coverage Under This Permit 1.0 Will a broader permit be put in place?  There are a

lot of use patterns that will not be covered. Meeting

11 Eckermann, Chuck 1.0 ‐ Coverage Under This Permit 1.0 Is what is being permitted the residue after the

pesticide has left? Meeting

12 Aydell, Gary 1.0 ‐ Coverage Under This Permit 1.0

In LA, definition of “Waters of the State (WOS)” is

broader than federal “Waters of the U.S. (WOUS)”;

the PPGP (prototype pesticides general permit)

needs to be broader to cover those additional

waters included in definition of WOS (by certain

states). The permit would cover all discharges

because it would be assumed that they’d all reach

WOS (because of the broad definition of WOS), and  

the PPGP should cover all pesticides regardless of

where used (because of LA’s broad definition of

WOS).

Also, hopes that a broader definition will simplify

(with respect to resource utilization) and be more

efficient.

Meeting

13 Schardt, Jeffrey 1.0 ‐ Coverage Under This Permit, Activities Covered 1.1.1 Will this section be expanded in the final version? Meeting

14 Schardt, Jeffrey 1.0 ‐ Coverage Under This Permit, Limitations on Coverage 1.1.2.5

This section (Endangered and Threatened Species

and Critical Habitat Protection) is currently noted as

"in development." Florida would like to assist with

the development of language for this section.

Meeting

15 Spitzmuller, Joe 1.0 ‐ Coverage Under This Permit, Activities Covered 1.1.1

Regarding agricultural tile drains ‐ are these

covered or exempt in the PGP? He recommends not

including them in this permit.

Meeting

16 Gray, Jim 1.0 ‐ Coverage Under This Permit 1.1.2.1 and 1.1.2.2.

Are impaired waters public information?

What happens if a water becomes newly‐listed (as

impaired) after the permit has been issued?

The permit needs to define "near".

Acknowledges that endangered species are

adequately addressed by FIFRA requirements and

recommends not adding new species requirements

in the NPDES permit (because FIFRA provides

adequate protection).

Meeting

17 Daiker, Davis 1.0 ‐ Coverage Under This Permit, Limitations on Coverage 1.1.2.3

Regarding discharges of equipment rinsate with

respect to endangered species requirements, why

include this bullet ‐ it seems to be a violation of

FIFRA to allow the discharge of rinsate to surface

waters.

Meeting

18 Simoneaux, Bobby 1.0 ‐ Coverage Under This Permit 1.1.1

Seeks clarification with respect to rice culture ‐ 

growing rice in flooded conditions. Pesticides are

applied at rice cultures ‐ are they covered under

this PGP?

Meeting

19 Aydell, Gary Authorization to Discharge Under this Permit 1.2

Suggestion for the PGP Fact Sheet (FS): copy the

NOI discussion in the FS for the Vessel Discharge

GP.

Also, in the PGP FS, desire to see a detailed

description of the FIFRA approval process and label

requirements for the pesticide product.

What is the definition of "water‐acre" (e.g., ditches

are considered Waters of the State in LA; therefore,

how does "water‐acre" translate to ditches)?

Footnote 1 (pg. 3): What are the "additional

effluent limitations"?

1.2.4, bullet #3: Correct the typo: "not" should be

"otherwise".

1.2.5.1: Is posting/processing the Notice of

Termination (NOT) on EPA's website necessary?

What is the timeframe for processing the NOT?

Meeting
20 Gray, Jim Authorization to Discharge Under this Permit 1.2.2

‐Terminology used in the two bullets: "responsible

party" versus "applicator" ‐‐ are they or/and

statements? Presents scenario to seek clarification

of who is responsible for submitting the NOI (e.g.,

homeowner's association or for‐hire applicator).

‐The term "Integrated Pest Management (IPM)" is

broad ‐ hard to define what is adequate IPM.

‐Who files the NOI? It seems unreasonable to

require a for‐hire applicator to implement IPM

(scenario/explanation that the homeowners'

association has tried IPM and as last‐resort hired

the applicator).

‐Follow on comment is recommendation to exclude

IPM as a requirement of Best Available Technology

(BAT).

‐Regarding online availability of NOIs ‐ asked EPA to

consider sensitivity of information/confidential

business information.

Meeting

21 Akers, David Fact Sheet Fact Sheet

For enforcement purposes, the PGP and the PGP FS

should define "pollutants" and when a violation is

triggered, to deal with the burden of proof issue.

Meeting

22 Akers, David Fact Sheet Fact Sheet The PGP FS text should explain why EPA is not

exempting Tier 2 waters from the PGP. Meeting

23 Hays, Robert 1.0 ‐ Coverage Under This Permit 1.2

‐Agrees that PGP should clearly define terms:

"responsible party", "operator", and "applicator".

‐With respect to homeowners' associations being

the party responsible for submitting the NOI, what

is the association's responsibility to Waters of the

U.S. (WOUS)?

Meeting

24 Spitzmuller, Joe Operators Required to Submit Notices of Intent (NOIs) 1.2.2

‐Confusing who is required to file NOI.

‐NOI deadlines (in Table on pg. 3) appear

tight/strict. Would activities be covered unless NOI

filers are notified of delay in authorization (is the

NOI automatically authorized 10 days after NOI

received by EPA)?

‐Informed EPA that some applicators (e.g., aerial

sprayers) might have difficulty meeting schedules.

‐Applicators may also change planned activities,

causing ripple effects in predicted applications (as

they may have initially reported on NOI), and

needing to contract out work ‐ posing question if

sub‐contracted applicators are knowledgeable of

NOI and permit requirements.

Meeting

25 Dwinell, Steve Authorization to Discharge Under this Permit 1.2

‐With respect to water‐acres, larvacides might

require a different threshold unit.

‐Is it possible to use a combination of a measure of

X and Y water‐acres, one that allows for drifts?

‐Will "land‐acres" also be included in the PGP? They

might also be appropriate in certain use patterns.

‐Regarding the NOI, naming specific waterbodies

might be difficult, would you consider allowing

naming by area instead?

Meeting

26 Akers, David Authorization to Discharge Under This Permit 1.2.4

‐With respect to number of acres, will an entity be

able to accurately estimate the number of acres for

the next 5 years? Further, if the applicator applies

to an area in excess of what was noted in the NOI, is

there a permit provision that allows for such an

overage?

‐Regarding Responsible Entities, if EPA requires

municipalities, control districts, etc., this may result

in a larger number of permittees (than if just

applicators were named as the responsible party),

thus increasing the workload to administer.

Meeting

27 Coram, Phil Authorization to Discharge Under this Permit 1.2

‐Do BAT requirements apply only after exceeding a

certain threshold?

‐As the PPGP currently reads, it appears a discharge

is covered even before submitting an NOI; language

needs to be more explicit.

Meeting
28 Schardt, Jeffrey 1.0 ‐ Coverage Under This Permit 1.0

‐FL Fish & Wildlife Conservation (FWC) issues

permits for aquatic weed control (for homeowners);

would FWC then be the responsible party and need

to obtain coverage under the NPDES PGP?

‐Also, FWC has many exemptions from their aquatic

plant control permits (e.g., size of land‐area, no

discharges to WOUS, use on private lands). Where

are similar controls triggered under NPDES?

Meeting

29 Eckermann, Chuck 2.0 ‐ Technology‐Based Effluent Limitations 2.0

Will the Clean Water Act (CWA) program provide

IPM training to permittees (believes many are not

knowledgeable, and that 4 months to educate prior

to implementation is a challenge)?

Meeting

30 Eaton, Angus Authorization to Discharge Under this Permit 1.2

‐It appears that NY implements some/most of the

PGP requirements already on pesticide applicators.

‐Is it possible EPA can share the "code" for their NOI

website, with states, so they can also

develop/implement eNOI‐type programs, and

ensure automatic posting of NOIs?

Meeting

31 Goans, Steve Authorization to Discharge Under this Permit 1.2

‐Is it possible to look at the number of acres rather

than number of applications?

‐Resource concerns: education for staff (essentially

creating a new program for his NPDES group to

administer); concern for level of effort

required/expected to review NOIs, other materials;

concern that expertise is lacking among staff; and

number of staff are down.

‐Clarify meaning/EPA's expectations of states'

reviews of NOIs

Meeting

32 Meredith, Bill

‐Feels challenge will come with quantification of

pesticides. Hopes values/numbers are science‐

based, emphasized that environmental non‐

governmental organizations (NGOs) will inspect to

determine if values are based on good science.

‐Comparison of small‐scale versus large‐scale

applications (effectiveness vs. actual adverse

impact).

‐Senses potential for applicators to try and "game"

the system through thresholds, to try and stay

under thresholds that trigger additional

requirements.

Meeting

33 Corell, Chuck

‐Are all public noticing requirements (under NPDES)

covered by the PGP?

‐Cost‐benefit comment with respect to applicators

and taxpayers, with potentially few environmental

benefits.

‐Due to the variability in application activities across

states, how much flexibility do states have to vary

from EPA's PPGP?

Meeting

34 Maguire, Charles 1.0 ‐ Coverage Under This Permit 1.2

‐Encourages seriousness in developing two

pathways for NOI submittal requirements.,

‐Regarding "acres", is it the acres "applied to" or

acres "affected by" the application of pesticides?

‐Regarding identification of waterbodies on NOI ‐ to

what level of detail is expected (e.g., 4‐digit HUC)?

Suggests setting a standard method for consistency

with water quality standards (WQS) systems.

Meeting

35 Dwinell, Steve 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐Using IPM as BAT is great, but problem is to what

extent will EPA require?

‐Concerns w/practicality of: (1) requiring

elimination of all breeding sites and (2) requiring

use of larvacides as primary pesticide.

‐Feels the statement/disclaimer re: documenting if

not possible, is not an enforceable piece.

‐Concern with 2.1.1.2 requirement to use "lowest

amount of pesticide product," because using a

lower amount causes potential resistance issues.

Meeting
36 Coram, Phil 2.0 ‐ Technology‐Based Effluent Limitations 2.1.3.2 and 2.1.5.4

‐Include a definition of "best industry practice

achievable" (e.g., Maximum Extent Practicable?).

‐2.1.3.2: The dredging/filling statement caught his

attention

‐2.1.5.4: What is considered an adequate training

program?

Meeting

37 Goans, Steve 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐Are training requirements targeted at specific

pesticides and their applications?

‐Are there options for types of training programs

(e.g., web‐based training)?

‐Regarding educating the public, who decides what

is acceptable training material and who then

develops the training materials?

‐Has anyone validated these control requirements

for effectiveness and to determine what is required

to satisfy the requirements?

‐Following EPA's response at what state programs

EPA researched during development of PPGP: feels

that CA, WA, FL and other states may be doing

more than other states are doing or even capable of

doing (i.e., Cadillac vs. Chevrolet programs).

Meeting

38 Meredith, Bill 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐Most of IPM in PPGP is routinely implemented by

larger mosquito control districts (though likely not

done by the smaller ones); he hopes the larger

control districts would adopt and implement the

IPM permit requirements.

‐Suggestions for PPGP:2.1.1.3: elaborate on

definition for "incidental deposition" (he feels it's

incidental because it's unavoidable and hopes there

are no adverse impacts because it should be very

dilute).

2.1.3.2: Regarding water management practices as

they are currently worded in PPGP, suggests using

more ambiguous terms (e.g., "environmentally

compatible" practices).

2.1.3.4: Call mosquitocides what they are, vs.

"growth regulators"; we know they're a chemical,

so call them a chemical.

2.1.4.3: Include tidal flooding in list of

environmental conditions for which to monitor.

2.1.4.4: Feels worded too strongly; more

practicable words might include "supplemental

information" instead of "available disease

surveillance reports" (current text implies

monitoring for disease is required.

Meeting

39 Gray, Jim 2.0 ‐ Technology‐Based Effluent Limitations 2.0

2.0: The use of "equipment manufacturer's

specifications" concerns him; linking permit

compliance to a third‐party should not be part of

the permit.

2.1.1.2: How much flexibility do states have with

this text? Feels this text is different than what is

recommended for compliance with labels.

Regarding 2.1.2 and 2.1.3 and enforcement of these

sections ‐ inspector needs to be an expert in the

field, because practically speaking, mosquito control

applicators are the best at what they do ‐ will a

permitting staff person/inspector know the due

diligence.

2.1.5.4: "ensure that pesticide applicators are

trained" ‐ is their certification or license adequate?

Suggest changing text to use "certified applicator"

or "working under the direction of a certified

individual."

2.1.6: Wonders if applicators have the wherewithal

to do that type/amount of public outreach

specified.

Meeting

40 Daiker, Davis 2.0 ‐ Technology‐Based Effluent Limitations 2.1

2.1.2.1: Is there flexibility with this language ‐ is EPA

open to using West Nile notifications or disease

status reports to serve as an action threshold?

2.1.3.1: Is this feasible for mosquito control districts

or is it covered under Outreach in Section 2.1.6?

Meeting
41 Spitzmuller, Joe 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐Seems that BAT for use of pesticides, should be the

product label requirements.

‐Product label requirements also appear to be best

training source for that product.

‐It feels as though the PPGP language steers

applicators away from label requirements

Meeting

42 Goans, Steve 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐Explain the difference between BAT and BMPs.

‐Concerned because labels do say the amount that

can be applied to water and feels it's difficult to

enforce and implement, but now are considered

BAT in the NPDES permit.

Meeting

43 Spitzmuller, Joe 2.0 ‐ Technology‐Based Effluent Limitations 2.1.5.4

‐Regarding training, in most states there are

certification programs for licensed applicators. Is

there a difference between "licensed" and

"certified"?

‐For‐hire applicators are required to complete

training programs; however,

associations/municipalities may not be required to

be licensed/certified. Who is responsible for

ensuring that these groups participate in training

programs?

‐Who attends training programs differs between

states; there may be gaps in who is trained if EPA

relies only on states' training programs.

Meeting

44 Aydell, Gary 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐Can EPA state in permit, "comply with FIFRA plus

some additional requirements" instead of

reinventing language?

‐Hopes for flexibility in language in section 2.1.3.5

‐Unclear of what definition of "pest action

threshold" is from an enforcement standpoint.

Meeting

45 Corell, Chuck 2.0 ‐ Technology‐Based Effluent Limitations 2.1.1.1

‐Clarify text to make sections that read "extent

achievable" match those sections that read "must"

(Chuck will offer language to EPA to consider).

‐Feels states should have more flexibility in how

they reference FIFRA label requirements.

Meeting

46 Simoneaux, Bobby 2.0 ‐ Technology‐Based Effluent Limitations 2.0

Louisiana has a virus workgroup that is made of

various groups doing surveillance work (available on

a website). Due to different grades of programs

across state, is it possible for other management

districts to reference surveillance work other

groups have already done?

Meeting

47 Hays, Robert 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐Many mosquito control districts are funded by CDC

grants; when the money runs out, the impact will

be felt.

‐Concern for lack of resources, money, to meet all

permit requirements (e.g., surveillance).

‐Some long‐standing mosquito control districts have

historical surveillance data: interference from

permit language that historical data are not

applicable, though those data are important and as

useful as doing more surveillance.

Meeting

48 Dwinell, Steve 2.0 ‐ Technology‐Based Effluent Limitations 2.0

What is the meaning of the statement, "If you find

that your control measures are not minimizing

pollutant discharges, you must modify these control

measures as expeditiously as practicable."?

Meeting

49 Akers, David

Acknowledges the need for additional expertise on

staff ‐ to determine from an enforcement side.

Will need to involve OECA to determine where the

bar is set by EPA, what is the strictness of

interpretation of permit requirements.

Meeting
50 Schardt, Jeffrey Aquatic Weed Control in Lakes and Ponds 2.2

‐2.2.1.1: Some chemicals are very soluble and will

transport across areas outside the direct application

area, even to interconnected water bodies (e.g.,

rivers, ocean); the language is strong in this section.

‐2.2.1.2: Using the lowest amount of pesticide

possible leads to resistance issues.

‐2.2.2.2: Regarding weed identification, it's not

always possible in advance, due to quick growth

and need for rapid response to control weeds.

‐2.2.3: Regarding requirement "prior to each

application," this is too much to have to explain and

will be inefficient. Florida has developed a

document that contains the basics of a program ‐ 

can Florida refer to this document?

‐2.2.3.2: Mechanical harvesting is not preferred

method, it may kill many fish in addition to other

aquatic species.

‐2.2.3.3: Promoting biocontrols may allow invasive

species to get a foothold and in the end need to

apply more pesticides to control and eradicate the

plants.

‐2.2.6.2.2: Regarding label human hazard warnings;

these warnings are for the undiluted

concentrations, not residue in water (if required pos

Meeting

51 Gray, Jim Aquatic Weed Control in Lakes and Ponds 2.2

‐In 2.2.2.3 and 2.2.2.4, if applicators are responsible

for filing NOI and complying with permit

requirements, it would be hard for them to identify

source, densities, and trends (practicality/ability for

weed control staff to decipher).

‐2.2.6.2: Why is such posting required? Issues:

posting near a public access point brings into play

jurisdictional issues, and what if you cannot access

the water ‐ why required to post?

‐2.2.6.2.2: What is the meaning of "label human

hazard warnings"?

Meeting

52 Spitzmuller, Joe Aquatic Weed Control in Lakes and Ponds 2.2.5.1

This section uses wiggle words, but what is the

intent, what are you trying to accomplish in this

section? Many pesticides are broad‐spectrum and

may affect other organisms.

Meeting

53 Corell, Chuck Aquatic Weed Control in Lakes and Ponds 2.2.1.1

The usage of BMPs, extent achievable ‐ does the

text in the generic effluent limitation language

modify all the text that follows?

‐The paragraph under 2.2.3.4 ("In the event that

any of the permit conditions in 2.2.3.2‐2.2.3.4 is not

FEASIBLE, you must document why you are unable

to comply with the condition."), what is meant by

"feasible"?

Meeting

54 Eaton, Angus Aquatic Weed Control in Lakes and Ponds 2.2.2.3

2.2.2.3 mentions nutrients but doesn't expand;

what is the responsibility of the permittee regarding

source identification? What is the point if it doesn't

trigger any action?

Meeting

55 Meredith, Bill 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐The sections between mosquito control and weed

control are similar; so comments between the two

sections will be applicable to both ‐ ensure

consistent changes.

‐2.2.6.2.2: References to label warnings may be

taken out of context. If applicator follows label

requirements, environmental and human health

factors do not apply, because the use poses "no

unreasonable risks to wildlife, etc."

Meeting

56 Cswercko, Courtney 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐Some of the "if required to submit an NOI"

requirements should be applicable to those

categorized as not having to submit an NOI (e.g.,

equipment calibration and maintenance).

‐Suggest using up‐front text to state requirements

applicable to all permittees.

Meeting

57 Schardt, Jeffrey Aquatic Weed Control in Lakes and Ponds 2.2.5.1

‐"Minimize" implies that using pesticides has a

negative impact on the environment, but when

controlling pests and weeds, this is really a positive

impact on the environment ‐ seeks rewording in

this section.

‐Regarding comment on nutrients, invasive plants

are not limited by nutrients, so it is not relevant to

say you will reduce invasive plants by reducing

nutrients.

Meeting
58 Gray, Jim ‐Process question: How do non‐NOI filers know the

PGP exists? Meeting

59 Eckermann, Chuck

‐General: If label requirements are followed, should

meet permit requirements.

‐If violation of the permit is also a violation of FIFRA,

which agency has jurisdiction?

Meeting

60 Cswercko, Courtney Next Steps with States

‐General comment: States could consider including

permit requirements as part of their state

certification/licensing exams for applicators

(acknowledge would need to coordinate permitting

and agricultural agencies).

Meeting

61 Dwinell, Steve 6.0 ‐ Integrated Pest Management (IPM) Plan 6.0

‐Supportive of IMP in BAT.

‐For the introductory paragraph, the American

Mosquito Control Assn has good IPM plans

available; it is possible a permittee can reference

that plan (as opposed to reinventing an IPM plan)?

‐Regarding the question in that introductory

paragraph, re: one IPM plan for each treatment

area or several treatment areas? ‐ suggest one IPM

plan for area of operation.

‐6.1.1.1: Why required to list team ‐ it may change.

‐6.1.1.2.(b) and (c): Maybe not make them site‐

specific.

‐6.1.1.3.(c): "...evaluation of any non‐toxic or less

toxic..." ‐ permittee may not have large number of

materials to choose from. Also, unsure of meaning

of "non‐toxic" or "less toxic," to fish or

invertebrates (it's not specific what this means)?

Meeting

62 Meredith, Bill 6.0 ‐ Integrated Pest Management (IPM) Plan 6.0

‐What level of detail in the IPM is adequate (2 pages

or 200 pages)?

‐This will incur a new expense for control

organizations to develop an IPM plan ‐ will

additional funding be available to control districts to

develop IPM plans?

Meeting

63 Schardt, Jeffrey 6.0 ‐ Integrated Pest Management (IPM) Plan 6.0

‐With many weed control options available, it

would be burdensome to explain each time why a

specific control option was not selected.

‐If states have flexibility in requirements to include,

could their permit refer to the website (discussed

previously) that houses such information (e.g.,

annual workplan estimates, application areas,

activities).

‐Is there the ability to use a website as an IPM plan

(and then include specifics, such as waterbodies

and maps separately)?

‐A kind of decision‐tree process is in‐place, and he

feels they could incorporate effectiveness of

individual activities into the website, if a website

could be used.

Original‐Meeting

64 Hays, Robert 6.0 ‐ Integrated Pest Management (IPM) Plan 6.0

‐Listing the Pesticide team is required, but the role

of an IPM coordinator is lacking from the permit, so

what is the purpose of requiring?

‐6.1.1.2.(f): Is a district‐wide map allowable or for

every application site a separate map would be

required?

‐6.1.1.3.(c): Alternative control measures ‐ 

someone could spend a lot of money/effort in

evaluating such measures; it should be part of the

general IPM decision making process.

Meeting

65 Corell, Chuck 6.0 ‐ Integrated Pest Management (IPM) Plan 6.0

‐Feels IPM plan is a valuable tool but goes back to

the issue of who must file an NOI and submit the

IPM plan.

‐Feels the individual for‐hire applicator should not

be required to develop an IPM plan, as the

applicator was just hired to do the application (did

not make the decision to apply pesticides).

Acknowledges control districts, municipalities

would be reasonable to require them to develop

IPM plan, but not the for‐hire applicator.

Meeting
66 Gray, Jim 6.0 ‐ Integrated Pest Management (IPM) Plan 6.0

‐Need to recognize limitations of applicators.

‐How will EPA ensure applicators did due diligence

in developing IPM plans ‐ are water regulators able

to recognize IPM and determine adequacy?

‐6.1.1.2: Feels unreasonable

‐6.1.2.2.(d): Feels this is an economic threshold.

Emphasis that serious consideration is currently

given to pesticide applications (implication is that

pesticide application is not given serious

consideration when doing so).

‐6.1.3.4: Feels data quality will be poor, if

monitoring for pesticides; recommends ambient

monitoring as more valuable data set.

Meeting

67 Hays, Robert 6.0 ‐ Integrated Pest Management (IPM) Plan 6.1.2.5 Is this text, "..and procedures for posting..." an

artifact? Should it be deleted? Meeting

68 Meredith, Bill 6.0 ‐ Integrated Pest Management (IPM) Plan 6.0

If the American Mosquito Control Association

(AMCA) has developed an IPM plan, could others

reference that plan, or would each applicant have

to write their own plan?

Meeting

69 Szylvian, Andrea 6.0 ‐ Integrated Pest Management (IPM) Plan 6.0 Asked if the IPM plans will be posted online like the

NOIs? Meeting

70 Simoneaux, Bobby 10.0 ‐ Recordkeeping 10.0 Need to use consistent terminology between

operator, permittee, applicator throughout permit. Meeting

71 Schardt, Jeffrey 10.0 ‐ Recordkeeping 10.0

‐Pesticide application logs are already required for

contractors.

‐Pesticide application logs, Section 4.i: recommend

limiting it to the area where pesticide is applied, it's

more exact than "treatment area."

‐Pesticide application logs, Section 6: results

currently for "Pre‐treatment", not "post‐treatment"

monitoring.

‐Pesticide application logs, Section 7: Unsure of

what they'd report for "any observed non‐target

impacts," because non‐target impacts will always

occur. What purpose does reporting serve, and

what would they report?

Meeting

72 Hays, Robert 10.0 ‐ Recordkeeping 10.0

‐Pesticide application logs, section 9: Why require

reporting on larviciding and not adulticiding (why

document one and not both)?

Meeting

73 Simoneaux, Bobby 10.0 ‐ Recordkeeping 10.0

‐Pesticide application logs: Where do they need to

be kept? PGP should clarify where permittees need

to keep those records.

‐Applicator Equipment Maintenance records ‐ to

what extent is this required (down to hand‐

sprayers, which have very little or no

maintenance)?

Meeting

74 Meredith, Bill 10.0 ‐ Recordkeeping 10.0

‐Pesticide application logs, section 9: consider

adding "...or why has failed" to the end of "For

mosquito control, if adulticiding, document why

larvaciding is not feasible...".

Meeting

75 Schardt, Jeffrey 10.0 ‐ Recordkeeping 10.0

‐How long do permittees need to maintain pesticide

application logs?

‐What is the purpose of equipment maintenance

records?

Meeting

76 Spitzmuller, Joe 10.0 ‐ Recordkeeping 10.0

‐It is common to have incomplete, incorrect records

(and predicts it will be rare to have records in

compliance with permit requirements).

‐Pesticide application logs, section 5: Regarding

weather conditions, does it mean conditions at the

beginning of, during, or end of application

(acknowledge that conditions will change during

extent of pesticide application)?

‐Acknowledge that meteorological sites may be at

different locations than actual site of application, so

data may not be representative.

Meeting

77 Schardt, Jeffrey 10.0 ‐ Recordkeeping 10.0

‐What is defined as a treatment area? Based on

each application or cumulative? Distances traveled

and areas applied will range; how would one

represent a treatment area?

Meeting

78 Dwinell, Steve 10.0 ‐ Recordkeeping 10.0 Wind and weather requirements regarding the use

of a pesticide are on the product label. Meeting
79 Gray, Jim

‐What is the purpose of this exercise ‐ is it a paper

exercise to comply with the court order or is it

because there is a concern that pesticides are not

adequately regulated currently?

Meeting

80 Spitzmuller, Joe 10.0 ‐ Recordkeeping 10.0

‐From a practical standpoint, he hears complaints

from applicators regarding recordkeeping

requirements. Hopeful only minimum requirements

in pesticide application logs (only keep what is

needed, acknowledge that some data are available

online, e.g., meteorological data).

Meeting

81 Schardt, Jeffrey 10.0 ‐ Recordkeeping 10.0

‐For weather information, consider relevancy to

application (wind speed data are relevant to a spray

operation, but not to a granular pesticide

application).

Meeting

82 Meredith, Bill Next Steps with States After PPDC meeting, fears the environmental

groups will want "FIFRA +++" (instead of "FIFRA +"). Meeting

83 Dwinell, Steve 2.0 ‐ Technology‐Based Effluent Limitations 2.1.1.1

‐Question from Day 1, was to clarify what was

meant by "technologically available and

economically practicable and achievable in light of

best industry practices."

‐Confused because with the BAT analysis,

sometimes if uneconomical, you still have to do it.

Meeting

84 Coram, Phil 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

Are you planning on referencing state water quality

standards (WQS), both narrative and numeric, in

the PGP?

Meeting

85 Schardt, Jeffrey 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

What is meant by the "discharge causes or

contributes to an exceedance of WQS..." ‐ 

herbicides are approved for use in water, when

applied, kill vegetation; this dead vegetation

resulting from treatment affects other aquatic life.

Meeting

86 Akers, David 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

Lynchpin of text referring back to risk analysis

performed under FIFRA (WQ analysis done and

determined what is risk), what is the comparison to

WQS? How strong is the FIFRA level of protection?

It may bring up many issues if you decide to use

FIFRA risk analysis as the basis for your translation

of a narrative WQS ("no toxics...").

Meeting

87 Dwinell, Steve 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐In FL, they regulate at the product level; if there is

a problem with the product they mitigate it then,

not at the operator level (i.e., don't enforce against

the operator, rather, take care of the product).

‐Is it possible for states to establish WQS applicable

in their states to address this issue?

Meeting

88 Aydell, Gary 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐LA WQS (approved by EPA) allow for short‐term

exemptions to WQS exceedances.

‐Acknowledged they are mostly used in 401

certifications, when they have spikes in turbidity.

Meeting

89 Meredith, Bill 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐If BAT (or BMPs, from the pesticide‐side) are

derived from FIFRA/pesticide practices, why would

you assume that CWA requirements would be met

adequately by FIFRA‐driven BMP development (is it

scientific?)?

‐Why isn't EPA establishing more numeric WQS? If

more WQS were developed, ambient monitoring

would increase.

Meeting

90 Jennings, Phil 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

Use caution with respect to visual

observations/inspections for pesticide effects:

visual inspections on stressed fish (due to

temperature, DO) look similar to those affected by

pesticides.

Meeting

91 Eaton, Angus 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐In calculating WQBELs, it's rare that the point of

discharge meets WQS. Beyond that, there is a

consideration of time (e.g., 3 days, lowest amount,

etc.) and at some point dilution factors are

considered; the time of compliance is tied to

WQBELs. Consider including a good explanation of

this in the Fact Sheet.

Meeting
92 Denton, Debra 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐On behalf of CA, many waters are listed on the

303(d) list for pesticides. For example, in the Central

Valley alone, there are 20 pesticides on the 303(d)

List and these are currently used pesticides, not

Legacy pesticides (i.e., they are the same pesticides

considered in the PPGP).

‐CA is in the process of developing a GP for

pesticide applications and it will include Receiving

Water limitations for pesticides.

‐An approach: can use the lowest OPP benchmark

value divided by a risk assessment factor to set as a

numeric value in the permit.

‐A fair cost analysis of items/components in PPGP is

needed (e.g., IPM development, visual sampling,

etc.).

‐CA and Region 9 coordinated efforts; the GP has a

range of options, and dependent on RPA, different

permit conditions are triggered (e.g., monitoring

requirements).

‐Offered website they’ve used, as far as data

they're considering.  

‐Acknowledged the intent is to prevent problems

associated with pesticide use, but also

acknowledged costs associated with TMDL

development, time to develop TMDLs, data

collection efforts.

Meeting

93 Dwinell, Steve 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

If water quality is based on the residual and that

language isn't included in the permit, then the Fact

Sheet needs to include that discussion.

Meeting

94 Meredith, Bill 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐For states with few numeric WQS, can they look at

maximum value stated on FIFRA label, and look at

the maximum amount after application? Is that an

allowable first approach at establishing numeric

WQS?

‐If applicators use the lower limit based on toxicity

data, then that use is ineffective (due to resistance

issues), isn't that an issue?

Meeting

95 Akers, David 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐With respect to changing WQS in CO, trying, but

the WQS have been on the books for many years,

difficult to change.

‐Are there any water quality data available,

representing post‐aerial applications?

Meeting

96 Meredith, Bill 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

USGS has data on mosquito control pesticides,

specific to Suffolk County, NY (due to lawsuit); data

should be available for review/use.

Meeting

97 Aydell, Gary 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

With respect to WQS and use designations,

considering the statement relating to "...desirable

aquatic species..." ‐ the eradication of weeds

enhances long‐term uses in some cases.

Meeting

98 Eckermann, Chuck 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐How do you differentiate residuals from

agricultural runoff and point source drift? Some of

the same pesticides are used in agricultural

activities and pesticide activities.

‐Feels you'd need to distinguish between them,

regardless of statement that limits are needed if

there's reasonable potential to "cause or contribute

to" a WQS exceedance, because what if the cause is

from an activity exempt under CWA (e.g.,

agricultural runoff).

Meeting

99 Jordan, Bill 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐Clarifying Linda and Marietta’s, that EPA expects

FIFRA requirements plus the permit requirements

will be sufficient to comply with applicable WQS.

‐Currently relying on toxicity and risk assessment

data by OPP and monitoring data from USGS, but

know there are other data sources out there (USGS

is not all‐inclusive); asks participants to forward

information on additional data sets, if known.

Meeting

100 Gray, Jim 8.0 ‐ Site Monitoring 8.0, 8.3

‐Referenced potential accessibility issues and

suggested EPA come up with a plan to address.

‐8.3, bullet #2: “pesticide of concern” –

acknowledge the significance of this term by OPP,

was this term chosen specifically? Does “pesticide

of concern” have linkage to WQS‐side?

Meeting
101 Meredith, Bill 8.0 ‐ Site Monitoring 8.1, 8.2

‐Commends visual monitoring as a starting point;

concern is that monitoring costs will be

considerable and especially during difficult

economic times, downsizing through attrition is

occurring, and concerned that meeting permit

requirements will come at the expense of other

program needs.

‐8.1: PGP needs to include a prescriptive definition

of “application site” – what is a site?

‐8.1.2: Regarding frequency/timing, some spraying

conducted overnight. Best visual monitoring would

be done during the morning/daylight; however,

there's not always the luxury of time ‐ cuts into

other duties and uses additional money. Again, you

need to define "application site" especially with

respect to wetland treatment areas. Also,

"accessible" ‐ but how (via helicopter, boat, etc.)?

‐8.1.3: Effects listed often seen without pesticide

applications (natural deaths/mortality). Concern is

with difficulty distinguishing between natural and

pesticide‐related effects  ‐ may spend time and

money documenting non‐events.

‐Acknowledged the need by CWA for minimum

requirements for monitoring.

‐8.2, 8.2.1: Enhanced monitoring may drive applicato

Meeting

102 Dwinell, Steve 8.0 ‐ Site Monitoring 8.1, 8.2

‐Monitoring for non‐target impacts could be

incorporated into routine applicator activities, but

timing is an issue (maybe 1 week later, but not

immediately post‐application).

‐Mosquito control applicators should be used for

some of the visual monitoring requirements

because they're already in mosquito control plans.

‐Concurs that some reports will be of non‐events

(i.e., natural deaths vs. pesticide‐related deaths).

‐8.1.3: "Report discomfort" is too vague and non‐

essential; should not be required.

‐8.2.1: Listing pesticides is not a good idea; feels

that pesticides that are considered a problem

should be dealt with through the product

registration process. Registrant studies would be

where you identify the problem with

pesticides/product.

Meeting

103 Corell, Chuck 8.0 ‐ Site Monitoring 8.0 Monitoring should be required to determine

compliance with effluent limitations, and that's it. Meeting

104 Daiker, Davis 8.0 ‐ Site Monitoring 8.0

‐If enhanced monitoring is required and goes

forward, PGP will need prescriptive sampling

requirements, because there will be side‐stepping

of vaguely‐written requirements.

‐Noted need to gather data that are

valid/worthwhile, and thus the need for strict

guidance on what's required.

Meeting

105 Coram, Phil 8.0 ‐ Site Monitoring 8.0

‐Hard to distinguish between reportable

impact/observations/adverse incident reporting.

‐Infers that enhanced monitoring is additional visual

monitoring, not ambient monitoring ‐ is that

correct? (If the intent is to require ambient

monitoring, ensure the PGP includes very clear,

prescriptive language as such).

Meeting

106 Eaton, Angus 8.0 ‐ Site Monitoring 8.3

‐Feels there is no need for enhanced monitoring,

because it is captured under section 8.3 (Additional

EPA Monitoring).

‐Feels that if that language/requirement survives

the review/comment, it should be held over until

the 2nd generation (2G) PGP (predicts language will

be contested and will require many changes).

‐Monitoring should be tailored to specific use

patterns, so applicators are looking for correct

symptoms when checking for adverse impacts.

Meeting
107 Akers, David 8.0 ‐ Site Monitoring 8.1, 8.2, 8.3, 8.4

‐8.1.1: Does this refer to aquatic or terrestrial

habitat (clarify if refers to aquatic habitat only)?

‐8.1.2, Non‐Aerial treatments of wetland and

aquatic areas: Fifth bullet specifies "flowing water",

but probable no‐flow in wetlands (consider

changing wording).

‐Use consistent terms re: visual

assessment/observation, between sections 8.1.1,

8.1.2, 8.1.3.

‐8.1.4, third bullet: Does it belong with

requirements listed above?

Meeting

108 Simoneaux, Bobby 8.0 ‐ Site Monitoring 8.0

‐Noted difficulty of visual monitoring.

‐Need better definition of what a single treatment

area is.

‐At certain times of the year, aerial spraying is

conducted throughout night ‐ how to conduct visual

monitoring, in certain areas inaccessible by boat

and very difficult on foot (sink in marshes).

‐Findings from coordination between LA,

universities, and public entities to report fish kills:

Fish kills due to pesticide applications are low, and if

from pesticides, then was due to spills or other

direct discharge of pesticides (not in accordance

with proper use). Most fish kills resulted from low

DO levels in water.

Meeting

109 Corell, Chuck 8.0 ‐ Site Monitoring 8.3

‐With respect to a GP format, it should require the

same monitoring requirements for a class of

permittees, and if something different is required,

then permittee would need coverage under an

Individual Permit (IP). Section 8.3 appears to negate

the need for a GP because it individualizes

monitoring requirements.

Meeting

110 Hays, Robert 8.0 ‐ Site Monitoring 8.3

‐What would the procedure be for including

additional discharge monitoring requirements?

‐When would changes be effective (i.e.,

immediately or at the end of an application

season)? It seems it could add requirements mid‐

permit cycle which would complicate ability to

comply with permit.

‐Seems that enhanced monitoring could be

addressed under section 8.3.

Meeting

111 Schardt, Jeffrey 8.0 ‐ Site Monitoring 8.1

‐8.1.2: Concerned with duration of time it'd take to

go back and do visual inspections following

applications.

‐8.1.3: Regarding adverse impact reporting, as a

permittee would expect to see some descriptors

listed, and maybe require reporting only if unique

or repeated.

Meeting

112 Meredith, Bill 8.0 ‐ Site Monitoring 8.0

‐Based on your calls during development of PPGP,

how would you implement site monitoring and how

would it work?

‐I envision proposing these requirements to my

state manager, including back‐check protocol, and

pay more attention to reporting visual inspections

required by the PGP. Checklists currently include a

"Notes" section and he'd instruct his staff to include

visual observations as required by the PGP in the

"Notes" section of the checklist.

‐Timing is always associated with control efficacy

back‐checks.

‐Concern for the lack of resources if told to

implement more time‐consuming activities required

by PGP.

Meeting

113 Aydell, Gary 8.0 ‐ Site Monitoring 8.0

‐Monitoring should be required for the discharge

limit; therefore, the BMP, to determine compliance

with permit.

‐Visual inspections may set precedent for other

permittees who may already be required to do WET

testing ‐ would visual monitoring (visual

observations and documentation of fish kills) be

open to them instead of reporting against WET

limits/sub‐lethal effects?

Meeting
114 Hora, Marvin 9.0 ‐ Reporting 9.0

‐Are annual reports (including those from tribes)

sent to EPA? If so, what will EPA do with them? If

data will not be reviewed, what is purpose?

‐Are there resources at EPA to keep current with

annual report reviews?

Meeting

115 Dwinell, Steve 9.0 ‐ Reporting 9.0

‐If we already have reporting requirements in place,

can we use those and not re‐create text (if so, that

would be preference)?

‐9.1, third filled bullet: Currently reads, "Quantity

applied over or near waters" ‐ do you need to split

out "near waters" from this bullet?

Meeting

116 Coram, Phil 9.0 ‐ Reporting 9.0, Appendix B

‐Section 9 compared to Appendix B.12 don't seem

to match.

‐"Adverse incident" vs. "Adverse Impact" ‐ are

these interchangeable?

‐Appendix B.12.F (24‐hour reporting) seems similar

to adverse incident reporting ‐ but with inconsistent

time frames.

Meeting

117 Corell, Chuck 9.0 ‐ Reporting 9.0

‐What is the purpose of the annual report (it

doesn't sound like it will provide useful

information)?

‐Is there a federal requirement for reporting in

NPDES permits?

Meeting

118 Gray, Jim 9.0 ‐ Reporting 9.0

‐The level of knowledge of where and how applied

(FIFRA requirements) is not known in all areas, and

varies among the states, so not all the states will

have the information required by the annual

reports.

Meeting

119 Goans, Steve 9.0 ‐ Reporting 9.0

‐Part of the reporting requirements apply only to

those required to submit the NOI, so you will miss a

large segment of pesticide applications.

‐Also, how is information submitted to EPA (is

electronic reporting available?) and to what level of

detail? Concern is with lack of resources (staff) to

enter data.

Meeting

120 Hays, Robert 9.0 ‐ Reporting 9.0

‐"Application" and "discharges" are used

interchangeably in the permit, but then on page 21

(in paragraph at top of page: "...in connection with a

discharge from your pesticide application."), they

are used together (need for consistent use of

terms).

Meeting

121 Gray, Jim 9.0 ‐ Reporting 9.2

‐On page 21, need to clarify when clock starts for

term "Within 14 days".

‐If reports are sent to EPA, states would like

assurance of timely feedback to states if review of

annual reports revealed adverse impacts.

Meeting

122 Schardt, Jeffrey 9.0 ‐ Reporting 9.2

‐With respect to "Product Name" and "EPA

Registration Number," can they report on the active

ingredient or EPA registration number specifically?

The product name/EPA registration number may

change, but the active ingredient remains the same.

‐9.1, two open bullets: Is there a difference

between "waterbody" and "jurisdiction"?

Meeting

123 Meredith, Bill 9.0 ‐ Reporting 9.0

Concern is with costs associated with reporting

requirements (also IPM plan development); along

with more reporting, requires more staff and more

money. Are 106 funds available to regulated

community?

Meeting

124 Spitzmuller, Joe 9.0 ‐ Reporting 9.1

‐Seeking clarification regarding who the "Operator"

is when asked to report the Operator's name and

mailing address.

‐Feels the data are available and should capture

from those not previously submitting the

information ‐ recognizes the value of some of the

information requested.

‐Is any of the information made publicly available ‐ 

concern for amount of data requests if they are

publicly available.

Meeting
125 Rose, Cheryl 9.0 ‐ Reporting 9.0

‐Annual reports are also a tickler for enforcement

actions; they provide a snapshot indication for

additional information. Annual reports provide

missing information.

‐County‐level information assists with information

follow‐up, watershed‐based approaches to

controls, assists in determining how to focus

resources.

‐Ensure that information is reviewed, evaluated,

and may hire a contractor to analyze and follow‐up.

‐Question regarding the comment of "within 14

days" ‐ are states interested in initial adverse

incident reports?

Meeting

126 Faulk, Jack 9.0 ‐ Reporting 9.0

‐To illustrate the importance of annual reports, I'll

use the Stormwater GP, annual reporting

requirements as an example. EPA needs to

determine how to target and identify the "Bad

Actors." The annual report intends to provide more

data, other than just the 2 pages submitted as the

NOI. The intent is to administer a concise but useful

program, advance, and assess effectiveness of the

program.

Meeting

127 Cswercko, Courtney 9.0 ‐ Reporting 9.0

‐How prescriptive will the requirements be? How

flexible can states be?

‐Under IA's state program, some licensed operators

already provide some information, but not all

information on PGP's list, can IA reduce the list?

Meeting

128 Goans, Steve 9.0 ‐ Reporting 9.0

‐Concern is that reports from many people may be

of insufficient quality, creates ripple effect of

problems, down the line.

‐Feels ambient monitoring would be ineffective

(poor reporting, runoff contributions hard to

quantify and identify source).

Meeting

129 Aydell, Gary 9.0 ‐ Reporting 9.0

‐Regarding ICIS, would the entire report be

electronically submitted?

‐What is the structure of an ICIS report ‐ concern

for variation in reporting quality.

Meeting

130 Goans, Steve 5.0 ‐ Corrective Action 5.0 Recommends using federal regulatory citations in

the permit (e.g., 40 CFR parts/sections). Meeting

131 Dwinell, Steve 5.0 ‐ Corrective Action 5.1

‐5.1, 2nd bullet: "you become aware, or EPA

determines, that your control measures are not

stringent enough..." ‐ how do you know if your

control measures are not minimizing effectively ‐ 

circular logic.

Meeting

132 Aydell, Gary 5.0 ‐ Corrective Action 5.1

‐Regarding "unauthorized release or discharge (e.g.,

spill, leak, ...)," are those also required to be

reported within that 14‐day period?

‐Are drips included in that group of "unauthorized

release or discharge (e.g., spill, leak, ...)"?

Meeting

133 Hays, Robert 5.0 ‐ Corrective Action 5.1 ‐Are the spills those that are operational, or to

WOUS? Meeting

134 Coram, Phil 5.0 ‐ Corrective Action 5.3.1

‐Suggest including an Appendix with a list of

appropriate agencies to which reporting (for

Adverse Incidents, under section 5.3.1) is required,

to help permittees get the appropriate information.

Meeting

135 Cswercko, Courtney 5.0 ‐ Corrective Action 5.3.2

‐Regarding documentation, you need to expand on

what information is required for the

documentation.

Meeting

136 Corell, Chuck 5.0 ‐ Corrective Action 5.3.1

‐There are existing requirements for reporting

hazardous conditions to emergency centers and

EPA; could reference those approaches for ideas.

Meeting

137 Gray, Jim

Seeking an understanding of what the fundamental

required portions of the NPDES permit are, hoping

for clarification of legal

requirements/underpinnings of NPDES permits.

Meeting

138 Corell, Chuck 2.0 ‐ Technology‐Based Effluent Limitations 2.0

‐Feels it would be beneficial to back up one layer,

especially with the effluent limitations section.

‐Let BMPs be options of how to meet effluent

limitations.

‐Leave out specificity of BMPs and leave to

permittees how to meet effluent limitations.

Meeting
139 Coram, Phil 1.0 ‐ Coverage Under This Permit 1.3, 1.3.2

‐Alternative Permits were not really discussed; is

that requirement based on NPDES regulations?

‐Is section 1.3.2 based on NPDES regulations?

Meeting

140 Aydell, Gary 1.0 ‐ Coverage Under This Permit 1.0

‐If someone is required to submit an NOI, can it be

tied to the pesticide registration program

somehow?

Meeting

141 Dwinell, Steve 1.0 ‐ Coverage Under This Permit 1.0

‐Regarding Gary Aydell's question about linking NOI

with pesticide registration programs, Steve

commented there may not be a good match of

information between the licensing/certification

system and the permit requirements.

Meeting

142 Goans, Steve Next Steps with States

‐Responding to Allison Wiedeman's question if the

timeline if feasible for states to meet, Steve noted

he feels the issue/complicating factor is with

changing WQS (and dealing with the narrative "...no

toxics in toxic amounts..."). The process alone, takes

time. Commented that their 2006 WQS were just

approved by EPA.

Meeting

143 Corell, Chuck Next Steps with States

‐Also in response to Allison Wiedeman's question

regarding feasibility of timeline with proposing and

finalizing a PGP, Chuck indicated he envisions much

effort in calming down his legislators because they

will perceive the permit as regulating farmers, and

will meet much resistance. The earlier draft

language can be distributed to the states the better,

as it will allow them to start working on the draft

and resolving perception issues.

‐1 year is a tight timeline.

‐Is it possible to receive the IPM principles first, so

IA (and other states) can begin the process by

meeting with applicators to discuss the

requirements for IPM plans?

Meeting

144 Rise, David Next Steps with States

‐Montana's intent will be to use EPA's PGP and

change the names.

‐The "no toxics" narrative is a state statute, not in

the WQS, so it would take more time to change to

incorporate.

Meeting

145 Akers, David Next Steps with States

‐Theoretically, CO would wait until after EPA posts

the proposed PGP, then, by gauging EPA's

responses to public comments, CO could change

language based on EPA's responses. Or, CO would

work concurrently with EPA and make changes to

permit language as EPA makes those changes (in

response to feedback/comments).

‐Feels CO could propose and finalize a PGP in 4 to 8

months, if they knew they could see permit

language, comments, and responses, concurrently;

there'd be a greater level of comfort in proposing a

PGP.

Meeting

146 Goans, Steve Next Steps with States

‐Appreciates the opportunity for partnering with

EPA through permit development process.

‐Would require details of permit language in order

to work with NPDES leads, look at rules/regulations

(to see what is necessary by NE rules/regulations),

and then begin drafting permit text.

‐Requires buy‐in from other parties in order to

make changes to regulations/rules.

Meeting

147 Hora, Marvin Next Steps with States

‐Feels 8 months is too short time frame to

propose/finalize PGP.

‐Feels permit text needs more development and

would be dependent on what EPA ends up drafting.

Meeting

148 Coram, Phil Next Steps with States

‐Would need to adopt this permit‐by‐rule (which

takes ~1 year, and even longer if there are

challenges).

‐Feels there is a need for change in the WQS;

anticipates controversy and challenges with that

route.

Meeting

149 Wiedeman, Allison Next Steps with States

‐Is there value in another face‐to‐face meeting?

Unanimous "YES" from participants.

‐Time frame possibly early‐March (prior to

proposed PGP, but with enough time to incorporate

changes based on that meeting).

Meeting
150 Lowry, Leslie Next Steps with States

‐Is EPA able to share portions of the permit draft as

it's being developed (i.e., comments/responses

resulting from biweekly teleconference calls)?

Meeting

151 Rose, Cheryl Next Steps with States

‐This process is unique in that it is moving so

quickly. There is a sensitivity issue to be mindful of;

not all ideas in the PGP have been vetted through

all the EPA offices yet, not all managers have been

briefed on PGP requirements, so there is a need to

hold on releasing the PGP to the public without all

parties within EPA knowing about it yet.

Meeting

152 Spitzmuller, Joe Next Steps with States

‐Regarding location of next face‐to‐face meeting

between EPA and the states: due to travel

restrictions, some states may not be able to attend

a second meeting ‐ are Webcasts a possibility (due

to travel restrictions)?

Meeting

153 Coram, Phil 3.0 ‐ Water Quality‐Based Effluent Limitations 3.0

‐It would help if EPA WQS folks could supply draft

language for states to consider for incorporating

short‐term WQS variances into their WQS (feels

that such variances wouldn't be approved today).

Meeting

154 Gray, Jim Next Steps with States

‐Acknowledges sensitivity issue with prematurely

releasing PGP information/language.

‐In ND, pesticides are regulated by the Agricultural

Department, and I've been asked to conduct

meetings to educate about upcoming PGP. Are

there education/outreach materials available to

me, to guide me on what level of specificity I can

discuss during these outreach meetings? Concerned

about outreach necessary to quell panic it might

create.

Meeting

155 Schardt, Jeffrey Next Steps with States

‐How soon can states receive the information that

is publicly available (e.g., Webcast Power Point

presentation, the presentation from the KC 2‐day

meeting)?

Meeting

156 Dwinell, Steve Next Steps with States

‐Fundamentally, EPA is on the right‐track with the

PPGP.

‐If requirements to implement/comply with PGP are

cumbersome and costly, acknowledge this will

cause an impact on public health (e.g., Dengue

Fever in FL, and hemorrhagic form is present in

Puerto Rico). Consider the complexity in

implementing the PGP and the potential impacts on

public health.

‐Consider the need for an Emergency Permit if not

finalized by April 2011, because if spraying is

needed (due to public health concerns/disease

outbreaks), there will be widespread CWA

violations.

Meeting

157 Goans, Steve 1.0 ‐ Coverage Under This Permit 1.0 ‐Sees a major issue with common understanding of

what "near water" is. Meeting

158 Meredith, Bill Next Steps with States

‐After the PPDC meeting and biweekly calls, how

quickly will the PPGP be modified for other use

patterns/categories (and to incorporate comments

heard at this KC 2‐day meeting)?

‐Feels the modified PGP (incorporating other use

patterns/categories) will be useful because there

are other use patterns out there that are more

useful to applicators.

Meeting

159 Schardt, Jeffrey 1.0 ‐ Coverage Under This Permit 1.0

‐Indicated that Army Corps of Engineers, USDA, and

Forest Service will need PGP coverage. Whoever

manages federal facilities will need PGP coverage.

Meeting

160 Corell, Chuck Next Steps with States ‐Is there a website for the Aquatic PGP program? Meeting

161 Gray, Jim Next Steps with States

Has EPA contemplated the NOI fee structure or

given any thought to developing guidance for state

agencies for developing states' fee structures?

Meeting

162 Spitzmuller, Joe Next Steps with States

‐Reiterated need to consider/address Agricultural

Tile Drains.

‐Is there a list of issues that EPA is considering, so

that states could offer feedback to EPA?

Meeting
163 Eckermann, Chuck Next Steps with States

Referring to Power Point Slide 13, the list of

pesticide use categories, when will this list be

finalized/clarified (e.g., if aquaculture categories are

covered)?

Meeting

164 Dwinell, Steve Next Steps with States How can states send EPA their input ‐ email

(because then it becomes public information)? Meeting

165 Meredith, Bill Next Steps with States ‐Has EPA received any comments/feedback from

the environmental groups yet? Meeting

166 Lowry, Leslie Next Steps with States

Acknowledged that pesticide issues attract different

environmental groups than water issues do, so even

though it's been "quiet" so far, there's been little to

respond to. Will await comments that will follow

the PPDC meeting.

Meeting

167 Aydell, Gary 1.0 ‐ Coverage Under This Permit 1.0

‐Inquired regarding applicability to aquaculture

feeding operations; is there a size threshold to

consider (and what if they're below that threshold)?

Meeting

168 Akers, David 1.0 ‐ Coverage Under This Permit 1.0

‐What about pesticide applications to ditch banks?

Is it presumed that applications to ditches will reach

WOUS?

Meeting

169 Dwinell, Steve If the PGP is adopted‐by‐rule, does it have to be

reviewed by OMB? Meeting

171 Dwinell, Steven Coverage Under This Permit 1.1.1

Comment: Activities Covered ‐ Aquaculture: control

of non‐invasive species; Rice Production; Sugar

Cane Production ‐ where there are in‐field canals

that connect to jurisdictional waters.

1‐Handwritten

172 Dwinell, Steven Coverage Under This Permit 1.1.2.5 Comment: FIFRA ‐ existing endangered species

program 1‐Handwritten

173 Dwinell, Steven 1.2.2

Comment: Two bullets ‐ (1) how to calculate water‐

acres for ground applications, aerial over land; (2)

near waters; (3) don't use multiple treatments per

acre

1‐Handwritten

174 Dwinell, Steven Coverage Under This Permit 1.2.2

Comment: 2nd bullet ‐ (1) Could capture a lot of

applicators; (2) private applicators or commercial

applicators that cumulatively treat over threshold

1‐Handwritten

175 Dwinell, Steven Coverage Under This Permit 1.2.2

Comment: X total water‐acre, another option: X

acres of jurisdictional waters within area of

responsibility and Y acres treated within that area.

1‐Handwritten

176 Dwinell, Steven Coverage Under This Permit 1.2.2

Comment: Best if "acres" used, not "treatments x

Acres". The latter approach will result in many more

operators being required to file NOIs due to year‐

long treatment seasons in southern states.

1‐Handwritten

177 Dwinell, Steven Coverage Under This Permit 1.2.4 Rewrite: Bullet (3) ‐ Suggest changing "not" to

"otherwise". 1‐Handwritten

178 Dwinell, Steven Technology‐Based Effluent Limitations 2.0

Comment: "Implementation of these control

measures must be in accordance with best industry

practices.." ‐ "should"? "Must" is problematic.

1‐Handwritten

179 Dwinell, Steven Technology‐Based Effluent Limitations 2.0

Question: "If you find that your control measures

are not minimizing pollutant discharges..." ‐ What

does this mean? How to determine?

1‐Handwritten

180 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.1.1 Comment: Applications are dependent on mosquito

populations and will vary over time. 1‐Handwritten

181 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.1.2

Comment: "Use the "lowest amount of pesticide

product per application"..." ‐ (1) Not enforceable

due to label directions for use ‐ allows higher rates;

(2) If EPA is concerned about a high rate, label

should be amended; (3) "Lowest" could result in

resistance development.

1‐Handwritten

182 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.1.2 Comment: "[NOTE: define season]" ‐ no "season" in

Florida. 1‐Handwritten

183 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.1.3 Comment: Consider aerial vs. ground 1‐Handwritten

184 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.1.3

Comment: "[NOTE: Fact Sheet could include a

discussion of unavoidable as incidental deposition.

Just an idea]" ‐ Include use of application practices

that minimize deposition (e.g., droplet size,

calibration, wind speed monitoring).

1‐Handwritten

185 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.2

Comment: "...prior to the first application each

"season" for each treatment area..." ‐ Year‐round in

Florida

1‐Handwritten

186 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.2.1

Comment: (1) This is done for each application; (2)

reference standard publications or published

BMPs?

1‐Handwritten
187 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.3 Question: Applies to all 5 sub‐bullets ‐ Will inclusion

of these practices in a program be compliant? 1‐Handwritten

188 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.3.1 Question: County‐wide? 1‐Handwritten

189 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.3.4 Comment: Methoprene and Bti are pesticides that

are discharged to water. 1‐Handwritten

190 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.5 Comment: Need to provide for flexibility for

"resources" available to a local government. 1‐Handwritten

191 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.5.2 Comment: (1) won't work; (2) 10x cost 1‐Handwritten

192 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.5.2 Rewrite: Suggests Use larvacide as part of an

integrated program where practicable. 1‐Handwritten

193 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.5.4 Comment: Use existing FIFRA requirements of

certifications. 1‐Handwritten

194 Dwinell, Steven Technology‐Based Effluent Limitations 2.1.5.6 Question: How often? 1‐Handwritten

195 Dwinell, Steven Technology‐Based Effluent Limitations 2.2.1.2 Comment: Resistance 1‐Handwritten

196 Dwinell, Steven Technology‐Based Effluent Limitations 2.2.2.1 Comment: May not be able to amend permit to

capture new species in a timely manner. 1‐Handwritten

197 Dwinell, Steven Technology‐Based Effluent Limitations 2.2.3.2 Comment: Can severely impact non‐target species. 1‐Handwritten

198 Dwinell, Steven Technology‐Based Effluent Limitations 2.2.3

Question: Regarding paragraph at end of section ‐ Is

cost an acceptable reason for not implementing a

control measure?

1‐Handwritten

199 Dwinell, Steven Water Quality‐Based Effluent Limitations 3.0 Comment: Florida has "no" waters impaired due to

pesticides. 1‐Handwritten

200 Dwinell, Steven Corrective Action 5.1 Comment: Should be based on CERCLA RQs. 1‐Handwritten

201 Dwinell, Steven Corrective Action 5.1 Question: 1st bullet ‐ "(...spill, leak..." ‐ To water? 1‐Handwritten

202 Dwinell, Steven Corrective Action 5.1 Question: 2nd bullet ‐ "applicable water quality

standards" ‐ WQBELs? 1‐Handwritten

203 Dwinell, Steven Corrective Action 5.1

Comment: 3rd bullet ‐ "...determines that

modifications to the control measures are

necessary to meet the non‐numeric effluent limits

in this permit" ‐ Under FIFRA pesticide

manufacturers responsible if product used

according to label directions for use.

1‐Handwritten

204 Dwinell, Steven Integrated Pest Management (IPM) Plan 6.0 Comment: One plan for activity for area of

operation. 1‐Handwritten

205 Dwinell, Steven Integrated Pest Management (IPM) Plan 6.1.1.1 Comment: (1) Why? (2) this can change frequently;

(3) not necessary. 1‐Handwritten

206 Dwinell, Steven Integrated Pest Management (IPM) Plan 6.1.1.2

Comment: (1) can't be made to be site‐specific; (2)

area of operation; (3) could be very costly to

produce.

1‐Handwritten

207 Dwinell, Steven Integrated Pest Management (IPM) Plan 6.1.1.3

Comment: Bullet (c) ‐ (1) Low levels can be non‐

efficacious; (2) limited number of materials that

meet public health efficacy requirements

1‐Handwritten

208 Dwinell, Steven Integrated Pest Management (IPM) Plan 6.1.1.3

Comment: Bullet (c) ‐ "...any non‐toxic or less toxic

pest control methods..." ‐ (1) risk, not toxicity; (2)

covered under FIFRA; (3) toxic to what‐

Invertebrates, Mammals?

1‐Handwritten

209 Dwinell, Steven Integrated Pest Management (IPM) Plan 6.1.1.4

Comment: (1) how to document; (2) yearly,

monthly? (3) extensive in large districts; (4) best to

take advantage of existing reporting requirements.

1‐Handwritten

210 Dwinell, Steven Site Monitoring 8.1 Question: When? 1‐Handwritten

211 Dwinell, Steven Site Monitoring 8.1.2 Question: 2nd open bullet ‐ What is meant by a

contact pesticide? 1‐Handwritten

212 Dwinell, Steven Site Monitoring 8.1.2 Comment: 3rd and 5th open bullets ‐ Not applicable

for mosquito control. 1‐Handwritten

213 Dwinell, Steven Site Monitoring 8.1.3 Comment: "...discomfort..." is too vague. 1‐Handwritten

214 Dwinell, Steven Site Monitoring 8.2.1

Comment: (1) no! Becomes a "hit list" for anti‐

pesticide activities; (2) does not take into account

existence of FIFRA review of pesticides ‐ Who

decides ‐ OPP or OW? (3) If there is a problem with

a pesticide, should be dealt with as a product issue,

not an operator issue. Product issues are resolved

by the registrant at their expense.

1‐Handwritten

215 Dwinell, Steven Reporting 9.1

Question: (1) Why is this required? (2) How will it be

used? (3) State pesticide programs either have or

can get this information if needed; (4) Use existing

reporting mechanisms that states have (e.g.,

mosquito annual pesticide use reports).

1‐Handwritten

216 Dwinell, Steven Reporting 9.1 Comment: 1st four bullets ‐ We will have this

information already. 1‐Handwritten

217 Dwinell, Steven Reporting 9.1

Question: "Quantity applied over or near waters" ‐ 

What is near? Near could mean: (1) the top of ditch

bank? (2) swath width (e.g., "Near is within one

swath width of the application equipment (for

aircraft = 1,100 feet, for ground equipment = 300

feet)).

1‐Handwritten
218 Dwinell, Steven Recordkeeping 10.1 Comment: 5th bullet ‐ Use existing FIFRA

requirements. 1‐Handwritten

219 Dwinell, Steven Recordkeeping 10.1 Comment: 6th filled bullet (Pesticide Application

Logs) ‐ use existing FIFRA reporting requirements. 1‐Handwritten

220 Dwinell, Steven Recordkeeping 10.1 Comment: 6th filled bullet (Pesticide Application

Logs), bullet (4h) ‐ GPS tracks 1‐Handwritten

221 Dwinell, Steven Recordkeeping 10.1

Comment: 6th filled bullet (Pesticide Application

Logs), bullet (9) ‐ Not necessary; larvaciding is done

when/where practical.

1‐Handwritten

222 Simoneaux, Bobby Coverage Under This Permit 1.1.1 Comment: "Additional use patterns" ‐ add

Aquaculture and Rice 2‐Handwritten

223 Simoneaux, Bobby Coverage Under This Permit 1.1.2.3 Comment: not needed 2‐Handwritten

224 Simoneaux, Bobby Coverage Under This Permit 1.2.2 Comment: Better define "responsible entity";

"applicator"; and "operator" 2‐Handwritten

225 Simoneaux, Bobby Coverage Under This Permit 1.2.2 Comment: "EPA will post on the Internet", No! ‐ CBI 2‐Handwritten

226 Simoneaux, Bobby Coverage Under This Permit 1.2.4 Rewrite: Suggests replacing "not" with "otherwise" 2‐Handwritten

227 Simoneaux, Bobby Technology‐Based Effluent Limitations 2

Question: "If you find that your control measures

are not minimizing pollutant discharges" ‐ What is

this?

2‐Handwritten

228 Simoneaux, Bobby Technology‐Based Effluent Limitations 2.1.4.1 Comment: $$ indicated 2‐Handwritten

229 Simoneaux, Bobby Technology‐Based Effluent Limitations 2.1.4.2 Comment: $$ indicated 2‐Handwritten

230 Simoneaux, Bobby Technology‐Based Effluent Limitations 2.1.5.2 Comment: not feasible 2‐Handwritten

231 Simoneaux, Bobby Technology‐Based Effluent Limitations 2.1.5.4 Comment: already done under FIFRA 2‐Handwritten

232 Simoneaux, Bobby Technology‐Based Effluent Limitations 2.1.5.6 Comment: FIFRA 2‐Handwritten

233 Simoneaux, Bobby Technology‐Based Effluent Limitations 2.2.1.2 Comment: resistance issues 2‐Handwritten

234 Simoneaux, Bobby Technology‐Based Effluent Limitations 2.2.6.2.2 Question: "label human hazard warnings" ‐ what is

this? 2‐Handwritten

235 Simoneaux, Bobby Site Monitoring 8.1 Rewrite: Suggest changing "possible" to

"observable" 2‐Handwritten

236 Simoneaux, Bobby Reporting 9.1 Rewrite: 1st bullet ‐ Suggests changing "Operator"

to "Permittee" 2‐Handwritten

237 Simoneaux, Bobby Reporting 9.1 Question: "Jurisdictions" ‐ ? 2‐Handwritten

238 Simoneaux, Bobby Recordkeeping 10.1 Question: Change "Operators required..." to

"Permittee required..."?? 2‐Handwritten

239 Simoneaux, Bobby Recordkeeping 10.1 Question: 6th bullet (Pesticide Application Logs) ‐ 

Where kept? 2‐Handwritten

240 Simoneaux, Bobby Recordkeeping 10.1

Rewrite: 6th bullet (Pesticide Application Logs),

bullet (9) ‐ Suggests adding to the end "or has

failed"

2‐Handwritten

241 Simoneaux, Bobby Recordkeeping 10.1 Comment: 7th bullet (Pesticide Application

Equipment Maintenance) ‐ Not needed. 2‐Handwritten

242 Hora, Marvin Coverage Under This Permit 1.3.1

Comment: Any interested person may petition EPA

to take action under this paragraph.  Sentence has

been starred(*)

3‐Handwritten

243 Hora, Marvin Technology‐Based Effluent Limitations 2.1.1.2 Comment: Resistance management 3‐Handwritten

244 Hora, Marvin Technology‐Based Effluent Limitations 2.1.4 Question: Will EPA establish action thresholds?

Bites per minute? Larval counts per 100ml? 3‐Handwritten

245 Hora, Marvin Site Monitoring 8.1 Question: "each application site" ‐ What is site? 3‐Handwritten

246 Hora, Marvin Site Monitoring 8.1 Rewrite: Suggests changing "possible" to "visual" 3‐Handwritten

247 Hora, Marvin Site Monitoring 8.2.1 Comment: Pesticide of Concern? "as info shows" 3‐Handwritten

248 Gray, Jim General

Question: In some fashion, can EPA indicate what

parts of the general permit are required for NPDES

permits and what components are optional?

4‐Handwritten

249 Gray, Jim General Question: point source discharge? (first page of

permit) 4‐Handwritten

250 Gray, Jim Coverage Under This Permit 1.1.1 Question: Is non‐agricultural stormwater runoff

exempted? 4‐Handwritten

251 Gray, Jim Coverage Under This Permit 1.1.2.1 Question: How do people know where these water

bodies are? 4‐Handwritten

252 Gray, Jim Coverage Under This Permit 1.1.2.2 Question: What if water body listed as impaired

after permit is issued? How will this be handled? 4‐Handwritten

253 Gray, Jim Coverage Under This Permit 1.1.2.3 Question: rinsate? 4‐Handwritten

254 Gray, Jim Coverage Under This Permit 1.1.2.5 Comment: Should be adequately addressed under

FIFRA through labeling and county bulletins 4‐Handwritten

255 Gray, Jim Coverage Under This Permit 1.1.2.5 Question: What is being contemplated here? 4‐Handwritten
256 Gray, Jim Coverage Under This Permit 1.2 Comment: More simplified message. 4‐Handwritten

257 Gray, Jim Coverage Under This Permit 1.2.2 Question: What does "near waters" mean? 4‐Handwritten

258 Gray, Jim Coverage Under This Permit 1.2.2 Question: Concerning the two bullets ‐ is this an

"or" or an "and"? 4‐Handwritten

259 Gray, Jim Coverage Under This Permit 1.2.2

Question: Y total water acre treatments during

coverage under this permit cycle ‐ per year or per 5

years?

4‐Handwritten

260 Gray, Jim Coverage Under This Permit 1.2.2

Question: 2nd paragraph, "responsible entity" ‐ a

mosquito control district, not the contracted

applicator?

4‐Handwritten

261 Gray, Jim Coverage Under This Permit 1.2.2

Comment: 3rd paragraph, "IPM plan" ‐ this is a

problem due to different definitions of IPM and

subjective interpretations

4‐Handwritten

262 Gray, Jim Coverage Under This Permit 1.2.2

Comment: "EPA will post on the internet, all NOIs

received" ‐ this may encourage harassment of

applicators by the public, CBI concerns.

4‐Handwritten

263 Gray, Jim Coverage Under This Permit 1.2.3 Comment: "near waters" ‐ need to define "near" 4‐Handwritten

264 Gray, Jim Coverage Under This Permit 1.2.3

Question: Table, Discharge Authorization Date, "10

days after complete NOI received and posted by

EPA" ‐ why is post date part of this?

4‐Handwritten

265 Gray, Jim Technology‐Based Effluent Limitations 2 Question: "best industry practices" ‐ what does this

mean? 4‐Handwritten

266 Gray, Jim Technology‐Based Effluent Limitations 2

Comment: "equipment manufacturer's

specifications" ‐ It is a bad idea to link permit

compliance to private entity's specifications

4‐Handwritten

267 Gray, Jim Technology‐Based Effluent Limitations 2 Comment: "IPM principles" ‐ Bad Idea! 4‐Handwritten

268 Gray, Jim Technology‐Based Effluent Limitations 2

Question: "If you find that you control measures are

not minimizing pollutant discharges" ‐ What does

this mean?

4‐Handwritten

269 Gray, Jim Technology‐Based Effluent Limitations 2 Question: How much flexibility will states have to

have less prescriptive BATs? 4‐Handwritten

270 Gray, Jim Technology‐Based Effluent Limitations 2.1.1.1 Comment: This is vague and unenforceable 4‐Handwritten

271 Gray, Jim Technology‐Based Effluent Limitations 2.1.1.2 Question: Does this encourage resistance to the

pesticide? 4‐Handwritten

272 Gray, Jim Technology‐Based Effluent Limitations 2.1.1.3 Comment: Behavior change and message

consistency 4‐Handwritten

273 Gray, Jim Technology‐Based Effluent Limitations 2.1.2 Question: Who is going to verify that all of this was

done? 4‐Handwritten

274 Gray, Jim Technology‐Based Effluent Limitations 2.1.3 Question: Who is going to verify that all of this was

done? 4‐Handwritten

275 Gray, Jim Technology‐Based Effluent Limitations 2.1.3.3 Comment: change "eliminate" to "minimize" 4‐Handwritten

276 Gray, Jim Technology‐Based Effluent Limitations 2.1.5.1 Comment: "minimize the use of" ‐ subjective term

that will be difficult to enforce 4‐Handwritten

277 Gray, Jim Technology‐Based Effluent Limitations 2.1.5.2 Comment: "primary pesticide" ‐ subjective term

that will be difficult to enforce 4‐Handwritten

278 Gray, Jim Technology‐Based Effluent Limitations 2.1.5.2 Question: "primary pesticide" ‐ is this based on

science? 4‐Handwritten

279 Gray, Jim Technology‐Based Effluent Limitations 2.1.5.4 Comment: Why not just require applicator to be

certified? 4‐Handwritten

280 Gray, Jim Technology‐Based Effluent Limitations 2.1.5.5 Comment: Already enforceable under pesticide

laws 4‐Handwritten

281 Gray, Jim Technology‐Based Effluent Limitations 2.1.5.6 Comment: Already enforceable under pesticide

laws. 4‐Handwritten

282 Gray, Jim Technology‐Based Effluent Limitations 2.1.6 Question: What if pesticide use is done by a private

firm and not a mosquito control district? 4‐Handwritten

283 Gray, Jim Technology‐Based Effluent Limitations 2.2.1.1 Comment: "extent achievable" = vague? 4‐Handwritten

284 Gray, Jim Technology‐Based Effluent Limitations 2.2.1.2 Comment: May encourage weed resistance to

herbicides. 4‐Handwritten

285 Gray, Jim Technology‐Based Effluent Limitations 2.2.2.3 Comment: Not feasible for most contracted

applicators. 4‐Handwritten

286 Gray, Jim Technology‐Based Effluent Limitations 2.2.2.4 Comment: Not feasible for most contracted

applicators. 4‐Handwritten

287 Gray, Jim Technology‐Based Effluent Limitations 2.2.3 Question: "prior to each pesticide application" ‐ ??? 4‐Handwritten

288 Gray, Jim Technology‐Based Effluent Limitations 2.2.3.2

Comment: Herbicide applicators are normally made

after these have failed.  If the applicator holds the

NOI, they may not have done these.

4‐Handwritten

289 Gray, Jim Technology‐Based Effluent Limitations 2.2.5.2 Question: What about cabin owners who use

general use herbicides on lake front property? 4‐Handwritten

290 Gray, Jim Technology‐Based Effluent Limitations 2.2.6.1 Question: Again, what if application is done by

private citizens? 4‐Handwritten

291 Gray, Jim Technology‐Based Effluent Limitations 2.2.6.2

Question: "post, near public access" ‐ (1) why is

there a posting requirement?, (2) what if there is no

public access point?

4‐Handwritten

292 Gray, Jim Technology‐Based Effluent Limitations 2.2.6.2.2 Question: "hazard warnings" ‐ what does this

mean? 4‐Handwritten
293 Gray, Jim Corrective Action 5.3.1 Comment: This is already discussed in section 9.2.  

Does it need to be re‐stated here? 4‐Handwritten

294 Gray, Jim Integrated Pest Management Plan 6.1.1.3 Comment: Bullet (c) ‐ No such thing as "non‐toxic" 4‐Handwritten

295 Gray, Jim Integrated Pest Management Plan 6.1.1.3 Comment: Bullet (d) ‐ This is a very open‐ended

statement. 4‐Handwritten

296 Gray, Jim Integrated Pest Management Plan 6.1.2.2 Comment: Bullets (c) and (d) ‐ Difficult to determine

for weed problems. 4‐Handwritten

297 Gray, Jim Integrated Pest Management Plan 6.1.2.3

Question: "IPM plan must document control

measures used/evaluated to minimize pesticide

discharging" ‐ How is water agency going to assess

this?

4‐Handwritten

298 Gray, Jim Integrated Pest Management Plan 6.1.3.3

Question: 6th bullet, "Name, location, telephone of

nearest chemical responder" ‐ Is this known in all

situations?

4‐Handwritten

299 Gray, Jim Integrated Pest Management Plan 6.1.3.4

Comment: NO! Increase ambient water monitoring

programs, not site‐specific monitoring.  The quality

of these site‐specific monitoring data will be

questionable.

4‐Handwritten

300 Gray, Jim Site Monitoring 8.1 Question: "identify any possible water..." ‐ Is

possible the best word to use here? 4‐Handwritten

301 Gray, Jim Site Monitoring 8.1.2 Question: Will there be access to all treated areas? 4‐Handwritten

302 Gray, Jim Site Monitoring 8.1.3 Comment: Quality of monitoring will be dependent

on who is responsible (applicator or landowner). 4‐Handwritten

303 Gray, Jim Site Monitoring 8.2.1 Question: How will these be determined? 4‐Handwritten

304 Gray, Jim Site Monitoring 8.3 Question: "pesticide of concern" ‐ From POINTS?

No. 4‐Handwritten

305 Gray, Jim Reporting 9.1 Question: 1st bullet, "operator name" ‐ Who is this? 4‐Handwritten

306 Gray, Jim Reporting 9.1

Comment: Maintaining records is already required

under FIFRA and state pesticide laws for many uses.

This may cause redundancy.  Also, many applicators

view these records as CBI.

4‐Handwritten

307 Gray, Jim Reporting 9.2

Question: "...the appropriate state wildlife or

natural resources agency..." ‐ What about state

water agency?

4‐Handwritten

308 Gray, Jim Reporting 9.2 Question: "within 14 days" ‐ Of the application or

when adverse effects first observed? 4‐Handwritten

309 Gray, Jim Reporting 9.2

Question: Will pesticide regulators be notified of

these adverse effect reports? This needs to be done

in a timely manner so that an investigation can be

done to determine if there was misuse.

4‐Handwritten

310 Gray, Jim Recordkeeping 10.1 Question: "Operator" ‐ What is an "operator"?? 4‐Handwritten

311 Gray, Jim Recordkeeping 10.1

Comment: 6th bullet (Pesticide Application Logs) ‐ 

Records are already required under FIFRA and many

state pesticide laws.  These additional requirements

may be redundant and cause confusion.

4‐Handwritten

312 Gray, Jim Recordkeeping 10.1

Comment: 6th bullet (Pesticide Application Logs),

bullet (4h), "Names of all waterbodies..." ‐ This will

not always be available.

4‐Handwritten

313 Daiker, Davis Coverage Under This Permit 1.1.1

Comment: One permit for Mosquito Control

(Larvicide and Adulticide) and Aquatic Weed

Control in Lakes and Ponds, or One permit for

Mosquito Control (Larvicide and Adulticide) and one

permit for Aquatic Weed Control in Lakes and

Ponds.

5‐Handwritten

314 Daiker, Davis Coverage Under This Permit 1.1.2.3

Question: Discharges of Equipment Rinsate or

Washwaters ‐ Not allowed under FIFRA? Does it

need to be stated?

5‐Handwritten

315 Daiker, Davis Coverage Under This Permit 1.1.2.5 Comment: Additional requirements outside of label

and OPP EFED requirements 5‐Handwritten

316 Daiker, Davis Coverage Under This Permit 1.2.2

Question: First two bullets describing operators ‐ 

Both must obtain NOI? If so, how can applicator

demonstrate IPM was followed, if IPM is done by

landowners?

5‐Handwritten

317 Daiker, Davis Coverage Under This Permit 1.2.2 Question: First bullet describing operator ‐ 

Landowner contracting for applicator? 5‐Handwritten

318 Daiker, Davis Coverage Under This Permit 1.2.2 Question: Are X and Y different? 5‐Handwritten

319 Daiker, Davis Coverage Under This Permit 1.2.2 Question: What is water‐acre for ground mosquito

control? 5‐Handwritten
320 Daiker, Davis Coverage Under This Permit 1.2.2

Comment: Last paragraph, "EPA will post on the

Internet, at www.epa.gov/npdes/noisearch, all

NOIs received" ‐ (a) CBI issues, (b) Unnecessary

disclosure, (c) Will this be required for state NPDES

agencies?

5‐Handwritten

321 Daiker, Davis Coverage Under This Permit 1.2.3 Question: Table ‐ Will this approach be required for

states with permitting authority? 5‐Handwritten

322 Daiker, Davis Coverage Under This Permit 1.2.3

Question: Table, Last column (Discharge

Authorization Date) ‐ "10 days after complete NOI

received and posted by EPA" ‐ Puts timing of

application in EPA's hands? How to avoid delays?

5‐Handwritten

323 Daiker, Davis Coverage Under This Permit 1.3.1

Question: "Any interested person may petition EPA

to take action under this paragraph" ‐ If I file NOI,

am I covered for operations in the interim while

EPA reviews petition?

5‐Handwritten

324 Daiker, Davis Technology‐Based Effluent Limitations 2.0

Comment: "If you find that your control measures

are not minimizing pollutant discharges, you must

modify these control measures as expeditiously as

practicable." ‐ What (does this mean?) and not

practical?

5‐Handwritten

325 Daiker, Davis Technology‐Based Effluent Limitations 2.1.1.2 Comment: "effectively" ‐ key issue 5‐Handwritten

326 Daiker, Davis Technology‐Based Effluent Limitations 2.1.2.1 Question: "action threshold" ‐ What about West

Nile Virus thresholds ‐ is it different? 5‐Handwritten

327 Daiker, Davis Technology‐Based Effluent Limitations 2.1.3

Question: Is this control feasible for a Mosquito

Control District (MCD) or should outreach and

education prove more practical?

5‐Handwritten

328 Daiker, Davis Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Suggests changing "eliminate" to

"minimize". 5‐Handwritten

329 Daiker, Davis Technology‐Based Effluent Limitations 2.1.3.4 Question: "Maintain and promote biological

control.." ‐ to who? 5‐Handwritten

330 Daiker, Davis Technology‐Based Effluent Limitations 2.1.3

Comment: Last paragraph, "In the event that any of

the permit conditions...is not feasible, you must

document why you are unable to comply with the

condition." ‐ Thank you.

5‐Handwritten

331 Daiker, Davis Technology‐Based Effluent Limitations 2.1.6 Question: Why, what is the point? 5‐Handwritten

332 Daiker, Davis Technology‐Based Effluent Limitations 2.2.2.2 Comment: Not always possible to get on permit. 5‐Handwritten

333 Daiker, Davis Technology‐Based Effluent Limitations 2.2.2.3 Question: "nutrients" ‐ How does applicator show

this? 5‐Handwritten

334 Daiker, Davis Technology‐Based Effluent Limitations 2.2.3.2 Question: Sections 2.2.3.2 through 2.2.3.4 ‐ Can

these be omitted in lieu of 2.2.3.1? 5‐Handwritten

335 Daiker, Davis Technology‐Based Effluent Limitations 2.2.6.1 Question: Is this practical on a large water body

with spot treatments for hyacinth or hydrilla? 5‐Handwritten

336 Daiker, Davis Technology‐Based Effluent Limitations 2.2.6.2.2 Question: "label human hazard warnings" ‐ What is

this? Signal word, use restrictions, re‐entry. 5‐Handwritten

337 Daiker, Davis Integrated Pest Management (IPM) Plan 6.1.1.1 Question: Why, as long as they're certified? 5‐Handwritten

338 Daiker, Davis Integrated Pest Management (IPM) Plan 6.1.1.2

Comment: Bullets (b) and (c) ‐ Has to be generic in

nature. To be specific would be cost‐prohibitive and

would require surveying.

5‐Handwritten

339 Daiker, Davis Integrated Pest Management (IPM) Plan 6.1.1.2 Comment: Bullet (f) ‐ Maps are impractical for a

general permit. 5‐Handwritten

340 Daiker, Davis Integrated Pest Management (IPM) Plan 6.1.1.3

Question: Bullet (c) "This should include an

evaluation of any non‐toxic or less toxic.." ‐ Less

toxic to what? OMIT.

5‐Handwritten

341 Daiker, Davis Integrated Pest Management (IPM) Plan 6.1.1.4 Question: Bullets (a) and (b) ‐ Can a reference to a

standard method be made? 5‐Handwritten

342 Daiker, Davis Site Monitoring 8.1 Rewrite: Suggests changing "possible" to

"observable". 5‐Handwritten

343 Daiker, Davis Site Monitoring 8.1.2

Question: 2nd full bullet and under that, the 2nd

open bullet ‐ "...when the "application area" for a

single treatment" ‐  What is this?

5‐Handwritten

344 Daiker, Davis Site Monitoring 8.2.1 Question: How to conduct monitoring? Bad idea. 5‐Handwritten

345 Daiker, Davis Reporting 9.1

Comment: 2nd and 3rd filled in bullet ("Quantity

applied directly to waters" and "Quantity applied

over or near waters") ‐ Reporting requirements

could be structured by application scenario.

5‐Handwritten

346 Daiker, Davis Recordkeeping 10.1 Comment: Pesticide Application Logs, bullet (3) ‐ 

"...waterbody..." ‐ won't work for mosquito control. 5‐Handwritten

347 Schardt, Jeffrey General

Comment: Overall, be sure all Plans, Reporting,

Recordkeeping adds value to resolve or prevent the

issue that began this process. Separate the "want‐

to‐know" from the "need‐to‐know" requirements.

6‐Handwritten
348 Schardt, Jeffrey Coverage Under This Permit 1.1.1 Question: Aquatic Weed Control in Lakes and Ponds

‐ Rivers and Canals (Waters of the U.S.)? 6‐Handwritten

349 Schardt, Jeffrey Coverage Under This Permit 1.1.2.2 Comment: Not in FL. 6‐Handwritten

350 Schardt, Jeffrey Coverage Under This Permit 1.1.2.5

Comment: Would like to work with you. Very

important to FL cases where invasive plant control [‐

‐‐] and

6‐Handwritten

351 Schardt, Jeffrey Coverage Under This Permit 1.2.1 Question: "Develop an IPM plan..." ‐ Website? 6‐Handwritten

352 Schardt, Jeffrey Coverage Under This Permit 1.2.2

Question: If FWC has certain permit exemptions,

does applicator need to get an individual NPDES

permit (e.g., 1/4‐ac pond); tailor to existing regs in

an individual state. (Jack [‐‐‐] statement covering

small site [applications]

6‐Handwritten

353 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.1 Question: What is discharge? Soluble herbicides will

move great distances. 6‐Handwritten

354 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.1.1 Comment: Aquatic herbicides registered for slow

moving waters, rivers, streams; drip method. 6‐Handwritten

355 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.1.2 Comment: If use "lowest amount", this leads to

resistance issues. 6‐Handwritten

356 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.1.2 Comment: "..per season..." ‐ year round south of

Orlando. 6‐Handwritten

357 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.2.2 Comment: CNGS (changes?) 6‐Handwritten

358 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.3.2

Comment: Delete and go with #1 (2.2.3.1). Not

selective; 30% young‐of‐the‐year sport fish killed

(through mech. controls).

6‐Handwritten

359 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.3.3 Rewrite: Delete "maintain" 6‐Handwritten

360 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.4.3 Comment: Can view site and speculate. 6‐Handwritten

361 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.5.1 Comment: Infeasible. Pesticides impact the

environment. 6‐Handwritten

362 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.6.1 Comment: Refer to website 6‐Handwritten

363 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.6.2 Question: Even for herbicides with no water use

restrictions? 6‐Handwritten

364 Schardt, Jeffrey Technology‐Based Effluent Limitations 2.2.6.2.2

Question: "...label human hazard warnings" ‐ Signal

word? Hazards are to the applicator if no water use

restriction.

6‐Handwritten

365 Schardt, Jeffrey Corrective Action 5.1

Comment: Last bullet ‐ [‐‐‐] be specific (ex.

Mechanical kill fish), [‐‐‐] non‐target control in year

of application.

6‐Handwritten

366 Schardt, Jeffrey Corrective Action 5.3.2

Comment: People who do not want [‐‐‐] [‐‐‐] what

do you have in mind? Could they point to [spotting]

[browning] [resulting] of standard [‐‐‐] of [‐‐‐] veg

even though research shows grows back.

6‐Handwritten

367 Schardt, Jeffrey Integrated Pest Management (IPM) Plan 6.0

Comment: Every water is different, every treatment

within waters different; different seasonally.

Countless statistics based on target/non‐target [‐‐‐]

uses.

6‐Handwritten

368 Schardt, Jeffrey Integrated Pest Management (IPM) Plan 6.1.1.1

Some teams have 2, some have 50 and 60.

Depending on the amount of expertise. Not

necessary to ID team ‐ what value added?

6‐Handwritten

369 Schardt, Jeffrey Integrated Pest Management (IPM) Plan 6.1.2 Question: "Aquatic Weed Control in "Lakes and

Ponds"" ‐ US Waters? 6‐Handwritten

370 Schardt, Jeffrey Integrated Pest Management (IPM) Plan 6.1.2.1 Question: [Statewide] IPM Plan? 450 waters; 1.25 w

a; 7,200 permits. 6‐Handwritten

371 Schardt, Jeffrey Integrated Pest Management (IPM) Plan 6.1.2.2 Comment: EDRR is basis ‐ WH doubles in 2 weeks,

HyD 2‐4"/day 6‐Handwritten

372 Schardt, Jeffrey Integrated Pest Management (IPM) Plan 6.1.2.3 Question: Bullet (b): Will website suffice? 6‐Handwritten

373 Schardt, Jeffrey Site Monitoring 8.1.2 Comment: Size limit on this (.1 ac ‐ 200 ac). 6‐Handwritten

374 Schardt, Jeffrey Site Monitoring 8.1.2 Comment: 1st filled bullet (non‐aerial treated), 2nd

open bullet underneath: Purpose (value added)? 6‐Handwritten

375 Schardt, Jeffrey Site Monitoring 8.1.2

Comment: 2nd filled bullet (aerially treated): # or

size of application (1) small subset, (2) keep records

at FWC for [unwanted] [‐‐‐]

6‐Handwritten

376 Schardt, Jeffrey Site Monitoring 8.1.3 Comment: 1st filled bullet ‐ Immediately if [‐‐‐] ‐we

[‐‐‐] use oxygen stress weeks after. 6‐Handwritten

377 Schardt, Jeffrey Site Monitoring 8.1.3

Comment: 6th filled bullet ‐ Applicators understand

but even though we work with anglers, hungers,

they usually point to non‐target [browning], etc.

6‐Handwritten

378 Schardt, Jeffrey Site Monitoring 8.1.3

Comment: 6th filled bullet specifically "non‐target" ‐

Call all plants targets up‐front or acknowledge that

there may be spotting, browning, [‐‐‐] biomass

reduction.

6‐Handwritten

379 Schardt, Jeffrey Site Monitoring 8.1.4

Comment: Submit to EPA or permit holder? FL

inspects 23 contractors 4x/year and retain this

information.

6‐Handwritten

380 Schardt, Jeffrey Site Monitoring 8.1.4 Comment: Sub‐[‐‐‐] "returns" appearance of water

body to "normal" condition 6‐Handwritten
381 Schardt, Jeffrey Site Monitoring 8.2

Question: How does monitoring [‐‐‐] safety after

application; (1) this is in the [‐‐‐]; (2) Don't use if

F&W are [‐‐‐] if CPD [compound?] has history of

impact to F&W

6‐Handwritten

382 Schardt, Jeffrey Site Monitoring 8.2

Comment: For these CPDS [compounds?], re‐

register and limit the areas approved for

application.

6‐Handwritten

383 Schardt, Jeffrey Reporting 9.1 Question: 1st open bullet‐"products", "registration

number" ‐ Active Ingredient? 6‐Handwritten

384 Schardt, Jeffrey Reporting 9.1

Question: 1st filled bullet ‐ "jurisdictions" ‐ for

aquatic plant control, is there a difference between

jurisdiction and waterbody?

6‐Handwritten

385 Schardt, Jeffrey Reporting 9.1 Question: If benefit of information is for the state,

why not keep the information at the state? 6‐Handwritten

386 Schardt, Jeffrey Recordkeeping 10.1 Question: 6th filled bullet (Pesticide Application

Logs) ‐ Just herbicides or adjuvants too? 6‐Handwritten

387 Schardt, Jeffrey Recordkeeping 10.1

Comment: 6th filled bullet (Pesticide Application

Logs) ‐ Record keeping by Applicators ‐ trade

secrets (CBI).

6‐Handwritten

388 Schardt, Jeffrey Recordkeeping 10.1 Question: 6th filled bullet (Pesticide Application

Logs) ‐ How long to keep records and in what form? 6‐Handwritten

389 Schardt, Jeffrey Recordkeeping 10.1 Question: 6th filled bullet (Pesticide Application

Logs), bullet (4i) ‐ Treatment area = area applied? 6‐Handwritten

390 Schardt, Jeffrey Recordkeeping 10.1

Comment: 6th filled bullet (Pesticide Application

Logs), bullet (5) ‐ Relevant to the application (e.g.,

oxygen or wind speed).

6‐Handwritten

391 Schardt, Jeffrey Recordkeeping 10.1 Question: 7th filled bullet (Pesticide Application

Equipment Maintenance) ‐ Purpose? 6‐Handwritten

392 Spitzmuller, Joe Coverage Under This Permit 1.1.1 Comment: Ag tile drains. 7‐Handwritten

393 Spitzmuller, Joe Coverage Under This Permit 1.1.1.1 Question: What is "near water"? 7‐Handwritten

394 Spitzmuller, Joe Coverage Under This Permit 1.1.2.5 Question: How do bulletins fit in here? 7‐Handwritten

395 Spitzmuller, Joe Coverage Under This Permit 1.2.2 Comment: "Operators Required to Submit..." ‐ 

Confusing words. 7‐Handwritten

396 Spitzmuller, Joe Coverage Under This Permit 1.2.2 Rewrite: Suggests inserting "surface" in between

"total" and "water acre" 7‐Handwritten

397 Spitzmuller, Joe Coverage Under This Permit 1.2.2 Question: Who is this communicated 7‐Handwritten

398 Spitzmuller, Joe Coverage Under This Permit 1.2.2 Comment: How does applicator know this? 7‐Handwritten

399 Spitzmuller, Joe Coverage Under This Permit 1.2.3 Question: What if work is subcontracted for

unanticipated reasons? 7‐Handwritten

400 Spitzmuller, Joe Coverage Under This Permit 1.2.3

Comment: Table, "NOI Deadline" & "Discharge

Authorization Date" ‐ Aggressive timeline, is this

doable?

7‐Handwritten

401 Spitzmuller, Joe Coverage Under This Permit 1.2.3 Question: Footnote 1 to the Table, "EPA may delay

your authorization..." ‐ How is this known? 7‐Handwritten

402 Spitzmuller, Joe Coverage Under This Permit 1.2.4

Rewrite: Suggests changing "not" to "otherwise" in

the following "...discharge of pesticides what would

not be covered..."

7‐Handwritten

403 Spitzmuller, Joe Coverage Under This Permit 1.3.1 Question: "Any interested person may petition

EPA..." ‐ What are the grounds? 7‐Handwritten

404 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.1.1 Rewrite: Suggests changing "permittee" to

"applicator" 7‐Handwritten

405 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.1.1

Comment: Referring to the NOTE in this bullet ‐ 

Pesticides are registered, the label represents

federal law.

7‐Handwritten

406 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.1.1.2 Comment: "effectively" ‐ How to deal, wiggle

words? 7‐Handwritten

407 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.1.2 Question: How, with fluctuating nature of mosquito

populations? 7‐Handwritten

408 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.1.2 Question: "Treatments based on threshold" ‐ what

is that? 7‐Handwritten

409 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.1.3.1 Question: How on private property? 7‐Handwritten

410 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.1.4 Question: Who is required? 7‐Handwritten

411 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.1.5.4 Question: Who monitors this? 7‐Handwritten

412 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.2.5.2 Question: How is this done? Not part of C & T ‐ 

who's responsible? 7‐Handwritten

413 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.2.6.2 Comment: Why posting? Little value! 7‐Handwritten

414 Spitzmuller, Joe Technology‐Based Effluent Limitations 2.2.6.2.2 Comment: "Label human hazard warnings" ‐ Not

applicable. 7‐Handwritten

415 Spitzmuller, Joe Integrated Pest Management Plan 6.1.1.1 Question: Why? 7‐Handwritten

416 Spitzmuller, Joe Site Monitoring 8.1 Comment: Define "application site" 7‐Handwritten

417 Spitzmuller, Joe Site Monitoring 8.1 Rewrite: Suggests changing "identify" to

"observable" 7‐Handwritten

418 Spitzmuller, Joe Site Monitoring 8.1.1 Rewrite: Suggests inserting "aquatic" between "of"

and "wildlife habitat". 7‐Handwritten

419 Spitzmuller, Joe Site Monitoring 8.1.3 Comment: "observed" ‐ visual 7‐Handwritten

420 Spitzmuller, Joe Reporting 9.1 Question: 1st bullet ‐ Who is operator? 7‐Handwritten
421 Spitzmuller, Joe Reporting 9.1 Comment: Open bullets (Names of products, etc.) ‐ 

Not all will be in system. 7‐Handwritten

422 Spitzmuller, Joe Reporting 9.1 Comment: (1) For your own purposes; (2) value; (3)

is any of this information protected? 7‐Handwritten

423 Spitzmuller, Joe Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs) ‐ 

Combine 7‐Handwritten

424 Goans, Steve General Comment: "Near" ‐ bed and bank of waterbody 8‐Handwritten

425 Goans, Steve General

Comment: We appreciate the opportunity to

comment.  It would be beneficial if we could get a

copy of the language so we could work on drafts

that we believe would fit our state that you could

see and consider before you put this out to the

public.

8‐Handwritten

426 Goans, Steve Coverage Under This Permit 1.1.1.2 Question: Regarding NOTE ‐ Oils? 8‐Handwritten

427 Goans, Steve Coverage Under This Permit 1.1.2.3 Comment: Or properly applied. 8‐Handwritten

428 Goans, Steve Coverage Under This Permit 1.1.2.5 Comment: FIFRA co‐program 8‐Handwritten

429 Goans, Steve Coverage Under This Permit 1.2.2 Comment: Decorative ponds, farm ponds, home

owners on banks. 8‐Handwritten

430 Goans, Steve Coverage Under This Permit 1.2.2 Comment: (1) Only over, near, TO; (2) sprayer

submits; (3) Is EPA going to provide e‐template? 8‐Handwritten

431 Goans, Steve Technology‐Based Effluent Limitations 2.1 Comment: (1) FIFRA is BAT; (2) Don't start with the

Cadillac when we barely drive a Chevy 8‐Handwritten

432 Goans, Steve Technology‐Based Effluent Limitations 2.1.1.2 Comment: Resistance Mgmt. 8‐Handwritten

433 Goans, Steve Technology‐Based Effluent Limitations 2.1.1.1 Comment: These are BMP 8‐Handwritten

434 Goans, Steve Technology‐Based Effluent Limitations 2.1.1.1 Comment: These are on the block as BAT.  Do not

put BMP in BAT. 8‐Handwritten

435 Goans, Steve Technology‐Based Effluent Limitations 2.1.3.3 Comment: change "eliminate" to "minimize" 8‐Handwritten

436 Goans, Steve Technology‐Based Effluent Limitations 2.1.5.3 Question: What is threshold? 8‐Handwritten

437 Goans, Steve Technology‐Based Effluent Limitations 2.1.5.4 Question: How to train? 8‐Handwritten

438 Goans, Steve Technology‐Based Effluent Limitations 2.2.1.1 Question: Enforceable? 8‐Handwritten

439 Goans, Steve Technology‐Based Effluent Limitations 2.2.1.1 Question: What kind of proof? 8‐Handwritten

440 Goans, Steve Technology‐Based Effluent Limitations 2.2.2.2 Comment: Spray as you go! 8‐Handwritten

441 Goans, Steve Technology‐Based Effluent Limitations 2.2.2.3 Question: Is this necessary? Wind blows weed

seeds? 8‐Handwritten

442 Goans, Steve Technology‐Based Effluent Limitations 2.2.2.4 Comment: Noxious weeds, zero tolerance. 8‐Handwritten

443 Goans, Steve Technology‐Based Effluent Limitations 2.2.3 Comment: BMP not must 8‐Handwritten

444 Goans, Steve Technology‐Based Effluent Limitations 2.2.3 Comment: These cannot be "musts" 8‐Handwritten

445 Goans, Steve Technology‐Based Effluent Limitations 2.2.4.1 Question: Would this include looking from a

helicopter, spraying as you fly the river? 8‐Handwritten

446 Goans, Steve Technology‐Based Effluent Limitations 2.2.4.2 Comment: Costly. 8‐Handwritten

447 Goans, Steve Technology‐Based Effluent Limitations 2.2.5.1 Comment: Rivers? 8‐Handwritten

448 Goans, Steve Technology‐Based Effluent Limitations 2.2.5.2 Comment: How? 8‐Handwritten

449 Goans, Steve Technology‐Based Effluent Limitations 2.2.5.3 Comment: BMP 8‐Handwritten

450 Goans, Steve Technology‐Based Effluent Limitations 2.2.5.4 Question: How often? 8‐Handwritten

451 Goans, Steve Technology‐Based Effluent Limitations 2.2.6.1 Comment: No 8‐Handwritten

452 Goans, Steve Water Quality‐Based Effluent Limitations 3.0 Comment: It will until use is completed. 8‐Handwritten

453 Goans, Steve Corrective Action 5.3.1 Comment: "14 days" ‐ standard with 40 CFR 8‐Handwritten

454 Goans, Steve Integrated Pest Management Plan 6.0 Comment: If IPM is BAT then it is effluent limit. 8‐Handwritten

455 Goans, Steve Integrated Pest Management Plan 6.1.1.1 Comment: Bullet (d) ‐ certification required 8‐Handwritten

456 Goans, Steve Integrated Pest Management Plan 6.1.1.2 Comment: Rain barrels 8‐Handwritten

457 Goans, Steve Integrated Pest Management Plan 6.1.1.2 Comment: The swamp, the ditch, the wet areas, the

marsh 8‐Handwritten

458 Goans, Steve Integrated Pest Management Plan 6.1.1.5 Comment: EPA web training and state applicator

certificate 8‐Handwritten

459 Goans, Steve Integrated Pest Management Plan 6.1.2.2 Comment: Too late, other applicator was hired. 8‐Handwritten

460 Goans, Steve Site Monitoring 8.1.2 Question: Who looks? 8‐Handwritten

461 Goans, Steve Site Monitoring 8.1.3 Comment: Can be natural. 8‐Handwritten

462 Goans, Steve Site Monitoring 8.1.2 Question: Can we get a grant for remote controlled

drones? 8‐Handwritten

463 Goans, Steve Reporting 9.1

Comment: Define what goal is.  Simplify so data is

actually submitted and useful otherwise don't

require reporting.

8‐Handwritten

464 Goans, Steve Reporting 9.1 Question: How many states actually track pesticide

use besides FL, NY, MD? 8‐Handwritten

465 Goans, Steve Reporting 9.1 Comment: "descriptions of locations treated..." ‐ lbs

per region. 8‐Handwritten

466 Goans, Steve Recordkeeping 10.1 Comment: If you truly want to protect the

environment let FIFRA be subject to challenge. 8‐Handwritten

467 Romary, Craig Technology‐Based Effluent Limitations 2.1.6 Comment: Public 9‐Handwritten

468 Romary, Craig Technology‐Based Effluent Limitations 2.2.6.1 Comment: Posting? 9‐Handwritten

469 Romary, Craig Site Monitoring 8.1.2 Rewrite: "X feet of flowing water" ‐ replace "flowing

water" with "shoreline"? 9‐Handwritten

470 Romary, Craig Site Monitoring 8.1.3 Comment: Last paragraph ‐ With cause directly

from pesticide. 9‐Handwritten

471 Romary, Craig Reporting 9.1

Comment: Annual report could be limited to 1 every

2 years or 2 per 5 year permit term, as long as

permittee is active during that time.

9‐Handwritten
472 Romary, Craig Recordkeeping 10.1 Rewrite: Suggests changing "Operators" to

"Permittee" 9‐Handwritten

473 Romary, Craig General

Comment: I'm still concerned about the level of

flexibility that states will be allowed in several of

these sections.  I think both water and pesticide

agencies concede that more effort could be made in

certain areas of their respective programs.  But

states should be allowed the ability to determine

how best to achieve the most environmental

benefit given the resources available to them.

9‐Handwritten

474 Romary, Craig General

Comment: Many of these requirements seem to be

nothing more than a paper shuffle with little to no

environmental benefit.  BAT, BMP, monitoring,

reporting, etc, all fit this need for flexibility, in my

opinion.

9‐Handwritten

475 Romary, Craig General

Comment: One thing that hasn't been discussed too

much, is the potential for increased numbers of

people needing to be certified/licensed ‐ and the

impact this will have on the agency responsible for

developing testing/training material.  (In Nebraska ‐ 

Cooperative Extension) Extension is also feeling

budget constraints with reduced number of sites

available for training, personnel, etc.  We are

moving towards web training & verification but I

think that is a long way away and there are

questions about the difference between web vs.

face to face training.

9‐Handwritten

476 Romary, Craig General

Comment: I would encourage members of your

work group to contact state pesticide agency

personnel regarding comments (submitted with

these copies) for specific sections so that you have a

better understanding of how pesticide applicators

are made, realizing the variability among states and

rules already in place, and even variability among

the regulated public with a state in regard to

economic and paperwork burden.

9‐Handwritten

477 Romary, Craig General

Comment: "near" could be defined using the terms

"bank" and/or "riparian zone".  I will look for

definitions from other references.  This will need to

be refined though when talking about a "farmed

wetland" and/or for areas that are truly a wetland

only a portion of the year ‐ is it a "wetland" or is it

"agricultural"? i.e., ephemeral, seasonal,

intermittent, is wet wet and dry dry?

9‐Handwritten

478 Romary, Craig General

Comment: I concur wholeheartedly with Jim Gray's

(ND) request for information that can be presented

to pesticide applicators this fall/winter.  This is

especially important when one considers that not

all of the applicator public is trained every year.  In

Nebraska, applicators are required to attend

recertification 1 time every 3 years.  While direct

mailings can be used, face to face training sessions

would be the best media for getting the word out

about potential permits and requirements.

9‐Handwritten

479 Corell, Chuck Coverage Under This Permit 1.1.1

Comment: Added another bullet under "Activities

Covered" ‐ control of fish that are not invasive ‐>

common means to control stunted panfish

populations

10‐Handwritten

480 Corell, Chuck Coverage Under This Permit 1.2.2

Comment: regarding "X" and "Y" ‐ opportunities for

delegated NPDES programs to vary from prototype

to improve efficiency of program and opportunity to

reduce burden.

10‐Handwritten

481 Corell, Chuck Coverage Under This Permit 1.2.4 Rewrite: Suggests changing "would not be" to

"would otherwise be" 10‐Handwritten

482 Corell, Chuck Technology‐Based Effluent Limitations 2.0 Rewrite: Suggest deleting "the equipment

manufacturer's specifications" 10‐Handwritten

483 Corell, Chuck Technology‐Based Effluent Limitations 2.1.1.1 Comment: Main theme for rest of section 10‐Handwritten

484 Corell, Chuck Technology‐Based Effluent Limitations 2.1.1.2 Rewrite: Suggests deleting section ‐ Resistance

management precludes this. 10‐Handwritten

485 Corell, Chuck Technology‐Based Effluent Limitations 2.1.2

Rewrite: Suggests adding at the end of the

statement (after "you must") ‐ "consider

implementing the following"

10‐Handwritten
486 Corell, Chuck Technology‐Based Effluent Limitations 2.1.2

Rewrite: Last paragraph, "permit conditions in

2.1.2.2 ‐ 2.1.2.4 is not feasible" ‐ suggests changing

"feasible" to "technologically available" or

"economically practical" or "achievable"

10‐Handwritten

487 Corell, Chuck Technology‐Based Effluent Limitations 2.1.3 Rewrite: 1st sentence ‐ Suggests changing "do" to

"consider implementing" 10‐Handwritten

488 Corell, Chuck Technology‐Based Effluent Limitations 2.1.3.3 Comment: change "eliminate" to "minimize" 10‐Handwritten

489 Corell, Chuck Technology‐Based Effluent Limitations 2.1.4 Rewrite: 2nd sentence ‐ Suggests changing "do" to

"consider implementing" 10‐Handwritten

490 Corell, Chuck Technology‐Based Effluent Limitations 2.1.5 Rewrite: 1st sentence ‐ Suggests adding after "you

must", "consider implementing the following" 10‐Handwritten

491 Corell, Chuck Technology‐Based Effluent Limitations 2.2.1.1

Comment: "technologically available and

economically practicable and achievable in light of

best industry practice" ‐ ? Together = feasible?

10‐Handwritten

492 Corell, Chuck Technology‐Based Effluent Limitations 2.2.2 Rewrite: Suggests changing "do" to "consider" 10‐Handwritten

493 Corell, Chuck Technology‐Based Effluent Limitations 2.2.3

Rewrite: 1st sentence ‐ Suggests changing "do" to

"consider implementing" and deleting "prior to

each pesticide application"

10‐Handwritten

494 Corell, Chuck Technology‐Based Effluent Limitations 2.2.4 Rewrite: Suggests changing "do" to "consider" 10‐Handwritten

495 Corell, Chuck Technology‐Based Effluent Limitations 2.2.5 Rewrite: Suggests adding after "you must",

"consider implementing the following" 10‐Handwritten

496 Corell, Chuck Technology‐Based Effluent Limitations 2.2.6 Rewrite: Suggests changing "do" to "consider" 10‐Handwritten

497 Corell, Chuck Technology‐Based Effluent Limitations 2.2.6.1 Comment: Private waters? 10‐Handwritten

498 Corell, Chuck Integrated Pest Management Plan 6.1.1.3 Rewrite: Suggests changing "control measures" to

BMPs 10‐Handwritten

499 Corell, Chuck Site Monitoring 8.1.1 Question: What is a municipal use? 10‐Handwritten

500 Corell, Chuck Site Monitoring 8.1.1 Comment: "disruption of wildlife habitat" ‐ killing

aquatic vegetation disrupts habitat 10‐Handwritten

501 Corell, Chuck Site Monitoring 8.3 Comment: Can't require individualized permit

conditions in a General Permit 10‐Handwritten

502 Cswercko, Courtney Coverage Under This Permit 1.1.1.1 Comment: "near waters" ‐ needs definition 11‐Handwritten

503 Cswercko, Courtney Coverage Under This Permit 1.1.2.3 Question: Does one need an individual permit for

discharge of rinsate or washwater? 11‐Handwritten

504 Cswercko, Courtney Coverage Under This Permit 1.2.1 Question: "operator" ‐ what/who is an operator? 11‐Handwritten

505 Cswercko, Courtney Coverage Under This Permit 1.2.2 Comment: "water acre" ‐ need to define 11‐Handwritten

506 Cswercko, Courtney Coverage Under This Permit 1.2.2

Question: Is it water acres where the pesticide is

directly applied, or water acres near application, or

a combo of both?

11‐Handwritten

507 Cswercko, Courtney Coverage Under This Permit 1.2.2

Question: Why would you want a city submitting an

NOI and developing and IPM, when a city official

knows little about pesticides, vs. the applicator,

who is an expert, submitting the NOI and

developing the IPM? It seems like this adds an

unneeded burden to city and state officials.

11‐Handwritten

508 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.1.2

Comment: (1) Lowest amount may not be

practicable because of resistance; (2) Pesticides

need to be applied according to the label

11‐Handwritten

509 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.2 Comment: define "feasible" 11‐Handwritten

510 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Suggests changing "eliminate" to

"minimize" 11‐Handwritten

511 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.4.4 Comment: Remove section 11‐Handwritten

512 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.4.4

Comment: Might not be killing mosquitoes to

prevent disease, just killing them to raise the quality

of life for a community, recommend removing this

requirement.

11‐Handwritten

513 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.5.2 Comment: Should be done even if an NOI is not

submitted 11‐Handwritten

514 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.5.3 Comment: Should be done even if an NOI is not

submitted 11‐Handwritten

515 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.5.5 Comment: Should be done even if an NOI is not

submitted 11‐Handwritten

516 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.5.6 Comment: Should be done even if an NOI is not

submitted 11‐Handwritten

517 Cswercko, Courtney Technology‐Based Effluent Limitations 2.1.5.4 Question: What is "adequate training"? 11‐Handwritten

518 Cswercko, Courtney Technology‐Based Effluent Limitations 2.2.3.1 Comment: Should be done by those not submitting

an NOI as well. 11‐Handwritten

519 Cswercko, Courtney Technology‐Based Effluent Limitations 2.2.3.2 Comment: Should be done by those not submitting

an NOI as well. 11‐Handwritten

520 Cswercko, Courtney Technology‐Based Effluent Limitations 2.2.3.2 Comment: insert "where practicable" (mechanical

control is not always good, it can kill fish) 11‐Handwritten
521 Cswercko, Courtney Technology‐Based Effluent Limitations 2.2.5.3 Comment: Should be done by those not submitting

an NOI as well. 11‐Handwritten

522 Cswercko, Courtney Technology‐Based Effluent Limitations 2.2.5.4 Comment: Should be done by those not submitting

an NOI as well. 11‐Handwritten

523 Cswercko, Courtney Technology‐Based Effluent Limitations 2.2.6.2 Comment: Should be done by those not submitting

an NOI as well. 11‐Handwritten

524 Cswercko, Courtney Technology‐Based Effluent Limitations 2.2.6.2

Rewrite: Suggests adding after "prior to each

pesticide application", insert "where the pesticide

has a documented water use effect" ‐ don't need to

post is there no water use effect.

11‐Handwritten

525 Cswercko, Courtney Water Quality‐Based Effluent Limitations 3 Comment: numeric WQS include dissolved oxygen 11‐Handwritten

526 Cswercko, Courtney Water Quality‐Based Effluent Limitations 3 Comment: the residual must not cause or

contribute to a WQ violation 11‐Handwritten

527 Cswercko, Courtney Water Quality‐Based Effluent Limitations 3 Question: Could you say use of pesticides according

to the FIFRA label will be consistent with the WQS? 11‐Handwritten

528 Cswercko, Courtney Corrective Action 5.3.1

Comment: "result of a discharge from" ‐ what is a

discharge from a pesticide application? This

wording is not clear, needs work (or just get rid of

"discharge from")

11‐Handwritten

529 Cswercko, Courtney Corrective Action 5.3.1 Rewrite: Suggests adding after "14 days", insert "of

discovery of the incident" 11‐Handwritten

530 Cswercko, Courtney Corrective Action 5.3.2 Comment: 1st paragraph, "documentation on site" ‐

what site? 11‐Handwritten

531 Cswercko, Courtney Corrective Action 5.3.2

Rewrite: 1st paragraph, 1st sentence ‐ Suggests

adding after "document the following information",

insert "in your pesticide application log or as part of

your pesticide application log"

11‐Handwritten

532 Cswercko, Courtney Corrective Action 5.3.2

Comment: 2nd paragraph ‐ Suggests adding after

"For situations other than adverse incidents you

must document the situation", insert the following

"in your pesticide application log or as part of your

pesticide application log"

11‐Handwritten

533 Cswercko, Courtney Integrated Pest Management Plan 6.0

Question: Do commercial applicators have to do all

of this?  Could commercial applicators have fewer

IPM requirements? Different IPMs for different

applicants.

11‐Handwritten

534 Cswercko, Courtney Integrated Pest Management Plan 6.1.1.1 Question: What happens when staff members

change? 11‐Handwritten

535 Cswercko, Courtney Integrated Pest Management Plan 6.1.1.3 Comment: Bullet (c) ‐ not necessary, commercial

applicators do not need to do this 11‐Handwritten

536 Cswercko, Courtney Integrated Pest Management Plan 6.1.1.3 Comment: Bullet (c) ‐ "less toxic" Less toxic to

what? Vertebrates? Invertebrates? 11‐Handwritten

537 Cswercko, Courtney Integrated Pest Management Plan 6.1.1.3

Comment: Bullet (c) ‐ "of each alternative's costs",

it can take forever to document all the alternatives

and why you did not use them ‐ this is not

necessary.  Should just say "we chose this pesticide

because..." and give a couple of reasons (as noted in

sub‐section b)

11‐Handwritten

538 Cswercko, Courtney Integrated Pest Management Plan 6.1.1.3 Question: Bullet (d) ‐ Aren't all the BMPs listed in

section 2? What other BMPs are there? 11‐Handwritten

539 Cswercko, Courtney Integrated Pest Management Plan 6.1.3.1 Comment: 2nd, 3rd, and 4th bullets, Suggests

inserting "spill, leaks, or" before "release" 11‐Handwritten

540 Cswercko, Courtney Integrated Pest Management Plan 6.1.3.3 Rewrite: 4th bullet ‐ Suggests deleting "contacts";

contacts change, just use phone #s 11‐Handwritten

541 Cswercko, Courtney Integrated Pest Management Plan 6.1.3.4

Comment: Monitoring procedures should be

standard for all pest applicators.  IPMs should

reference standard monitoring and say who will do

the monitoring.

11‐Handwritten

542 Cswercko, Courtney Site Monitoring 8.1 Question: What is an "application site"? 11‐Handwritten

543 Cswercko, Courtney Site Monitoring 8.1.2 Question: What constitutes a "treatment"? 11‐Handwritten

544 Cswercko, Courtney Site Monitoring 8.1.3 Question: How do you know if any of these are

caused by the pesticide application? 11‐Handwritten

545 Cswercko, Courtney Site Monitoring 8.1.3

Rewrite: Suggests adding after "note any of the

following symptoms", insert "to non‐target

organisms"

11‐Handwritten

546 Cswercko, Courtney Site Monitoring 8.1.3 Rewrite: Suggests replacing "discomfort" with

"confirmed pesticide effects" 11‐Handwritten

547 Cswercko, Courtney Site Monitoring 8.1.4

Rewrite: Suggests deleting "The discharger will

inspect the area around the adverse finding to

approximate and note" and replace with "An

approximation of the magnitude and impact." ‐

11‐Handwritten

548 Cswercko, Courtney Site Monitoring 8.1.4

Comment: The rest of the bullets are what to

report, not what to do.  This bullet should match

the others.

11‐Handwritten
549 Cswercko, Courtney Site Monitoring 8.2.3 Question: What does enhanced monitoring consist

of? 11‐Handwritten

550 Cswercko, Courtney Reporting 9.1 Question: Who is the operator? The entity that got

the NOI? Clarify. 11‐Handwritten

551 Cswercko, Courtney Reporting 9.1 Rewrite: Suggests changing "jurisdictions" to

"locations" 11‐Handwritten

552 Cswercko, Courtney Reporting 9.2 Rewrite: Suggest deleting from the 1st sentence, "a

discharge from" 11‐Handwritten

553 Cswercko, Courtney Reporting 9.2 Question: Who is the operator? 11‐Handwritten

554 Cswercko, Courtney Recordkeeping 10.1 Question: Where do they keep the records? 11‐Handwritten

555 Cswercko, Courtney Recordkeeping 10.1

Comment: 6th bullet (Pesticide Application Logs) ‐ 

Persons not required to submit NOIs should keep

application logs.

11‐Handwritten

556 Cswercko, Courtney Recordkeeping 10.1

Comment: 6th bullet (Pesticide Application Logs),

bullet (4i), "Total size of treatment area" ‐ define.  Is

this the area where pesticides are directly applied?

11‐Handwritten

557 Cswercko, Courtney Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs),

bullet (6) ‐ not for those not submitting NOIs 11‐Handwritten

558 Cswercko, Courtney Recordkeeping 10.1

Comment: 7th bullet (Pesticide Application

Equipment Maintenance) ‐ this is good; equipment

maintenance records need to be kept.  Should

copies of this info go to the person who submitted

an NOI? (yes)

11‐Handwritten

559 Cswercko, Courtney Appendix B ‐ Standard Permit Conditions (Reporting Requirements)

Comment: These need to be tailored to match the

rest of the permit, remove sections of the standard

conditions that are duplicated in the permit.

11‐Handwritten

560 Cswercko, Courtney Appendix B ‐ Standard Permit Conditions (Reporting Requirements) B.13

Comment: This section is not necessary, there are

no pesticide bypasses.  You only need the standard

conditions applicable to the situation.

11‐Handwritten

561 Cswercko, Courtney Appendix B ‐ Standard Permit Conditions (Reporting Requirements) B.14 Comment: This section is not necessary, no

pesticide upset. 11‐Handwritten

562 Knorr, Michele Coverage Under This Permit 1.1.1

Comment: Place language in permit that states the

residual for chemical and biological (full

application). In fact sheet, provide examples of how

residuals occur; e.g., over water spraying, what hits

water is residual.

12‐Handwritten

563 Knorr, Michele Coverage Under This Permit 1.2.4 Rewrite: Suggests changing "not be covered" to

"otherwise be covered" 12‐Handwritten

564 Knorr, Michele Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Suggests changing "eliminate or reduce" to

"minimize" 12‐Handwritten

565 Knorr, Michele Water Quality‐Based Effluent Limitations 3.0 Comment: Look at Louisiana's issue ‐ Mindy sent

note to Lee and David to get opinion. 12‐Handwritten

566 Knorr, Michele Corrective Action 5.1 Comment: 5th bullet, "adverse incident" ‐ Phil

Jennings, fish stressors (behavior) 12‐Handwritten

567 Knorr, Michele Site Monitoring 8.1 Comment: Areas that may not be accessible or

unsafe. 12‐Handwritten

568 Knorr, Michele Site Monitoring 8.1 Question: "Application site" ‐ what is it? 12‐Handwritten

569 Knorr, Michele Site Monitoring 8.1 Comment: Applicator vs. NOI Submitter vs.

Someone else? 12‐Handwritten

570 Knorr, Michele Site Monitoring 8.1 Rewrite: Suggests changing "possible" to

"observable" 12‐Handwritten

571 Knorr, Michele Site Monitoring 8.1.1 Comment: "disruption of wildlife habitat" ‐ 

terrestrial or aquatic? Clarify aquatic! 12‐Handwritten

572 Knorr, Michele Site Monitoring 8.1.2

Comment: Non‐aerial treatments, 2nd open bullet,

"immediately following treatment" ‐ Timing an issue

for some applicators.  Truck spraying in evening,

can't monitor ‐ best is next morning.

12‐Handwritten

573 Knorr, Michele Site Monitoring 8.1.2 Comment: Non‐aerial treatments, 5th open bullet,

"flowing water" ‐ probably can't see flow in wetland 12‐Handwritten

574 Knorr, Michele Site Monitoring 8.1.3 Comment: Change "inspection" to "visual

assessment" 12‐Handwritten

575 Knorr, Michele Site Monitoring 8.1.3 Comment: Consider salt marshes, unique situation. 12‐Handwritten

576 Knorr, Michele Site Monitoring 8.1.3 Comment: add‐ Phil Jennings Fish Stressors 12‐Handwritten

577 Knorr, Michele Site Monitoring 8.1.3 Comment: Last paragraph, "Any discomfort" ‐ 

needs to change 12‐Handwritten

578 Knorr, Michele Site Monitoring 8.1.4 Comment: Difference between observable impacts

and adverse effects reporting. 12‐Handwritten

579 Knorr, Michele Site Monitoring 8.1.4 Comment: 3rd bullet, "The discharger will inspect

the area..." ‐ not a reporting requirement. 12‐Handwritten

580 Knorr, Michele Site Monitoring 8.2 Comment: (1) Tie NOI to monitoring; (2) Don't need

enhanced since you have section 8.3 12‐Handwritten

581 Knorr, Michele Site Monitoring 8.2.1 Comment: Consider different requirements for

different uses (i.e., rotenone) 12‐Handwritten
582 Knorr, Michele Site Monitoring 8.3 Comment: Needs more clarification 12‐Handwritten

583 Knorr, Michele Site Monitoring 8.3

Comment: 2nd bullet, "Pesticide of concern" ‐ 

different definitions, need to clarify/use a different

term.

12‐Handwritten

584 Knorr, Michele Reporting 9.1

Comment: "Operator" ‐ Who are you referring to?

Needs to be permittee or applicator? Person who

submitted NOI?

12‐Handwritten

585 Knorr, Michele Reporting 9.1 Comment: "Jurisdictions" ‐ Not clear for states,

need to clarify: county, etc. 12‐Handwritten

586 Knorr, Michele Reporting 9.2 Comment: Needs clarification. 12‐Handwritten

587 Knorr, Michele Reporting 9.2 Comment: "within 14 days" ‐ of what? 12‐Handwritten

588 Akers, Dave Coverage Under This Permit 1.1.1.2 Comment: Need to define in the fact sheet when

the "discharge of a pollutant" takes place. 13‐Handwritten

589 Akers, Dave Coverage Under This Permit 1.1.2.2

Comment: Need a detailed explanation in the fact

sheet as to how these discharges will not cause

significant degradation to Tier 2 waters.

13‐Handwritten

590 Akers, Dave Coverage Under This Permit 1.2.2 Question: Will the entity be able to accurately

predict this for 5 years into the future? 13‐Handwritten

591 Akers, Dave Coverage Under This Permit 1.2.2

Comment: 2nd paragraph ‐ will require many more

certifications as many applicators will be working on

behalf of several entities.

13‐Handwritten

592 Akers, Dave Coverage Under This Permit 1.2.4 Comment: Note that a complete, timely, NOI must

be submitted to continue coverage. 13‐Handwritten

593 Akers, Dave Technology‐Based Effluent Limitations 2.1.1 Comment: For all of these, what documentation will

be required? 13‐Handwritten

594 Akers, Dave Technology‐Based Effluent Limitations 2.1.1.1

Comment: "technologically available and

economically practicable and achievable" ‐ How will

this be measured for compliance? Some fact sheet

language to give examples/methods to assess

would be helpful.

13‐Handwritten

595 Akers, Dave Technology‐Based Effluent Limitations 2.1.1.2 Question: How do we measure this for compliance? 13‐Handwritten

596 Akers, Dave Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Suggests changing "eliminate or reduce" to

"minimize" 13‐Handwritten

597 Akers, Dave Technology‐Based Effluent Limitations 2.1.4 Comment: Private property issue ‐ will everyone

just opt out based on this? 13‐Handwritten

598 Akers, Dave Technology‐Based Effluent Limitations 2.1.4.1 Comment: Repetitive of 2.1.2.1 13‐Handwritten

599 Akers, Dave Corrective Action 5.2 Rewrite: 3rd sentence ‐ Replace  "is" with "are" 13‐Handwritten

600 Akers, Dave Corrective Action 5.3.1

Comment: Regarding the "immediately notify" or

"within 24 hours" ‐ which one? Or clarify if 24 hours

meets the "immediately" requirement.

13‐Handwritten

601 Akers, Dave Integrated Pest Management Plan 6.1.1.2

Question: Why have them list WQS unless there is a

requirement to meet the standard through a limit

and/or monitoring?

13‐Handwritten

602 Akers, Dave Site Monitoring 8.1.1

Rewrite: Suggests adding before "wildlife habitat",

insert "aquatic."  Do we have authority to address

terrestrial habitat?

13‐Handwritten

603 Akers, Dave Site Monitoring 8.1.2 Rewrite: Suggests adding "inspection/" before

"assessment" 13‐Handwritten

604 Akers, Dave Site Monitoring 8.1.2

Comment: Non‐aerial treatments, 5th open bullet,

"Flowing water" ‐ wetlands will likely not have a

"flow"

13‐Handwritten

605 Akers, Dave Site Monitoring 8.1.2 Question: Does 8.1.2 reference back to 8.1.1, or

forward to 8.1.3, or both? 13‐Handwritten

606 Akers, Dave Site Monitoring 8.1.4

Rewrite: Suggests moving the 3rd bullet (from

section 8.1.4, which starts, "The discharger will...")

to the last bullet in section 8.1.3

13‐Handwritten

607 Akers, Dave Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs),

bullet (3) ‐ include Lat/Long? 13‐Handwritten

608 Akers, Dave Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs),

bullet (4e) ‐ mg/L, lbs/1,000 gallons. 13‐Handwritten

609 Akers, Dave Recordkeeping 10.1 Rewrite: 6th bullet (Pesticide Application Logs),

bullet (4i) ‐ Suggests moving this bullet to bullet 3. 13‐Handwritten

610 Akers, Dave Recordkeeping 10.1

Question: 7th bullet (Pesticide Application

Equipment Maintenance) ‐ What if they are not the

permittee?

13‐Handwritten

611 Akers, Dave EPA Addresses 11.1.8 Comment: Wrong address for EPA Region 8 13‐Handwritten

612 Corey, Fred Coverage Under This Permit 1.1.1.2 Comment: "near" has the potential to affect waters

of the US 14‐Handwritten

613 Corey, Fred Coverage Under This Permit 1.1.2.1

Rewrite: Suggests adding within the following "as

not meeting applicable State water quality

standards" ‐ after "State" insert "or Tribal"

14‐Handwritten

614 Corey, Fred Coverage Under This Permit 1.1.2.3 Rewrite: Suggests adding after "compliance with all

Federal, State" insert "Tribal" 14‐Handwritten

615 Corey, Fred Coverage Under This Permit 1.2.2

Comment: For Tribal programs, NOIs should be

CC'ed to Tribal Pesticide Programs (where they

exist) to facilitate inspections by Tribal Pesticide

Inspectors

14‐Handwritten
616 Corey, Fred Technology‐Based Effluent Limitations 2.1.6 Comment: Also provide information to Tribal

natural and/or environmental programs. 14‐Handwritten

617 Corey, Fred Technology‐Based Effluent Limitations 2.2.6.1 Comment: Also provide information to Tribal

natural and/or environmental programs. 14‐Handwritten

618 Corey, Fred Corrective Action 5.3.1 Rewrite: Suggests adding after "notify EPA and the

appropriate state", insert "and Tribal" 14‐Handwritten

619 Corey, Fred Integrated Pest Management Plan 6.1.3.3 Comment: 5th bullet ‐ Include Tribal contacts and

phone numbers 14‐Handwritten

620 Corey, Fred Integrated Pest Management Plan 6.1.3.3 Comment: after "nearest emergency medical

facility" include "Tribal health facilities" 14‐Handwritten

621 Corey, Fred Reporting 9.1

Comment: For Tribal Lands, copies of reports should

be CC'ed to appropriate Tribal Program

(water/pesticides)

14‐Handwritten

622 Corey, Fred Reporting 9.2 Comment: after "notify EPA and the appropriate

state" insert "and Tribal" 14‐Handwritten

623 Corey, Fred Appendix C 1

Comment: Include Aroostook Band of Micmacs

Tribal Land (Maine).  EPA has not delegated NPDES

authority on Micmac Tribal Land.

14‐Handwritten

624 Papadopoulos,

George Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Suggests changing "eliminate" to"minimize" 15‐Handwritten

625 Papadopoulos,

George Technology‐Based Effluent Limitations 2.1.4.1 Comment: "Best Industry Practices" ‐ Define in fact

sheet. 15‐Handwritten

626 Papadopoulos,

George Technology‐Based Effluent Limitations 2.1.4 Comment: Last paragraph, "...is not feasible you

must document..." ‐ in annual report? 15‐Handwritten

627 Papadopoulos,

George Technology‐Based Effluent Limitations 2.2.2 Rewrite: Suggests moving this section beforesection 2.2.1 15‐Handwritten

628 Papadopoulos,

George Technology‐Based Effluent Limitations 2.2.6.1 Comment: posting: e‐mail? 15‐Handwritten

629 Papadopoulos,

George Technology‐Based Effluent Limitations 2.2.6.1.2 Question: What about info on minimizing fertilizer

& phosphate based cleaner use? 15‐Handwritten

630 Papadopoulos,

George Technology‐Based Effluent Limitations 2.2.6.2 Comment: Suggests including contact name and

phone number. 15‐Handwritten

631 Papadopoulos,

George Corrective Action 5.3.2

Question: What is "on site?" Entity's office or

applicators office/home vs. application site? Need

definition in fact sheet.

15‐Handwritten

632 Papadopoulos,

George Integrated Pest Management Plan 6.1.1.2 Comment: For bullets (a) through (d) why not justcite part 2.1.2 instead of spelling it all out again? 15‐Handwritten

633 Papadopoulos,

George Integrated Pest Management Plan 6.1.1.2 Comment: for bullet (a) targeted mosquito species ‐ if known? 15‐Handwritten

634 Papadopoulos,

George Integrated Pest Management Plan 6.1.1.4 Comment: Why not refer back to part 2.1.4 15‐Handwritten

635 Papadopoulos,

George Site Monitoring 8.1.2 Question: What about for night time application? 15‐Handwritten

636 Papadopoulos,

George Site Monitoring 8.1.3 Comment: These conditions could be brought about

by many other causes. 15‐Handwritten

637 Papadopoulos,

George Reporting 9.1 Comment: Allow e‐mail/pdf submittals. 15‐Handwritten

638 Papadopoulos,

George Reporting 9.1 Question: reference other reporting to FIFRA or

other statute by reference? 15‐Handwritten

639 Papadopoulos,

George Reporting 9.2 Question: Require phone call and no submittalrequired after 14 days unless requested? 15‐Handwritten

640 Papadopoulos,

George Reporting 9.2 Comment: Allow e‐mail submittal and then include

incident in annual report. 15‐Handwritten

641 Papadopoulos,

George Recordkeeping 10.0 Comment: Operator/permittee/applicator ‐ define

in face sheet. 15‐Handwritten

642 Papadopoulos,

George Recordkeeping 10.1

Comment: 6th bullet, (Pesticide Application Logs)

bullet (7) ‐ suggests inserting "species" after "non‐

target" and asks about "discharge" ‐ "or

application?"

15‐Handwritten

643 Beaton, Morris NO COMMENTS IN THIS DOCUMENT 17‐Handwritten

644 Szylvian, Andrea Coverage Under This Permit 1.1.1

Comment: Please define "operator" ‐ what is

definition of operator? Word application would be

more understandable for user community.

18‐Handwritten

645 Szylvian, Andrea Coverage Under This Permit 1.1.1 Question: What is "near"? 18‐Handwritten

646 Szylvian, Andrea Coverage Under This Permit 1.1.1 Comment: Aquaculture products are not only in the

invasive category ‐ rice products ‐ example. 18‐Handwritten

647 Szylvian, Andrea Coverage Under This Permit 1.1.2

Comment: 25(b)(s) ‐ needs to be looked at.  Thos

products have highly varying labels and lack clarity

(many times) as EPA doesn't approve the many

products ‐ it will be hard to monitor for us rules,

etc.  Also, some of those products might pose risks

to non‐targets.  Plus, many states register these

products as a result of the pesticidal claims.

18‐Handwritten

648 Szylvian, Andrea Coverage Under This Permit 1.1.2.2 Question: "You..." Who is you? The applicant? 18‐Handwritten

649 Szylvian, Andrea Coverage Under This Permit 1.1.2.4 Comment: Better define who is "you" ‐ the permit

applicant, the applicator of the pesticide? 18‐Handwritten
650 Szylvian, Andrea Coverage Under This Permit 1.1.2.4 Comment: Invasive species have impacted

endangered species. 18‐Handwritten

651 Szylvian, Andrea Coverage Under This Permit 1.2.1

Comment: The use of IPM as a term that is

enforceable may frustrate many IPM practitioners

as many are not comfortable with enforceable IPM.

18‐Handwritten

652 Szylvian, Andrea Coverage Under This Permit 1.2.1 Comment: 2nd open bullet ‐ Best Management Plan

is IPM plan 18‐Handwritten

653 Szylvian, Andrea Coverage Under This Permit 1.2.2 Rewrite: 4th paragraph ‐ Suggests adding

"responsible party and/or" after "operator" 18‐Handwritten

654 Szylvian, Andrea Coverage Under This Permit 1.2.2 Comment: Versus safety of applicators? 18‐Handwritten

655 Szylvian, Andrea Coverage Under This Permit 1.2.4 Rewrite: Suggests changing "not be covered" to

"otherwise be covered" 18‐Handwritten

656 Szylvian, Andrea Technology‐Based Effluent Limitations 2.0

Question: How can this be documented? What if

specs are no longer available but equipment is still

in use and serviceable? What if manufacturer is out

of business?

18‐Handwritten

657 Szylvian, Andrea Technology‐Based Effluent Limitations 2.0

Comment: "Modify control measures as

expeditiously as practicable" ‐ isn't this telling the

operator they are violating the law?

18‐Handwritten

658 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.1.2 Comment: Doesn't leave any options ‐ vs. achieving

to label. 18‐Handwritten

659 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.1.2 Question: How to manage resistance management? 18‐Handwritten

660 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.2

Question: What if these areas are not under control

of responsible party of operation? Who to

document? How to enforce?

18‐Handwritten

661 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.2 Comment: Public health pests ‐WNV ‐EEE 18‐Handwritten

662 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.2 Question: Cost effective? Have infrastructure to do

this? 18‐Handwritten

663 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.3.2 Comment: State wetlands regs 18‐Handwritten

664 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Suggests changing "eliminate" to

"minimize" 18‐Handwritten

665 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.3

Question: How far out? Not do‐able for responsible

party or applicators; lack expertise, funds, etc.;

applicators not doing this work.

18‐Handwritten

666 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.3

Comment: determining economically feasible and

practicable ‐ needs to be clear as this standard will

likely eliminate some applicators from the

marketplace.

18‐Handwritten

667 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.4

Question: How do we document compliance with

all of these? Who has expertise to evaluate

whatever documentation is supplied.

18‐Handwritten

668 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.4

Comment: Most of New England and states already

fund PSAs and outreach materials; programs that

address mosquito control, plays plus ways folks can

reduce their exposure.

18‐Handwritten

669 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.6

Comment: educating the public is already done by

DPHs and community health organizations.  Why is

this duplication needed? Waste of resources.

18‐Handwritten

670 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.5.2 Comment: (1) Not always possible; (2) Operator or

applicator 18‐Handwritten

671 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.5.4 Comment: Depending on the state the certifications

and training program already does this. 18‐Handwritten

672 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.5.4 Comment: Change "pesticide applicators" to

"operator or applicator" 18‐Handwritten

673 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.5.6 Comment: "pesticide label" ‐ thought this wasn't

included. 18‐Handwritten

674 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.5.5 Question:  How to document? How to enforce? 18‐Handwritten

675 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.5.6 Question:  How to document? How to enforce? 18‐Handwritten

676 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.6 Comment: already done by DPH and area medical

facilities 18‐Handwritten

677 Szylvian, Andrea Technology‐Based Effluent Limitations 2.1.6 Question: "residents in treatment area" ‐ what

about summer renters? How/what is range? 18‐Handwritten

678 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.1.2 Comment: Resistance management. 18‐Handwritten

679 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.2 Comment: FIFRA 2ee site specified on label‐

pesticide might not be 18‐Handwritten

680 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.2.3 Comment: Need? 18‐Handwritten

681 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.3 Comment: justification time consuming. 18‐Handwritten

682 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.3.2 Comment: Too prescriptive documentation at each

step ‐ what is expected level? Cost. 18‐Handwritten

683 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.3.3 Comment: Too prescriptive documentation at each

step ‐ what is expected level? Cost. 18‐Handwritten

684 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.3.4 Comment: Too prescriptive documentation at each

step ‐ what is expected level? Cost. 18‐Handwritten
685 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.4 Comment: document not feasible ‐ what is

acceptable level of documentation? 18‐Handwritten

686 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.5.1 Question: What is an action threshold for aquatic

vegetation? 18‐Handwritten

687 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.5.1 Comment: "minimizing" ‐ selecting? Negative

impact of use implied. 18‐Handwritten

688 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.5.2 Question: "adverse incidents" ‐ what is this? Define. 18‐Handwritten

689 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.5.4 Comment: Inherent in label directions. 18‐Handwritten

690 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.6.1 Comment: Not clear, expertise approach? 18‐Handwritten

691 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.6.1.3 Question: Right expertise to provide information? 18‐Handwritten

692 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.6.2 Question: How far out is prior/immediately? 18‐Handwritten

693 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.6.2.1 Question: What if dates change. 18‐Handwritten

694 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.6.2

Question: What is there are multiple access points?

How long do they stay up? Signs made by operator?

How to ensure sign was posted? Applications by

homeowners ‐ they do this too?

18‐Handwritten

695 Szylvian, Andrea Technology‐Based Effluent Limitations 2.2.6.2 Comment: already on label, applicator risk, not to

public. 18‐Handwritten

696 Szylvian, Andrea Water Quality‐Based Effluent Limitations 3.0 Comment: Frequency of sampling. 18‐Handwritten

697 Szylvian, Andrea Integrated Pest Management Plan 6.0 IPM ‐ FIFRA section 23 only ag IPM 18‐Handwritten

698 Szylvian, Andrea Integrated Pest Management Plan 6.1 Comment: "spill control plans" ‐ this is outlined on

pesticide label and state regs 18‐Handwritten

699 Szylvian, Andrea Integrated Pest Management Plan 6.1 Comment: "IPM" ‐ aquatic weed management plan 18‐Handwritten

700 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.1 Comment: They are not managing the pest ‐ they

facilitate addressing the problem. 18‐Handwritten

701 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.1 Question: "corrective actions" ‐ what are these? 18‐Handwritten

702 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.1 Comment: evaluate every season ‐ not a lot of

changes 18‐Handwritten

703 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.2 Comment: (1) Suggests inserting "Plan" after "IPM";

(2) BMP or Aquatic Weed Management. 18‐Handwritten

704 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.2 Comment: Bullet (c) ‐ not always doable. 18‐Handwritten

705 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.2 Question: Bullet (e) "applicable water quality

standards" ‐ where do these come from? 18‐Handwritten

706 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.2 Question: Bullet (f) ‐ What if only portion of

waterbody is treated? Level of expectation? 18‐Handwritten

707 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.3 Question: 1st sentence, "must" ‐ Level of

expectation/documentation? 18‐Handwritten

708 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.3 Question: Bullet (b) ‐ How extensive is this expected

to be? 18‐Handwritten

709 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.3

Question: Bullet (c) ‐ (1) what is expected here,

could be many pages long; (2) "Less toxic pest

control" ‐ What is this?

18‐Handwritten

710 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.4 Comment: "surveillance procedures" ‐ application 18‐Handwritten

711 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.3 Question: Who has expertise in water to develop

and evaluate IPM plan? 18‐Handwritten

712 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.5 Rewrite: Suggests inserting "plan" after "the IPM" 18‐Handwritten

713 Szylvian, Andrea Integrated Pest Management Plan 6.1.1.5

Comment: The IPM plan (should be BMP ‐ not IPM)

is required before NOI, shouldn't NOI require date

of IPM development.

18‐Handwritten

714 Szylvian, Andrea Integrated Pest Management Plan 6.1.2.2 Comment: What client wants 0 weeds? 18‐Handwritten

715 Szylvian, Andrea Integrated Pest Management Plan 6.1.2.5

Question: (1) Where are education sources ‐ who

will be the educator? Materials? (2) "Prevention

efforts" ‐ what are these? How extensive should

this be?

18‐Handwritten

716 Szylvian, Andrea Integrated Pest Management Plan 6.1.3.3 Comment: need more specificity, want them to call

SLA and DEP/DEQ 18‐Handwritten

717 Szylvian, Andrea Site Monitoring 8.1 Question: What do we plan to do with these

reports? 18‐Handwritten

718 Szylvian, Andrea Site Monitoring 8.1

Question: (1) "visual assessment" ‐ what

parameters should be evaluated, frequency? (2)

"application site" ‐ define.

18‐Handwritten

719 Szylvian, Andrea Site Monitoring 8.1 Question: Permittee or NOI filer does monitoring? 18‐Handwritten

720 Szylvian, Andrea Site Monitoring 8.1.1 Question: Recreational ‐ how would this be

determined? 18‐Handwritten

721 Szylvian, Andrea Site Monitoring 8.1.2

Question: Non‐aerial treatments, 3rd open bullet,

"within one week of completion of treatment" ‐ 

what if you can't get back to treatment site?

18‐Handwritten

722 Szylvian, Andrea Site Monitoring 8.1.2 Question: Non‐aerial treatments ‐ Immediately

means? 18‐Handwritten

723 Szylvian, Andrea Site Monitoring 8.1.3 Question: "you" ‐ permittee? 18‐Handwritten

724 Szylvian, Andrea Site Monitoring 8.1.3 Question: all linked to application? 18‐Handwritten

725 Szylvian, Andrea Site Monitoring 8.1.3 Comment: visual assessment. 18‐Handwritten
726 Szylvian, Andrea Site Monitoring 8.1.4 Comment: treatment is what ‐ spot treatments?

Impact to entire application area cost? 18‐Handwritten

727 Szylvian, Andrea Site Monitoring 8.1.4

Question: How many times are issue inspections

required? Some of this takes a long period of time

to appear.

18‐Handwritten

728 Szylvian, Andrea Site Monitoring 8.2

Comment: (1) Need AI looking for; (2) sampling

techniques/frequencies; (3) lab analysis required;

(4) any lab certification needed; (5) cost estimates

18‐Handwritten

729 Szylvian, Andrea Site Monitoring 8.2.1

Comment: justification registration process ‐ add

based on past performance ‐ additional monitoring

may be required.

18‐Handwritten

730 Szylvian, Andrea Site Monitoring 8.3 Question: When does this take place? 18‐Handwritten

731 Szylvian, Andrea Site Monitoring 8.3 Comment: combine info for 8.2 and 8.3 18‐Handwritten

732 Szylvian, Andrea Site Monitoring 8.3 Comment: 2nd bullet "pesticide of concern" ‐ FIFRA

Coop Agreement Guidance term change 18‐Handwritten

733 Szylvian, Andrea Reporting 9.1 Rewrite: 1st bullet ‐ suggests changing "operator"

to "permittee" 18‐Handwritten

734 Szylvian, Andrea Reporting 9.1 Comment: 3rd filled bullet ‐ define "near waters" 18‐Handwritten

735 Szylvian, Andrea Reporting 9.1 Comment: public info ‐ data requests 18‐Handwritten

736 Szylvian, Andrea Reporting 9.2 Comment: Change "pesticide registration" to

"pesticide regulation" 18‐Handwritten

737 Szylvian, Andrea Reporting 9.2

Comment: "within 14 days" ‐ SLAs would probably

require 7 days or less ‐ no evidence would be viable

most likely

18‐Handwritten

738 Szylvian, Andrea Reporting 9.2 Comment: location ‐ many times counties are not

known 18‐Handwritten

739 Szylvian, Andrea Recordkeeping 10.1 Comment: Only NOIs (filers) 18‐Handwritten

740 Szylvian, Andrea Recordkeeping 10.1 Question: 6th bullet (Pesticide Application Logs) ‐ 

Inspection of records authorized by CWA? 18‐Handwritten

741 Szylvian, Andrea Recordkeeping 10.1

Question: 6th bullet (Pesticide Application Logs),

bullet (4), "application details" ‐ each application or

daily/weekly activity?

18‐Handwritten

742 Szylvian, Andrea Recordkeeping 10.1 Question: What is meant by "treatment"? 18‐Handwritten

743 Szylvian, Andrea Recordkeeping 10.1

Question: 6th bullet (Pesticide Application Logs),

bullet (4h), "names of waterbodies..." ‐ adulticiding

fogging ‐ might be hard to know

18‐Handwritten

744 Szylvian, Andrea Recordkeeping 10.1

Rewrite: 6th bullet (Pesticide Application Logs),

bullet (4i), suggests adding after "total size of

treatment area", to which pesticides are applied"

18‐Handwritten

745 Szylvian, Andrea Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs) ‐ 

already required by state pesticide regs. 18‐Handwritten

746 Szylvian, Andrea Recordkeeping 10.1

Question: 6th bullet (Pesticide Application Logs),

Bullet (6) ‐ how often is this to be done? How many

return trips?

18‐Handwritten

747 Szylvian, Andrea Recordkeeping 10.1

Rewrite: 6th bullet (Pesticide Application Logs),

Bullet (9) ‐ suggests adding to the end "or failure of

larviciding"

18‐Handwritten

748 Szylvian, Andrea Recordkeeping 10.1

Question: 7th bullet (Pesticide Application

Equipment Maintenance) ‐ is this needed? Implied

via license and label.

18‐Handwritten

749 Recordkeeping 10.2 Comment: 3 year time frame conflict with state

pesticide record retention laws.

750 Szylvian, Andrea Appendix B ‐ Standard Permit Conditions (Reporting Requirements) B.12 Comment: regarding eNOI ‐ do we have to have this

made available in paper format upon request? 18‐Handwritten

751 Rise, David NO COMMENTS IN THIS DOCUMENT 19‐Handwritten

752 Wilkinson, Bruce Technology‐Based Effluent Limitations 2.1.1.2 Question: Growing season? Application season? Per

year? 20‐Handwritten

753 Wilkinson, Bruce Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Suggests changing "eliminate" to

"minimize" 20‐Handwritten

754 Wilkinson, Bruce Integrated Pest Management Plan 6.1.1.2 Rewrite: 1st sentence ‐ Suggests adding "Plan" after

"IPM" 20‐Handwritten

755 Wilkinson, Bruce Site Monitoring 8.1 Rewrite: Suggests changing "possible" to

"observable" 20‐Handwritten

756 Thilsted, Eugene Coverage Under This Permit 1.1.1.1

Comment: Could "operator" be changed to "entity" ‐

something other than "operator" as operator is

confusing.  Operator of what?

22‐Handwritten

757 Thilsted, Eugene Coverage Under This Permit 1.1.2.5 Question: Could a website address be added here?

Or Not specific enough? 22‐Handwritten

758 Thilsted, Eugene Coverage Under This Permit 1.2.2 Comment: 3rd paragraph, "Operators..." ‐ Is this not

the "responsible entity?" 22‐Handwritten

759 Thilsted, Eugene Technology‐Based Effluent Limitations 2.2.1.2 Comment: May result in resistance to pesticides 22‐Handwritten

760 Thilsted, Eugene Technology‐Based Effluent Limitations 2.2.2.4 Rewrite: Suggests deleting "past or" 22‐Handwritten

761 Thilsted, Eugene Technology‐Based Effluent Limitations 2.2.3.2 Comment: If applicable? 22‐Handwritten

762 Thilsted, Eugene Technology‐Based Effluent Limitations 2.2.4.3 Question: Are or will they be trained to do this? Or

"conduct control obtained"? 22‐Handwritten
763 Thilsted, Eugene Technology‐Based Effluent Limitations 2.2.5.3 Comment: These are documented? 22‐Handwritten

764 Thilsted, Eugene Technology‐Based Effluent Limitations 2.2.6.2.2 Comment: Suggests deleting, because not

applicable. May give wrong impression of pesticide. 22‐Handwritten

765 Thilsted, Eugene Water Quality‐Based Effluent Limitations 3.0

Comment: Need to know which states have

numerical standards.  Are we looking for "no effect"

limits?

22‐Handwritten

766 Thilsted, Eugene Integrated Pest Management Plan 6.0 Question: What amount of detail are we looking

for? Can they reference a website or document? 22‐Handwritten

767 Thilsted, Eugene Integrated Pest Management Plan 6.1.1.1 Comment: This will change.  No IPM coordinator

mentioned. 22‐Handwritten

768 Thilsted, Eugene Integrated Pest Management Plan 6.1.1.2 Rewrite: 1st sentence ‐ Suggests adding "Plan" after

"IPM" 22‐Handwritten

769 Thilsted, Eugene Integrated Pest Management Plan 6.1.1.2 Comment: Bullet (a) "if feasible" ‐ is misleading. 22‐Handwritten

770 Thilsted, Eugene Integrated Pest Management Plan 6.1.1.3

Question: Bullet (c) "non‐toxic" and "less toxic" ‐ 

too what? What about "comparable" in terms of %

control?

22‐Handwritten

771 Thilsted, Eugene Integrated Pest Management Plan 6.1.2 Comment: "must" ‐ enforceable, means do all 22‐Handwritten

772 Thilsted, Eugene Integrated Pest Management Plan 6.1.2.1 Comment: No IPM Coordinator mentioned (the one

that wrote the IPM Plan). 22‐Handwritten

773 Thilsted, Eugene Integrated Pest Management Plan 6.1.2.3

Comment: (1) Bullet (a) can they list "none'? (2)

Bullet (b) is there a #? (3) Bullet (c) this will take

time and probably no environmental impact.

22‐Handwritten

774 Thilsted, Eugene Integrated Pest Management Plan 6.1.2.5 Comment: out of place. 22‐Handwritten

775 Thilsted, Eugene Site Monitoring 8.1.1 Rewrite: Suggests adding before "wildlife habitat",

insert "aquatic." 22‐Handwritten

776 Thilsted, Eugene Site Monitoring 8.1.2 Question: Non‐aerial treatments, 2nd open bullet ‐ 

what does this mean? 22‐Handwritten

777 Thilsted, Eugene Site Monitoring 8.1.2 Question: Non‐aerial treatments, 3rd and 4th open

bullets ‐ does this answer it? 22‐Handwritten

778 Thilsted, Eugene Site Monitoring 8.1.3 Comment: May be non‐event; if so, monitor to

determine cause. 22‐Handwritten

779 Thilsted, Eugene Site Monitoring 8.2.1

Question: Are these to be determined? Or those

that cause a problem? Can several be added after

an incident?

22‐Handwritten

780 Thilsted, Eugene Recordkeeping 10.1 Rewrite: 1st sentence ‐ suggests changing

"Operator" to "Those" 22‐Handwritten

781 Thilsted, Eugene Recordkeeping 10.1 Question: 6th bullet (Pesticide Application Logs) ‐ 

Will there be a template for these? 22‐Handwritten

782 Thilsted, Eugene Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs),

bullet (4h) ‐ isn't this answered by GPS document? 22‐Handwritten

783 Thilsted, Eugene Recordkeeping 10.1

Question: 6th bullet (Pesticide Application Logs),

bullet (4i) ‐ Total size of treatment area? Targeted

area? Area pesticide applied?

22‐Handwritten

784 Thilsted, Eugene Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs),

bullet (7) ‐ this may not be a negative impact. 22‐Handwritten

785 Tenbrook, Patti Coverage Under This Permit 1.2.4 Rewrite: Under bullet (3) the word "not" should be

changed to "otherwise" 23‐Handwritten

786 Tenbrook, Patti Technology‐Based Effluent Limitations 2.1.6.1 Comment: Nothing to do with WQ 23‐Handwritten

787 Tenbrook, Patti Technology‐Based Effluent Limitations 2.2.4

Comment: In calculating cost of monitoring consider

that people are already in the field to do

surveillance

23‐Handwritten

788 Tenbrook, Patti Site Monitoring 8.3 Comment: Under bullet (3), "pesticide of concern" ‐ 

don't need new term, but need to define 23‐Handwritten

789 Tenbrook, Patti Reporting 9.3 Comment: Safety and access concerns: same for

surveillance work 23‐Handwritten

790 Lowry, Leslie Coverage Under This Permit 1.2.1

Question: If a permit is issued for an application on

a specific area/waterbody and then additional

areas/waterbodies are needed, how would the

permittee supplement their existing permit? Would

an additional NOI be needed?

24‐Handwritten

791 Lowry, Leslie Coverage Under This Permit 1.2.2

Comment: Also NOI need this all water to possibly

be applied. If not the agency would have a difficult

time identify 303(d) list and Tier3 waters

24‐Handwritten

792 Lowry, Leslie Corrective Action 5.1 Comment: Correct paragraph alignment 24‐Handwritten

793 Lowry, Leslie Corrective Action 5.2 Comment: Correct paragraph alignment 24‐Handwritten

794 Lowry, Leslie Site Monitoring 8.1 Comment: ". . . application . . ." ‐ Waterbody as a

whole or each site applied? 24‐Handwritten

795 Lowry, Leslie Site Monitoring 8.2.3 Comment: Correct paragraph alignment 24‐Handwritten

796 Lowry, Leslie Site Monitoring 8.3 Comment: Correct paragraph alignment 24‐Handwritten

797 Lowry, Leslie Reporting 9.1 Comment: Correct paragraph alignment 24‐Handwritten

798 Lowry, Leslie Reporting 9.1 Comment: Correct paragraph alignment 24‐Handwritten

799 Lowry, Leslie Reporting 9.1 Question: Last paragraph ‐ Why 1 year from their

date of coverage? 24‐Handwritten

800 Lowry, Leslie Reporting 9.2 Comment: Correct paragraph alignment 24‐Handwritten
801 Lowry, Leslie Recordkeeping 10.1

Question: Why or would the permittee not need to

submit the IPM with the NOI? Especially for new

permits but not for Renewals for other general

permits like general SW permit we require SWPPP

to be submitted with NOI

24‐Handwritten

802 Lowry, Leslie Recordkeeping 10.1

Rewrite: 6th bullet (Pesticide Application Logs),

bullet 4.g ‐ and total applied per site/waterbody

annually

24‐Handwritten

803 Lowry, Leslie Recordkeeping 10.1

Comment: 7th bullet (Pesticide Application

Equipment Maintenance) ‐ location of records kept

and for how long (life of permit)

24‐Handwritten

804 Mortensen, Ginah General Comment: Permit needs to be enforceable 25‐Handwritten

805 Mortensen, Ginah General Comment: Permit needs to be practical 25‐Handwritten

806 Mortensen, Ginah General Comment: Need to be articulate about harm and if

no harm, don’t have requirements 25‐Handwritten

807 Mortensen, Ginah General Comment: Must demonstrate need for the permit

and for any requirements 25‐Handwritten

808 Mortensen, Ginah General

Comment: Please try to write a permit with lots of

options for example, for "these" pesticides you

don’t need a lot of requirements, but for "these

pesticides need more and for "these" Pesticides

need the most requirements because they are the

most problematic

25‐Handwritten

809 Mortensen, Ginah General

Question: What about the use of a pesticide to

achieve and improve water quality ‐ for example

using a pesticide to eliminate an exotic or invasive

species

25‐Handwritten

810 Mortensen, Ginah General Comment: The value of the permit is to be able to

localize the condition of the permit 25‐Handwritten

811 Mortensen, Ginah General Question: What is the environmental harm you are

trying to eliminate?  Avoid? 25‐Handwritten

812 Mortensen, Ginah General

Comment: Don’t want to end up with EPA in the

middle of  public health issues and pesticides

applied for mosquitoes

25‐Handwritten

813 Mortensen, Ginah General

Comment: There are many terms throughout the

draft permit that need to be defined before we can

determine enforcement ability ‐ operator, you,

treatment area

25‐Handwritten

814 Mortensen, Ginah General

Comment: There are many terms throughout that

are basically unenforceable on their face ‐ minimize,

reduce, feasible

25‐Handwritten

815 Mortensen, Ginah Coverage Under This Permit 1.1.1.1 Question: What is the definition of "near"? 25‐Handwritten

816 Mortensen, Ginah Coverage Under This Permit 1.1.1.1 Question: When (at what point in time) does ag

stormwater exemption kick in? 25‐Handwritten

817 Mortensen, Ginah Coverage Under This Permit 1.2.4 Rewrite: Under bullet (3) the word "not" should be

changed to "otherwise" 25‐Handwritten

818 Mortensen, Ginah Technology‐Based Effluent Limitations 2.1.1 Comment: Applies to all, not just NOI 25‐Handwritten

819 Mortensen, Ginah Technology‐Based Effluent Limitations 2.1.2 Comment: Last paragraph, "feasible" ‐ is a

judgment call 25‐Handwritten

820 Mortensen, Ginah Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Change "eliminate" to "minimize" 25‐Handwritten

821 Mortensen, Ginah Technology‐Based Effluent Limitations 2.1.3 Question: Last paragraph, "feasible"‐ What is the

definition of feasible 25‐Handwritten

822 Mortensen, Ginah Technology‐Based Effluent Limitations 2.1.4.5 Comment: ". . . weather station(s) . . ." ‐ ? 25‐Handwritten

823 Mortensen, Ginah Technology‐Based Effluent Limitations 2.1.6

Question: Does this mean before the 1st application

or within 30 days before or after the pesticide

application?

25‐Handwritten

824 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.3.3 Comment: ". . . Maintain . . ." ‐ how 25‐Handwritten

825 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.3.3 Comment: ". . . Enhance . . ." ‐ how 25‐Handwritten

826 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.3.3 Comment: ". . . Promote . . ." ‐ how, to whom 25‐Handwritten

827 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.3.3 Question: "biological controls" ‐ What are these? 25‐Handwritten

828 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.3.4 Comment: Under last sentence in 2.2.3, "feasible" ‐ 

? 25‐Handwritten

829 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.6.1 Comment: "web site" ‐ facebook? Myspace? 25‐Handwritten

830 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.6.1 Comment: Post ‐ when, how long, how big, how

high, what color? 25‐Handwritten

831 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.6.1.3 Comment: "information" ‐ about what 25‐Handwritten

832 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.6.2 Comment: Public Access ‐ roads? Sidewalks? Boat

ramps? Trails? 25‐Handwritten

833 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.6.2 Question: "each pesticide" ‐ All pesticides or just for

aquatic weed? 25‐Handwritten

834 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.6.2

Question: "post, near, public access point, users,

surrounding, treatment area" ‐ What do these

mean?

25‐Handwritten

835 Mortensen, Ginah Technology‐Based Effluent Limitations 2.2.6.2.2 Comment: "label human hazard warnings" ‐ ? 25‐Handwritten

836 Mortensen, Ginah Integrated Pest Management (IPM) Plan 6.1.1.3 Comment: Under part c, "and non‐toxic" and "less

toxic pest control" ‐ ? 25‐Handwritten

837 Mortensen, Ginah Integrated Pest Management (IPM) Plan 6.1.3.2 Question: "schedule" ‐ What is the definition? 25‐Handwritten

838 Mortensen, Ginah Integrated Pest Management (IPM) Plan 6.1.3.3 Question: "incident" ‐ What is the definition? 25‐Handwritten

839 Mortensen, Ginah Integrated Pest Management (IPM) Plan 6.1.4 Question: What does this mean? 25‐Handwritten
840 Mortensen, Ginah Site Monitoring 8.1 Question: "each application site" ‐ What is the

definition? 25‐Handwritten

841 Mortensen, Ginah Site Monitoring 8.1 Comment: "possible" ‐ ? 25‐Handwritten

842 Mortensen, Ginah Site Monitoring 8.1.1

Comment: "disruption of wildlife habitat" ‐ Driving

the application equipment in the area could

"disrupt wildlife habitat"

25‐Handwritten

843 Mortensen, Ginah Site Monitoring 8.1.2

Question: 2nd open bullet, "Immediately following"

What about label prohibition on entering a treated

area for a specific amount of time?

25‐Handwritten

844 Mortensen, Ginah Site Monitoring 8.1.2

Comment: 4th open bullet, "act of treatment" ‐ 

Probably don't want applicators moving back into

an area just treated ‐ health and safety issue

25‐Handwritten

845 Mortensen, Ginah Site Monitoring 8.1.3 Question: Where? For how long? 25‐Handwritten

846 Mortensen, Ginah Site Monitoring 8.1.3

Question: "distressed, dead, juvenile, small fishes" ‐ 

How will you know that/these are a result of the

pesticide application?

25‐Handwritten

847 Mortensen, Ginah Site Monitoring 8.1.3 Question: "Fish swimming abnormally or erratically"

‐ How will they know? 25‐Handwritten

848 Mortensen, Ginah Site Monitoring 8.1.3 Question: Under last sentence in 8.1.3 ‐ From the

pesticide application? 25‐Handwritten

849 Mortensen, Ginah Site Monitoring 8.1.4 Question: 4th bullet,  "Species" ‐ How will they

know? 25‐Handwritten

850 Mortensen, Ginah Site Monitoring 8.1.4 Question: 5th bullet ‐ How will they know? What is

purpose? 25‐Handwritten

851 Mortensen, Ginah Site Monitoring 8.2 Comment: "Enhanced" ‐ define 25‐Handwritten

852 Mortensen, Ginah Site Monitoring 8.2.3

Comment: "immediately following" ‐ Same

comment as above regarding re‐entry into treated

area depending on how the pesticide was applied

25‐Handwritten

853 Mortensen, Ginah Site Monitoring 8.2.3 Question: "within" ‐ 20 min later? 25‐Handwritten

854 Mortensen, Ginah Site Monitoring 8.3 Question: References the title of 8.3 ‐ Should this be

"Monitoring Required by EPA"? 25‐Handwritten

855 Mortensen, Ginah Site Monitoring 8.3 Question: 1st bullet, "determined" ‐ By whom? 25‐Handwritten

856 Mortensen, Ginah Site Monitoring 8.3 Question: 2nd bullet, "pesticide of concern" ‐ What

does this mean? 25‐Handwritten

857 Mortensen, Ginah Site Monitoring 8.3 Question: 4th bullet, "pesticide use" ‐ Under this

permit? 25‐Handwritten

858 Mortensen, Ginah Site Monitoring 8.3 Comment: Last paragraph, second sentence,  

"reasonable" ‐ ? 25‐Handwritten

859 Mortensen, Ginah Reporting 9.1 Question: 1st bullet, "operator" ‐ Permittee? 25‐Handwritten

860 Mortensen, Ginah Reporting 9.1 Question: What are the plans for EPA review of

these reports? 25‐Handwritten

861 Mortensen, Ginah Reporting 9.1

Comment: If the reporter is not the applicator it

may be difficult for reporter to get some of their

info

25‐Handwritten

862 Mortensen, Ginah Reporting 9.1 Comment: 1st filled square bullet,  "Jurisdiction" ‐ ? 25‐Handwritten

863 Mortensen, Ginah Reporting 9.1 Comment: 3rd filled/square bullet,  "near" ‐ 

Definition? 25‐Handwritten

864 Mortensen, Ginah Reporting 9.2 Comment: Under last sentence of first paragraph,

"registration" ‐ regulation 25‐Handwritten

865 Mortensen, Ginah Reporting 9.2 Comment: Under bullet (1),  "operator" ‐ Define 25‐Handwritten

866 Mortensen, Ginah Reporting 9.2

Comment: References bullets 6‐13 ‐ If operator is

not the applicator, some of this info may not be

available

25‐Handwritten

867 Mortensen, Ginah Recordkeeping 10.1 Question: Under first paragraph, first sentence ‐ 

Where? 25‐Handwritten

868 Mortensen, Ginah Recordkeeping 10.1 Question: 5th bullet, "of employee training as" ‐ 

What employee training? Which employees? 25‐Handwritten

869 Mortensen, Ginah Recordkeeping 10.1

Question: 5th bullet, "training appropriate to

employees' specified duties ‐ With respect to which

duties?

25‐Handwritten

870 Mortensen, Ginah Recordkeeping 10.1 Question: 6th bullet (Pesticide Application Logs)

What is the purpose of the records? 25‐Handwritten

871 Mortensen, Ginah Recordkeeping 10.1 Question: 6th bullet (Pesticide Application Logs) 4i ‐ 

What is the definition of "treatment area"? 25‐Handwritten

872 Mortensen, Ginah Recordkeeping 10.1 Comment: 6th bullet, 5,  "time, site, local weather

forecast" ‐ (all were circled) 25‐Handwritten

873 Mortensen, Ginah Recordkeeping 10.1

Comment: 7th bullet, (Pesticide Application

Equipment Maintenance) ‐ Permittee may not be

the pesticide applicator and may not have this info

25‐Handwritten

874 Shafii, Mo General Comment: Define "near" of the water 26‐Handwritten

875 Shafii, Mo General Comment: "near" is not in 40 CFR 26‐Handwritten

876 Shafii, Mo General Question: Where is the fact sheet? 28‐Handwritten

877 Shafii, Mo Coverage Under This Permit 1.1.1.1 Question: We need to define "residual". How does

operator must Certify "no residual"? 28‐Handwritten
878 Shafii, Mo Coverage Under This Permit 1.1.2.5 Comment: Not for "states" only Federal 28‐Handwritten

879 Shafii, Mo Coverage Under This Permit 1.1.2.6 Comment: Not for "states" only Federal 28‐Handwritten

880 Shafii, Mo Coverage Under This Permit 1.2.2 Question: Do they have to submit IPM for approval? 28‐Handwritten

881 Shafii, Mo Coverage Under This Permit 1.2.2

Comment: References "operators" in title of 1.2.2 ‐ 

By 40 CFR operator has to have permit. So, you

could use ARK Reg.No.6. Definition of operator.

Operator could be "co‐permittee." Define "near"

and "water‐acre."

28‐Handwritten

882 Shafii, Mo Coverage Under This Permit 1.2.4 Question: When do they need to submit NOI? 28‐Handwritten

883 Shafii, Mo Coverage Under This Permit 1.2.4 Rewrite: Replace the word "not" in 3. with

"otherwise" 28‐Handwritten

884 Shafii, Mo Coverage Under This Permit 1.2.5.1 Comment: "QLP" could give to state a waiver so

cover individual homeowner by operator 28‐Handwritten

885 Shafii, Mo Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Replace the word "eliminate" with the

word "minimum" 28‐Handwritten

886 Shafii, Mo Corrective Action 5.1 Question: Under last bullet ‐ Is this the same as #2 ‐ 

above. 28‐Handwritten

887 Shafii, Mo Corrective Action 5.2 Question: Is this the same as upset condition that is

required by 40 CFR 122? 28‐Handwritten

888 Shafii, Mo Corrective Action 5.2 Comment: 2nd sentence,  "within 14 days" ‐ 40 CFR

is required 5 days 28‐Handwritten

889 Shafii, Mo Site Monitoring 8.1.3 Comment: Define "discomfort" 28‐Handwritten

890 Jennings, Phillip General Question: Factsheet ‐ it is as important as the

permit ‐ where is it? 29‐Handwritten

891 Jennings, Phillip General

Question: It is likely that EPA's permit, regardless of

what its requirements are, will be challenged by

one or more interest groups. Have we considered

similar challenges the states will face and how we

will work with them to resolve?

29‐Handwritten

892 Jennings, Phillip Coverage Under This Permit 1.1.1.1

Comment: "near" means within aerial drift or other

dissemination patterns which would reasonably be

expected to cause the chemical to reach waters of

the U.S. This would consider the effects of

wind/rain at the time of application.

29‐Handwritten

893 Jennings, Phillip Coverage Under This Permit 1.2.2 Comment: responsible entity, operator, applicator ‐ 

define these terms 29‐Handwritten

894 Jennings, Phillip Coverage Under This Permit 1.2.4 Rewrite: Replace word "not" with "otherwise" 29‐Handwritten

895 Jennings, Phillip Technology‐Based Effluent Limitations 2.1.2 Question: Last sentence ‐ Is this reported? Before or

after application? 29‐Handwritten

896 Jennings, Phillip Technology‐Based Effluent Limitations 2.1.3.2 Question: Case we really require all of this through

an NPDES Permit??? 29‐Handwritten

897 Jennings, Phillip Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Replace "eliminate" with "minimize" 29‐Handwritten

898 Jennings, Phillip Technology‐Based Effluent Limitations 2.1.3 Question: Last sentence, "feasible" ‐ feasible

measure means? 29‐Handwritten

899 Jennings, Phillip Technology‐Based Effluent Limitations 2.1.4

Comment: Clarify ‐ "Musts" vs. "should," flexibility

lies where we have a "should" statement, but not

where we have a "must" statement.

29‐Handwritten

900 Jennings, Phillip Technology‐Based Effluent Limitations 2.1.4.4

Rewrite: Change "as an indicator of the need to

initiate an adult control program" to "as additional

indicator".

29‐Handwritten

901 Jennings, Phillip Technology‐Based Effluent Limitations 2.1.5

Comment: Apply at the rate designed by FIFRA but

you may not be applying the compound in a

scenario that the FIFRA label is designed for.

29‐Handwritten

902 Jennings, Phillip Technology‐Based Effluent Limitations 2.1.5.6 Comment: Consider the application 29‐Handwritten

903 Jennings, Phillip Technology‐Based Effluent Limitations 2.2.1 Comment: References "Pesticide" in title of ‐ 

Herbicide 29‐Handwritten

904 Jennings, Phillip Technology‐Based Effluent Limitations 2.2.3.1

Comment: e.g.? Applying copper compounds for

weed control may cause toxicity to fish and

invertebrates.

29‐Handwritten

905 Jennings, Phillip Technology‐Based Effluent Limitations 2.2.3.2 Question: Must do this first? 29‐Handwritten

906 Jennings, Phillip Technology‐Based Effluent Limitations 2.2.3.3 Question: Must do this first? 29‐Handwritten

907 Jennings, Phillip Technology‐Based Effluent Limitations 2.2.3.4 Question: Must do this first? 29‐Handwritten

908 Jennings, Phillip Technology‐Based Effluent Limitations 2.2.4.2 and 2.2.5.1

Question: After the discussion on this I am

confused. You apply an herbicide to kill of

unwanted plants. As a side effect, the decomposing

plant material causes a depletion of dissolved

oxygen which then caused a fish kill (as well as lots

of small organisms, fish and invertebrates).

Wouldn't this be an unintended effect to non‐target

species that should be addressed?

29‐Handwritten

909 Jennings, Phillip Water Quality‐Based Effluent Limitations 3.0

Question: 1st paragraph, 1st sentence ‐ This is the

limit ‐ how is this compliance with this to be

measured? Visual inspection is not adequate with

respect to invertebrates and small fish.

29‐Handwritten
910 Jennings, Phillip Water Quality‐Based Effluent Limitations 3.0

Comment: Note: Temperature and DO stressed fish,

or trout feeding on mayflies that are emerging to

the adult stage ‐ both cases may be confused with a

direct effect related to Pesticide Application.

29‐Handwritten

911 Jennings, Phillip Corrective Action 5.1

Comment: 5th bullet ‐ what about killing things you

don't see ‐ invertebrates, crayfish, daphnids,

minnows, etc ‐ all are part of the food chain that

supports larger organisms

29‐Handwritten

912 Jennings, Phillip Corrective Action 5.3.2

Question: Clarify ‐ What is required and where do

we have flexibility (and how much flexibility is

allowed)?

29‐Handwritten

913 Jennings, Phillip Integrated Pest Management (IPM) Plan 6.1.1.1 Question: Qualifications or Certifications? 29‐Handwritten

914 Jennings, Phillip Integrated Pest Management (IPM) Plan 6.1.2

Question: Overall for this permit ‐ Have we looked

into how well all of these measures have worked in

the permits they originated in? What would those

permit writers/enforcers do differently if they did it

over?

29‐Handwritten

915 Jennings, Phillip Site Monitoring 8.1.2 Question: Nonaerial treatments, first three open

bullets ‐ 3 visits to site for 1 treatment? 29‐Handwritten

916 Jennings, Phillip Site Monitoring 8.1.2

Question: Non aerial treatments, 5th open bullet ‐ 

Concern maybe at points downstream or otherwise

outside the intended areas ‐ wouldn't this be a

logical place to sample?

29‐Handwritten

917 Jennings, Phillip Site Monitoring 8.1.3

Question: What about invertebrates and larval

post/larval fish? These are very small 10,000 bass or

catfish fry could die in an area 4 feet square and 3

inches deep and you would not be able to discern

that any organism was even present, much less

dead.

29‐Handwritten

918 Jennings, Phillip Reporting 9.1 Question: "operator" ‐ permittee, applicator? 29‐Handwritten

919 Jennings, Phillip Reporting 9.1

Question: Under last dash, first oval, third box ‐ 

Would % of area sprayed or % of product applied be

more useful? If you sprayed 1000 acres, but only 50

of those acres were located over or "near" waters,

your use pattern should reflect over or near (50

acres) not the total 1000 acres.

29‐Handwritten

920 Jennings, Phillip Recordkeeping 10.1

Question: If the "responsible entity" hires someone

else to apply pesticide, which one is the operator in

this section? Who has to keep which records?

29‐Handwritten

921 Jennings, Phillip Recordkeeping 10.1

Comment: 6th bullet (Pesticide Application Logs),

"pesticide applicator" ‐ I agree with the

recordkeeping ‐ including weather. These

requirements will help us understand when

something goes wrong and an incident occurs. It is

very difficult to try to reconstruct weather on after

the fact data, and it only takes a few seconds to jot

those few words down.

29‐Handwritten

922 Jennings, Phillip Recordkeeping 10.1

Comment: 7th bullet (Pesticide Application

Equipment Maintenance) ‐ Would think this

depends on who submits the NOI.

29‐Handwritten

923 Jennings, Phillip Appendix B ‐ Standard Permit Conditions (Reporting Requirements) B.10 Question: A, "volume" and "nature of the

monitored activity" ‐ What does this mean? 29‐Handwritten

924 Maguire, Charles Coverage Under This Permit 1.2.2

Question: Please require NOI only for situations

where we use the data effectively. Acres of contact

or affected by contact?

30‐Handwritten

925 Maguire, Charles Coverage Under This Permit 1.2.2 Comment: Can have lower thresholds if few have to

file NOI. 30‐Handwritten

926 Maguire, Charles Coverage Under This Permit 1.2.2 Comment: Need to address cumulative impacts ‐ 

not considered in permit process ‐ in factsheet 30‐Handwritten

927 Maguire, Charles Technology‐Based Effluent Limitations 2.0 Comment: Shouldn't the IPM include the other two.

Yet balance them to get best results. 30‐Handwritten

928 Maguire, Charles Technology‐Based Effluent Limitations 2.2.2.3 Comment: Last sentence ‐ So if not responsible then

nothing triggered by source ID. 30‐Handwritten

929 Coram, Phil General Question: 1st sentence, "point source discharge of

pollutants" ‐ To where? W‐o‐u‐s 31‐Handwritten

930 Coram, Phil General

Question: 3rd bullet, "If required by Part 1.2.2,

submits a complete and accurate NOI is authorized

to discharge" ‐ What?

31‐Handwritten

931 Coram, Phil Coverage Under This Permit 1.1.1

Question: 2nd bullet ‐ Is Copper Sulfate for algae

control in drinking water supply water reservoirs

covered?

31‐Handwritten

932 Coram, Phil Coverage Under This Permit 1.1.1 Question: 3rd bullet ‐ What about rivers, streams,

canals and estuaries? 31‐Handwritten

933 Coram, Phil Coverage Under This Permit 1.1.1 Comment: 3rd bullet ‐ Pesticide use for aquaculture

activities 31‐Handwritten

934 Coram, Phil Coverage Under This Permit 1.1.2.1 Comment: Have Drew B. look at language 31‐Handwritten
935 Coram, Phil Coverage Under This Permit 1.1.2.1 Question: What happens when impaired listing

occurs during permit coverage period? 31‐Handwritten

936 Coram, Phil Coverage Under This Permit 1.1.2.2 Question: Correct website? 31‐Handwritten

937 Coram, Phil Coverage Under This Permit 1.1.2.3 Comment: Already FIFRA prohibition 31‐Handwritten

938 Coram, Phil Coverage Under This Permit 1.1.2.4 Comment: w/o different distinction 31‐Handwritten

939 Coram, Phil Coverage Under This Permit 1.1.2.4 Comment: Assumes previous permit has 5 year

coverage period. 31‐Handwritten

940 Coram, Phil Coverage Under This Permit 1.1.2.4 Question: 3rd bullet ‐ Why? May want some under

6P. 31‐Handwritten

941 Coram, Phil Coverage Under This Permit 1.2.2 Comment: After threshold? Lbs/yr. 31‐Handwritten

942 Coram, Phil Coverage Under This Permit 1.2.2 Comment: 2nd bullet  ‐ IBID. 31‐Handwritten

943 Coram, Phil Coverage Under This Permit 1.2.2 Comment: 3rd paragraph and table under 1.2.3 ‐ 

Discuss relationships between these!!! 31‐Handwritten

944 Coram, Phil Coverage Under This Permit 1.2.2

Question: 3rd paragraph, "exceeding the threshold"

‐ Important. Any requirements before exceeding

threshold??

31‐Handwritten

945 Coram, Phil Coverage Under This Permit 1.2.4

Comment: 1st paragraph, "under this permit will

automatically remain covered by this permit until

the earliest of:" ‐ (1) Does not make sense; (2)

Replace "not" with "otherwise"

31‐Handwritten

946 Coram, Phil Coverage Under This Permit 1.3.1 Question: "122.64 and 124.5" ‐ What are these

criteria? Basis for petition? 31‐Handwritten

947 Coram, Phil Coverage Under This Permit 1.3.1 Question: Reasons why EPA would take this action? 31‐Handwritten

948 Coram, Phil Coverage Under This Permit 1.3.1 Question: Reference to applicable fed regs? 31‐Handwritten

949 Coram, Phil Coverage Under This Permit 1.3.1 Comment: Last two sentences and the title of 1.3.2 ‐

40 CFR 122.28? 31‐Handwritten

950 Coram, Phil Coverage Under This Permit 1.3.2 Question: (1) Legal basis? (2)Why restrictions for

applying for individual permits? 31‐Handwritten

951 Coram, Phil Technology‐Based Effluent Limitations 2.0 Question: Better use of FIFRA label? 31‐Handwritten

952 Coram, Phil Technology‐Based Effluent Limitations 2.0

Comment: "best industry practices, and minimized

pollutant discharge" ‐ (1) Defined? Need guidance ;

(2) Ref. to 5.0 ‐ control actions

31‐Handwritten

953 Coram, Phil Technology‐Based Effluent Limitations 2.1.1.1

Comment: References "extent achievable,

technologically available, economically practicable,

and achievable in light of best industry practice" ‐ 

Defined?

31‐Handwritten

954 Coram, Phil Technology‐Based Effluent Limitations 2.1.1.2 Comment: "use the lowest amount of" ‐ Resistance

problems. 31‐Handwritten

955 Coram, Phil Technology‐Based Effluent Limitations 2.1.1.3 Comment: 1st sentence, "and" ‐ Weather should be

recommendation not required. 31‐Handwritten

956 Coram, Phil Technology‐Based Effluent Limitations 2.1.1.3 Comment: Note at the end of the section ‐ Good

idea! 31‐Handwritten

957 Coram, Phil Technology‐Based Effluent Limitations 2.1.1.3

Comment: Need to rewrite. Two thoughts: 1) Do

not apply to water‐‐consider wind conditions to

prevent. 3) and OK to apply to waters‐‐no need to

consider wind

31‐Handwritten

958 Coram, Phil Technology‐Based Effluent Limitations 2.1.2.1 Question: DACs comments? 31‐Handwritten

959 Coram, Phil Technology‐Based Effluent Limitations 2.1.2.2 Question: DACs comments? 31‐Handwritten

960 Coram, Phil Technology‐Based Effluent Limitations 2.1.2.3 Question: DACs comments? 31‐Handwritten

961 Coram, Phil Technology‐Based Effluent Limitations 2.1.2.4 Question: DACs comments? 31‐Handwritten

962 Coram, Phil Technology‐Based Effluent Limitations 2.1.3 Question: DACs comments? 31‐Handwritten

963 Coram, Phil Technology‐Based Effluent Limitations 2.1.3.2 Comment: "filling in wetlands" ‐ dredging? 31‐Handwritten

964 Coram, Phil Technology‐Based Effluent Limitations 2.1.3 Comment: Last sentence ‐ Addressed in IPM plan. 31‐Handwritten

965 Coram, Phil Technology‐Based Effluent Limitations 2.1.3 Comment: Last sentence, "is not feasible" ‐ Define

or guidance 31‐Handwritten

966 Coram, Phil Technology‐Based Effluent Limitations 2.1.4 Question: DACs comments? 31‐Handwritten

967 Coram, Phil Technology‐Based Effluent Limitations 2.1.4.3 Question: Normal practice? 31‐Handwritten

968 Coram, Phil Technology‐Based Effluent Limitations 2.1.4.4 Question: Does FDOH do this? 31‐Handwritten

969 Coram, Phil Technology‐Based Effluent Limitations 2.1.4.4 Comment: Too strongly worded! 31‐Handwritten

970 Coram, Phil Technology‐Based Effluent Limitations 2.1.5 Question: DACs comments? 31‐Handwritten

971 Coram, Phil Technology‐Based Effluent Limitations 2.1.5.4 Comment: Weak. Need more specifically on

adequacy of training. 31‐Handwritten

972 Coram, Phil Technology‐Based Effluent Limitations 2.1.6 Comment: Tiered‐‐should apply to mosquito control

districts, government agencies, etc. 31‐Handwritten

973 Coram, Phil Technology‐Based Effluent Limitations 2.1.6.1 Comment: Normal practice in Florida? Yes. 31‐Handwritten

974 Coram, Phil Technology‐Based Effluent Limitations 2.2.1 Comment: FWC comments 31‐Handwritten

975 Coram, Phil Technology‐Based Effluent Limitations 2.2.1.1 Comment: FWC comments 31‐Handwritten

976 Coram, Phil Technology‐Based Effluent Limitations 2.2.1.2 Comment: FWC comments 31‐Handwritten

977 Coram, Phil Technology‐Based Effluent Limitations 2.2.1.2 Comment: resistance issues 31‐Handwritten

978 Coram, Phil Technology‐Based Effluent Limitations 2.2.2 Comment: FWC. 31‐Handwritten

979 Coram, Phil Technology‐Based Effluent Limitations 2.2.2 Comment: No feasibility language. (as last

paragraph, as in other sections) 31‐Handwritten

980 Coram, Phil Technology‐Based Effluent Limitations 2.2.2.3 Comment: Will control applicator know this. 31‐Handwritten

981 Coram, Phil Technology‐Based Effluent Limitations 2.2.2.4 Comment: Will control applicator know this. 31‐Handwritten

982 Coram, Phil Technology‐Based Effluent Limitations 2.2.3.2 Comment: Big issue. 31‐Handwritten

983 Coram, Phil Technology‐Based Effluent Limitations 2.2.3.3 Question: Is it really a BMP? 31‐Handwritten

984 Coram, Phil Technology‐Based Effluent Limitations 2.2.3.3 Comment: Feasibility could be addressed in IPM

plan. 31‐Handwritten

985 Coram, Phil Technology‐Based Effluent Limitations 2.2.4 Comment: FWC 31‐Handwritten
986 Coram, Phil Technology‐Based Effluent Limitations 2.2.5 Comment: FWC 31‐Handwritten

987 Coram, Phil Technology‐Based Effluent Limitations 2.2.5.2 Comment: Same training comments. 31‐Handwritten

988 Coram, Phil Technology‐Based Effluent Limitations 2.2.6.1 Comment: Do we do this already? Yes. 31‐Handwritten

989 Coram, Phil Technology‐Based Effluent Limitations 2.2.6.2 Question: "you must post, near a public access" ‐ 

Alternatives? 31‐Handwritten

990 Coram, Phil Technology‐Based Effluent Limitations 2.2.6.2 Comment: May already be required under FIFRA

label. 31‐Handwritten

991 Coram, Phil Technology‐Based Effluent Limitations 2.2.6.2 Comment: Do we already to do this?? Yes! 31‐Handwritten

992 Coram, Phil Technology‐Based Effluent Limitations 2.2.6.2.2 Question: "label human hazard warnings" ‐ (1)

More guidance; (2) Needed? 31‐Handwritten

993 Coram, Phil Technology‐Based Effluent Limitations 2.2.6.2 Question: What if public access not available? 31‐Handwritten

994 Coram, Phil Water Quality‐Based Effluent Limitations 3.0 Comment: Ref. to state numeric and narrative WQS

for pesticides. 31‐Handwritten

995 Coram, Phil Water Quality‐Based Effluent Limitations 3.0 Question: Revise Florida WQS to allow temp.

variations ‐ other options??? 31‐Handwritten

996 Coram, Phil Corrective Action 5.1 Comment: 5th bullet, "adverse incident" ‐ Define or

guidance 31‐Handwritten

997 Coram, Phil Corrective Action 5.3.1 Question: Should identify appropriate agencies

somewhere! w/contact info? 31‐Handwritten

998 Coram, Phil Corrective Action 5.3.2 Question: "other than adverse incidents" ‐ What are

these? Define or guidance, or ref. back to 5.1. 31‐Handwritten

999 Coram, Phil Integrated Pest Management (IPM) Plan 6.0

Comment: References the Note, "One plan to cover

several treatment areas?" ‐ For entire DACs and

FWC programs ‐ state wide or geographic area ‐ 

mosquito control districts

31‐Handwritten

1000 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.1.1 Question: "(by name or title)" ‐ Names or position

IDs? 31‐Handwritten

1001 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.1.1 Comment: Bullet (d) ‐ May not know when NOI

submitted 31‐Handwritten

1002 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.1.2 Comment: DACs and FWC 31‐Handwritten

1003 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.1.3 Comment: Bullet (c), "non‐toxic or less toxic" ‐ 

Define 31‐Handwritten

1004 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.1.3 Comment: DACs and FWC 31‐Handwritten

1005 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.1.4 Comment: DACs and FWC 31‐Handwritten

1006 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.2 Question: Why restricted to only these

waterbodies? 31‐Handwritten

1007 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.2.1 Comment: DACs and FWC 31‐Handwritten

1008 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.2.2 Comment: Bullet (d), "weed action threshold" ‐ 

Define 31‐Handwritten

1009 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.2.2 Comment: DACs and FWC 31‐Handwritten

1010 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.2.3 Comment: DACs and FWC 31‐Handwritten

1011 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.2.4 Comment: DACs and FWC 31‐Handwritten

1012 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.2.5 Comment: DACs and FWC 31‐Handwritten

1013 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.3.1 Comment: DACs and FWC 31‐Handwritten

1014 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.3.1 Comment: Spill reporting under CERCLA reference? 31‐Handwritten

1015 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.3.2 Comment: DACs and FWC 31‐Handwritten

1016 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.3.2 Comment: See previous comments on training. 31‐Handwritten

1017 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.3.3 Comment: DACs and FWC 31‐Handwritten

1018 Coram, Phil Integrated Pest Management (IPM) Plan 6.1.3.3 Comment: "adverse incident" ‐ Define 31‐Handwritten

1019 Coram, Phil Site Monitoring 8.0 Question: Different monitoring for different use

patterns? 31‐Handwritten

1020 Coram, Phil Site Monitoring 8.1 Comment: "application site" ‐ Define 31‐Handwritten

1021 Coram, Phil Site Monitoring 8.1.2 Comment: DACs and FWC 31‐Handwritten

1022 Coram, Phil Site Monitoring 8.1.2 Comment: Non‐aerial treatments, 2nd open bullet,

"immediately" ‐ Define 31‐Handwritten

1023 Coram, Phil Site Monitoring 8.1.2 Comment: Non‐aerial treatments, 5th open bullet,

"X water feet of flowing water" ‐ Wetland ‐ acres 31‐Handwritten

1024 Coram, Phil Site Monitoring 8.1.2 Question: Aerial treatments ‐ Practicable for

airplanes?

1025 Coram, Phil Site Monitoring 8.1.3 Comment: Maybe unrelated to application 31‐Handwritten

1026 Coram, Phil Site Monitoring 8.1.3 Comment: Last sentence ‐ Too vague! 31‐Handwritten

1027 Coram, Phil Site Monitoring 8.1.4 Comment: FDACs and FWC comments 31‐Handwritten

1028 Coram, Phil Site Monitoring 8.1.4 Comment: Move (5.3.1) (9.2) 31‐Handwritten

1029 Coram, Phil Site Monitoring 8.1.4

Question: Difference between adverse incident and

observable impact? Different reporting

requirements?

31‐Handwritten

1030 Coram, Phil Site Monitoring 8.2 Comment: Needed (could be covered by 8.3)? 31‐Handwritten

1031 Coram, Phil Site Monitoring 8.2.1 Comment: DACs and FWC 31‐Handwritten

1032 Coram, Phil Site Monitoring 8.3

Rewrite: Change title from "Additional EPA

Monitoring" to "Water Quality Chemical

Monitoring"

31‐Handwritten

1033 Coram, Phil Site Monitoring 8.3 Comment: Not typical in GPs. 31‐Handwritten

1034 Coram, Phil Site Monitoring 8.3 Question: How to do this? Letter? 3rd party notice?

Challenge opportunity for permittee or 3rd party? 31‐Handwritten

1035 Coram, Phil Site Monitoring 8.3 Comment: 2nd bullet, "pesticide of concern" ‐ 

Defined? Change these. 31‐Handwritten

1036 Coram, Phil Reporting 9.1 Comment: References title of 9.1 ‐ Relationship to

appendix B.12.D. 31‐Handwritten
1037 Coram, Phil Reporting 9.1 Question: Require permittees to enter

electronically? 31‐Handwritten

1038 Coram, Phil Reporting 9.1 Comment: "Jurisdictions" ‐ Define; geopolitical? 31‐Handwritten

1039 Coram, Phil Reporting 9.1 Comment: "near" ‐ Define 31‐Handwritten

1040 Coram, Phil Reporting 9.1 Comment: Last sentence ‐ Good idea. 31‐Handwritten

1041 Coram, Phil Reporting 9.2 Comment: Define "Adverse Incident" 31‐Handwritten

1042 Coram, Phil Reporting 9.2 Question: Difference with observable impact

reporting (8.1.3 ‐ 8.1.4)? 31‐Handwritten

1043 Coram, Phil Reporting 9.2 Comment: Also Appendix B.12.F require similar

reporting 31‐Handwritten

1044 Coram, Phil Reporting 9.2 Comment: DACs and FWC comments 31‐Handwritten

1045 Coram, Phil Reporting 9.2 Question: 1st paragraph, "within 14 days" ‐ of

application or knowledge of adverse incident? 31‐Handwritten

1046 Coram, Phil Reporting 9.2 Question: 6th bullet ‐ Needed? Or Active

ingredient? 31‐Handwritten

1047 Coram, Phil Recordkeeping 10.1 Comment: 5th bullet ‐ Not specific in 2.0 see from

comments on training. 31‐Handwritten

1048 Coram, Phil Recordkeeping 10.1 Question: 6th bullet (Pesticide Application Logs),

"pesticide applicator" ‐ What if not the NOI holder? 31‐Handwritten

1049 Coram, Phil Recordkeeping 10.1 Question: 6th bullet (Pesticide Application Logs),

"maintain" ‐ Where do you maintain logs? 31‐Handwritten

1050 Coram, Phil Recordkeeping 10.1 Question: 6th bullet (Pesticide Application Logs), 2.,

"application" ‐ Define. What this is? 31‐Handwritten

1051 Coram, Phil Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs),

4e, "product" ‐ Define 31‐Handwritten

1052 Coram, Phil Recordkeeping 10.1 Comment:6th bullet (Pesticide Application Logs),

(4i), "treatment area" ‐ Define 31‐Handwritten

1053 Coram, Phil Recordkeeping 10.1

Comment: 6th bullet (Pesticide Application Logs), 5 ‐

Time issue ‐ conditions change over course of

application

31‐Handwritten

1054 Coram, Phil Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs), 9 ‐

See previous comments 31‐Handwritten

1055 Coram, Phil Recordkeeping 10.1 Comment: 7th bullet (Pesticide Application

Equipment Maintenance) ‐ Truly needed? 31‐Handwritten

1056 Coram, Phil Recordkeeping 10.1

Question: 7th bullet (Pesticide Application

Equipment Maintenance), 1st paragraph, "pesticide

applicator" ‐ What if not the NOI holder?

31‐Handwritten

1057 Coram, Phil Recordkeeping 10.2 Comment: Last sentence, "of at least 3 years from

date" ‐ +5 years GP coverage = 8 years 31‐Handwritten

1058 Coram, Phil Appendix B ‐ Standard Permit Conditions (Reporting Requirements) B.12.D Question: Where is it specified? 31‐Handwritten

1059 Coram, Phil Appendix B ‐ Standard Permit Conditions (Reporting Requirements) B.12.D.1 Question: Other than annual reports what other

data are required to be submitted? 31‐Handwritten

1060 Coram, Phil Appendix B ‐ Standard Permit Conditions (Reporting Requirements) B.12.D.1

Question: Visual observations? Observable

impacts? Report findings? Enhance monitoring?

Additional EPA monitoring? Adverse incident

report? Application O&M lobs?

31‐Handwritten

1061 Coram, Phil Appendix B ‐ Standard Permit Conditions (Reporting Requirements) B.12.F.1

Question: 1st sentence, "endanger health or the

environment" ‐ Would not this be an adverse

incident?

31‐Handwritten

1062 Hays, Robert Coverage Under This Permit 1.1.1 Comment: 2nd bullet ‐ Full permit will expand to

include canals, streams, etc. 32‐Handwritten

1063 Hays, Robert Coverage Under This Permit 1.1.1 Comment: 3rd bullet ‐ Aquaculture 32‐Handwritten

1064 Hays, Robert Coverage Under This Permit 1.1.2.1 Comment: Wide scope 32‐Handwritten

1065 Hays, Robert Coverage Under This Permit 1.1.2.2 Comment: Emerging invasive species "milfoil" 32‐Handwritten

1066 Hays, Robert Coverage Under This Permit 1.1.2.3 Comment: "for discharges of equipment rinsate" ‐ 

flush application equip. ‐ 2EE application 32‐Handwritten

1067 Hays, Robert Coverage Under This Permit 1.1.2.4 Comment: 2nd bullet ‐ State temp. exempt for

standards 32‐Handwritten

1068 Hays, Robert Coverage Under This Permit 1.1.2.4 Comment: Applications submitted and returned 32‐Handwritten

1069 Hays, Robert Coverage Under This Permit 1.1.2.5 Comment: Protection requires some chemical use 32‐Handwritten

1070 Hays, Robert Coverage Under This Permit 1.2.2 Question: 1st sentence, "operators" ‐ 

Applicator/operator ‐ Which is it? 32‐Handwritten

1071 Hays, Robert Coverage Under This Permit 1.2.2 Question: 1st bullet ‐ Who has priority if both

qualify? 32‐Handwritten

1072 Hays, Robert Coverage Under This Permit 1.2.2 Question: "than X" ‐How many? 32‐Handwritten

1073 Hays, Robert Coverage Under This Permit 1.2.2 Comment: Annual average or Syn. Accumulation 32‐Handwritten

1074 Hays, Robert Coverage Under This Permit 1.2.2 Comment: Annual contract 5 yr. permit 32‐Handwritten

1075 Hays, Robert Coverage Under This Permit 1.2.2 Comment: May contractor operate under

responsible party NOI 32‐Handwritten

1076 Hays, Robert Coverage Under This Permit 1.2.2 Comment: Threshold variations 32‐Handwritten
1077 Hays, Robert Coverage Under This Permit 1.2.4 Comment: Superseded by update or addendum or

amendment 32‐Handwritten

1078 Hays, Robert Technology‐Based Effluent Limitations 2.0 Comment: 3rd sentence, "manufacturer's

specifications" ‐ "must" 32‐Handwritten

1079 Hays, Robert Technology‐Based Effluent Limitations 2.1.1.2 Comment: Resistance 32‐Handwritten

1080 Hays, Robert Technology‐Based Effluent Limitations 2.1.2 Comment: Last sentence in section ‐ Economics,

budget functions 32‐Handwritten

1081 Hays, Robert Technology‐Based Effluent Limitations 2.1.3.2 Comment: Wetlands sign 32‐Handwritten

1082 Hays, Robert Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Change "eliminate" to "minimize" 32‐Handwritten

1083 Hays, Robert Technology‐Based Effluent Limitations 2.1.4 Comment: Last sentence ‐ Econ Based Exclusion 32‐Handwritten

1084 Hays, Robert Technology‐Based Effluent Limitations 2.1.5.2 Comment: Can not use larvacide first on most

emerging problems 32‐Handwritten

1085 Hays, Robert Technology‐Based Effluent Limitations 2.2.1 Comment: Impact vs. Discharge (is an application) 32‐Handwritten

1086 Hays, Robert Technology‐Based Effluent Limitations 2.2.5.2 Comment: Over FIFRA 32‐Handwritten

1087 Hays, Robert Technology‐Based Effluent Limitations 2.2.6 Comment: CDC Input 32‐Handwritten

1088 Hays, Robert Technology‐Based Effluent Limitations 2.2.6.2 Comment: Notification over FIFRA 32‐Handwritten

1089 Hays, Robert Technology‐Based Effluent Limitations 2.2.6.2.2 Comment: "label human hazard warnings" ‐ ? 32‐Handwritten

1090 Hays, Robert Water Quality‐Based Effluent Limitations 3.0 Comment: "discharge" ‐ application 32‐Handwritten

1091 Hays, Robert Water Quality‐Based Effluent Limitations 3.0 Comment: 2nd paragraph, "applicable water quality

standards" ‐ "0" is still "0" 32‐Handwritten

1092 Hays, Robert Corrective Action 5.1 Question: "an unauthorized release or discharge"

To waters of US? 32‐Handwritten

1093 Hays, Robert Corrective Action 5.1 Comment: Appendix contacts for related contact

points: USGS, ArmyCorp of Engineers, USF&WS 32‐Handwritten

1094 Hays, Robert Integrated Pest Management (IPM) Plan 6.1.1.2 Comment: (1) Inclusive in district & will change; (2)

mosquitoes 32‐Handwritten

1095 Hays, Robert Integrated Pest Management (IPM) Plan 6.1.1.2 Comment: Bullet (f) ‐ District‐wide permit which

includes waters of the US 32‐Handwritten

1096 Hays, Robert Integrated Pest Management (IPM) Plan 6.1.1.3 Comment: Bullet (c) ‐ WOW 32‐Handwritten

1097 Hays, Robert Integrated Pest Management (IPM) Plan 6.1.2.5 Question: "procedures for posting" ‐ Is this the right

spot for this? Exceeds FIFRA requirements? 32‐Handwritten

1098 Hays, Robert Integrated Pest Management (IPM) Plan 6.3 Comment: Fumigation Plan ‐ FIFRA 32‐Handwritten

1099 Hays, Robert Site Monitoring 8.1 Comment: "each application site" ‐ each 32‐Handwritten

1100 Hays, Robert Site Monitoring 8.1 Comment: "any possible" ‐ observable 32‐Handwritten

1101 Hays, Robert Site Monitoring 8.1.1 Rewrite: In the last sentence before 8.1.2, insert the

word "aquatic" between "of" and "wildlife habitat" 32‐Handwritten

1102 Hays, Robert Site Monitoring 8.1.2 Comment: Responsible Party Applicator or

permittee 32‐Handwritten

1103 Hays, Robert Site Monitoring 8.1.2 Comment: Non‐aerial treatments, 2nd open bullet,

"immediately" ‐ Reasonable time 32‐Handwritten

1104 Hays, Robert Site Monitoring 8.1.3 Comment: Many causes 32‐Handwritten

1105 Hays, Robert Site Monitoring 8.3 Comment: Procedure when "at end of" season 32‐Handwritten

1106 Hays, Robert Reporting 9.1 Question: "operator" ‐ Permittee? 32‐Handwritten

1107 Hays, Robert Reporting 9.2

Comment: "a discharge from your pesticide

application" ‐ Application and discharge has been

used (interchanged) throughout document now we

have a combo. Recommended the use of the term

"application".

32‐Handwritten

1108 Hays, Robert Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs),

bullets 1‐4 ‐ Consistent with recordkeeping FIFRA 32‐Handwritten

1109 Hays, Robert Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs), 5 ‐

Site different from forecast site/station 32‐Handwritten

1110 Hays, Robert Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs), 7,

"discharge" ‐ Application 32‐Handwritten

1111 Hays, Robert Recordkeeping 10.1

Question: 7th bullet (Pesticide Application

Equipment Maintenance) ‐ Benefit? Outside scope

of permit.

32‐Handwritten

1112 Hays, Robert Recordkeeping 10.2 Comment: 8 yrs (permit + 3 yrs) 32‐Handwritten

1113 Hays, Robert Recordkeeping 10.2 Comment: Fumigation maintenance plan and

storage with permittee 32‐Handwritten

1114 Hays, Robert Recordkeeping 10.2 Comment: Similar to Fumigation management plans 32‐Handwritten

1115 Aydell, Gary General

Comment: Permit should simply refer to applicable

portions of FIFRA label (not portions which address

applicator safety)

33‐Handwritten
1116 Aydell, Gary General

Comment: (1) See factsheet for vessel general

permit ‐ it refers to other laws and regs including

FIFRA ‐‐ this is in respect to controlling invasive

species;  (2) See 40 CFR 125.3 ‐ case by case BAT

determination, cost is included, non‐WQ env.

impacts ‐ see other factors in (h); (3) State WQ

standards LAC 33:IX.1109.D ‐ provide for short‐term

activities that do not comply with water quality

standards ‐ includes mosquito abatement projects,

algae and weed control and fish eradication

projects

33‐Handwritten

1117 Aydell, Gary Coverage Under This Permit 1.1.1 Question: 2nd bullet ‐ What about rivers, canals,

etc? 33‐Handwritten

1118 Aydell, Gary Coverage Under This Permit 1.1.1 Question: What about fire outs, pine beetles? 33‐Handwritten

1119 Aydell, Gary Coverage Under This Permit 1.1.1.1

Comment: Water of the state (LA) includes all water

courses in the state, including private ditches and

ponds ‐ even applications on dry ground is subject

to discharge when it rains ‐ dust on veg. garden may

be discharged when it rains

33‐Handwritten

1120 Aydell, Gary Coverage Under This Permit 1.1.2.2

Comment: LA does not want to exempt outstanding

natural resource waters because may need to spray

for weed control, mosquito control, or invasive

species of fish

33‐Handwritten

1121 Aydell, Gary Coverage Under This Permit 1.1.2.2

Comment: Factsheet include a detailed description

of what FIFRA docs and what the "label"

means/does

33‐Handwritten

1122 Aydell, Gary Coverage Under This Permit 1.1.2.3 Question: "subsequent batch" ‐ What does this

mean? 33‐Handwritten

1123 Aydell, Gary Coverage Under This Permit 1.2.2

Comment: See Vessel general permit factsheet ‐ it

references other laws and regulations including

FIFRA ‐ suggest this factsheet do the same thing

33‐Handwritten

1124 Aydell, Gary Coverage Under This Permit 1.3.2

Comment: BAT determination includes cost and

does not include reference to risk. Risk is included

by WQ based limits

33‐Handwritten

1125 Aydell, Gary Technology‐Based Effluent Limitations 2.1.1.3 Comment: "over waters of the United States" ‐ 

Wetlands 33‐Handwritten

1126 Aydell, Gary Technology‐Based Effluent Limitations 2.1.1.3 Comment: Mosquito Control Authorities 33‐Handwritten

1127 Aydell, Gary Technology‐Based Effluent Limitations 2.1.5 Comment: "to control mosquitoes in waters of the

United States" ‐ Wetlands 33‐Handwritten

1128 Aydell, Gary Water Quality‐Based Effluent Limitations 3.0 Comment: State our risk assessment protocol 33‐Handwritten

1129 Aydell, Gary Reporting 9.1

Comment: Suggest the NOI submittal be linked to

the state registration of pesticide applicators and

thus annual reporting

33‐Handwritten

1130 Nigoff, Mindy Technology‐Based Effluent Limitations 2.1.2.1 Comment: F 34‐Handwritten

1131 Nigoff, Mindy Technology‐Based Effluent Limitations 2.1.2.2 Comment: MF 34‐Handwritten

1132 Nigoff, Mindy Technology‐Based Effluent Limitations 2.1.2.3 Comment: F 34‐Handwritten

1133 Nigoff, Mindy Technology‐Based Effluent Limitations 2.1.2.4 Comment: LMF 34‐Handwritten

1134 Nigoff, Mindy Technology‐Based Effluent Limitations 2.1.3.1 Comment: LMF 34‐Handwritten

1135 Nigoff, Mindy Technology‐Based Effluent Limitations 2.1.3.2 Comment: MF 34‐Handwritten

1136 Nigoff, Mindy Technology‐Based Effluent Limitations 2.1.3.3 Comment: F 34‐Handwritten

1137 Nigoff, Mindy Technology‐Based Effluent Limitations 2.1.3.4 Comment: F 34‐Handwritten

1138 Nigoff, Mindy Technology‐Based Effluent Limitations 2.1.3.5 Comment: LMF 34‐Handwritten

1139 Nigoff, Mindy Site Monitoring 8.1.2 Comment: Look at small subset instead of every

single application 34‐Handwritten

1140 Nigoff, Mindy Site Monitoring 8.3 Comment: More discussion under factsheet 34‐Handwritten

1141 Nigoff, Mindy Reporting 9.1 Comment: Factsheet ‐ difference between adverse

incident report and observable incident report 34‐Handwritten

1142 Nigoff, Mindy Reporting 9.1 Comment: Doesn't match up with standard 34‐Handwritten

1143 Nigoff, Mindy Reporting 9.1 Question: "Jurisdictions" ‐ Asked whether they need

this? 34‐Handwritten

1144 Bertrand, Charlotte Coverage Under This Permit 1.1.2.1 Question: How will this permit handle inerts? 35‐Handwritten

1145 Bertrand, Charlotte Coverage Under This Permit 1.1.2.1 Comment: Not clear how the applicator will know

what the degradates are. 35‐Handwritten

1146 Bertrand, Charlotte Coverage Under This Permit 1.2.2

Comment: "Operators Required to Submit" ‐ still

area for decisions ‐ not all requirements can be

met.

35‐Handwritten

1147 Bertrand, Charlotte Coverage Under This Permit 1.2.2

Comment: "X" and "Y" ‐ possible legal risk of being

arbitrary "X and Y" unless you can justify the cut off

with some type of analysis. For example, analyze

the # of NOIs that may be received under certain

cut‐offs and base the cut‐off on economics and

costs ‐ particularly to small entities.

35‐Handwritten

1148 Bertrand, Charlotte Coverage Under This Permit 1.2.3

Question: Footnote 1 to Table, "EPA may delay your

authorization" ‐ what are timeframes for this?

When can a NOI submitter expect to hear back?

35‐Handwritten
1149 Bertrand, Charlotte Coverage Under This Permit 1.2.4 Rewrite: Suggests changing "not be covered" to

"otherwise be covered" 35‐Handwritten

1150 Bertrand, Charlotte Coverage Under This Permit 1.2.4

Comment: Still concerned that the permit continues

to remain in effect through ALL adverse incidents

that may occur ‐ no matter how many times the

adverse event happens or how severe.  Would it be

possible to set some limitations on certain adverse

events?

35‐Handwritten

1151 Bertrand, Charlotte Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Suggest removing "eliminate or" 35‐Handwritten

1152 Bertrand, Charlotte Technology‐Based Effluent Limitations 2.1.5.2 Comment: Why is this a must, rather than "when

feasible" 35‐Handwritten

1153 Bertrand, Charlotte Technology‐Based Effluent Limitations 2.1.6

Comment: Perhaps limit this to publically managed

lands of a certain size of uses ‐ or make the larger

outreach efforts apply to public‐managed lands

such as parks...but for others have the applicator

provide a fact sheet to the landowner on 2.1.6.1  ‐ 

2.1.6.3 when contract is signed.

35‐Handwritten

1154 Bertrand, Charlotte Technology‐Based Effluent Limitations 2.2.6.2.1

Comment: Comment made 2x before ‐ why is this

different than 2.1.6.1 ‐ 2.1.6.3 (applies to 2.2.6.2.1 ‐ 

2.2.6.2.5)

35‐Handwritten

1155 Bertrand, Charlotte Integrated Pest Management Plan 6.1.1.4

Question: 1st sentence, "must" ‐ What if

surveillance was not feasible? Would an HOA do all

this?

35‐Handwritten

1156 Bertrand, Charlotte Site Monitoring 8.1.3 Comment: "You must note" ‐ this seems excessive 35‐Handwritten

1157 Bertrand, Charlotte Site Monitoring 8.1.3

Comment: 3rd bullet, "swimming abnormally" ‐ one

fish would require a notification? Assumption is that

the applicator is an ecological expert to know what

is abnormal.  When do these observations become

an adverse effect?

35‐Handwritten

1158 Bertrand, Charlotte Site Monitoring 8.1.4

Comment: 5th bullet, "state of decomposition of

dead organisms" ‐ I don't believe an applicator will

be able to provide credible or consistent

description.

35‐Handwritten

1159 Bertrand, Charlotte Site Monitoring 8.1.4 Comment: 6th bullet, "conditions" ‐ will fact sheet

elaborate on what "conditions" EPA is expecting? 35‐Handwritten

1160 Bertrand, Charlotte Site Monitoring 8.1.4 Comment: 8th bullet, "Estimated flow rate" ‐ how

would an applicator know this? 35‐Handwritten

1161 Bertrand, Charlotte Site Monitoring 8.1.4

Comment: 9th bullet, "weather conditions" ‐ when?

Those during the earlier application or when the

observation was made?

35‐Handwritten

1162 Bertrand, Charlotte Reporting 9.1

Comment: "annual report" ‐ what about limiting the

reporting to when applications are different that

the NOI? Were other timeframes considered? Every

two years, etc?

35‐Handwritten

1163 Bertrand, Charlotte Reporting 9.2 Question: What prevents someone from applying

30 days before end of year and then terminating? 35‐Handwritten

1164 Phillips, Todd Coverage Under This Permit 1.2.4 Rewrite: Under bullet (3) the word "not" should be

changed to "otherwise" 36‐Handwritten

1165 Phillips, Todd Technology‐Based Effluent Limitations 2.1.1.2 Comment: Must think about resistance issues 36‐Handwritten

1166 Phillips, Todd Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Change the word "eliminate" to

"minimize" 36‐Handwritten

1167 Meredith, Bill Technology‐Based Effluent Limitations 2.1.1 Comment: on NOTE ‐ GOOD! 37‐Handwritten

1168 Meredith, Bill Technology‐Based Effluent Limitations 2.1.1.1 Rewrite: 1st sentence ‐ Suggests inserting

"practicably" in between "extent" and "achievable" 37‐Handwritten

1169 Meredith, Bill Technology‐Based Effluent Limitations 2.1.1.1 Comment: "economically practicable and

achievable" ‐ GOOD! 37‐Handwritten

1170 Meredith, Bill Technology‐Based Effluent Limitations 2.1.1.2 Comment: concern over wording for resistance

issues. 37‐Handwritten

1171 Meredith, Bill Technology‐Based Effluent Limitations 2.1.1.2

Rewrite: Suggests adding at the end of the bullet,

"But which is doing must also consider still using

spray rates sufficient to prevent or reduce pesticide

resistance."

37‐Handwritten

1172 Meredith, Bill Technology‐Based Effluent Limitations 2.1.1.3 Comment: from language in PR‐1, 2005. 37‐Handwritten

1173 Meredith, Bill Technology‐Based Effluent Limitations 2.1.1.3 Comment: on NOTE ‐ yes! Incidental because its

unavoidable! 37‐Handwritten

1174 Meredith, Bill Technology‐Based Effluent Limitations 2.1.2

Comment: This could be met simply by what has

historically been done or used and to cite such

history.  You don't want to have to generate or

newly establish such at the start of each year.

37‐Handwritten

1175 Meredith, Bill Technology‐Based Effluent Limitations 2.1.3.1 Rewrite: Suggests inserting at the very beginning of

the statement, "Whenever practicable to do," 37‐Handwritten

1176 Meredith, Bill Technology‐Based Effluent Limitations 2.1.3.2 Rewrite: Suggests inserting "environmentally

compatible" after "Use" 37‐Handwritten
1177 Meredith, Bill Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Suggests inserting at the very beginning of

the statement, "Whenever practicable to do," 37‐Handwritten

1178 Meredith, Bill Technology‐Based Effluent Limitations 2.1.3.4 Rewrite: Suggests inserting at the very beginning of

the statement, "Whenever practicable to do," 37‐Handwritten

1179 Meredith, Bill Technology‐Based Effluent Limitations 2.1.3.5 Rewrite: Suggests inserting at the very beginning of

the statement, "Whenever practicable to do," 37‐Handwritten

1180 Meredith, Bill Technology‐Based Effluent Limitations 2.1.3.4

Comment: "growth regulators" and "bacteria" ‐ 

these are much more appropriately identified as

mosquito control pesticides, along with more

chemical products.

37‐Handwritten

1181 Meredith, Bill Technology‐Based Effluent Limitations 2.1.3.4 Rewrite: Suggests deleting "growth regulators (e.g.,

methoprene), and bacteria (e.g., Bti)" 37‐Handwritten

1182 Meredith, Bill Technology‐Based Effluent Limitations 2.1.4.3 Rewrite: Suggests adding "tidal flooding" 37‐Handwritten

1183 Meredith, Bill Technology‐Based Effluent Limitations 2.1.4.3 Rewrite: Suggests inserting "or hydrology" in

between "weather" and "station". 37‐Handwritten

1184 Meredith, Bill Technology‐Based Effluent Limitations 2.1.4.4

Rewrite: (1) Suggests inserting at the very beginning

of the statement, "Where practicable and

meaningful,"; (2) Suggests adding a comma after

"reports"; (3) Suggests replacing "an indicator of the

need" with "supplemental information of the need"

37‐Handwritten

1185 Meredith, Bill Technology‐Based Effluent Limitations 2.1.5.1

Rewrite: (1) Suggests adding "to the extent

practicable" in between "minimizing" and "the"; (2)

Suggests adding at the end of the bullet ", while still

maintaining pest control efficacy."

37‐Handwritten

1186 Meredith, Bill Technology‐Based Effluent Limitations 2.1.5.2

Rewrite: (1) Suggests adding to the very beginning

of the bullet "In most areas,"; (2) Suggests adding in

between "inadequate" and "document" the

following "or not the most practicable approach,";

(3) Suggests adding at the end of the bullet "or not

applicable"

37‐Handwritten

1187 Meredith, Bill Technology‐Based Effluent Limitations 2.1.5.4

Rewrite: Suggests adding at the end of the bullet ",

often demonstrated by certification or licensing

programs administered by states.

37‐Handwritten

1188 Meredith, Bill Technology‐Based Effluent Limitations 2.1.5.5 Comment: As also dictated by FIFRA 37‐Handwritten

1189 Meredith, Bill Technology‐Based Effluent Limitations 2.1.5.6 Comment: As also dictated by FIFRA 37‐Handwritten

1190 Meredith, Bill Technology‐Based Effluent Limitations 2.1.5.6 Rewrite: Suggests inserting "spray rates," after

"adulticide equipment," 37‐Handwritten

1191 Meredith, Bill Technology‐Based Effluent Limitations 2.1.6

Comment: (1) "treatment area" ‐ could be

statewide.; (2) Suggests inserting "press release"

after the colon, before "community newspaper".

37‐Handwritten

1192 Meredith, Bill Technology‐Based Effluent Limitations 2.2

Comment: Review section 2.2 to see what

comments in 2.1 for mosquito control would also

apply here ‐ several do.

37‐Handwritten

1193 Meredith, Bill Technology‐Based Effluent Limitations 2.2.6.2.2 Comment: Don't let this appear in public without

proper context. 37‐Handwritten

1194 Meredith, Bill Integrated Pest Management Plan 6.1 Comment: Costs? Will federal funds be available to

help MCDs write up their IPM plans? 37‐Handwritten

1195 Meredith, Bill Integrated Pest Management Plan 6.1 Comment: Plan length/detail? 2 pages? 200 pages?

Somewhere in between? 37‐Handwritten

1196 Meredith, Bill Integrated Pest Management Plan 6.1.1.2

Comment: Bullet (f) ‐ The entire state! for

adulticides ‐ for larvicides, everywhere except

center of fast flowing streams.

37‐Handwritten

1197 Meredith, Bill Integrated Pest Management Plan 6.1.1.4 Rewrite: Bullet (c) ‐ Suggests inserting "meaningful"

at the end of the bullet 37‐Handwritten

1198 Meredith, Bill Site Monitoring 8.0

Comment: a practicable, realistic approach ‐ only

when doing back checks for control efficacy ‐ will

then determine number of sites examined,

frequency and timing for non target impact

observations.

37‐Handwritten

1199 Meredith, Bill Site Monitoring 8.1 Comment: "each application site" ‐ how to define?

Big issue? 37‐Handwritten

1200 Meredith, Bill Site Monitoring 8.1 Rewrite: Suggests changing "possible" to

"observable" 37‐Handwritten

1201 Meredith, Bill Site Monitoring 8.1.2

Comment: Non‐aerial treatments, 2nd open bullet,

"immediately following treatment" ‐ what does this

mean? When ground fogging in evening?

37‐Handwritten

1202 Meredith, Bill Site Monitoring 8.1.2 Comment: Non‐aerial treatments, 3rd open bullet,

methoprene? 37‐Handwritten

1203 Meredith, Bill Site Monitoring 8.1.2 Comment: Aerial treatments, 2nd open bullet ‐ 

accessible how? $1500/hr for helicopter use. 37‐Handwritten

1204 Meredith, Bill Site Monitoring 8.1.3 Comment: 1st five bullets ‐ See a lot of this is

untreated areas due to NATURAL conditions. 37‐Handwritten
1205 Meredith, Bill Site Monitoring 8.2.1

Comment: As soon as a product is identified as

requiring "enhanced monitoring" applicators will

then seek to find and use alternate products.

37‐Handwritten

1206 Meredith, Bill Site Monitoring 8.3 Comment: 2nd bullet,  "Pesticide of concern" ‐ what

might these be? 37‐Handwritten

1207 Meredith, Bill Reporting 9.1

Comment: How to pay for any additional costs for

such new reporting? Will federal funds be available

to assist the regulated community?

37‐Handwritten

1208 Meredith, Bill Recordkeeping 10.1

Comment: 6th bullet (Pesticide Application Logs),

bullet (4h) ‐ need to be able to do this in a broad

geographic sense, can't be done on micro‐ or mini‐

scales, needs to be meso‐ or macro‐scale.

37‐Handwritten

1209 Meredith, Bill Recordkeeping 10.1

Comment: 6th bullet (Pesticide Application Logs),

bullet (5), "weather conditions at the time and site

of application" ‐ how much of this might actually be

needed?

37‐Handwritten

1210 Meredith, Bill Recordkeeping 10.1

Rewrite: 6th bullet (Pesticide Application Logs),

bullet (9) ‐ Suggests adding at the end of the bullet,

"or has failed."

37‐Handwritten

1211 Meredith, Bill Recordkeeping 10.1

Comment: 7th bullet (Pesticide Application

Maintenance Equipment) ‐ depending upon

equipment used, some of this might be done by the

MCDs, other by contractual applicators.

37‐Handwritten

1212 Eaton, Angus Coverage Under This Permit 1.1.1 Comment: Suggests adding "and pest" to 2nd filled

bullet 38‐Handwritten

1213 Eaton, Angus Coverage Under This Permit 1.1.1 Comment: add bullet point "use in aquaculture" 38‐Handwritten

1214 Eaton, Angus Coverage Under This Permit 1.1.1 Comment: cranberries 38‐Handwritten

1215 Eaton, Angus Coverage Under This Permit 1.1.2.3 Comment: FIFRA prohibits rinsate from being

discharged to waters. 38‐Handwritten

1216 Eaton, Angus Coverage Under This Permit 1.1.2.4 Comment: 3rd bullet, "terminated" ‐ allow where

intended to transfer. 38‐Handwritten

1217 Eaton, Angus Coverage Under This Permit 1.1.2.5

Comment: (1) Invasive species over running; (2) EPA

only condition; (3) FIFRA bulletins; (4) same as

construction permit

38‐Handwritten

1218 Eaton, Angus Coverage Under This Permit 1.1.2.6 Comment: EPA only condition 38‐Handwritten

1219 Eaton, Angus Coverage Under This Permit 1.2.2

Comment: Need to be able to choose "responsible

entity" to foster efficient administration.  If

applicators already make applications, report, etc,

maybe better to have applicators as "responsible

entity" ‐ can potentially have permit requirements

for applicators to receive certified IPM plan from

owners

38‐Handwritten

1220 Eaton, Angus Coverage Under This Permit 1.2.2 Comment: 1st bullet, "coverage under this permit" ‐ 

any one calendar year. 38‐Handwritten

1221 Eaton, Angus Coverage Under This Permit 1.2.3 Comment: Footnote 1 ‐ very difficult. 38‐Handwritten

1222 Eaton, Angus Technology‐Based Effluent Limitations 2.1

Comment: Consider and improvement where

feasible, cost effective, practicable ‐ justify if not

used?

38‐Handwritten

1223 Eaton, Angus Technology‐Based Effluent Limitations 2.1.3.1 Comment: Conflicts with state waters 38‐Handwritten

1224 Eaton, Angus Technology‐Based Effluent Limitations 2.1.3.2 Comment: echo Phil's concern about this language. 38‐Handwritten

1225 Eaton, Angus Technology‐Based Effluent Limitations 2.1.3.2

Comment: The NRC report on stormwater

recommends keeping more water on the land, not

draining more.

38‐Handwritten

1226 Eaton, Angus Technology‐Based Effluent Limitations 2.1.5.4 Comment: Certified, or working under direct

supervision of cert. Applicators 38‐Handwritten

1227 Eaton, Angus Technology‐Based Effluent Limitations 2.2 Comment: Nutrient reduction program. 38‐Handwritten

1228 Eaton, Angus Technology‐Based Effluent Limitations 2.2.2.3 Comment: to add to 303(d) listing? 38‐Handwritten

1229 Eaton, Angus Water Quality‐Based Effluent Limitations 3.0

Comment: Include following language "only after

done doing what supposed to do" (residual) except

for biological

38‐Handwritten

1230 Eaton, Angus Site Monitoring 8.1.1 Rewrite: Suggests adding before "wildlife habitat",

insert "aquatic." 38‐Handwritten

1231 Eaton, Angus Site Monitoring 8.1.3 Comment: Not necessary? 38‐Handwritten

1232 Eaton, Angus Site Monitoring 8.3 Comment: Individual Permits? 38‐Handwritten

1233 Eaton, Angus Site Monitoring 8.3 Comment: define "pesticide of concern" 38‐Handwritten

1234 Eaton, Angus Reporting 9.1 Comment: 1st filled bullet, "jurisdiction where

applied" ‐ include city, town village, etc. 38‐Handwritten

1235 Eaton, Angus Report 9.2 Comment: 6th bullet ‐ include active ingredients 38‐Handwritten

1236 Eaton, Angus Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs) ‐ 

FIFRA requirements 38‐Handwritten

1237 Eaton, Angus Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs),

bullet (3) ‐ GPS coordinates. 38‐Handwritten

1238 Eaton, Angus Recordkeeping 10.1

Comment: 6th bullet (Pesticide Application Logs),

bullet (4i), "total size of treatment area" ‐ area

pesticide applied

38‐Handwritten
1239 Eaton, Angus Appendix A ‐ Definitions and Acronyms Comment: define ag stormwater for pesticides 38‐Handwritten

1240 Eaton, Angus Appendix A ‐ Definitions and Acronyms Comment: Define "near water" 38‐Handwritten

1241 Eaton, Angus Appendix A ‐ Definitions and Acronyms Comment: Define "immediately" for visual

observation 38‐Handwritten

1242 Eaton, Angus Appendix A ‐ Definitions and Acronyms Comment: Define "adverse incident" 38‐Handwritten

1243 Eckermann, Chuck Coverage Under This Permit 1.1.1 Comment: 2nd bullet ‐ (all waters) 39‐Handwritten

1244 Eckermann, Chuck Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Change the word "eliminate" to

"minimize" 39‐Handwritten

1245 Krudner, Maureen NO COMMENTS IN THIS DOCUMENT 41‐Handwritten

1246 Denton, Debra Coverage Under This Permit 1.1.2.1 Question: What about a toxicity listing? 42‐Handwritten

1247 Denton, Debra Technology‐Based Effluent Limitations 2.1.1.2

Question: "lowest amount" ‐ Lower than the label?

How can the applicant know what can be used

lower than the amount on the label?

42‐Handwritten

1248 Denton, Debra Technology‐Based Effluent Limitations 2.1.3 Question: Last sentence, "feasible" ‐ How is this

defined? 42‐Handwritten

1249 Denton, Debra Water Quality‐Based Effluent Limitations 3.0 Rewrite: Delete words "as necessary" from the 1st

sentence. 42‐Handwritten

1250 Denton, Debra Water Quality‐Based Effluent Limitations 3.0

Comment: Need a list of these chemical WQS and

narrative WQS for the permittee in order to

determine compliance.

42‐Handwritten

1251 Denton, Debra Water Quality‐Based Effluent Limitations 3.0 Rewrite: Delete word "exceedance" and replace

with "excursion". 42‐Handwritten

1252 Denton, Debra Water Quality‐Based Effluent Limitations 3.0 Question: "Part XX" ‐ Where is this? 42‐Handwritten

1253 Denton, Debra Corrective Action 5.1

Comment: 2nd bullet, "meet applicable water

quality standards" ‐ Both chemical‐specific WQS

and narratives such as no toxics in toxic amounts

42‐Handwritten

1254 Denton, Debra Integrated Pest Management (IPM) Plan 6.1.1.2

Question: Bullet (e), "applicable water quality

standards" ‐ Where are these defined? Does the

applicant know what the WQS are for the

waterbody?

42‐Handwritten

1255 Denton, Debra Site Monitoring 8.1.1 Question: How are spot checks defined? 42‐Handwritten

1256 Denton, Debra Site Monitoring 8.1.2 Question: Non‐aerial treatments, 5th open bullet ‐ 

What is a treatment? 42‐Handwritten

1257 Denton, Debra Site Monitoring 8.2 Comment: See EPA R9 comments submitted on

9/21/09 42‐Handwritten

1258 Denton, Debra Reporting 9.1

Rewrite: Last paragraph, 1st sentence ‐ Delete the

word "strongly", and suggest either require or

recommend

42‐Handwritten

1259 Flournoy, Karen NO COMMENTS IN THIS DOCUMENT 44‐Handwritten

1260 Boornazian, Linda General Comment: CROMERR rule ‐ electronic. 45‐Handwritten

1261 Boornazian, Linda General Comment: More explicitly say no IPM if under

threshold. 45‐Handwritten

1262 Boornazian, Linda General Comment: IPM training 45‐Handwritten

1263 Boornazian, Linda General Comment: NOI ‐ have ICIS do it 45‐Handwritten

1264 Boornazian, Linda General Comment: Ponds 45‐Handwritten

1265 Boornazian, Linda General Comment: Acres rather than number of times they

apply. Acres that could be affected downstream. 45‐Handwritten

1266 Boornazian, Linda General Comment: Let states have flexibility on NOI

threshold. 45‐Handwritten

1267 Boornazian, Linda General Comment: Texas uses 4‐digit HUC 45‐Handwritten

1268 Boornazian, Linda General Comment: If waters get listed during permit term. 45‐Handwritten

1269 Boornazian, Linda Technology‐Based Effluent Limitations 2.0 Comment: Priority with money available 45‐Handwritten

1270 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.1

Comment: In Fact Sheet say minimize = label. There

may be unique situations where many years do we

need that much.

45‐Handwritten

1271 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.1.2 Comment: Resistance management 45‐Handwritten

1272 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.2.1 Comment: West Nile 45‐Handwritten

1273 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.3

Rewrite: Consider ‐ "If you are required to submit

an NOI, you must do to the extent practicable the

following prior to pesticide application:"

45‐Handwritten

1274 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.3 Comment: Lowest extent could cause resistance

issues. 45‐Handwritten

1275 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.3.1 Question: Is this for mosquito control to do or

rather promotion to public? 45‐Handwritten

1276 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.3.2 Comment: Environmentally compatible 45‐Handwritten

1277 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Change "eliminate" to "minimize" 45‐Handwritten

1278 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.4 Comment: Small municipalities ‐ what to do 45‐Handwritten

1279 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.4 Comment: CDC surveillance money may dry up 45‐Handwritten

1280 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.4.4 Comment: (1) if meaningful; (2) where practicable;

(3) as supplemental 45‐Handwritten

1281 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.5.2 Comment: Unless not most practical 45‐Handwritten

1282 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.5.4

Comment: (1) certified; (2) direct supervision; (3)

what is adequate; (4) web certification; (5) In MN

label may be sufficient

45‐Handwritten

1283 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.5.4 Question: Who would run this if not

licensed/registered (municipality)? 45‐Handwritten

1284 Boornazian, Linda Technology‐Based Effluent Limitations 2.1.6 Comment: (1) maybe not for small; (2) sign 45‐Handwritten
1285 Boornazian, Linda Technology‐Based Effluent Limitations 2.2.2 Comment: (1) Invasive; (2) first time 45‐Handwritten

1286 Boornazian, Linda Technology‐Based Effluent Limitations 2.2.2.3 Question: What is a follow up? 45‐Handwritten

1287 Boornazian, Linda Technology‐Based Effluent Limitations 2.2.3 Comment: Website has document, 1000 pages,

refer to that instead. 45‐Handwritten

1288 Boornazian, Linda Technology‐Based Effluent Limitations 2.2.3.1 Comment: (1) Good; (2) environmentally

compatible 45‐Handwritten

1289 Boornazian, Linda Technology‐Based Effluent Limitations 2.2.3.2 Comment: (1) take out; (2) one‐third of 10,000 fish

killed 45‐Handwritten

1290 Boornazian, Linda Technology‐Based Effluent Limitations 2.2.5.1 Comment: reporting threshold 45‐Handwritten

1291 Boornazian, Linda Technology‐Based Effluent Limitations 2.2.6.2.2 Comment: Delete? Concentration not necessary 45‐Handwritten

1292 Boornazian, Linda Water Quality‐Based Effluent Limitations 3.0 Comment: Mixing zone 45‐Handwritten

1293 Boornazian, Linda Water Quality‐Based Effluent Limitations 3.0

Rewrite: Suggestion is parenthetical text in

following ‐ "Your discharge (e.g., residual after done

doing job) must be controlled..."

45‐Handwritten

1294 Boornazian, Linda Water Quality‐Based Effluent Limitations 3.0 Comment: 2nd paragraph ‐ Or more product

control can occur 45‐Handwritten

1295 Boornazian, Linda Water Quality‐Based Effluent Limitations 3.0 Comment: 3rd paragraph ‐ Who submits NOI ‐ 

mechanical; calibrate (reference) 45‐Handwritten

1296 Boornazian, Linda Water Quality‐Based Effluent Limitations 3.0 Comment: 3rd paragraph ‐ Lethal, chronic 45‐Handwritten

1297 Boornazian, Linda Integrated Pest Management (IPM) Plan 6.0 Comment: AMCA (IPM plan) ‐ Tier it (based on

program type?); Weed control plan 45‐Handwritten

1298 Boornazian, Linda Integrated Pest Management (IPM) Plan 6.1 Comment: Or state where they are found; on web,

if possible 45‐Handwritten

1299 Boornazian, Linda Integrated Pest Management (IPM) Plan 6.3 Comment: (1) small; (2) WOUS 45‐Handwritten

1300 Boornazian, Linda Site Monitoring 8.1.2 Comment: (1) when checking for efficiency; (2)

1x/Quarter, 1/2‐day each; (3) per acre for wetlands 45‐Handwritten

1301 Boornazian, Linda Site Monitoring 8.1.2 Comment: Suggestion for guidance on how to

sample 45‐Handwritten

1302 Boornazian, Linda Site Monitoring 8.1.3 Comment: (1) "unanticipated"; (2) "where

practicable" 45‐Handwritten

1303 Boornazian, Linda Site Monitoring 8.1.4 Comment: When checking for efficacy check for

effects except in salt marsh since conditions change 45‐Handwritten

1304 Boornazian, Linda Site Monitoring 8.2 Comment: NY, DE, FL didn't like 45‐Handwritten

1305 Boornazian, Linda Site Monitoring 8.2.3 Comment: Monitoring for effluent limits 45‐Handwritten

1306 Boornazian, Linda Site Monitoring 8.3 Comment: "308" 45‐Handwritten

1307 Boornazian, Linda Reporting 9.0 Comment: Discharge = residual 45‐Handwritten

1308 Boornazian, Linda Reporting 9.1

Rewrite: Suggestion is "electronically" in following ‐ 

"...you must submit an annual report to EPA

electronically that includes the following

information:"

45‐Handwritten

1309 Boornazian, Linda Reporting 9.1 Rewrite: 1st bullet ‐ Suggests changing "Operator

name" to "Permittee" 45‐Handwritten

1310 Boornazian, Linda Reporting 9.1 Comment: (1) watersheds; (2) Mosquito control

rather than over/near 45‐Handwritten

1311 Boornazian, Linda Reporting 9.1 Comment: 1st filled bullet ‐ "Jurisdictions" is circled

and "county" is written in margin 45‐Handwritten

1312 Boornazian, Linda Reporting 9.1 Comment: Include notify and pesticide agencies in

state 45‐Handwritten

1313 Boornazian, Linda Reporting 9.2 Question: If licensed do we want to duplicate

reporting? 45‐Handwritten

1314 Boornazian, Linda Reporting 9.2 Rewrite: 2nd sentence ‐ Suggests changing

"written" (report) to "electronic" 45‐Handwritten

1315 Boornazian, Linda Recordkeeping 10.1 Comment: 6th filled bullet (Pesticide Application

Logs) ‐ NOI needs to say where logs are maintained 45‐Handwritten

1316 Boornazian, Linda Recordkeeping 10.1 Comment: 6th filled bullet (Pesticide Application

Logs), bullet (4) ‐ Logs on aquatic weeks already 45‐Handwritten

1317 Boornazian, Linda Recordkeeping 10.1

Comment: 6th filled bullet (Pesticide Application

Logs), bullet (4h) ‐ (1) Restricted recordkeeping ‐ go

with; (2) Names of waters ‐ may not have them,

GPS logs where

45‐Handwritten

1318 Boornazian, Linda Recordkeeping 10.1

Rewrite: 6th filled bullet (Pesticide Application

Logs), bullet (4i) ‐ Suggested adding "applied" at the

end of the bullet

45‐Handwritten

1319 Boornazian, Linda Recordkeeping 10.1 Comment: 6th filled bullet (Pesticide Application

Logs), bullet (5) ‐ Relevant 45‐Handwritten

1320 Boornazian, Linda Recordkeeping 10.1

Rewrite: 6th filled bullet (Pesticide Application

Logs), bullet (5) in bracketed statement, suggestion

is "at site or" text ‐ "clarify in the fact sheet, "at site

or" using the nearest..."

45‐Handwritten

1321 Boornazian, Linda Recordkeeping 10.1

Comment: 6th filled bullet (Pesticide Application

Logs), bullet (5) ‐ (1) wind speed‐beginning?; (2)

define target

45‐Handwritten

1322 Boornazian, Linda Recordkeeping 10.1 Comment: 6th filled bullet (Pesticide Application

Logs), bullet (6) ‐ Inspect before, monitor routinely 45‐Handwritten
1323 Boornazian, Linda Recordkeeping 10.1 Comment: 6th filled bullet (Pesticide Application

Logs), bullet (7) ‐ browning of leaves 45‐Handwritten

1324 Boornazian, Linda Recordkeeping 10.1

Rewrite: 6th filled bullet (Pesticide Application

Logs), bullet (9) ‐ Suggested adding "or has failed" at

the end of the bullet

45‐Handwritten

1325 Boornazian, Linda Recordkeeping 10.1

Comment: 7th filled bullet (Pesticide Application

Equipment Maintenance) ‐ (1) How long do you

keep logs‐will cost to automate or a lot of paper; (2)

equipment maintenance; (3) CBI‐Florida

45‐Handwritten

1326 Boornazian, Linda Appendix B ‐ Standard Permit Conditions (Reporting Requirements) B.12 Comment: B.12.F ‐ electronic 45‐Handwritten

1327 McIntosh, Maureen NO COMMENTS IN THIS DOCUMENT 46‐Handwritten

1328 Chan, Jennifer Coverage Under This Permit 1.2.4 Rewrite: Under bullet (3) the word "not" should be

changed to "otherwise" 68‐Handwritten

1329 Chan, Jennifer Technology‐Based Effluent Limitations 2.0 Comment: + Part 6 68‐Handwritten

1330 Chan, Jennifer Technology‐Based Effluent Limitations 2.1.3.3 Rewrite: Remove the word "eliminate" 68‐Handwritten

1331 Chan, Jennifer Technology‐Based Effluent Limitations 2.1.3.4 Rewrite: Remove "growth regulators (e.g.,

methoprene), and bacteria (e.g., Bti)" 68‐Handwritten

1332 Chan, Jennifer Technology‐Based Effluent Limitations 2.2.5.2 Comment: Note ‐ using FIFRA training requirement

is sufficient 68‐Handwritten

1333 Chan, Jennifer Technology‐Based Effluent Limitations 2.2.6.2 Comment: Delete section ‐ require by label, not

very effective 68‐Handwritten

1334 Chan, Jennifer Site Monitoring 8.1.1 Rewrite: In the last sentence before 8.1.2, insert the

word "aquatic" between "of" and "wildlife habitat" 68‐Handwritten

1335 Chan, Jennifer Site Monitoring 8.1.2 Comment: Non‐aerial treatment, 5th open bullet ‐ 

No flow in wetland. 68‐Handwritten

1336 Chan, Jennifer Site Monitoring 8.1.4 Question: 3rd bullet ‐ Does this belong here? 68‐Handwritten

1337 Chan, Jennifer Reporting 9.1 Question: 1st open bullet, "and associated EPA

registration" ‐ Do we need this? 68‐Handwritten

1338 Chan, Jennifer Reporting 9.1 Comment: 1st filled bullet, "Jurisdictions" ‐ County 68‐Handwritten

1339 Chan, Jennifer Recordkeeping 10.1 Comment: 6th bullet (Pesticide Application Logs),

Bullet 8 ‐ Also for herbicide 68‐Handwritten