ECONOMIC ANALYSIS OF THE PESTICIDE GENERAL PERMIT (PGP)

FOR POINT SOURCE DISCHARGES FROM THE APPLICATION OF 

PESTICIDES

May 26, 2010 

United States Environmental Protection Agency 

Office of Wastewater Management 

1200 Pennsylvania Avenue N.W. 

Washington, D.C. 20460 
i May 2010 

Table of Contents 

EXECUTIVE SUMMARY .............................................................................................. V

1. INTRODUCTION......................................................................................................1

1.1. Background..................................................................................................................... 1

1.2. States, Territories, and Federal Facilities to be Covered ................................................ 2

1.3. Organization of the Analysis .......................................................................................... 2

2. OVERVIEW OF PESTICIDES GENERAL PERMIT..........................................4

2.1. Technology-Based Effluent Limitations......................................................................... 4

2.1.1. Minimize Pesticide Discharges to Waters of the United States................................ 4

2.1.2. Integrated Pest Management (IPM) Practices........................................................... 4

2.1.2.1 Mosquito and Other Flying Insect Pest Control ................................................ 4

2.1.2.2 Aquatic Weed and Algae Control...................................................................... 5

2.1.2.3 Aquatic Nuisance Animal Control .................................................................... 6

2.1.2.4 Forest Canopy Pest Control............................................................................... 7

2.2. Administrative Requirements ......................................................................................... 7

2.2.1. Notice of Intent ......................................................................................................... 8

2.2.2. Pesticide Discharge Management Plan..................................................................... 8

2.2.3. Annual Reporting...................................................................................................... 8

2.2.4. Recordkeeping .......................................................................................................... 8

2.2.5. Site Monitoring ......................................................................................................... 9

2.2.6. Summary................................................................................................................... 9

3. IDENTIFICATION OF LIKELY AFFECTED ENTITIES................................10

3.1. Mosquito and Other Flying Insect Pest Control ........................................................... 10

3.2. Aquatic Weed and Algae Control................................................................................. 14

3.2.1. Public Entities ......................................................................................................... 14

3.2.2. Private Entities........................................................................................................ 16

3.2.3. Summary................................................................................................................. 18

3.3. Aquatic Nuisance Animal Control................................................................................ 19

3.4. Forest Canopy Pest Control .......................................................................................... 22

3.5. Summary....................................................................................................................... 24

4. OVERLAP WITH EXISTING REQUIREMENTS .............................................25

4.1. Mosquito and Other Flying Insect Pest Control ........................................................... 25

4.2. Aquatic Weed and Algae Control................................................................................. 27

4.3. Aquatic Nuisance Animal Control................................................................................ 29

4.4. Forest Canopy Pest Control .......................................................................................... 30

5. ANALYSIS OF COSTS...........................................................................................31

5.1. Technology-Based Effluent Limitations....................................................................... 31

5.1.1. Minimizing Pesticide Discharges into Waters of the United States ....................... 31

5.1.2. Integrated Pest Management Practices ................................................................... 32

5.1.2.1 Mosquito and Other Flying Insect Pest Control .............................................. 32

5.1.2.2 Aquatic Weed and Algae Control.................................................................... 40

5.1.2.3 Aquatic Nuisance Animal Control .................................................................. 47
ii May 2010 

5.1.2.4 Forest Canopy Pest Control............................................................................. 50

5.1.3. Summary of Technology-Based Effluent Limitation Costs.................................... 53

5.2. Administrative and Monitoring .................................................................................... 54

5.2.1. Notice of Intent ....................................................................................................... 55

5.2.2. Pesticide Discharge Management Plan................................................................... 55

5.2.3. Recordkeeping ........................................................................................................ 56

5.2.4. Reporting................................................................................................................. 57

5.2.5. Site Monitoring ....................................................................................................... 57

5.2.6. Total Annual Costs ................................................................................................. 57

5.3. Summary of Costs......................................................................................................... 60

6. SMALL ENTITY ANALYSIS................................................................................65

6.1. Identification of Small Entities..................................................................................... 65

6.2. Evaluating Potential Economic Impact......................................................................... 66

6.3. Summary....................................................................................................................... 69

7. QUALITATIVE DISCUSSION OF BENEFITS ..................................................70

7.1. Potential for Reduced Loadings.................................................................................... 70

7.2. Potential Adverse Effects Associated with Pesticides.................................................. 70

7.3. Environmental Benefits ................................................................................................ 72

7.3.1. Ecological Benefits ................................................................................................. 72

7.3.2. Ecological Benefit Values....................................................................................... 73

REFERENCES ................................................................................................................74

APPENDIX A...................................................................................................................80
iii May 2010 

List of Tables and Figures 

Table 1-1: NPDES Unauthorized States, Territories, and Federal Facilities (2009)...................... 2

Table 2-1: Annual Treatment Area Thresholds .............................................................................. 8

Table 2-2: Administrative and Monitoring Requirements for Affected Entities............................ 9

Table 3-1: Potentially Affected Entities: Mosquito and Other Flying Insect Pest Control .......... 13

Table 3-2: Entities Exceeding Annual Treatment Area Thresholds: Mosquito and Other Flying 

Insect Pest Control ............................................................................................................ 14

Table 3-3: Estimated Number of Public Drinking Water Utilities with Surface Water Intakes... 16

Table 3-5: Estimated Number of Industrial Facilities with Surface Water Intakes...................... 17

Table 3-6: Potentially Affected Entities: Aquatic Weed and Algae Control................................ 18

Table 3-7: Entities Exceeding Annual Treatment Area Thresholds: Aquatic Weed and Algae 

Control .............................................................................................................................. 19

Table 3-8: Estimated Number of Potentially Affected Entities with Surface Water Intakes ....... 20

Table 3-9: Potential Number of Affected Entities: Aquatic Nuisance Animal Control ............... 21

Table 3-10: Entities Exceeding Annual Treatment Area Thresholds: Aquatic Nuisance Animal 

Control .............................................................................................................................. 21

Table 3-11: Potentially Affected Entities: Forest Canopy Pest Control....................................... 23

Table 3-12: Entities Exceeding Annual Treatment Area Thresholds, Forest Canopy Pest Control

........................................................................................................................................... 23

Table 3-13: Summary of Potentially Affected Entities1 ............................................................... 24

Table 4-1: Current Implementation of Best Management Practices for Mosquito and Other 

Flying Insect Pest Control................................................................................................. 27

Table 4-2: Current Implementation of Best Management Practices in Non-Drinking Water 

Entities: Aquatic Weed and Algae Control....................................................................... 28

Table 5-1: Massachusetts Mosquito Control District Expenditures ............................................. 33

Table 5-2: Estimated Incremental Costs to Regional/District Entities: Identifying the Problem, 

Mosquito and Other Flying Insect Pest Control ............................................................... 36

Table 5-3: Estimated Incremental Costs to Municipal Entities: Identifying the Problem, Mosquito 

and Other Flying Insect Pest Control................................................................................ 36

Table 5-4: Estimated Incremental Costs: Pest Management, Mosquito and Other Flying Insect 

Pest Control ($/yr)............................................................................................................. 39

Table 5-5: Potential Costs: Identifying the Problem, Aquatic Weed Control .............................. 42

Table 5-6: Potential Affected Acres and Feasible Costs: Pest Management, Aquatic Weed and 

Algae Control1 .................................................................................................................. 45

Table 5-7: Potential Costs: Pesticide Use, Aquatic Weed and Algae Control.............................. 47

Table 5-8: Summary of Estimated Unit Costs .............................................................................. 53

Table 5-9: Summary of Estimated Annual Technology-based Effluent Limitation Costs ($/yr). 54

Table 5-10: Estimated Labor Cost ($/hour).................................................................................. 55

Table 5-11: Potential Costs for NOI Submittal............................................................................. 55

Table 5-12: Potential Level of Effort to Prepare PDMP............................................................... 56

Table 5-13: Potential Cost to Produce PDMP .............................................................................. 56

Table 5-14: Potential Recordkeeping Costs.................................................................................. 57

Table 5-15: Potential Reporting Cost ........................................................................................... 57

Table 5-16: Potential Site Monitoring Cost.................................................................................. 57
iv May 2010 

Table 5-17: Summary of Potential Annual Administrative and Monitoring Costs by Component

........................................................................................................................................... 58

Table 5-18: Administrative and Monitoring Costs ($/yr)............................................................. 59

Table 5-19: Summary of Potential Annual Administrative and Monitoring Costs ($/yr) ............ 60

Table 5-20: Total Estimated Costs For Entities Above and Below Treatment Thresholds ($/yr)1

........................................................................................................................................... 61

Table 5-21: Summary of Total Estimated Costs ($/yr)1 ............................................................... 61

Table 5-22: Key Uncertainties of the Analysis............................................................................. 62

Table 5-23: Potential Average Entity Costs for Mosquito and Other Flying Insect Pest Control1

........................................................................................................................................... 63

Table 5-24: Potential Average Entity Costs for Aquatic Weed and Algae Control1.................... 63

Table 5-25: Potential Average Entity Costs for Aquatic Nuisance Animal Control1................... 63

Table 5-26: Potential Average Entity Costs for Forest Canopy Pest Control1 ............................. 64

Table 6-1: Average Compliance Costs for Entities Exceeding Annual Treatment Area Thresholds 

and Potential Revenue Threshold Values for Characterizing Impacts to Small 

Governments..................................................................................................................... 67

Table 6-2: Average Compliance Costs for Entities that do not Exceed Annual Treatment Area 

Thresholds and Potential Revenue Threshold Values for Characterizing Impacts to Small 

Governments..................................................................................................................... 67

Table 6-3: Municipality and County Revenues based on Average Per Capita Revenues1........... 68

Table 7-1: Potential Toxic Effects of Pesticides........................................................................... 71

Table 7-2: Types of Benefits Associated With Environmental Policies: Ecological Improvements

........................................................................................................................................... 72

Figure 1: Map of Massachusetts Mosquito Control Projects, 2009.............................................. 11 
v May 2010 

Executive Summary 

This report presents an evaluation of the potential costs and benefits associated with 

implementing the requirements of the draft National Pollutant Discharge Elimination System 

(NPDES) Pesticide General Permit (PGP) for the application of pesticides resulting in discharges 

to waters of the United States. 

Note that the administrative and monitoring costs presented herein likely are much less than if 

individual permits were issued to each of the approximately 35,000 operators in the areas for 

which EPA is developing this general permit. 

ES.1 Introduction 

On November 27, 2006, the U.S. Environmental Protection Agency (EPA) issued a final 

regulation to codify its interpretation of the Clean Water Act (CWA) as not requiring NPDES 

permits for application of pesticides to and over, including near, waters of the United States if the 

application is consistent with Federal Insecticide, Fungicide and Rodenticide Act requirements. 

After the rule was published, petitions for review were filed in eleven Circuit Courts. These 

petitions were consolidated in the Sixth Circuit Court of Appeals. On January 7, 2009, the Sixth 

Circuit Court ruled in National Cotton Council, et al. v. EPA to vacate the CWA Pesticides Rule. 

On April 9, 2009 the Department of Justice filed a motion to stay issuance of the Court’s 

mandate for two years. In addition, industry petitioners filed a motion to seek a rehearing of the 

court’s decision. 

However, in August 2009, the Sixth Circuit Court denied rehearing the case, and on February 22, 

2010, the Supreme Court denied hearing the case. Thus, EPA and states authorized to issue 

NPDES permits are required to issue permits to point source dischargers for pesticide 

applications that result in a direct discharge of pesticides to waters of the United States. The 

proposed PGP addresses this requirement for states, federal facilities, tribal lands, and territories 

where EPA has NPDES permitting authority for pesticide discharges (also referred to as the 

unauthorized areas). 

The draft PGP is applicable to discharges to waters of the United States from the application of 

biological pesticides and chemical pesticides that leave a residue. The following pesticide use 

patterns are covered under the PGP: 

• Mosquito and Other Flying Insect Pest Control

• Aquatic Weed and Algae Control

• Aquatic Nuisance Animal Control

• Forest Canopy Pest Control

The draft PGP includes requirements associated with technology-based effluent limitations, and 

administrative and monitoring activities. The technology-based effluent limitations require all 

entities to implement control measures to minimize the discharge resulting from application of 

pesticides and certain entities to implement Integrated Pest Management (IPM) practices related 

to problem identification, pest management, and pesticide use. Administrative requirements 

include submitting a Notice of Intent (NOI) to be covered under the permit, conducting site 

monitoring, developing and implementing a pesticide discharge management plan (PDMP), 

preparing annual reports, and recordkeeping. The applicability of the different permit 
vi May 2010 

requirements depends on the extent of pesticide applications (annual treatment area thresholds, in 

acres or linear miles treated, which vary by use patterns). 

ES.2 Potentially Affected Entities 

The types of entities that may be affected by the draft PGP vary by use pattern but may include 

federal and tribal governments; state and local governments (including territories); utilities; 

operators of irrigated farms; and forest owners and other private entities. These entities may 

perform pesticide activities themselves or contract out pesticide activities to commercial pest 

control operators. In all instances of contract activity, EPA assumes that the responsibilities and 

costs are ultimately borne by the hiring entity, and thus reports the activity at the hiring entity 

level. Data are not available for all areas and use patterns. Therefore, in a number of instances, 

EPA developed estimates based on existing information (e.g., internet sources suggesting that 

certain units of government may be involved in the different use patterns) or to provide 

conservatively high estimates of entities that may be affected (e.g., assuming that all irrigated 

farms in unauthorized areas apply pesticides to irrigation ditches). More accurate information on 

the number of entities that would be subject to the draft PGP may substantially affect the cost 

analyses. 

Table ES-1 shows the estimates of potentially affected entities by unauthorized area and use 

pattern. Over 90% (approximately 31,600) of these entities are operators of irrigated farms, who 

fall under the aquatic weed and algae control use pattern. However, there is uncertainty 

regarding whether all of these entities will be affected by the draft PGP. Moreover, EPA does 

not expect affected pesticide applications on irrigated farms will exceed the 20 linear miles 

annual treatment area threshold established in the draft PGP for the aquatic weed and algae 

control use pattern. The annual treatment area thresholds (Table 2-1) determine the applicability 

of the different permit requirements. 

Table ES-1: Summary of Potentially Affected Entities 

Area 

Mosquito and 

Other Flying 

Insect Pest 

Control 

Aquatic Weed 

and Algae 

Control 

Aquatic 

Nuisance 

Animal Control

Forest 

Canopy 

Pest Control 

Total 

Alaska 2 325 15 18 360

Idaho 23 16,313 11 48 16,395

Massachusetts 9 2,140 26 214 2,389

New Hampshire 44 632 10 85 771

New Mexico 13 10,244 8 26 10,291

Oklahoma 1 3,811 74 159 4,045

District of Columbia 1 8 2 0 11

Territories 1 289 35 10 335

Tribes 17 89 24 50 180

Federal Facilities 10 10 10 29 59

Total 121 33,861 215 639 34,836

ES.3 Potential Costs 

Potentially affected entities may incur costs associated with the technology-based effluent 

limitations and the administrative and monitoring requirements of the draft PGP. The draft PGP 

will only result in incremental costs associated with the technology-based effluent limitation 
vii May 2010 

provisions in instances where the requirements represent activities are not already being 

implemented by affected entities. EPA used existing information provided by representatives 

from a number of the unauthorized areas to estimate the extent of current compliance with 

components of the draft PGP. In instances where information was not available, EPA generally 

assumes that entities are not currently implementing the required activities and would therefore 

incur incremental costs to comply with the PGP. 

Technology-Based Effluent Limitations 

The technology-based effluent limitations of the draft PGP requires that entities who are required 

to submit an NOI (those who will exceed annual treatment area thresholds) implement IPM 

practices that may or may not result in incremental costs for affected entities; entities below the 

annual treatment area thresholds will only be subject to the administrative and monitoring 

requirements. Entities subject to technology-based effluent limitations that are not currently in 

compliance with the requirements may incur incremental costs that depend on the extent of 

pesticide applications (e.g., number of acres or linear miles treated) and the feasibility of 

alternatives to pesticide use. Some information on the potential unit costs of required activities is 

available from the unauthorized states and other sources (e.g., entities performing pesticide 

applications in the unauthorized states). However, because the feasibility and cost of alternatives 

to pesticide use will be highly site and entity-specific, EPA could only develop illustrative 

estimates based on potential incremental unit costs for some draft PGP components. For this 

reason, actual costs incurred may vary substantially. 

Two components of the requirements for the mosquito and other flying insect pest control use 

pattern may result in incremental costs: identifying the problem (including target species and 

densities and breeding sites) and pest management. Under the aquatic weed and algae control 

use pattern, costs may be associated with requirements for identifying the problem, pest 

management, and pesticide use. Technology-based effluent limitations for aquatic nuisance 

animal control and forest canopy pest control are not likely to be associated with incremental 

costs. Table ES-2 provides a summary of the potential annual incremental costs associated with 

the different practices (unit costs for various draft PGP requirements). For mosquito and other 

flying insect pest control, the potential unit costs provided are midpoints for ranges of potential 

costs. That is, for identifying the problem, small operators (most likely small municipalities) 

costs are expected to fall within the range of $15,000-$24,000 for all related activities. For 

larger operators (e.g. multi-county mosquito abatement districts), costs associated with 

identifying the problem are expected to be $15,000-$369,000. The range of costs for pest 

management activities range from $7,000-$389,000 per entity. Given that many of the entities 

under this use pattern are likely to be relatively small, EPA believes that most will incur costs 

more towards the lower end of the range of potential costs. However, to be conservative (i.e., 

erring on the side of greater impacts) the midpoint estimate will be used to reflect potential unit 

costs in this analysis. 
viii May 2010 

Table ES-2: Summary of Estimated Unit Costs for Technology-based Effluent Limitations ($/yr) 

Requirement Potential Unit Cost Description and Source 

Mosquito and Other Flying Insect Pest Control

Identify the problem: 

Species/target densities 

 

Mapping breeding sites 

Municipality-level costs 

$99,000/entity 

$112,000/entity 

$20,000/entity 

Midpoint of surveillance expenditures in mosquito 

control districts in MA (MADEP, 2009; MDAR, 2008) 

Midpoint of expenditures in mosquito control districts 

in MA (MADEP, 2009; MDAR, 2008) and costs 

estimated for Idaho ISDA (2009) 

Average annual cost for problem identification for 

municipalities in New Hampshire (McGregor, 2009; 

NHDHHS, 2010) 

Pest management 

Regional-level costs 

Municipality-level costs 

$195,000/entity 

$800/entity 

Midpoint cost for implementing water management 

and vegetation and sediment removal in mosquito 

control districts in MA (MADEP, 2009; MDAR, 2008) 

Low end of range for implementing water 

management and vegetation and sediment removal 

in mosquito control districts in MA (MADEP, 2009; 

MDAR, 2008) 

Aquatic Weed and Algae Control

Identify the problem $100/acre Surveying costs; Coble (2009) 

Pest management $50/acre - $500/acre Illustrative only; represents potential feasible cost 

difference between pesticide use and use of 

alternative method1

Pesticide use $100/acre Surveillance monitoring of aquatic weed treatments; 

ISDA (2009) 

Aquatic Nuisance Animal Control

NA NA NA 

Forest Canopy Pest Control

NA NA NA 

NA = not applicable (no incremental costs identified). 

1. Assumed for half of affected acres. Actual costs of feasible alternatives to pesticide use will be site- and entity-specific. 

Table ES-3 shows the potential annual costs by unauthorized area and use pattern. As shown in 

Table ES-3, technology-based effluent limitation costs may be in the range of $11.6 million to 

$12.5 million annually; these costs are attributable primarily to IPM practices under the mosquito 

and other flying insect pest control use pattern. 
ix May 2010 

Table ES-3: Summary of Potential Annual Technology-based Effluent Limitation Costs by Use 

Pattern and Unauthorized Area ($/yr) 

Area 

Mosquito and 

Other Flying 

Insect Pest 

Aquatic 

Weed and 

Algae 

Control 

Aquatic 

Nuisance 

Animal 

Control 

Forest 

Canopy 

Pest 

Control Total Costs 

Alaska $0 $0 $0 $0 $0

Idaho $4,017,000

$7,000 - 

$21,000 $0 $0 

$4,024,000 - 

$4,038,000

Massachusetts $0

$25,000 - 

$69,000 $0 $0 

$25,000 - 

$69,000

New Hampshire $35,000

$10,000 - 

$53,000 $0 $0 

$45,000 - 

$88,000

New Mexico $2,535,000 $0 $0 $0 $2,535,000

Oklahoma $21,000

$25,000 - 

$50,000 $0 $0 

$46,000 - 

$71,000

District of Columbia $195,000 $0 $0 $0 $195,000

Territories $0 $0 $0 $0 $0

Tribes 

$104,000 - 

$354,000

$36,000 - 

$73,000 $0 $0 

$140,000 - 

$427,000

Federal Facilities $4,060,000

$508,000 - 

$1,016,000 $0 $0 

$4,568,000 - 

$5,076,000

Total 

$10,967,000 - 

$11,217,000

$611,000 - 

$1,282,000 $0 $0 

$11,578,000 - 

$12,499,000

1. Includes illustrative cost estimate for pest management based on potential, feasible net incremental costs; actual costs will be 

site- and entity-specific.

Administrative and Monitoring 

Administrative and monitoring requirements in the draft PGP differ to some extent for entities 

that will exceed the annual treatment area thresholds. A number of entities not required to 

implement IPM practices (those below the annual treatment area threshold) may incur 

administrative and monitoring costs. Table ES-4 provides a summary of the potential annual 

incremental costs for the different activities, and Table ES-5 shows total potential annual costs 

by use pattern and unauthorized area. Total costs may be approximately $5 million per year. 

These costs primarily reflect the cost associated with recordkeeping and monitoring of pesticide 

use in ditch banks on irrigated farms to control aquatic weeds. 
x May 2010 

Table ES-4: Potential Annual Administrative and Monitoring Costs 

Requirement 

Entities 

Exceeding 

Threshold 

Entities Not 

Exceeding 

Threshold 

NOI $30 NA

PDMP $430 NA

Recordkeeping $200 $80

Reporting $100 NA

Site Monitoring $200 $50

Total $960 $130

NA: not applicable 

NOI: Notice of Intent 

PDMP: Pesticide Discharge Management Plan 

Table ES-5: Summary of Potential Annual Administrative and Monitoring Costs ($/yr) 

Area 

Mosquito and 

Other Flying 

Insect Pest 

Control 

Aquatic Weed 

and Algae 

Control 

Aquatic 

Nuisance 

Animal Control

Forest 

Canopy Pest 

Control 

Total 

Alaska $300 $43,000 $3,000 $3,000 $49,300

Idaho $22,000 $2,128,000 $2,000 $8,000 $2,160,000

Massachusetts $9,000 $301,000 $4,000 $30,000 $344,000

New Hampshire $42,000 $104,000 $2,000 $12,000 $160,000

New Mexico $12,000 $1,333,000 $2,000 $4,000 $1,351,000

Oklahoma $1,000 $547,000 $10,000 $22,000 $580,000

District of Columbia $1,000 $2,000 $1,000 $0 $4,000

Territories $1,000 $43,000 $10,000 $10,000 $64,000

Tribes $5,000 - $18,000 $25,000 $17,000 $48,000 $95,000 -

$108,000

Federal Facilities $10,000 $10,000 $10,000 $28,000 $58,000

Total $103,000 - 

$116,000 $4,536,000 $61,000 $165,000 $4,865,000 -

4,878,000

Total and Average Costs 

Table ES-6 provides a summary of the technology-based effluent limitation and administrative 

and monitoring costs across the unauthorized areas and use patterns. Total annual costs may be 

in the range of $16.4 million to $17.4 million. Approximately 30% of the total estimated costs 

represent administrative and monitoring costs, although there are substantial uncertainties 

associated with components of total costs. In particular, there is uncertainty regarding the annual 

incremental costs that will be incurred to comply with IPM practices for mosquito and other 

flying insect pest control (which affects the magnitude of the technology-based effluent 

limitation costs), and with the number of affected entities under the different use patterns. 
xi May 2010 

Table ES-6: Summary of Total Potential Annual Costs ($/yr)1 

Area 

Mosquito and 

Other Flying 

Pest Insect 

Aquatic Weed 

and Algae 

Aquatic 

Nuisance 

Animal 

Forest 

Canopy Total 

Alaska $300 $43,000 $3,000 $3,000 $49,300

Idaho $4,039,000

$2,135,000 - 

$2,149,000 $2,000 $8,000

$6,184,000 - 

$6,198,000

Massachusetts $9,000

$326,000 - 

$370,000 $4,000 $30,000

$369,000 - 

$413,000

New Hampshire $77,000

$114,000 - 

$157,000 $2,000 $12,000

$205,000 - 

$248,000

New Mexico $2,547,000 $1,333,000 $2,000 $4,000 $3,886,000

Oklahoma $22,000

$572,000 - 

$597,000 $10,000 $22,000

$626,000 - 

$651,000

District of 

Columbia $196,000 $2,000 $1,000 $0 $199,000

Territories $1,000 $43,000 $10,000 $10,000 $64,000

Tribes 

$109,000 - 

$372,000

$61,000 - 

$98,000 $17,000 $48,000

$235,000 - 

$535,000

Federal Facilities $4,070,000

$518,000 - 

$1,026,000 $10,000 $28,000

$4,626,000 - 

$5,134,000

Total 

$11,070,000 - 

$11,333,000

$5,147,000 - 

$5,818,000 $61,000 $165,000

$16,443,000 - 

$17,377,000

1. See Table 5-9 and Table 5-19. 

The largest average (per entity) costs are associated with state and local government and federal 

entities that perform mosquito and other flying insect pest control. These costs, which reflect 

both administrative and monitoring costs and technology-based effluent limitation costs, may be 

in the range of $200 to $400,000 annually (see Table 5-23). Average annual costs for entities 

performing aquatic weed and algae control may range from $1,000 to $100,000 (see Table 5-24). 

Average annual costs for entities performing aquatic nuisance animal or forest canopy pest 

control may range from $100 to $1,000 (see Table 5-25). For entities below the annual treatment 

area thresholds performing mosquito and other flying insect pest control, average annual costs 

may range from $0 to $200 and for the other use patterns from $0 to $100 (see Table 5-26). 

Since entities that fall below the annual treatment area threshold are not required to meet IPM 

practices, these costs only reflect administrative and monitoring costs. 

ES.5 Small Entity Analysis 

There are very limited data available to identify the specific entities potentially affected by the 

draft PGP. Thus, it is not possible to determine the exact number of entities considered to be 

small governments/businesses or their applicable revenues for comparison to potential 

compliance costs to determine the economic impact. 
xii May 2010 

Under a conservative (i.e., erring on the side of greater impacts) scenario, there could be 

115 small entities under the mosquito and other flying insect pest control use pattern, 33,838 

small entities (including those that would only incur costs associated with administrative and 

monitoring requirements) under the aquatic weed and algae control use pattern, 192 small 

entities under the aquatic nuisance animal control use pattern, and 607 small entities (mostly 

private forest owners) under the forest canopy pest control use pattern. 

Lack of revenue data precludes estimating how many of these entities could incur significant 

economic impact based on a comparison of revenues to compliance costs. However, data on 

average revenues/sales for municipalities, counties, and irrigated farms provides some indication 

of the likelihood of level of impact, which varies across the unauthorized areas and by use 

pattern. 

ES.4 Potential Benefits 

At this time, information is not available to quantify or monetize any beneficial impacts of this 

permit. However, information from the published literature suggests that pesticides covered 

under the draft PGP may have adverse effects on aquatic ecosystems. As a result, reducing 

loadings of these pesticides, such as through the IPM practices and pesticide discharge 

management plans required under the draft PGP, may lead to ecological benefits and associated 

values. 

Pesticides, although typically designed to target a narrow range of species, nonetheless may have 

unintended adverse impacts on other aquatic species and plants. For example, one laboratory 

study found that the freshwater fish Puntius conchonius, if given chronic exposure to the 

pesticide carbaryl, developed branchial, hepatic, and renal lesions (Gill et al., 1988). Another 

study found that the adulticide ethofenprox caused lethal adverse impacts on the freshwater fish 

Oreochromis mossambicus at concentrations of 2.849 ppm and sublethal impacts beginning at 

concentrations of 1.305 ppm. These sublethal effects included erratic swimming, changes in 

opercular movement, loss of equilibrium, mucus secretion, and chromatic changes to skin 

(Muniyan and Veeraraghavan, 1999). 

Other pesticide products covered under the draft PGP may also have adverse impacts on wildlife 

and vegetation, and overall ecosystem health and function. For example, the mosquito larvicide 

fungus Lagendidium giganeum is known to greatly inhibit the reproduction of water fleas 

(cladocera) (Helgen et al., 1987). These small organisms are critical determinants of the 

structure of aquatic ecosystems as a whole, and reductions in their numbers can impact the entire 

food web (Carpenter et al., 1985). 

By minimizing discharges of the pesticides to waters of the United States, the PGP will limit the 

potential for adverse health and mortality impacts to aquatic wildlife. For any pollutants that 

accumulate in the system, reduced loadings will reduce the potential for accumulation and 

toxicity to aquatic life (from exposure to accumulated pesticides in sediments), and potential 

future remediation efforts. Although current data and information is insufficient to identify the 

extent or potential magnitude of benefits that will result from reducing pesticide loads to waters 

of the U.S., information gathered from monitoring and reporting activities may enable such an 

effort in the future. 
1 May 2010 

1. Introduction 

This report presents an evaluation of the potential costs and benefits associated with 

implementing the requirements of the draft National Pollutant Discharge Elimination System 

(NPDES) Pesticide General Permit (PGP) for the application of pesticides resulting in discharges 

to waters of the United States. 

Note that the administrative and monitoring costs presented herein likely are much less than if 

individual permits were issued to each of the approximately 35,000 operators in the areas for 

which EPA is developing this general permit. 

1.1. Background 

On November 27, 2006, the U.S. Environmental Protection Agency (EPA) issued a final 

regulation to codify its interpretation of the Clean Water Act (CWA) as not requiring NPDES 

permits for application of pesticides to and over, including near, waters of the United States if the 

application is consistent with relevant Federal Insecticide, Fungicide and Rodenticide Act 

(FIFRA) requirements. 

After the rule was published, petitions for review were filed in eleven Circuit Courts. These 

petitions were consolidated in the Sixth Circuit Court of Appeals. On January 7, 2009, the Sixth 

Circuit Court ruled in National Cotton Council, et al. v. EPA to vacate the CWA Pesticides Rule. 

On April 9, 2009 the Department of Justice filed a motion to stay issuance of the Court’s 

mandate for two years. In addition, industry petitioners filed a motion to seek a rehearing of the 

court’s decision. 

However, in August 2009, the Sixth Circuit Court denied rehearing the case, and on February 22, 

2010, the Supreme Court denied hearing the case. Thus, EPA and states authorized to issue 

NPDES permits are required to issue permits to point source dischargers for pesticide 

applications that result in a direct discharge of pesticides to waters of the United States. The 

proposed PGP addresses this requirement for states, federal facilities, tribal lands, and territories 

where EPA has NPDES permitting authority for pesticide discharges. 

The draft PGP is applicable to discharges to waters of the United States from the application of 

biological pesticides and chemical pesticides that leave a residue. The following pesticide use 

patterns are covered under the PGP: 

• Mosquito and Other Flying Insect Pest Control – to control public health/nuisance and 

other flying insect pests that develop or are present during a portion of their life cycle in 

or above standing or flowing water. Public health/nuisance and other flying insect pests 

in this use category include but are not limited to mosquitoes and black flies. 

• Aquatic Weed and Algae Control – to control invasive or other nuisance weeds and algae 

in water and at water’s edge, including irrigation ditches and/or irrigation canals. 

• Aquatic Nuisance Animal Control – to control invasive or other nuisance animals in 

water and at water’s edge. Aquatic nuisance animals in this use category include, but are 

not limited to fish, lampreys, and mollusks. 

• Forest Canopy Pest Control – aerial application of a pesticide over a forest canopy to 

control the population of a pest species (e.g., insect or pathogen) where to target the pests 
2 May 2010 

effectively a portion of the pesticide unavoidably will be applied over and deposited to 

water. 

1.2. States, Territories, and Federal Facilities to be Covered 

The draft PGP applies only to states and territories where EPA has NPDES permitting authority 

for pesticide discharges; states and territories with complete NPDES permitting authority are 

responsible for developing their own permit for pesticide discharges. States that are not 

authorized by EPA to issue NPDES permits for any discharge to waters of the United States 

include Massachusetts, Idaho, New Hampshire, and New Mexico. EPA has full NPDES 

permitting authority for these states; additionally, EPA has permitting authority over pesticide 

discharges in Alaska and Oklahoma. In this document, these six states are collectively referred 

to as “unauthorized states.” In addition, EPA has permitting authority over all U.S. territories 

(except the Virgin Islands), tribal lands within 31 states, and federal facilities within four states. 

In this document, these areas and the unauthorized states are collectively referred to as 

“unauthorized areas.” Table 1-1 shows the areas for which EPA has NPDES permitting 

authority. 

Table 1-1: NPDES Unauthorized States, Territories, and Federal Facilities (2009) 

Unauthorized States 

Alaska (only unauthorized for 

pesticide discharges) 

Idaho 

Massachusetts 

New Hampshire 

New Mexico 

Oklahoma (only unauthorized for 

pesticide discharges) 

Unauthorized Territories 

American Samoa 

District of Columbia1 

Guam 

Johnston Atoll 

Midway Island & Wake Island 

Northern Mariana Islands 

Puerto Rico 

States with Federal Facilities for which EPA has Permitting Authority 

Colorado 

Delaware Vermont Washington 

States with Tribal Lands for which EPA has Permitting Authority 

Alabama 

Alaska 

Arizona 

California 

Colorado 

Connecticut 

Florida 

Idaho 

Iowa 

Kansas 

Louisiana 

Massachusetts 

Michigan 

Minnesota 

Mississippi 

Montana 

Nebraska 

Nevada 

New Mexico 

New York 

North Carolina 

North Dakota 

Oklahoma 

Oregon 

Rhode Island 

South Dakota 

Texas 

Utah 

Washington 

Wisconsin 

Wyoming 

1. Technically not a territory but included in this group for the purpose of this analysis. 

1.3. Organization of the Analysis 

The remainder of the report is organized, as follows: 

Section 2: Overview of Pesticide General Permit provides a description of the permit 

requirements. 
3 May 2010 

Section 3: Identification of Likely Affected Entities describes the types of entities that potentially 

apply pesticides under the four use patterns, and presents an assessment of the numbers and types 

of pesticide applicators potentially affected by the draft PGP. 

Section 4: Overlap with Existing Requirements summarizes current practices and regulations that 

already cover pesticide applicators in the areas of concern. 

Section 5: Analysis of Costs presents an analysis of potential incremental costs to affected 

entities associated with compliance with the draft PGP. 

Section 6: Small Business Analysis presents an assessment of the cost of regulatory requirements 

on the likelihood of significant economic impacts on small entities. 

Section 7: Benefits Analysis provides discussion of the environmental effects associated with 

pesticide discharges and the benefits of reducing these discharges. 
4 May 2010 

2. Overview of Pesticides General Permit 

This section provides an overview of the requirements of the draft PGP, which covers point 

source discharges to waters of the United States from applications of pesticides for specific use 

patterns. There are four general use patterns covered under the PGP: mosquito and other flying 

insect pest control, aquatic weed and algae control, aquatic nuisance animal control and forest 

canopy pest control. The draft PGP includes technology-based effluent limitations, including 

specific integrated pest management (IPM) practices for each use pattern, and requirements 

associated with administrative tasks and monitoring. 

2.1. Technology-Based Effluent Limitations 

Technology-based effluent limitations provisions include requirements that operators reduce or 

eliminate discharges of pesticides to waters of the United State to the extent technologically 

available and economically practicable and achievable. 

2.1.1. Minimize Pesticide Discharges to Waters of the United States 

All operators must minimize the discharge resulting from application of pesticides. All operators 

must also do the following: Operators must use the “lowest effective amount of pesticide 

product per application and optimum frequency” of applications required to control the target 

pest and reduce the potential for development of resistance. Operators must also perform regular 

maintenance activities to reduce the risk of leaks, spills or unintentional discharges and 

additionally maintain pesticide application equipment in proper operating condition. Operators 

must calibrate, clean and repair equipment on a regular basis to ensure effective pesticide 

application and pest control. 

2.1.2. Integrated Pest Management (IPM) Practices 

All operators who are required to submit an NOI, as required in Part 1.2.2 of the permit, must 

implement IPM practices. These practices are aimed at reducing pesticide use and lessening the 

affects of pesticides that are applied. The IPM practices required in the draft PGP seek to limit 

the discharge of pesticides to waters of the United States. Each use pattern has its own IPM 

practices, and these requirements are divided into three different sections: identify the problem, 

pest management and pesticide use. Under the permit, all operators must identify the problem 

prior to pesticide application, consider using non-chemical control measures, perform 

surveillance before pesticide application, and reduce impacts of pesticide use. 

2.1.2.1 Mosquito and Other Flying Insect Pest Control 

Mosquito and other flying insect pest control involves the control of public health/nuisance and 

other flying insect pests that develop or are present during a portion of their life cycle in or above 

standing or flowing water. Public health/nuisance and other flying insect pests in this use 

category include but are not limited to mosquitoes and black flies. The draft PGP requires the 

following: 

• Identify the Problem 
5 May 2010 

3⁄4 Establish densities for larval and adult mosquito or flying insect pest populations to serve 

as action threshold(s) for implementing pest management strategies; 

3⁄4 Identify target mosquito or flying insect pest species to develop species-specific pest 

management strategies based on developmental and behavioral considerations for each 

species; 

3⁄4 Identify known breeding sites for source reduction, larval control program, and habitat 

management; 

3⁄4 Analyze existing surveillance data to identify new or unidentified sources of mosquito or 

flying insect pest problems as well as sites that have recurring pest problems. 

• Pest Management 

3⁄4 Evaluate management options considering impact to water quality, impact to non-target 

organisms, pest resistance, feasibility, and cost effectiveness: no action, prevention, 

mechanical/ physical methods, cultural methods, biological control agents, and 

pesticides. 

• Pesticide Use 

3⁄4 Conduct larval and/or adult surveillance prior to each pesticide application to assess the 

pest management area and to determine when action threshold(s) are met that necessitate 

the need for pest management; 

3⁄4 Assess environmental conditions (e.g. temperature, precipitation, and wind speed) in the 

treatment area prior to each pesticide application to identify whether existing 

environmental conditions support development of pest populations and are suitable for 

control activities; 

3⁄4 Reduce the impact on the environment and on non-target organisms by applying the 

pesticide only when the action threshold has been met; 

3⁄4 In situations or locations where practicable and feasible for efficacious control, use 

larvicides as a preferred pesticide for mosquito or flying insect pest control when larval 

action thresholds have been met; 

3⁄4 In situations or locations where larvicide use is not practicable or feasible for efficacious 

control, use adulticides for mosquito or flying insect pest control when adult action 

thresholds have been met. 

2.1.2.2 Aquatic Weed and Algae Control 

Aquatic weed and algae control involves the control of invasive or other nuisance weeds and 

algae in water and at water’s edge, including irrigation ditches and/or irrigation canals. The draft 

PGP requires the following: 
6 May 2010 

• Identify the Problem 

3⁄4 Identify areas with aquatic weed or algae problems and characterize the extent of the 

problems, including, for example, water use goals not attained (e.g. wildlife habitat, 

fisheries, vegetation, and recreation); 

3⁄4 Identify target weed species; 

3⁄4 Identify possible factors causing or contributing to the weed or algae problem (e.g., 

nutrients, invasive species, etc); 

3⁄4 Establish past or present aquatic weed or algae densities to serve as action threshold(s) 

for implementing pest management strategies. 

• Pest Management 

3⁄4 Evaluate management options considering impact to water quality, impact to non-target 

organisms, pest resistance, feasibility, and cost effectiveness: no action, prevention, 

mechanical/ physical methods, cultural methods, biological control agents, and 

pesticides. 

• Pesticide Use 

3⁄4 Conduct surveillance prior to each pesticide application to assess the pest management 

area and to determine when the action threshold is met that necessitates the need for pest 

management; 

3⁄4 Reduce the impact on the environment and non-target organisms by applying the 

pesticide only when the action threshold has been met. 

2.1.2.3 Aquatic Nuisance Animal Control 

Aquatic nuisance animal control involves the control of invasive or other nuisance animals in 

water and at water’s edge. Aquatic nuisance animals in this use category include, but are not 

limited to fish, lampreys, and mollusks. The draft PGP requires the following: 

• Identify the Problem 

3⁄4 Identify areas with aquatic nuisance animal problems and characterize the extent of the 

problems, including, for example, water use goals not attained (e.g. wildlife habitat, 

fisheries, vegetation, and recreation); 

3⁄4 Identify target aquatic nuisance animal species; 

3⁄4 Identify possible factors causing or contributing to the problem (e.g., nutrients, invasive 

species); 

3⁄4 Establish past or present aquatic nuisance animal densities to serve as action threshold(s) 

for implementing pest management strategies. 

• Pest Management 

3⁄4 Evaluate management options considering impact to water quality, impact to non-target 

organisms, pest resistance, feasibility, and cost effectiveness: no action, prevention, 

mechanical/ physical methods, biological control agents, and pesticides. 

• Pesticide Use 
7 May 2010 

3⁄4 Conduct surveillance prior to each application to assess the pest management area and to 

determine when the action threshold is met that necessitates the need for pest 

management; 

3⁄4 Reduce the impact on the environment and non-target organisms by evaluating site 

restrictions, application timing, and application method in addition to applying the 

pesticide only when the action threshold has been met. 

2.1.2.4 Forest Canopy Pest Control 

Forest canopy pest control involves aerial application of a pesticide over a forest canopy to 

control the population of a pest species (e.g., insect or pathogen) where to target the pests 

effectively a portion of the pesticide unavoidably will be applied over and deposited to water. 

The draft PGP requires the following: 

• Identify the Problem 

3⁄4 Establish target pest densities to serve as action threshold(s) for implementing pest 

management strategies; 

3⁄4 Identify target species to develop a species-specific pest management strategy based on 

developmental and behavioral considerations for each species; 

3⁄4 Identify current distribution of the target pest and assess potential distribution in the 

absence of control measures. 

• Pest Management 

3⁄4 Evaluate management options considering impact to water quality, impact to non-target 

organisms, pest resistance, feasibility, and cost effectiveness: no action, prevention, 

mechanical/ physical methods, cultural methods, biological control agents, and 

pesticides. 

• Pesticide Use 

3⁄4 Conduct surveillance prior to each application to assess the pest management area and to 

determine when the pest action threshold is met that necessitates the need for pest 

management; 

3⁄4 Assess environmental conditions (e.g. temperature, precipitation, and wind speed) in the 

treatment area to identify conditions that support target pest development and are 

conducive for treatment activities; 

3⁄4 Reduce the impact on the environment and non-target organisms by evaluating the 

restrictions, application timing, and application methods in addition to applying the 

pesticide only when the action thresholds have been met; 

3⁄4 Evaluate using pesticides against the most susceptible developmental stage. 

2.2. Administrative Requirements 

The draft PGP administrative requirements include submittal of a Notice of Intent (NOI) and a 

Pesticide Discharge Management Plan (PDMP), as well as performance of annual reporting, 

recordkeeping, and site monitoring. 
8 May 2010 

2.2.1. Notice of Intent 

Any entity that has operational control over pesticide activities or applies pesticides directly will 

be required to submit an NOI if they will exceed one or more of the annual treatment area 

thresholds (see Error! Reference source not found.). All other entities are not required to 

submit an NOI. 

Table 2-1: Annual Treatment Area Thresholds 

Pesticide Use Pattern Annual Threshold 

Mosquitoes and Other Flying Insect Pest Control 640 acres of treatment 

Aquatic Weed and Algae Control 20 acres of water treatment 

20 linear miles at water’s edge 

Aquatic Nuisance Animal Control 20 acres of water treatment 

20 linear miles at water’s edge 

Forest Canopy Pest Control 640 acres of forest canopy 

2.2.2. Pesticide Discharge Management Plan 

Any operator that is required to submit an NOI must also submit a PDMP. A PDMP must 

include: identification of the pesticide discharge management team; a description of the pest 

management area; and a description of the control measure(s) evaluated. Operators must also 

provide schedules and procedures for application rate and frequency, spill prevention, 

maintaining pesticide application equipment, performing pest surveillance and assessing 

environmental conditions. In addition, the PDMP must include spill response procedure and 

adverse incident response procedure as well as pesticide monitoring schedules and procedures. 

2.2.3. Annual Reporting 

Operators that are required to submit an NOI must also submit an annual report. The report must 

include operator’s name, NPDES permit tracking number(s), contact information, and, for each 

pest treatment area, the following must be reported: identification of any waters or other 

treatment area, including size, either by name or by location, to which pesticides were 

discharged; pesticide use pattern(s); company name(s) and contact information for pesticide 

applicator(s), if different from the NOI submitter; total amount of each pesticide product applied 

for the reporting year by the EPA registration number(s) and by application method; whether the 

pest control activity was addressed in the PDMP prior to pesticide application; adverse incident 

reports; and description of any corrective action(s). 

2.2.4. Recordkeeping 

All entities must keep accurate and complete written records sufficient to demonstrate 

compliance with conditions of the draft PGP. EPA recommends that all operators keep records 

of acres or linear miles treated for relevant use patterns to help determine whether the annual 

treatment area threshold has been met. Operators required to submit an NOI have increased 

recordkeeping requirements for each pesticide application which include keeping information on: 

the date on which the operator knew or reasonably should have known that they would exceed an 

annual treatment area threshold during any calendar year; surveillance method(s) used, date(s) of 

surveillance activities, and findings of surveillance; target pest(s); pest density prior to pesticide 

application; company name and contact information for pesticide applicator; pesticide 

application date(s); description of treatment area; name of each pesticide product used including 
9 May 2010 

the EPA registration number; quantity of pesticide applied; concentration of active ingredient in 

formulation; for pesticide application directly to water, the effective concentration of active 

ingredient required for control; any unusual or unexpected effects identified to non-target 

organisms; and documentation of any equipment maintenance. 

2.2.5. Site Monitoring 

All entities covered under the draft PGP must perform site monitoring. Operators must ensure 

that their equipment is in proper working order and they are using the lowest amount of 

pesticides required to effectively control the pest. In addition, operators must conduct a visual 

assessment at the application site when surveillance or an efficacy check is conducted. The 

visual assessment must consist of spot checks where pesticides are applied for possible and 

observable adverse incidents. 

2.2.6. Summary 

As described above, the administrative requirements vary based on whether an entity will exceed 

an applicable annual treatment area threshold. Table 2-2 summarizes the requirements for each 

type of entity. 

Table 2-2: Administrative and Monitoring Requirements for Affected Entities 

Level of Pesticide Use NOI PDMP Reporting Recordkeeping Site 

Monitoring

Exceed threshold X X X X X 

Do not exceed threshold X1 X 

1. Entities that are not required to submit an NOI have reduced recordkeeping requirements. 
10 May 2010 

3. Identification of Likely Affected Entities 

This section provides available information on the four pesticide use patterns in the unauthorized 

areas and identifies entities that may be required to comply with the draft PGP requirements. 

There is no one central source of data to identify potentially affected entities. EPA therefore 

relied on preliminary information available from the unauthorized areas. Where specific 

information was not available, EPA made assumptions based on other available data to estimate 

the number or types of likely affected entities. Using more accurate estimates for the 

unauthorized areas could yield different results and possibly different conclusions. However, in 

the absence of better data, EPA’s analysis represents a preliminary estimate of the number and 

types of potentially affected entities. 

3.1. Mosquito and Other Flying Insect Pest Control 

Mosquito and other flying insect pest control is often performed to protect public health, and 

almost always involves some degree of chemical control, including ground and aerial control 

targeted at adult mosquitoes and larvae. Typically, applicators use Ultra Low Volume (ULV) 

sprays or foggers because the amount of insecticide used is small compared to the area treated. 

Doing this limits the exposure and health risks to humans and the environment. In addition, 

ULV sprayers and foggers are a cost effective solution for smaller applicators due to the 

relatively lower capital costs. 

Information from the unauthorized areas indicates that mosquito and other flying insect pest 

control are conducted by public entities1

, although these entities may contract out the activity to 

commercial pest control operators. (In all instances of contract activity, EPA assumes that the 

responsibilities and costs are ultimately borne by the hiring entity, and thus reports the activity at 

the hiring entity level.) The level of government at which this type of pest control occurs varies. 

Many city and county governments implement mosquito control programs. Local and state 

mosquito control agencies generally collaborate with state public health departments to monitor 

(and at times control) mosquitoes with the goal of preventing mosquito-borne illnesses. In some 

states, cities and counties form regional mosquito eradication districts which perform mosquito 

control independent of the state government. For example, Massachusetts has nine mosquito 

control districts, comprising between 2 and 32 towns (though most districts have over 20 towns). 

Figure 1 provides a map of the control districts with municipal boundaries shown; note that there 

are a number of municipalities that are not covered by a control district. 

 

1

 EPA does not have information to suggest that private entities are involved in mosquito or other flying insect pest 

control efforts to or over, including near, waters of the United States. 
11 May 2010 

Figure 1: Map of Massachusetts Mosquito Control Projects, 2009 

Source: MADEP, 2009

The unauthorized areas include six states, six territories, and the District of Columbia, within 

which exist numerous counties and cities. Mosquito control may also be performed by tribes and 

at federal facilities. There are over 300 federal facilities within the four states of interest 

(Colorado, Delaware, Vermont, and Washington), including army bases (administered by 

Department of Defense), federal prisons (administered by Department of Justice), National 

Wildlife Refuge Areas (administered by Bureau of Reclamation), and National Forests 

(administered by Forest Service), among others. There are 10 federal agencies responsible for 

these facilities or land areas. There are also 174 unique Indian reservations in 26 authorized 

states.2

 

To determine the number of entities that could be affected by the draft PGP, EPA relied on 

information provided by the unauthorized states and other publicly available data. The Alaska 

Department of Environmental Conservation (ADEC, 2009) indicates that there is no organized 

effort to control mosquitoes, and only two locations in the state have issued mosquito control 

permits in the past. The Idaho State Department of Agriculture (ISDA) indicates that there are 

23 mosquito control districts in the state (ISDA, 2009). As stated previously, there are nine 

mosquito control districts in Massachusetts (MADEP, 2009), and the New Hampshire 

Department of Agriculture, Markets, and Food (NHDAMF, 2009) indicates that there are 43 

mosquito control districts in the state plus one permit for mosquito control at the University of 

New Hampshire. New Mexico has 13 mosquito control districts (Conlon, 2009), and the 

 

2

 Based on GIS data from National Atlas (www.nationalatlas.gov). 
12 May 2010 

Oklahoma Department of Agriculture, Food, and Forestry (ODAFF, 2009) indicates that Tulsa is 

the only city in the state that currently performs mosquito control.3

 For the District of Columbia, 

information on its Department of Health (DOH) website indicates that the District uses larvicides 

for mosquito control (DCDOH, 2005). 

EPA searched for mosquito control information for tribal reservations with land areas greater 

than 100,000 acres (52 total) and found that only 8 are using pesticides to control for mosquitoes. 

However, a number of reservations in Arizona (an authorized state) perform mosquito control 

with the assistance of state partnerships. Tribes working with authorized states to control 

mosquitoes would most likely be permitted under the state’s NPDES program and not under the 

draft PGP. Thus, EPA found evidence of only five tribal reservations in which mosquito control 

with pesticides is taking place independent of state assistance. This represents approximately 

10% of the number of unique Indian reservations with areas greater than 100,000 acres (5 out of 

52). Assuming that percentage is representative of reservations with less than 100,000 acres 

(122 total), there could be 17 tribal entities potentially affected by the draft PGP [5 + (122 × 

10%)]. 

For the territories, there is no information to indicate that any of the territories other than Puerto 

Rico use pesticides for mosquito control. Thus, EPA assumes that only Puerto Rico would be 

required to obtain a permit for mosquito control under the draft PGP. 

For federal facilities there is no information on the number using pesticides for mosquito control. 

For this analysis, EPA assumes that each federal agency is using pesticides for mosquito control 

and would receive a single permit for all activities across facilities/land areas. Thus, EPA 

estimated costs for 10 unique federal agencies potentially affected by the draft PGP. 

Table 3-1 presents estimates of the number of potentially affected entities. Due to incomplete 

data on the extent of mosquito and other flying insect pest control activities involving pesticide 

applications eligible for the draft PGP, the number of potentially affected entities may be higher 

or lower than the amount shown. Nonetheless, the number of potentially affected entities below 

represents the best estimate given the information available. Any entity may apply pesticides at 

one or more sites covered by a single permit. 

 

3

 In the past, at most a handful of cities have been involved in mosquito control, and before the threat of West Nile 

Virus, no mosquito control was performed in Oklahoma. Any mosquito control in Tulsa is likely rudimentary, 

involving spraying adulticides using truck-mounted foggers (ODAFF, 2009). 
13 May 2010 

Table 3-1: Potentially Affected Entities: Mosquito and Other Flying Insect Pest Control 

State Total Number of Potentially 

Affected Entities1 Source 

Alaska 2 ADEC (2009) 

Idaho 23 ISDA (2009) 

Massachusetts 9 MADEP (2009) 

New Hampshire 44 NHDAMF (2009) 

New Mexico 13 NMDOH (2009) 

Oklahoma 1 ODAFF (2009) 

District of Columbia 1 DCDOH (2009) 

Territories 1 Assumed only Puerto Rico affected 

Tribes1 17 Assumed 10% potentially affected 

Federal Facilities2 10 Represents number of unique agencies

Total 121 

Sources: ADEC, 2009; ISDA, 2009; MADEP, 2009; NHDAMF, 2009; NMDOH, 2009; ODAFF, 2009. 

1. Estimate based on 10% of the number of unique Indian reservation listings for 26 authorized states; tribal activities in 

unauthorized states assumed to be included in number of potentially affected entities in unauthorized states. 

2. Estimate based on number of unique federal agencies with facilities in four states (CO, DE, VT and WA).

The draft PGP establishes annual treatment area thresholds applicable to permittees for 

identifying the need to comply with some permit requirements. For mosquito and other flying 

insect pest control, the annual treatment area threshold is 640 acres of treatment. Mosquito and 

other flying insect pest control conducted by vector control districts (e.g., entities in Idaho, 

Massachusetts, New Hampshire, and New Mexico) will generally cover more than 640 acres. 

For the two cities in Alaska, EPA assumes that the treatment areas are less than the threshold 

based on information provided by the State that there is no organized effort to control 

mosquitoes. For the city of Tulsa, Oklahoma, the Department of Environmental Health’s 

website indicates that in a typical mosquito season it sprays over 800 square miles (512,000 

acres) for adult mosquitoes, which is above the applicable threshold. EPA identified at least five 

tribes likely to be treating areas greater than the applicable threshold. However, it is uncertain 

whether the remaining 12 tribal entities are treating more than 640 acres. Thus, EPA uses a 

range assuming that all 12 tribal entities are either above the threshold or below the threshold. 

Because there is no information on the federal facility lands on which pesticides are used to 

control mosquitoes, EPA assumes that all agencies are either treating areas above the threshold 

or are treating multiple sites with total treatment areas exceeding the threshold. Table 3-2 shows 

the number of entities that may be above the applicable threshold. 
14 May 2010 

Table 3-2: Entities Exceeding Annual Treatment Area Thresholds: Mosquito and Other Flying 

Insect Pest Control 

Estimated Number of Affected Entities State Above Threshold Below Threshold Total 

Alaska1 0 22

Idaho2 23 0 23

Massachusetts2 9 09

New Hampshire2 44 0 44

New Mexico2 13 0 13

Oklahoma3 1 01

District of Columbia2 1 01

Territories2 1 01

Tribes4 5-17 0-12 17

Federal Facilities5 10 0 10

Total 107-119 2-14 121

1. Assumes city-level control is for less than 640 acres. 

2. Mosquito control districts likely treating more than 640 acres. 

3. Information from Tulsa DHS indicates that it treated more than 512,000 acres per year. 

4. EPA uses a range assuming that all 12 tribal entities are either above the threshold or below the threshold.. 

5. Assumes all federal facilities treating greater than 640 acres. 

3.2. Aquatic Weed and Algae Control 

The aquatic weed and algae control use pattern refers to the application of pesticides to manage 

invasive or other nuisance weeds and algae in water and water’s edge, including irrigation 

ditches and/or irrigation canals. Typically these programs target specific weeds or invasive 

species and utilize a variety of techniques, including spraying pesticides. The pesticides are 

applied in or near water, which results in discharge to waters of the United States. Information 

from the unauthorized areas indicates that aquatic weed and algae control is conducted by both 

public and private entities. 

3.2.1. Public Entities 

Public entities may include state, county, or municipal governments and public drinking water 

utilities. These entities may perform the work themselves or contract it out to commercial pest 

control operators. (In all instances of contract activity, EPA assumes that the responsibilities and 

costs are ultimately borne by the hiring entity, and thus reports the activity at the hiring entity 

level.) 

ADEC (2009) indicates that the state of Alaska has not issued any permits for aquatic weed 

control in the past. In Idaho, ISDA manages a very aggressive water milfoil4

 control program 

that has historically treated 5,000 acres per year; however, budgetary constraints limit the current 

treatment area to about 600 acres (ISDA, 2009). In Massachusetts, treatment for aquatic weeds 

occurs in approximately 8% of waters (permits issued for 260 out of 3,100 waterbodies) 

(MADEP, 2009). Available information from Massachusetts indicates that the majority of the 

260 permits were issued to private entities; EPA assumes that only about 26 (or 10%) are public 

 

4

 Milfoil is often considered a nuisance plant because it can alter a water's ecology by forming very dense mats of 

vegetation on the surface of the water. These mats interfere with recreational activities such as swimming, fishing, 

water skiing, and boating; cause flooding; create good habitat for mosquitoes; rob oxygen from the water by 

preventing the wind from mixing the oxygenated surface waters to deeper water; and increase the sedimentation rate 

by trapping sediments. 
15 May 2010 

entities. In New Hampshire, the state issues 20 to 25 permits annually for treatment of invasive 

exotic aquatic weeds; EPA assumes that all 25 of these entities are public. NMDAMF (2009) 

indicates that, along with the Bureau of Land Management, they are responsible for aquatic weed 

control within the state. However, NMDAMF (2010) also indicates that aquatic weeds and algae 

are not problems in New Mexico, and that almost no aquatic pesticide use occurs directly in 

waters of the state. Based on this information, EPA assumes that there are no entities in New 

Mexico affected by the draft PGP due to a lack of pesticide use. The State of Oklahoma issued 

60 licenses – mostly to municipalities – to perform weed control (ODAFF, 2009) on specific 

water bodies. Consequently, EPA assumes that potentially 60 public entities are affected under 

the use pattern in Oklahoma. 

Information is lacking on the extent of aquatic weed control in the District of Columbia, U.S. 

territories, tribal lands, and federal facilities. In the District of Columbia, the absence of 

information from the Department of the Environment website regarding aquatic weed control 

suggests that no aquatic weed control programs are ongoing. There is no information confirming 

the practice of aquatic weed control in the U.S. territories. For example, EPA found no evidence 

of spraying to control invasive species in Puerto Rico, Johnston Atoll, or American Samoa. 

Given this, EPA assumes that aquatic weed control is minimal or absent in U.S. territories. 

For tribal lands, the Southwest Vegetation Management Association’s trade listing indicates that 

two of the largest tribes in the country, Navajo and Hopi, have committees for invasive plants 

and weeds (SWVMA, 2008). However, there is no indication that either of these committees is 

active or uses pesticides to control aquatic weeds. To err on the side of potentially higher costs, 

EPA assumes that 10% of tribes (or 17 of 174) would be affected by the draft PGP. In addition, 

there is evidence that pesticide applications for aquatic weed control are occurring at federal 

facilities. For example, McChord Air Force Base in Tacoma, Washington contracts out aquatic 

weed control to The Nature Conservancy (The Nature Conservancy, 2007). However, 

information on the extent of such activities is unavailable. For the purpose of this analysis, EPA 

assumes that each unique federal agency with facilities across the affected states (10 total) could 

be affected by the draft PGP. 

Pesticide use for aquatic weed control may also occur in right-of-way ditches. There are no data 

available from which to determine the number of entities subject to the PGP or the location or 

number of ditches potentially covered by the draft PGP. However, EPA assumes that pesticide 

application to right-of-way ditches is conducted at the state or tribal level (e.g., by the 

department of transportation), and EPA includes a single entity for each state/territory. For 

federal facilities, EPA assumes the Federal Highway Administration is responsible for pesticide 

applications along right-of-way ditches (already accounted for above); for tribes, EPA assumes 

that right-of-way ditch pesticide applications are already captured in the estimate described 

above because tribal governments are not likely to have separate entities controlling aquatic 

weeds. 

A number of public drinking water utilities withdraw surface water for domestic use through 

intake structures. Depending on the level of biological activity in the source water, these entities 

may find it necessary to use chemical controls at the intake structure to reduce biofouling 

organisms, such as algae or zebra mussels (see Section 3.3 for discussion of aquatic nuisance 

animal control). EPA’s Safe Drinking Water Information System (SDWIS) contains information 

on public drinking water systems; the data are based on information for the fiscal year that ended 

September 2008, as reported to EPA by the states. Table 3-3 shows the number of drinking 
16 May 2010 

water systems that use surface waters (includes direct surface water and purchased surface water) 

potentially affected by the draft PGP.5

Table 3-3: Estimated Number of Public Drinking Water Utilities with Surface Water Intakes 

State Estimated Number with Surface 

Water Intake

Alaska 103 

Idaho 54 

Massachusetts 168 

New Hampshire 56 

New Mexico 43 

Oklahoma 605 

District of Columbia 5 

Territories 217 

Tribes 61 

Total 1,312 

Source: EPA (2008). 

3.2.2. Private Entities 

In addition to public entities, private entities also perform aquatic weed and algae control 

practices and may be affected by the draft PGP. Examples of such private entities include farms 

that use pesticides for controlling aquatic weeds along ditch banks, industrial facilities using 

pesticides to prevent clogging of surface water intakes, and others using pesticides for aesthetic 

or recreational purposes in private lakes/ponds. 

Based on the 2007 Census of Agriculture (USDA, 2007), there are 31,636 irrigated crop farms in 

the six unauthorized states, as shown in Table 3-4. These farms likely use irrigation ditches to 

transport water to crops. However, there is no information indicating whether any of the ditch 

banks are treated with pesticides or whether the ditches connect to or result in a discharge to a 

water of the United States. To be conservative (i.e., erring on the side of overstating impacts), 

EPA assumes that all irrigated farms use pesticides along ditch banks and that those ditches drain 

to waters of the United States. In addition to ditches on irrigated farms, there may also be a 

portion of non-irrigated farms that have drainage ditches (e.g., to transport farm waste water off 

farm, as normal topography of the farm land). Although the likelihood of farmers using 

pesticides along these ditch banks that lead to waters of the United States is not known, the 

assumption that all irrigated farms are potentially affected by the draft PGP should compensate 

for the undetermined number of affected non-irrigated farms with treated drainage ditch banks. 

Table 3-4: Irrigated Farms in Unauthorized States 

State Number of Irrigated Farms 

Alaska 184 

Idaho 16,124 

Massachusetts 1,630 

New Hampshire 505 

New Mexico 10,167 

Oklahoma 3,026 

Total 31,636 

Source: USDA (2007). 

 

5

 Non-community water systems (both transient and non-transient) are excluded because they serve only a small 

portion of the population, and it is not clear whether most of these systems use a surface water intake. 
17 May 2010 

Industrial facilities withdraw surface water for a variety of purposes. For example, power plants 

withdraw water for cooling. Regardless of the end use of the water, the facility would use an 

intake structure of some type. Depending on the level of biological activity in the source water, 

these entities may also find it necessary to use chemical controls at the intake structure to reduce 

biofouling organisms, such as algae or zebra mussels (See Section 3.3 for discussion of aquatic 

nuisance animal control). 

In 1999, EPA issued a screener survey to over 2,500 industrial facilities, including power plants 

and a wide range of manufacturing sectors6

 as part of its 316(b) rulemaking to identify facilities 

that operate a cooling water intake structure and would therefore potentially be subject to 316(b) 

regulations. The survey results indicated that approximately 25% of the surveyed facilities 

would potentially be subject to the 316(b) rule. Using this ratio and information on NPDES 

permitted industrial dischargers in EPA’s permit compliance system database, EPA estimated the 

potential number of industrial dischargers with surface water intake structures in the 

unauthorized states (Table 3-5). EPA assumes that all of these industrial facilities could 

potentially be affected by the draft PGP. 

Table 3-5: Estimated Number of Industrial Facilities with Surface Water Intakes 

State Total NPDES Permits1 Estimated Number with Surface 

Water Intake2 

Alaska 149 37 

Idaho 200 50 

Massachusetts 325 81 

New Hampshire 113 28 

New Mexico 130 33 

Oklahoma 476 119 

District of Columbia 9 2

Territories 261 66 

Tribes 42 11 

Total 1,705 427 

1. General permits, stormwater-only permits, and inactive permit excluded. 

2. Based on assumption that approximately 25% of industrial dischargers have surface water intakes. 

There may also be private property owners that use pesticides to control for aquatic weeds and 

algae that could potentially be affected by the draft PGP. For example, in Idaho, private land 

owners treat approximately 100 acres per year for aquatic plants such as milfoil. In 

Massachusetts, based on information available from the state, EPA assumes that of 260 permits 

issued in 2009, 90% (234 permits) were issued to private property owners (MADEP, 2009). In 

New Hampshire, the state issued 17 permits in 2009 to treat private ponds. Historically only 5% 

to 10% of the 1- to 2-acre average-sized ponds are treated in a given season (NHDAMF, 2009). 

However, because the draft PGP lasts for five years regardless of the frequency of pesticide 

applications, EPA assumes that there are 17 private entities in New Hampshire potentially 

affected by the draft PGP. EPA does not have information indicating that private property 

owners in Alaska, New Mexico, and Oklahoma are using pesticides for aquatic weed control. 

 

6

 The industry sectors targeted included primary metals, petroleum refining, paper products, and chemicals. These 

four sectors (in addition to power plants) account for 99% of cooling water withdrawals in the US. The screener 

survey did not address drinking water intakes. 
18 May 2010 

3.2.3. Summary 

Various types of entities could be affected by the draft PGP, as discussed above. Table 3-6 

summarizes the estimated number of potentially affected entities under the aquatic weed and 

algae control use pattern. In instances in which only information regarding the number of acres 

treated is available, the number of affected entities shown in the table reflect estimates based on 

the potential number of waters treated (derived by dividing the total acreage by the average acres 

for waters in the state) and assuming that each represents an affected entity. 

Table 3-6: Potentially Affected Entities: Aquatic Weed and Algae Control 

Potential Number of Affected Entities 

Area Government1 DOT (rightof-way)2 

Drinking 

Water 

Utility3 

Farms4 Industrial5 Other 

Private1,6 Total 

Alaska 0 1 103 184 37 0 325

Idaho 72 1 54 16,124 50 12 16,313

Massachusetts 26 1 168 1,630 81 234 2,140

New 

Hampshire 25 1 56 505 28 17 632

New Mexico 0 1 43 10,167 33 0 10,244

Oklahoma 60 1 605 3,026 119 0 3,811

District of 

Columbia 0 1 5 0 2 0 8

Territories 0 6 217 0 66 0 289

Tribes 17 0 61 0 11 0 90

Federal 

Facilities7 9 1 0 0 0 0 10

Total 209 14 1,312 31,636 427 263 33,861

1. Based on information from ADEC (2009), ISDA (2009), MADEP (2009), NHDAMF (2009), NMDOH (2009), and ODAFF (2009). 

For Idaho, number of entities based on number of lake/pond acres treated and average lake size (8.3 acres; USGS, 2009) and 

assuming each lake represents a single entity. For Massachusetts, EPA assumes 90% of permits are for private entities and 10% 

are for public entities. For tribes and federal facilities, EPA based estimated number of entities on assumption that 10% of all 

entities would require coverage under the draft PGP. 

2. Based on assumption that state-level department of transportation is responsible for pesticide applications along right-of-way 

ditches, Federal Highway Administration is responsible for federally owned right-of-ways, and right-of-way pesticide applications 

are already accounted for in 10% estimate under the “Government” category. 

3. Based on number of surface water systems in EPA’s SDWIS database for each area. 

4. Assumes all irrigated farms have irrigation ditches and use pesticides to treat ditch banks. 

5. Based on number of NPDES dischargers (excluding general and storm water permits) in each area and average percent of 

industrial facilities with surface water intakes [25%; 1999 316(b) Rulemaking Survey]. 

6. Represents private property owners using pesticides to control for aquatic weeds and algae. 

7. Federal Highway Administration excluded from government entities and included under right-of-way entities. 

The draft PGP establishes annual treatment area thresholds applicable to permittees for 

identifying the need to comply with some permit requirements. For aquatic weed and algae 

control, the annual treatment area threshold is 20 acres of water treatment or 20 linear miles at 

water’s edge. Based on the information discussed above, there could be a number of entities 

performing aquatic weed and algae control that would fall below these thresholds, resulting in 

reduced permit requirements. 

For example, the 72 government entities in Idaho treat about 600 acres per year, or an average of 

approximately eight acres per entity. Based on this average, EPA assumes that 90% (or 65 of 

72) of the public entities in Idaho would be below the 20 acre treatment threshold. For 

government entities in Massachusetts, New Hampshire, New Mexico, Oklahoma, tribal lands, 

and federal facilities, there is no information indicating the size of the treatment areas for each 
19 May 2010 

affected entity. To be conservative (i.e., erring on the side of higher costs), EPA assumes that all 

of the entities could be above the applicable threshold. Because EPA assumes that right-of-way 

ditches are controlled at the state level, all of these entities would likely be above the thresholds. 

Also, drinking water utilities and industrial facilities are likely treating less than an acre of water 

around the surface water intake structure, and would be well below the threshold of 20 acres. In 

addition, the average farm size of irrigated farms in any of the unauthorized states is less than 

100 square miles; thus, the presence of a ditch bank over 20 linear miles long is unlikely. 

Finally, private landowners with aquatic weed permits are likely treating ponds smaller than 20 

acres. Table 3-7 summarizes the number of entities likely to be exceeding the applicable annual 

treatment area thresholds. 

Table 3-7: Entities Exceeding Annual Treatment Area Thresholds: Aquatic Weed and Algae 

Control 

Number of Affected Entities 

State Above Threshold1 Below Threshold2 Total 

Alaska 1 324 325

Idaho 8 16,305 16,313

Massachusetts 27 2,113 2,140

New Hampshire 26 606 632

New Mexico 1 10,243 10,244

Oklahoma 61 3,750 3,811

District of Columbia 1 7 8

Territories 6 283 289

Tribes 17 72 90

Federal Facilities 10 0 10

Total 158 33,703 33,861

1. Includes all entities responsible for right-of-way ditch bank pest control and all government entities responsible for aquatic weed 

control, except for Idaho in which 10% of the public government entities are assumed to be above the threshold. 

2. Includes 90% of public government entities in Idaho, drinking water utilities and industrial facilities with surface water intakes, 

farmers, and private property owners. 

3.3. Aquatic Nuisance Animal Control 

Aquatic nuisance animal species are any species that negatively impact aquatic biodiversity. 

Impacts can be in the form of decreased water quality, impeded commercial and recreational 

activities (e.g. fishing, boating, agricultural irrigation) and reduced populations of native aquatic 

species including those that are threatened or endangered. Aquatic nuisance animal species 

include, but are not limited to, lamprey, mollusks, and fish. The type of control required for an 

aquatic nuisance animal depends on the biology of the target species and the environmental 

conditions and concerns for a specific area. Control methods could include chemical, 

mechanical, physical, and biological. In general, control methods not only limit target species 

number, but also restore native species and habitats and prevent future invasions. 

There is limited information on the number and types of entities responsible for aquatic nuisance 

animal control in the unauthorized areas. However, because there may be some level of aquatic 

nuisance animal control within each of the unauthorized areas at the government level (see 

section 4.3 regarding the Aquatic Nuisance Prevention and Control Act of 1990), EPA assumes 

that there is at least one public entity in each unauthorized state or territory affected by the draft 

PGP for aquatic nuisance animal control. For tribes, in the absence of more specific information, 

EPA assumes that 10% of total entities use pesticides for aquatic nuisance animal control. For 
20 May 2010 

federal entities, EPA assumes that each unique agency (10 total) is using pesticides for aquatic 

nuisance animal control. 

In addition to statewide control of aquatic nuisance animals, public drinking water utilities and 

industrial facilities with surface water intakes (Table 3-3 and Table 3-5) may also use pesticides 

for aquatic nuisance animal control. In marine or estuarine waters, hydrozoans, anemones, 

barnacles, bryozoans, entoproct, tunicates, polychaetes, and bivalves can cause biofouling and 

damages to intake structures; mollusks such as Asiatic clams, zebra mussels, and quagga mussels 

can be problems in fresh waters. The occurrence of these invasive nuisance species varies across 

the country (e.g., USGS distribution maps indicate that there are no Asiatic clams in Alaska but 

they are prevalent in Massachusetts; there are no zebra mussels in Idaho or New Mexico). In the 

absence of specific information on the location of the facilities using pesticides to control for 

aquatic nuisance animals at intake structures, EPA assumes that 10% of public drinking water 

utilities and industrial facilities with surface water intakes could be affected by the draft PGP 

(Table 3-8). 

Table 3-8: Estimated Number of Potentially Affected Entities with Surface Water Intakes 

Public Drinking Water Utilities Industrial Facilities

State Number with 

Surface Water 

Intake1 

Number 

Potentially 

Affected2 

Number with 

Surface Water 

Intake3 

Number 

Potentially 

Affected2 

Alaska 103 10 37 4

Idaho 54 5 50 5

Massachusetts 168 17 81 8

New Hampshire 56 6 28 3

New Mexico 43 4 33 3

Oklahoma 605 61 119 12 

District of Columbia 5 1 2 0

Territories 217 22 66 7

Tribes 61 6 11 1

Total 1,312 132 427 43 

1. Table 3-3. 

2. Based on assumption that approximately 10% could be affected by draft PGP. 

3. Table 3-5. 

Table 3-9 summarizes the total number of potentially affected entities for the aquatic nuisance 

animal control use pattern. This table incorporates the number of potentially affected entities 

from Table 3-8 and the number of government entities based on the assumption that aquatic 

nuisance animal control is performed at the state/government level by a single public entity. 
21 May 2010 

Table 3-9: Potential Number of Affected Entities: Aquatic Nuisance Animal Control 

Potential Number of Affected Entities Area Government1 Drinking Water Utility2 Industrial3 Total 

Alaska 1 10 4 15

Idaho 1 5 5 11

Massachusetts 1 17 8 26

New Hampshire 1 6 3 10

New Mexico 1 4 3 8

Oklahoma 1 61 12 74

District of Columbia 1 1 0 2

Territories 6 22 7 35

Tribes 17 6 1 24

Federal Facilities 10 0 0 10

Total 40 132 43 215

1. Based on assumption that aquatic animal nuisance control is performed at state level by a single public entity. For tribes and 

federal facilities, EPA based estimated number of entities on assumption that 10% of entities could be affected by the draft PGP. 

2. Based on number of surface water systems in EPA’s SDWIS database for each area and assuming 10% would use pesticides 

for aquatic nuisance animal control at intakes. 

3. Based on number of NPDES dischargers (excluding general and stormwater permits) in each area, average percent of 

industrial facilities with surface water intakes [25%; 1999 316(b) Rulemaking Survey], and assuming 10% would use pesticides for 

aquatic nuisance animal control at intakes. 

The draft PGP establishes annual treatment area thresholds applicable to permittees for 

identifying the need to comply with some permit requirements. For aquatic nuisance animal 

control, the water-treatment area annual threshold is 20 acres of water treatment, or 20 linear 

miles at water’s edge. Because drinking water utilities and industrial facilities with surface water 

intakes are likely to only treat in the vicinity of the intake structure to control for aquatic 

nuisance animals, they would not be above the threshold. EPA assumes that because the 

government entities performing aquatic nuisance animal control are state agencies, the 

application areas could exceed the thresholds. Table 3-10 summarizes the number of entities 

above and below applicable thresholds. 

Table 3-10: Entities Exceeding Annual Treatment Area Thresholds: Aquatic Nuisance Animal 

Control 

Number of Affected Entities State Above Threshold1 Below Threshold2 Total 

Alaska 1 14 15

Idaho 1 10 11

Massachusetts 1 25 26

New Hampshire 1 9 10

New Mexico 1 7 8

Oklahoma 1 73 74

District of Columbia 1 1 2

Territories 6 29 35

Tribes 17 7 24

Federal Facilities 10 0 10

Total 40 175 215

1. Includes state-level government entities responsible for aquatic nuisance animal control. 

2. Includes drinking water utilities and industrial facilities with surface water intakes. 
22 May 2010 

3.4. Forest Canopy Pest Control 

Forest canopy pest control activities affected by the draft PGP include aerial pest control projects 

in and over forest canopies where there are waters of the United States below the canopy. Under 

this use pattern, pesticides will be unavoidably discharged to waters in the course of controlling 

pests (but not necessarily aquatic) that are present near or over waters. These pests may include 

airborne non-aquatic insects, and other non-aquatic organisms detrimental to industry, the 

environment, or public health. Spraying can be performed seasonally or periodically as the need 

arises and is generally triggered by surveillance data indicating a problem. Although there are 

mechanical and physical techniques that can help control widely dispersed infestations, these 

techniques are often cost prohibitive. The National Forest Alliance Organization (NAFO, 2009) 

indicates that there are generally only two circumstances in which forest pesticide application 

would be over or directly adjacent to natural waters: 

3⁄4 Insecticide use to control insects such as gypsy moth, where application to the forest 

canopy of the entire affected area is required 

3⁄4 Herbicide use in forested wetlands that are managed for timber production. 

However, the latter does not represent the forest canopy, and therefore is not covered under this 

permit. 

There is no specific information on the use of forest canopy pest control in the unauthorized 

areas. However, EPA has information indicating the presence of state and national parks as well 

as private forest land. EPA assumes that public forest land is managed at the state government 

level, and that there is at least one public entity in each unauthorized state affected by the draft 

PGP for forest canopy pest control. For territories, EPA relied on publicly available data from 

territory websites (FAO, 2005) and the National Forest Service (USDA, 2001; 2002) to identify 

whether forested land exists. For tribes, Bureau of Indian Affairs (BIA, 2005) identifies tribes 

with forest/timberland management plans. EPA assumes that all tribes with management plans 

could be affected by the draft PGP. For federal facilities, EPA used GIS data (from National 

Atlas Federal Lands layer) to locate national parks in the unauthorized states. For private forest 

land, EPA used data from Birch (1994) to identify the number of private forest property owners 

in each state. Survey results of four National Forest Alliance Organization (NAFO) member 

companies with the largest forest land ownership indicate that pesticides are used on 

approximately 5% of land and that insecticides are used on 2% of treated land (NAFO, 2009). 

Table 3-11 summarizes the number of potentially affected entities for the unauthorized areas. 
23 May 2010 

Table 3-11: Potentially Affected Entities: Forest Canopy Pest Control 

Potential Number of Affected Entities Area Government1 Private2 Total 

Alaska 1 17 18

Idaho 1 47 48

Massachusetts 1 213 214

New Hampshire 1 84 85

New Mexico 1 25 26

Oklahoma 1 158 159

District of Columbia 0 0 0

Territories 4 6 10

Tribes 33 17 50

Federal Facilities 22 7 29

Total 65 574 639

1. For states, based on assumption that forest canopy pest control is performed at the state/government level by a 

single public entity. For the District of Columbia, territories, tribes and federal facilities, EPA based estimated number of 

entities on GIS data indicating the presence of forest land. 

2. Birch (1994) provides data on the number of private forest land owners in each unauthorized state; NAFO (2009) 

suggests that pesticides may be used on 5% of lands, and that pesticides are applied aerially on 2% of these lands. 

The draft PGP establishes annual treatment area thresholds for identifying the need to comply 

with various permit requirements. For forest canopy pest control, the annual treatment area 

threshold is 640 acres of forest canopy. EPA assumes that all government entities would exceed 

the treatment area threshold. For private forest owners, Birch (1994) provides data on the 

number of forests greater than and less than 500 acres for various regions. Based on these 

proportions, EPA estimated the number of private forest land owners likely to exceed the annual 

treatment area threshold. Table 3-12 summarizes the potential number of entities exceeding and 

not exceeding the annual treatment area threshold. 

Table 3-12: Entities Exceeding Annual Treatment Area Thresholds, Forest Canopy Pest Control 

Number Exceeding Threshold1 Number Not Exceeding Threshold2 

Area Government Private Government Private 

Alaska 1 0 0 17

Idaho 1 1 0 46

Massachusetts 1 1 0 212

New Hampshire 1 0 0 84

New Mexico 1 0 0 25

Oklahoma 1 1 0 157

District of Columbia 0 0 0 0

Territories 4 6 0 0

Tribes 33 17 0 0

Federal Facilities 22 7 0 0

Total 65 33 0 541

1. Based on assumption that all government entities exceed the threshold; for private entities, number exceeding threshold based 

on proportion of forest greater than and less than 500 acres from Birch (1994). Massachusetts and New Hampshire in New 

England Region, Oklahoma in Southern region, Idaho and New Mexico in Rocky Mountain Region, and Alaska in Pacific region. 

2. Based on assumption that no government entities fall below the threshold; for private entities, number below the threshold 

based on proportion of forest greater than and less than 500 acres from Birch (1994). Massachusetts and New Hampshire in New 

England Region, Oklahoma in Southern region, Idaho and New Mexico in Rocky Mountain Region, and Alaska in Pacific region. 
24 May 2010 

3.5. Summary 

Table 3-13 summarizes the estimates of potentially affected entities by unauthorized area and use 

pattern. Approximately 31,600 (91%) of these entities are operators of irrigated farms. There is 

substantial uncertainty regarding whether all of these entities will be affected by the draft PGP. 

Moreover, as mentioned EPA does not expect that farmers will exceed the annual treatment area 

threshold. 

Table 3-13: Summary of Potentially Affected Entities1

Area 

Mosquito and 

Other Flying 

Insect Pest 

Control 

Aquatic Weed 

and Algae 

Control 

Aquatic 

Nuisance 

Animal 

Control 

Forest 

Canopy Pest 

Control 

Total 

Alaska 2 325 15 18 360

Idaho 23 16,313 11 48 16,395

Massachusetts 9 2,140 26 214 2,389

New Hampshire 44 632 10 85 771

New Mexico 13 10,244 8 26 10,291

Oklahoma 1 3,811 74 159 4,045

District of Columbia 1 8 2 0 11

Territories 1 289 35 10 335

Tribes 17 89 24 50 180

Federal Facilities 10 10 10 29 59

Total 121 33,861 215 639 34,836

1. Includes public and private entities. 

 
25 May 2010 

4. Overlap with Existing Requirements 

The draft PGP will only result in incremental costs associated with the technology-based effluent 

limitation provisions in instances in which the requirements represent activities not already being 

implemented by affected entities. This section summarizes publicly available data and 

information provided by the unauthorized states regarding existing (i.e., baseline) pesticide 

regulations and practices in relation to draft PGP requirements for the four use patterns. In 

addition, under the Federal Insecticide Fungicide and Rodenticide Act, the government controls 

the licensing, sale, and use of pesticides. FIFRA essentially requires applicators to use pesticides 

in accordance with label specification and to minimize the amount needed for use. FIFRA also 

controls which pesticides can and cannot be used to control various pests. 

In instances of insufficient information to assess current compliance with any of the 

requirements of the draft PGP, EPA assumes that, in general, entities are not already 

implementing these requirements. 

4.1. Mosquito and Other Flying Insect Pest Control 

Information from the unauthorized areas indicates that certain entities are already implementing 

some of the requirements of the draft PGP related to mosquito and other flying insect control as a 

result of existing state requirements. As described below, the level of implementation varies 

greatly throughout unauthorized areas. In instances of insufficient information to assess current 

compliance with the requirements of the draft PGP, EPA assumes that, in general, entities are not 

already implementing these requirements. 

Alaska does not require any mapping or surveillance activities for its two mosquito control 

permits. In addition, ADEC did not provide data on existing pest management or pesticide use 

practices. Accordingly, EPA assumes that entities in Alaska are not currently implementing 

requirements for mosquito and other flying insect pest control in the draft PGP. 

The Idaho State Department of Agriculture (ISDA, 2009) indicates that 18 of 23 control districts 

in the state currently identify species and establish target population densities. In addition, ISDA 

(2009) suggests that approximately 10% of the districts in the state currently map breeding sites 

(2 of 23), and that between 75% and 100% of districts currently perform source reduction and 

habitat modification activities; to be conservative (i.e., erring on the side of higher costs), EPA 

assumes that only 75% (17 of 23) districts are currently performing these activities. In addition, 

ISDA (2009) indicates that no districts practice vegetation management. 

The Massachusetts Department of Environmental Protection (MADEP, 2009) indicates that each 

of nine mosquito control districts must identify the species of concern in their area; as part of 

those activities, the districts use light traps (MDAR, 2008). Each of the nine districts currently 

uses GIS mapping as a part of their IPM activities. Pest management activities in Massachusetts 

include some combination of source reduction and habitat modification activities in all mosquito 

control districts (MDAR, 2008). Eight of the nine districts indicate that they conduct some 

source reduction activities including: ditch management programs, open marsh water 

management (OMWM), and tire/container removal. While the Berkshire District does not 

indicate the use of source reduction activities, it (along with all other districts) performs specific 

ditch maintenance. Ditch maintenance programs within each district include inland/freshwater 

and salt marsh maintenance, as applicable, using either hand tools or mechanized equipment. 
26 May 2010 

Five of the nine districts also indicate the use of biological control measures, including 

introducing predatory fish and invertebrates to waters. These data suggest that the districts are 

largely already implementing the most efficient and effective means of pest management and are 

considering impact on non-target organisms, pest resistance, feasibility, and cost effectiveness. 

For New Hampshire, the NHDAMF (2009) indicates that all of the 43 mosquito control districts 

(plus the University of New Hampshire) currently identify species and establish densities. Only 

two commercial companies currently serve towns/cities within these districts, and both perform 

survey work as a part of their activities. The state has also compelled commercial applicators to 

add capabilities for producing maps electronically. Currently, New Hampshire permit 

applications routinely include very detailed electronic maps that identify potential breeding sites. 

NHDAMF (2009) indicates that little to no control measures beyond pesticide applications for 

mosquito control are used within the state. The information suggests that existing entities are 

likely to be in compliance with permit requirements to identify the problem (i.e., will not incur 

additional costs related to these requirements), but existing capacity to perform other control 

measures may be minimal. 

The New Mexico Department of Health (NMDOH) requires all county and municipal mosquito 

control programs to: 1) identify the source of the problem (i.e., locate breeding sources); 2) 

perform continuous surveillance; and 3) perform the periodic collection of adult mosquitoes for 

arbovirus testing (NMDOH, 2009). These requirements would likely result in compliance with 

requirements for identifying the problem in the draft PGP. The New Mexico Department of 

Agriculture (NMDA) did not provide data on existing pest management practices. Thus, it is 

uncertain whether current methods comply with draft PGP requirements. To be conservative 

(i.e., erring on the side of higher costs), EPA assumes that no districts in New Mexico are 

implementing measures consistent with the pest management and pesticide use requirements in 

the draft PGP. 

In Oklahoma, the ODAFF (2009) indicates that Tulsa is not in compliance with surveillance and 

mapping requirements in the draft PGP. ODAFF (2009) did not provide data on existing pest 

management practices. It is therefore uncertain whether current methods comply with draft PGP 

requirements. For the purpose of this analysis, EPA assumes that Tulsa is not currently 

implementing measures consistent with any of the requirements in the draft PGP. 

For the District of Columbia, information from the DOH indicates that the city performs 

surveillance, trapping, and testing (DCDOH, 2005). While it is likely that the DOH is already in 

compliance with the problem identification requirements of the PGP, given the lack of 

information on existing practices related to pest management and pesticide use requirements, 

EPA assumes that the District of Columbia is not currently implementing the applicable 

requirements. 

For tribes there is some indication that those using pesticides to control for mosquitoes and other 

flying insect pests may be implementing some of the requirements in the draft PGP. For 

example, the Arizona Department of Health Services works with tribes and IHS programs 

throughout Arizona on implementing West Nile virus surveillance and control. The program 

provides surveillance equipment, training, mosquito speciation and testing support, and larvicidal 

products (Arizona DHS, 2005). However, due to uncertainty related to the exact number of 

tribes using pesticides for mosquito control, EPA is unable to determine the extent of existing 
27 May 2010 

compliance with draft PGP requirements. To be conservative, EPA assumes in this analysis that 

no affected tribes are currently implementing draft PGP requirements to the extent necessary. 

In territories, there is limited information regarding existing pesticide practices for mosquito 

control. In Puerto Rico, the Puerto Rico Department of Health (PRDOH) collaborates with the 

Center for Disease Control (CDC) to implement mosquito control practices for the purpose of 

preventing the spread of West Nile Virus and Dengue Fever. Efforts include animal and 

mosquito surveillance, non-insecticide control measures and limited use of pesticides. Much of 

the West Nile Virus response plan indicates non-centralized efforts; however there is an overall 

mosquito control apparatus in place in Puerto Rico (PRDOH, no date). Based on this limited 

information, EPA assumes that Puerto Rico is the only territory already implementing problem 

identification and pest management requirements, and that none of the territories are 

implementing the pesticide use requirements of the draft PGP. 

There is little information on which federal facilities use pesticides for mosquito control and the 

measures currently implemented in relation to the requirements of the draft PGP. For the 

purpose of this analysis, EPA therefore assumes that no federal facilities are in compliance with 

any of the draft PGP requirements. 

Table 4-1 summarizes the information and assumptions regarding current compliance with the 

individual IPM requirements for mosquito and other flying insect pest control for the potentially 

affected entities. 

Table 4-1: Current Implementation of Best Management Practices for Mosquito and Other Flying 

Insect Pest Control 

Estimated Number of Entities in Compliance2 

Identify the Problem 

Area 

Number of 

Potentially 

Affected 

Entities1

Identifying Species 

and Targeting 

Densities 

Identifying and 

Mapping 

Breeding Sites

Pest 

Management 

Pesticide 

Use 

Alaska 0 0 0 0 0 

Idaho2 23 18 2 17 0 

Massachusetts 9 9 9 9 0 

New Hampshire 44 44 44 0 0 

New Mexico 13 13 13 0 0 

Oklahoma 1 0 0 0 0 

District of Columbia 1 1 1 0 0 

Territories 1 1 1 1 0 

Tribes 5 - 17 0 0 0 0 

Federal 10 0 0 0 0 

Total 107 - 119 86 70 27 0 

Sources: ADEC, 2009; ISDA, 2009; MADEP, 2009; NHDAMF, 2009; NMDOH, 2009; ODAFF, 2009. 

1. Potential affected entities that exceed treatment area thresholds (see Table 3.2) 

2. Based on discussion in Section 4.1. 

4.2. Aquatic Weed and Algae Control 

Information from the unauthorized areas indicates that certain entities are already implementing 

some of the requirements of the draft PGP related to aquatic weed and algae control as a result of 

existing state requirements. As described below, the level of implementation varies greatly in 

the unauthorized areas. 
28 May 2010 

Under Idaho’s water milfoil program, ISDA (2009) suggests 60% current compliance with 

activities to identify the problem and 40% compliance with application surveillance requirements 

of the draft PGP. In addition, ISDA (2009) suggests low use of mechanical and biological 

controls for aquatic weeds, and that mechanical/physical control methods are cost prohibitive in 

most areas of Idaho. 

In Massachusetts, MADEP (2009) indicates 100% compliance with activities to identify problem 

areas for its aquatic weed control permits. MADEP (2009) also indicates widespread use of 

mechanical controls and habitat modification practices prior to pesticide application, and limited 

use of methods to maintain, enhance and promote biological controls. However, MADEP (2009) 

indicates that virtually no application surveillance occurs in Massachusetts. 

New Hampshire estimated that anywhere from 50% to 100% of the entities to which it issues 

aquatic weed control permits are compliant with PGP problem identification requirements 

(NHDAMF, 2009). EPA assumes a midpoint of 75% compliance for problem identification 

activities. NHDAMF (2009) indicates that where practical, New Hampshire applicators engage 

in use of mechanical controls, habitat modification practices, and methods to maintain, enhance 

and promote biological controls. In addition, current compliance in application surveillance is 

100% due to the current permitting system (NHDAMF, 2009). 

Oklahoma estimated that 15% to 30% of the entities to which it issues aquatic weed control 

licenses are in compliance with the problem identification provisions of the draft PGP (ODAFF, 

2009). ODAFF (2009) also indicates a 10% compliance rate for biological control, a 15% to 

30% compliance rate for mechanical control, and that application surveillance occurs in 

approximately 15% to 30% of Oklahoma waters. Thus, EPA used midpoints of each range to 

estimate current compliance (e.g., 23% for problem identification, 20% for pest management, 

and 23% for pesticide use). 

The information on existing practices provides some information on potentially affected entities 

and current compliance (Table 4-2). 

Table 4-2: Current Implementation of Best Management Practices in Non-Drinking Water Entities: 

Aquatic Weed and Algae Control 

Percent of Non-Drinking Water and Non-Right-of-Way Entities 

Area Currently in Compliance 

Identifying the Problem Pest Management Pesticide Use 

Alaska No entities No entities No entities 

Idaho 60% 0% 40% 

Massachusetts 100% 0% 0% 

New Hampshire 75% 0% 100% 

New Mexico 0% 0% 0% 

Oklahoma 23% 20% 23% 

District of Columbia No entities No entities No entities

Territories No entities No entities No entities

Tribes 0% 0% 0%

Federal Facilities 0% 0% 0%

Sources: ADEC, 2009; ISDA, 2009; MADEP, 2009; NHDAMF, 2009; NMDA, 2009; ODAFF, 2009. 

In addition, right-of-way pesticide applicators and public drinking water utilities using pesticides 

to control aquatic weeds and algae at surface water intakes are already in compliance with 
29 May 2010 

problem identification and pesticide use requirements because both are necessary to successfully 

eradicate pests and eliminate the problem. It is uncertain whether the entities are implementing 

all of the pest management requirements. However, given that pest management provisions 

require use of pesticide alternatives where feasible, EPA assumes these entities are already using 

the most feasible or cost-effective methods available. 

4.3. Aquatic Nuisance Animal Control 

Current Federal regulations, specifically Section 1204 of the Aquatic Nuisance Prevention and 

Control Act of 1990 (amended as the National Invasive Species Act of 1996), require states to 

develop comprehensive Non-indigenous Aquatic Nuisance Species Management Plans. All of 

the states that are unauthorized to permit for pesticide discharges (Alaska, Idaho, Massachusetts, 

New Hampshire, New Mexico, and Oklahoma) have already developed or are currently in the 

late stages of developing these management plans: 

• Alaska – the plan details the aquatic nuisance species problems and concerns within the 

state as well as any pathways for the current and future introductions of species; 

management actions include sections concerning prevention of new species as well as 

detecting, monitoring, containing, reducing, or eradicating populations as quickly as 

possible with the lowest environmental impact (ADF&G, 2002). 

• Idaho – the plan presents high-priority animal species (both native and non-native to 

Idaho); plan sections cover early intervention-prevention, early detection and rapid 

response, and containment, control and restoration (IISC, 2007). 

• Massachusetts – the plan identifies the priority species (or species groups) for established 

freshwater and coastal species and threatening freshwater and coastal species including 

animals (mussels, clams, fish, etc.); management actions and objectives include 

prevention, monitoring, early detection/eradication, and control (MA AIS Working 

Group, 2002). 

• New Hampshire – the aquatic nuisance species (ANS) communication plan indicates that 

an overall management plan for aquatic nuisance species in the state is currently in 

development; this communication plan signifies that the state has identified the problem 

species and is in the process of determining the various means to control the species 

including monitoring efforts (NHFGD, 2006). 

• New Mexico – the plan includes objectives for preventing the introduction of aquatic 

invasive species (AIS) into New Mexico, detecting, monitoring, and eradicating pioneer 

AIS, and where feasible, controlling and eradicating established AIS that have significant 

impacts (AISAC, 2008). 

• Oklahoma – the plan defines the problem in the state including a list of non-indigenous 

aquatic animals (fish, mussels, snails, etc.); objectives include preventing the introduction 

of new ANS, detecting, monitoring, and eradicating ANS, and controlling and eradicating 

established ANS that have significant impacts (ODWC, 2008). 

In addition, Executive Order 13112 (February 1999), established the National Invasive Species 

Council (NISC) which was tasked with preparing and issuing a national plan to deal with 

invasive species, among other things. Completed in 2001, the National Invasive Species 

Management Plan serves as a comprehensive “blueprint” for federal action on invasive species. 

NISC (2008) estimates that 59% of the plan’s 170 specific actions have been completed or are in 
30 May 2010 

progress. The national plan has five strategic goals intended to be completed by 2012: 

prevention; early detection and rapid response; control and management; restoration; and 

organizational collaboration. Given the presence of the National Invasive Species Management 

Plan and the requirement for states to develop their own management plans for aquatic invasive 

species, it is likely that the District of Columbia, the six U.S. Territories, tribal lands in 31 states, 

and federal facilities in four states are covered by one of these plans. Therefore, the 

unauthorized areas should be in compliance with requirements related to identifying the problem 

and pest management in the draft PGP. Given the potential for current compliance with pesticide 

use under state and national invasive species management plans, incremental compliance costs 

associated with pesticide use for aquatic nuisance animal control are unlikely. 

EPA assumes that public drinking water utilities using pesticides to control aquatic nuisance 

animals at surface water intakes are already in compliance with problem identification and 

pesticide use requirements because both are necessary to successfully eradicate the pests and 

eliminate the problem. It is uncertain whether the utilities are implementing all of the pest 

management requirements. However, given that pest management provisions require use of 

pesticide alternatives where feasible, EPA assumes these entities are already using the most 

feasible or cost-effective methods available. 

4.4. Forest Canopy Pest Control 

There is no specific information on whether any current forest canopy applications are compliant 

with permit requirements for pesticide use. In general, the use of aerial forest canopy pest 

control necessitates a coordinated, controlled approach, including proper surveillance (e.g. 

identifying pests, identifying distribution of pests) and application assessment of effectiveness. 

Therefore, EPA assumes that where forest canopy pest control is occurring in the unauthorized 

areas, entities would already be in compliance with problem identification and pesticide use 

requirements in the draft PGP. For pest management, alternative methods are likely not to be 

feasible across large areas; thus, costs associated with pest management for forest canopy pest 

control may be minimal. 
31 May 2010 

5. Analysis of Costs 

This section provides an analysis of the potential incremental costs that may be associated with 

the draft PGP. Incremental costs represent expenditures above those required for existing 

regulations and current practices (i.e., baseline conditions) up to compliance with the draft PGP. 

The costs are divided into technology-based effluent limitation controls and administrative and 

monitoring. 

5.1. Technology-Based Effluent Limitations 

The method for estimating the potential incremental costs associated with the technology-based 

effluent limitation provisions in the draft PGP involves identifying entities that may be affected 

by the particular provision, determining incremental control activities (i.e., activities above and 

beyond those necessary under existing regulations) needed for compliance with the draft PGP, 

and estimating unit costs of those activities. Unit costs for the incremental activities multiplied 

by the number of affected entities performing the respective incremental activities provide an 

estimate of the incremental cost. Note that the costs presented in this section represent estimates 

and actual incremental costs may differ depending on the number of entities affected, current 

compliance costs, and existing level of controls. 

5.1.1. Minimizing Pesticide Discharges into Waters of the United States 

Section 2.1 of the draft PGP, Minimize Pesticide Discharges into Waters of the United States, 

requires the following: 

All operators must minimize the discharge of pollutants resulting from the application of 

pesticides. All operators must also do the following: 

Section 2.1.1 

Use the lowest effective amount of pesticide product per application and optimum 

frequency of pesticide applications necessary to control the target pest, consistent with 

reducing the potential for development of pest resistance; 

Section 2.1.2 

Perform regular maintenance activities to reduce leaks, spills, or other unintended 

discharges of pesticides associated with the application of pesticides covered under this 

permit; and 

Section 2.1.3 

Maintain pesticide application equipment in proper operating condition by adhering to 

any manufacturer’s conditions and industry practices, and by calibrating, cleaning, and 

repairing such equipment on a regular basis to ensure effective pesticide application and 

pest control. You must ensure that the equipment’s rate of pesticide application is 

calibrated to deliver the precise quantity of pesticide needed to achieve greatest efficacy 

against the target pest. 

The extent to which minimizing pesticide discharges into waters of the United States result in 

incremental compliance costs will depend on: (1) the extent to which pesticide use continues 

under the permit (see requirements for integrated pest management practices), (2) whether 
32 May 2010 

applicators are currently in compliance with the requirements, and (3) the unit costs of the 

activities. 

Estimates of the costs associated with the activities required under Section 2.1 of the draft PGP, 

as currently being implemented by affected entities, are not available. However, given FIFRA 

and pesticide label requirements that already stipulate the use of the lowest effective amount of 

the product per application (along with the optimum rate and frequency) and information from 

Idaho, Massachusetts, and New Hampshire indicating that all entities are currently performing 

maintenance (including equipment calibration) as a part of normal operating procedures (ISDA, 

2009; MADEP, 2009; and NHDAMF, 2009), incremental compliance costs are likely zero. 

5.1.2. Integrated Pest Management Practices 

The draft PGP requires implementation of IPM practices for pesticide applications performed by 

entities that will exceed the annual treatment area thresholds for the four use patterns: mosquito 

and other flying insect pest control, aquatic weed and algae control, aquatic nuisance animal 

control, and forest canopy pest control. 

5.1.2.1 Mosquito and Other Flying Insect Pest Control 

Under the draft PGP, pesticide applications for mosquito and other flying insect pest control 

must conform to IPM practices regarding identifying the problem, pest management, and 

pesticide use. 

Mosquito control activities are not performed at the same level (e.g., city, district) across the 

unauthorized areas, and information is not available on the area treated by those entities 

performing such activities. Thus, it is difficult to estimate costs to entities potentially affected by 

the draft PGP based on available cost or expenditure data. For example, program expenditures 

by mosquito control districts in Massachusetts (Table 5-1; MADEP, 2009) include a variety of 

activities required under the draft PGP (mapping breeding sites, surveillance, analyzing 

surveillance data, and alternatives to traditional pesticide use). However, these expenditures 

vary across districts, sometimes substantially (e.g., $800 for water management in the Suffolk 

District compared to $389,386 in the Cape Cod District). Differences in cost are most likely the 

result of different district sizes (e.g., population and area served/treated), and to a lesser extent, 

other issues such as different standard surveillance practices. 
33 May 2010 

Table 5-1: Massachusetts Mosquito Control District Expenditures 

Massachusetts Mosquito Control Districts Cost 

Category Bristol Berkshire Cape 

Cod Central Norfolk Northeast Plymouth Suffolk 

Breeding 

Sites, 

Mapping 

$79,539 $43,335 $180,081 $145,483 $126,711 $144,404 $124,013 -

Surveillance1 $95,496 - $32,045 $92,565 $93,742 $158,499 $86,919 -

Disease 

Surveillance $58,234 - - - - - $10,000 $8,000

Surveillance 

Data Analysis - - $17,472 $97,039 $55,492 - $56,511 -

Water 

Management $78,456 $1,760 $389,386 $199,637 $45,282 $124,583 $33,127 $800

Veg/land 

Mgmt & 

Sediment 

Removal 

$71,234 - - $141,662 $98,821 $127,420 $91,122 -

Adulticiding - 

ULV $213,456 $16,042 - $110,947 $151,833 $36,443 $245,061 $37,788

Larval Control $234,223 $50,039 $193,347 $131,690 $420,983 $359,404 $268,408 $217,406

Public 

Outreach/ 

Notifications 

$34,567 - - $139,992 $19,100 $440 $33,994 -

Email/Web 

Updates $8,790 - - $12,700 $6,000 $530 $9,600 -

Equipment - 

Trucks, ULV, 

etc 

$89,567 $7,490 $89,876 $122,247 $74,129 $62,500 $82,409 -

Pesticide 

Licenses & 

Training 

$7,234 $873 $4,225 $61,425 $5,480 $5,800 $4,170 -

Other Misc $134,000 $48,757 - $277,400 $274,961 $313,582 $343,453 -

Total $1,104,796 $168,296 $906,432 $1,532,787 $1,372,534 $1,333,605 $1,388,787 $263,994

Source: MADEP (2009) and MDAR (2008). No expenditure data reported for the East Middlesex District. 

‘’-“ = information unavailable. 

1. Also includes data analysis for some districts, although specific information on which districts and how much analysis cost is 

included is not available.

For example, the control districts vary in size and make-up (Figure 1, pg 11). Each district 

covers vastly different territory, ranging in densities from rural to suburban sprawl to urban, and 

from heavily forested area to coastal salt marshes. For example, the Suffolk County district 

covers two urban cities (Boston and Chelsea); Cape Cod covers 15 rural-to-suburban coastal 

cities and towns; and Berkshire covers eight rural and heavily forested towns. Central, East 

Middlesex, Norfolk are all primarily suburban districts; while Bristol, Plymouth and Northeast 

are mainly suburban-to-rural districts. All districts use larvicides, and all districts, except Cape 

Cod, use adulticides. In addition, all districts perform ditch maintenance (water management), 

and all, except East Middlesex, perform source reduction. The cost to perform different 

activities for each district reflect the budget for each district as well as the districts’ geographic 

area, local community values, topography and urban/suburban/rural characteristics (MADEP, 

2009 and MDAR, 2008). 

Available information on unit costs suggests that incremental costs to comply with the permit 

requirements for entities not currently performing these activities will vary substantially. 
34 May 2010 

Examples of factors that may affect incremental costs include land area, population density, 

water area, climate, geography, existing government expenditures and program capabilities, and 

opportunities to share capabilities with other nearby control districts or governments (e.g., 

Arizona DHS and IHS assistance to area tribes). Differences in incremental costs may also be 

attributed to the fact that some entities (e.g., towns, federal facilities) are likely to utilize 

commercial services rather than develop capabilities in house. 

Identify the Problem 

Section 2.2.1.1 of the draft PGP, Identify the Problem, requires the following: 

Prior to the first pesticide application covered under this permit that will result in a 

discharge to waters of the U.S., and at least once each calendar year thereafter prior to 

the first pesticide application for that calendar year, you must do the following for each 

pest management area, as defined in Appendix A: 

Section 2.2.1.1.1 

Establish densities for larval and adult mosquito or flying insect pest populations to serve 

as action threshold(s) for implementing pest management strategies; 

Section 2.2.1.1.2 

Identify target mosquito or flying insect pest species to develop species-specific pest 

management strategies based on developmental and behavioral considerations for each 

species; 

Section 2.2.1.1.3 

Identify known breeding sites for source reduction, larval control program, and habitat 

management; and 

Section 2.2.1.1.4 

Analyze existing surveillance data to identify new or unidentified sources of mosquito or 

flying insect pest problems as well as sites that have recurring pest problems. 

Section 2.2.1.1.5 

In the event there is no data for your pest management area in the past calendar year, see 

Part 5 for any documentation requirements regarding why current data are not available 

and the data you used to meet the permit conditions in Part 2.2.1.1. 

The potential for incremental compliance costs related to this section of the draft PGP depends 

on the extent to which mosquito and other flying insect pest control activities are currently being 

implemented by entities subject to IPM requirements in the unauthorized areas and the extent to 

which the required IPM activities—identifying mosquito or other flying insect species, 

establishing target densities, identifying known breeding sites, and analyzing surveillance data—

are already being performed under existing IPM programs. 

Potential Unit Costs 

Information on mosquito control efforts in Massachusetts indicates that the districts already 

identify species and establish target densities. Based on this information, the three cost 

categories for surveillance may reflect the permit requirements to identify the problem and 
35 May 2010 

analyze data. These costs range from $8,000 (Suffolk District) to approximately $190,000 

(Central District), with a midpoint of approximately $99,000. For identifying and mapping 

breeding sites, the Massachusetts control district costs range from $43,000 to $180,000, with a 

midpoint of approximately $112,000. Additional analysis would be needed to meaningfully 

normalize these expenditures by factors such as land area or population. However, the estimates 

may be representative of typical county- or regional-level expenditures related to problem 

identification for mosquito and other flying insect pest control. 

New Hampshire mosquito control occurs at the municipal level, and is currently performed by 

two commercial companies. Municipalities’ budgets can be as low as $15,000 per year and as 

high as $105,000 per year, but generally average $40,000 per year (McGregor, 2009). Average 

costs of adult surveillance may range from $4,000 to $8,000 per year, and the cost to perform 

larval surveillance activities varies greatly from town to town, but most likely exceeds the cost to 

perform adult surveillance (McGregor, 2009). In total, 25 municipalities spent over $400,000, or 

an average of $16,000 per municipality on larval surveillance (McGregor, 2009). Total costs for 

adult and larval surveillance could range from $20,000 to $24,000 per year ($4,000 to $8,000 per 

year plus $16,000 per year). New Hampshire Department of Health and Human Services 

(DHHS) estimates the cost of performing annual larval and adult surveillance at $15,000 

(NHDHHS, 2010). Thus, for entities that conduct mosquito control at a geographic level more 

similar to that of a municipality (compared to a larger mosquito control district), problem 

identification may be on the order of $15,000 to $24,000 annually, or approximately $20,000 per 

year, on average. 

As suggested by the information discussed above, entities that operate on a regional or county 

level (e.g., those in Idaho, Massachusetts, New Mexico, District of Columbia, territories, and 

federal agencies) may incur costs for identifying species and establishing target densities on the 

order of $99,000 and costs for identification and mapping of breeding sites on the order of 

$112,000. Entities that operate on a smaller, municipal level (e.g., those in Alaska, New 

Hampshire, Oklahoma, and tribal lands) may incur costs for species identification, establishment 

of densities, and mapping of approximately $20,000. 

Potential Total Costs 

Table 5-2 and Table 5-3 present estimates of the number of affected entities, potential 

incremental costs of surveillance and mapping compliance activities (described above), and the 

sum total of these potential incremental costs for Regional/District entities and Municipal 

entities, respectively. The number of affected entities is based on subtracting the number of 

entities currently implementing the required best management practices (BMPs) from the total 

number of affected entities (Table 3-1). 
36 May 2010 

Table 5-2: Estimated Incremental Costs to Regional/District Entities: Identifying the Problem, 

Mosquito and Other Flying Insect Pest Control 

Identifying Species and 

Targeting Densities 

Identifying and Mapping Breeding 

Sites 

Area Estimated 

No. of 

Entities1

Unit Cost 

($/entity)

Potential 

Cost 

Estimated 

No. of 

Entities1

Unit Cost 

($/entity) 

Potential 

Cost 

Total 

Potential 

Cost

Idaho 5 $99,000 $495,000 21 $112,000 $2,352,000 $2,847,000

Massachusetts 0 $99,000 $0 0 $112,000 $0 $0

New Mexico 0 $99,000 $0 0 $112,000 $0 $0

District of 

Columbia 0 $99,000 $0 0 $112,000 $0 $0

Territories 0 $99,000 $0 0 $112,000 $0 $0

Federal Facilities 10 $99,000 $990,000 10 $112,000 $1,120,000 $2,110,000

Total 22 NA $1,485,000 37 NA $3,472,000 $4,957,000

NA: not applicable 

1. Based on the difference between the number of potentially affected entities and the number of entities currently performing each 

activity (Table 4-1). 

Table 5-3: Estimated Incremental Costs to Municipal Entities: Identifying the Problem, Mosquito 

and Other Flying Insect Pest Control 

Area Estimated No. of 

Entities1 Unit Cost ($/entity) Potential Cost 

Alaska 0 $20,000 $0

New Hampshire 0 $20,000 $0

Oklahoma 1 $20,000 $20,000

Tribes 5 - 17 $20,000 $100,000 - $340,000

Total 6 - 18 NA $120,000 - $360,000 

NA: not applicable 

1. Based on the difference between the number of potentially affected entities and the number of entities currently performing each 

activity (Table 4-1). 

2. Total problem identification costs of $20,000 per entity for municipal-level entities are not broken out by species identification and 

breeding site mapping. 

Total cost associated with problem identification for mosquito and other flying insect control 

could be approximately $5,077,000 to $5,317,000 (sum of regional/district entity costs and 

municipality entity costs). 

Pest Management 

Section 2.2.1.2 of the draft PGP, Pest Management, requires the following: 

Prior to the first pesticide application covered under this permit that will result in a 

discharge to waters of the U.S., and at least once each calendar year thereafter prior to 

the first pesticide application for that calendar year, you must select and implement, for 

each pest management area, efficient and effective means of pest management that 

minimize discharges resulting from application of pesticides to control mosquitoes or 

other flying insect pests. In developing these pest management strategies, you must 

evaluate the following management options, considering impact to water quality, impact 

to non-target organisms, pest resistance, feasibility, and cost effectiveness: no action; 
37 May 2010 

prevention; mechanical/ physical methods; cultural methods; biological control agents; 

pesticides. 

Whether or not the requirements of Section 2.2.1.2 of the draft PGP result in incremental costs 

will depend on the extent to which pesticide applicators are currently implementing the most 

efficient and effective means of pest management to minimize pesticide discharges, and the net 

incremental cost of such methods (i.e., compared to conventional pesticide use). 

No Action: No action is to be taken, although a problem has been identified. This may be 

appropriate in cases where, for example, available control methods may cause secondary or nontarget impacts that are not justified or no available control methods exist. 

Prevention: Prevention strategies are program activities which eliminate developing pest 

populations through environmental modifications and/or habitat management. For mosquito 

control, these activities are physical methods, such as habitat modification, cultural methods that 

reduce sources of mosquitoes, and biological control. 

Mechanical/Physical Methods: Habitat modification, also known as physical or permanent 

control, is in many cases the most effective mosquito control technique available and is 

accomplished by eliminating mosquito breeding sites. Habitat modification activities have the 

potential to be both effective and economical in some areas and can virtually eliminate the need 

for pesticide use in and adjacent to the affected habitat. However, the ability to use prevention 

strategies is dependent upon local authority and restrictions. 

Cultural Methods: Cultural methods can reduce sources of mosquitoes and can be as simple as 

properly discarding old containers that hold water capable of producing Aedes aegypti, Ae. 

Albopictus or Culex spp. or as complex as implementing Rotational Impoundment Management 

(RIM) or Open Marsh Water Management (OMWM) techniques. 

Biological Control Agents: Biocontrol is utilization of parasites, predators, and pathogens to 

regulate pest populations; the major mechanism of biological control is Gambusia affinis 

(commonly referred to as mosquitofish). 

Pesticides: There are chemical and biological pesticide products registered for use against 

mosquitoes. 

Potential Unit Costs 

The extent to which methods other than pesticide use are efficient and effective means of pest 

management is site specific. For example, the City of Davis, California, established an IPM 

program in 1989, and in 2005 developed an IPM policy that included less reliance on chemical 

controls as well as balancing weed controls within economic constraints (2008). Several 

alternative pest control methods were continued in 2008 to reduce reliance on pesticides and 

meet IPM objectives, including: mechanical removal, hand removal, flooding, and weed habitat 

removal. However, the City notes that future reliance on these methods could be curtailed by 

budgetary constraints. (The City also used volunteer labor for some IPM program components.) 

Unit costs may also depend on the extent of the current use of methods other than pesticides. For 

example, the allocation of expenditures between pesticide related activities and other pest 

management activities varies greatly. Expenditures in the Suffolk District in Massachusetts are 

primarily related to pesticide application (approximately 97%). There may therefore be 

opportunities for more efficient or effective methods to minimize pesticide use. In comparison, 
38 May 2010 

only 22% of expenditures in the Cape Cod District in Massachusetts may be attributable to 

pesticide use, as compared with 43% for water management and vegetation and sediment 

removal. Feasible and cost-effective uses of methods that minimize pesticide discharges may be 

greater in that district and opportunities to replace remaining pesticide use less feasible or costeffective. 

As an estimate of potential expenditures related to the pest management options in the draft PGP, 

the expenditures in Table 5-1 for mosquito control districts in Massachusetts for water 

management and vegetation and sediment removal can be used. Costs of implementing these 

practices range widely ($800 in the Suffolk District to $389,000 in the Cape Cod District). In 

addition, ISDA (2009) indicates an annual cost of $7,500 per district for water management 

practices. The effectiveness of these activities for minimizing pesticide discharges may vary by 

location. However, the midpoint of total costs for implementing both water management and 

vegetation and sediment removal, based on the Massachusetts estimates, is approximately 

$195,000. These costs could be representative of costs that a regional entity or control district 

might spend on alternative, non-pesticide control methods; the low end of the range ($800) could 

be representative of expenditures associated with municipalities. 

Potential Total Costs 

Feasibility and cost-effectiveness may prevent entities from selecting any method for which the 

net incremental cost exceeds the cost of conventional pesticide application for a similar level of 

control. If all entities found other methods infeasible or not cost effective, incremental 

compliance costs would be zero. On the other end of the spectrum, the net incremental cost 

(over and above the cost of pesticide use for the same level of control) at which all entities may 

implement alternative methods would likely be close to zero, and incremental compliance costs 

would also be minimal. 

More likely, entities will work within budget constraints and site-specific circumstances to 

implement alternative methods of control when funds are available and seek additional funding 

to accommodate methods that minimize pesticide discharges. Chemical and safety costs 

associated with pesticide use could also increase over time and change the net incremental cost 

differential between conventional pesticide use and other methods. In this case, compliance 

costs would also likely be minimal. 

The incremental costs that any entity will bear in determining whether alternative methods are 

feasible and cost-effective is speculative; for example, the ability and willingness to incur 

increased control costs is likely related to income in the community, among other factors. Table 

 5-4 provides estimates of potentially affected entities and illustrative estimates of potential costs 

assuming that affected entities incur net incremental costs (costs of alternative methods less cost 

of conventional pesticide use) for water management and vegetation and sediment removal 

methods of approximately $195,000 for regional entities and $800 for municipalities. 
39 May 2010 

Table 5-4: Estimated Incremental Costs: Pest Management, Mosquito and Other Flying Insect Pest 

Control ($/yr) 

Area Entities Potentially Incurring 

Incremental Cost1

Potential Feasible Net 

Incremental Cost2

Alaska 0 $0

Idaho 6 $1,170,000

Massachusetts 0 $0

New Hampshire 44 $35,000

New Mexico 13 $2,535,000

Oklahoma 1 $1,0003

District of Columbia 1 $195,000

Territories 0 $0

Tribes 5 - 17 $4,000 - $14,000

Federal Facilities 10 $1,950,000

Total 80 - 92 $5,890,000 - $5,900,000

1. Based on the difference between the number of potentially affected entities and the number of entities currently performing

each activity (Table 4-1). 

2. Estimates for illustration only; actual costs/cost savings will be entity-specific. Costs calculated by multiplying the number of 

regional entities potentially incurring net incremental costs (in ID, MA, NM, District of Columbia, Territories Federal Facilities) 

by $195,000, and the number of municipalities potentially incurring net incremental costs (in AL, NH, OK and Tribes) by $800. 

3. Rounded up from $800. 

Pesticide Use 

Section 2.2.1.3 of the draft PGP, Pesticide Use, requires the following: 

If a pesticide is selected to manage mosquitoes or flying insect pests and application of 

the pesticide will result in a discharge to a water of the U.S., you must: 

Section 2.2.1.3.1 

Conduct larval and/or adult surveillance prior to each pesticide application to assess the 

pest management area and to determine when action threshold(s) are met that necessitate 

the need for pest management; 

Section 2.2.1.3.2 

Assess environmental conditions (e.g. temperature, precipitation, and wind speed) in the 

treatment area prior to each pesticide application to identify whether existing 

environmental conditions support development of pest populations and are suitable for 

control activities; 

Section 2.2.1.3.3 

Reduce the impact on the environment and on non-target organisms by applying the 

pesticide only when the action threshold has been met; and 

Section 2.2.1.3.4 

In situations or locations where practicable and feasible for efficacious control, use 

larvicides as a preferred pesticide for mosquito or flying insect pest control when larval 

action thresholds have been met; and 

Section 2.2.1.3.5 
40 May 2010 

In situations or locations where larvicide use is not practicable or feasible for efficacious 

control, use adulticides for mosquito or flying insect pest control when adult action 

thresholds have been met. 

The potential for the requirements of Sections 2.2.1.3.1 and 2.2.1.3.2 of the draft PGP to result in 

incremental costs depends on: the extent of current larval and adult surveillance and assessment 

of environmental activities prior to each pesticide application, per-application surveillance and 

assessment costs, and the number of pesticide applications still occurring after applicators select 

the most efficient and effective method of pest management to minimize pesticide discharges to 

waters of the United States. 

Since the effect of Section 2.2.1.2 of the draft PGP (selecting the most efficient and effective 

method to minimize pesticide discharges) on pesticide applications is not known, estimates of 

incremental compliance cost for surveillance would be speculative. Further, available 

information on current program expenditures (e.g., information from Massachusetts and Idaho) is 

not sufficient to determine whether surveillance and assessment of environmental conditions is 

performed before each application, or how many applications are reflected in existing program 

expenditures. For example, for entities currently conducting surveillance but not prior to each 

application, existing expenditures may not increase if non-pesticide methods replace some 

pesticide applications. For entities that do not currently conduct surveillance, incremental 

compliance costs are likely, but expenditures levels in other states may not be representative 

because pesticide application rates and amounts may differ. In addition, a portion of the 

surveillance costs may already be included in the surveillance estimates under problem 

identification. 

For Sections 2.2.1.3.3 and 2.2.1.3.5 of the draft PGP, costs are likely minimal or there may be a 

cost savings associated with only applying pesticides when an action threshold is met. 

For Sections 2.2.1.3.4 of the draft PGP, it is difficult to quantify the costs of using larvicides as 

the preferred pesticide (e.g., switching away from or decreasing the use of adulticides). 

However, there is some evidence to suggest that equipment costs associated with applying 

larvicides may be cheaper than applying adulticides (Town of Silvercity; Alabama Department 

of Public Health), although labor requirements may differ as well. While there is also evidence 

to suggest that adoption of IPM practices leads to slightly greater chemical spending on average, 

pesticide applications may be reduced as a result of selecting the most efficient and effective 

method to minimize pesticide use (Norton, 2009). Therefore, potential incremental costs 

associated with pesticide use provisions are likely minimal. 

5.1.2.2 Aquatic Weed and Algae Control 

The following practices apply to any pesticide applicator for aquatic weed and algae control that 

meets the annual treatment area thresholds (as identified in Section 3.2.3). 

Identify the Problem 

Section 2.2.2.1 of the draft PGP, Identify the Problem, requires the following: 

Prior to the first pesticide application covered under this permit that will result in a 

discharge to waters of the U.S., and at least once each calendar year thereafter prior to 

the first pesticide application for that calendar year you must do the following for each 

pest management area, as defined in Appendix A: 
41 May 2010 

Section 2.2.2.1.1 

Identify areas with aquatic weed or algae problems and characterize the extent of the 

problems, including, for example, water use goals not attained (e.g. wildlife habitat, 

fisheries, vegetation, and recreation); 

Section 2.2.2.1.2 

Identify target weed species; 

Section 2.2.2.1.3 

Identify possible factors causing or contributing to the weed or algae problem (e.g., 

nutrients, invasive species, etc); and 

Section 2.2.2.1.4 

Establish past or present aquatic weed or algae densities to serve as action threshold(s) 

for implementing pest management strategies. 

Section 2.2.2.1.5 

In the event there is no data for your pest management area in the past calendar year, see 

Part 5 for any documentation requirements regarding why current data are not available 

and the data you used to meet the permit conditions in Part 2.2.1.1. 

The potential for incremental compliance costs resulting from the draft PGP requirements to 

identify the problem will depend on the extent to which entities that control aquatic weeds and 

algae are currently conducting problem identification activities and the cost of such activities. In 

general, identifying weed species, weed issues, and more general aquatic conditions falls under 

the category of scouting. Scouting involves identifying weed species and evaluating weed 

location and density, and is done on the ground by walking and/or riding in an all-terrain vehicle 

or boat (Blankinship, 2009). On the ground, surveyors will visually observe the plants and map 

out problem areas (Hamel, 2009). Some will also use a sampling rake at intervals to collect, 

sample and identify the species. Other surveyors utilize viewing tubes, underwater cameras or 

divers and snorkelers to investigate conditions under the surface. Scouting can also be 

accomplished by aerial survey using helicopter or plane, though this method is more expensive 

(Blankinship, 2009). Where submerged aquatic weeds are present, bathymetric surveys can be 

employed. Locations and densities of aquatic plant nuisances are typically plotted using GIS 

software. 

Potential Unit Costs 

The amount of time necessary to scout an area depends on a variety of factors, including size and 

depth, access, type of weed, and time of year (Blankinship, 2009). A surveyor typically spends 

about one day per lake (200 acres or less) studying conditions and weed cover and assessing 

locations for herbicide application (Hamel, 2009). Typical costs may range from $100 per acre 

for a small pond or lake to $1,000 per day for a larger lake that requires a full day or longer to 

survey (Coble, 2009). Cost data for ditch bank scouting are not available. 

In order to properly identify sources of the problem, a full limnological study may be required 

(Hamel, 2009). Given the size, scope, and complexity of these studies, costs are, at a minimum, 

in the hundreds of thousands of dollars and can exceed millions of dollars per area. Hamel 

(2009) explains that most nutrient problems arise due to a variety of watershed inputs and are 
42 May 2010 

largely out of the control of local populations or regulating agencies. Due to the impracticality 

of performing a long-term study to identify problems, EPA assumes that problem identification 

will be much less nuanced and performed during surveillance to determine weed type and weed 

cover. That is, the potential cost of identification is likely closer to Coble’s (2009) lower 

estimate of $100 per acre. 

Potential Total Costs 

Table 5-5 summarizes the potentially affected area for aquatic weed control based on 

information in Section 3.2.3 and Section 4.2. For this analysis, EPA assumes that each affected 

entity represents a single waterbody, and the number of affected acres is calculated by 

multiplying the number of entities/waterbodies not already in compliance with draft PGP 

requirements by the average lake size in the state/area. Note that average water body sizes are 

below the threshold for aquatic weed control; however, EPA assumes that entities would need to 

treat for multiple pests, resulting in an increased treatment acreage exceeding the threshold. For 

federal entities, EPA assumes that approximately 1% of all waterbody acres located at federal 

facilities (225,619 acres, based on NHD GIS data) would need to be treated with pesticides for 

aquatic weed control. 

Also, the number of affected waterbodies does not include private property owners, such as ditch 

banks on farms and surface water intake structure operators, as these entities are not likely to 

exceed the annual treatment area thresholds (see Section 3.2.3). 

Table 5-5: Potential Costs: Identifying the Problem, Aquatic Weed Control 

Area 

Number 

of 

Affected 

Entities1

Percent of 

Entities Not 

in 

Compliance2

Number of 

Entities Not 

in 

Compliance2

Potential 

Acres not in 

Compliance4

Total 

Potential 

Costs ($/yr)5

Alaska 0 0% 0 0 $0 

Idaho 7 60% 3 25 $3,000 

Massachusetts 26 100% 0 0 $0 

New Hampshire 25 75% 6 46 $5,000 

New Mexico 0 0% 0 0 $0 

Oklahoma1 60 23% 46 110 $11,000 

District of Columbia 0 0% 0 0 $0 

Territories 0 0% 0 0 $0 

Tribes 17 0% 17 162 $16,000 

Federal Facilities 9 0% 9 2,256 $226,000 

Total 144 - 81 2,599 $261,000 

NA: not applicable 

1. Includes only government entities (see Table 3-6 and 3.7); EPA assumes that right-of-way ditch bank pesticide applicators and 

public drinking water utilities are not likely to incur net incremental costs. 

2. Compliance estimates based on percentages in Table 4-2. 

4. Calculated by assuming that each affected entity represents one waterbody, and multiplying the number of entities/waterbodies 

not in compliance with draft PGP requirements by the average lake size (in acres). For federal facilities, it is assumed that 1% of all 

waterbody acres on facility lands are treated with pesticides for aquatic weed and algae. 

5. Represents number of potentially affected acres not in compliance with draft PGP multiplied by a unit cost of $100/acre (Coble, 

2009).
43 May 2010 

Pest Management 

Section 2.2.2.2 of the draft PGP, Pest Management, requires the following: 

Prior to the first pesticide application covered under this permit that will result in a 

discharge to waters of the U.S., and at least once each calendar year thereafter prior to 

the first pesticide application for that calendar year, you must select and implement, for 

each pest management area, efficient and effective means of pest management that 

minimize discharges resulting from application of pesticides to control aquatic weeds or 

algae. In developing these pest management strategies, you must evaluate the following 

management options, considering impact to water quality, impact to non-target 

organisms, pest resistance, feasibility, and cost effectiveness: no action; prevention; 

mechanical/physical methods; cultural methods; biological control agents; pesticides. 

Whether or not the requirements of Section 2.2.1.2 of the draft PGP result in incremental costs 

will depend on 1) the extent to which pesticide applicators are currently implementing the most 

efficient and effective means of pest management to minimize pesticide discharges and 2) the net 

incremental cost of such methods (i.e., compared to conventional pesticide use). 

The efficiency and effectiveness of pest management methods that do not involve the use of 

pesticides will be site specific. 

No Action: No action is to be taken, although a problem has been identified. This may be 

appropriate in cases where, for example, available control methods may cause secondary or nontarget impacts that are not justified or no available controls exist. 

Prevention: Preventing introductions of possible aquatic weeds and algae is the most efficient 

way to reduce the threat of nuisance species (ANS Task Force, 2009). Identifying primary 

pathways of introduction and actions to cut off those pathways is essential to prevention. 

Through a better understanding of the transportation and introduction of aquatic weeds and 

algae, private entities (aquaculture) and the public have the necessary knowledge to assist in 

local aquatic weed and algae control by reducing conditions that encourage the spread of aquatic 

weeds and algae in their immediate surroundings. For example, recreational water users provide 

a pathway of unintentional introductions. Increasing public awareness of aquatic weeds and 

algae, their impacts, and what individuals can do to prevent their introduction and spread is 

critical for prevention. Other examples of prevention include: better design of water holding 

sites, better management and maintenance of potential problem sites, and volunteer removal of 

pest species (e.g., hand weeding). Monitoring and detection also play important roles in the 

prevention of the spread and introduction of aquatic weeds and algae. 

Mechanical and Biological Control: Mechanical and biological controls will be the appropriate 

method of control method in some cases, or a part of a combination of methods. In some 

instances, the need for chemical pesticide use in and adjacent to the affected habitat can be 

reduced or virtually eliminated with proper execution of alternative strategies and proper best 

management practices. 

Mechanical control techniques will vary depending on the pest. Examples include dewatering, 

pressure washing, abrasive scrubbing, and weed removal by hand or machine. 

Biological control of aquatic weeds and algae may be achieved through the introduction of 

diseases, predators, or parasites. While biological control generally has limited application for 
44 May 2010 

control of aquatic weeds and algae, the operator should fully consider this option in evaluating 

pest management options. 

Cultural Methods: Cultural techniques include the use of pond dyes and water-level drawdown. 

Pond dyes are used to manage filamentous algae and submersed (underwater) vegetation. Several 

pond colorants and one or two dyes are EPA-registered for aquatic-weed control. They are 

effective if there is little water outflow from the pond; however, they are intended to intercept 

sunlight needed by algae and other underwater plants for photosynthesis and thus tend to be 

ineffective on floating plants like duckweed and water lilies and emergent (growing above the 

surface) plants like cattails and bulrushes. They are nontoxic and do not kill the plants, and they 

are safe for use in ponds for irrigation, fishing and livestock. They are not intended for use in 

large lakes with significant water flow or lakes used for public water supplies.7 

Pesticides: Aquatic herbicides are chemicals specifically formulated for use in water to kill or 

control aquatic plants. Aquatic herbicides are sprayed directly onto floating or emergent aquatic 

plants or are applied to the water in either a liquid or pellet form. Systemic herbicides are 

capable of killing the entire plant. Contact herbicides cause the parts of the plant in contact with 

the herbicide to die back, leaving the roots alive and able to re-grow. Non-selective, broad 

spectrum herbicides will generally affect all plants that they come in contact with. Selective 

herbicides will affect only some plants.8

Potential Unit Costs 

ISDA (2009), MADEP (2009), NHDAMF (2009), and ODAFF (2009) all provide various unit 

costs for aquatic weed management. For mechanical/physical methods of control, estimates vary 

from a low of $460 to a high of $5,000 per acre, and from $12,000 to $20,000 per mile of river. 

The only estimate for light attenuation is between $50 and $500 per acre. Estimates for bottom 

barriers vary from $15,300 per acre to $50,000 per acre. The estimates for the cost of biological 

agents range from $15 per acre to $3,000 per acre. 

Net unit costs equal the cost of the most efficient/effective method less the total cost of pesticide 

use (e.g., any surveillance costs that would not be incurred with other methods). However, 

information is not available on the current cost of pesticide use. Costs may also vary based on 

the extent of current use of alternative methods; operators already using the most feasible and 

cost-effective opportunities to minimize pesticide discharges would not likely incur costs related 

to use of non-pesticide methods. 

Potential Total Costs 

As described in the mosquito control section, feasibility and cost-effectiveness may prevent 

entities from selecting any method for which the net incremental cost exceeds the cost of 

pesticide application for a similar level of control. If all entities found non-pesticide methods 

infeasible/not cost effective, incremental compliance costs would be zero. However, more 

likely, entities will work within budget constraints and site-specific circumstances to implement 

alternative methods of control when funds are available, seek funding increases over time to 

accommodate methods that minimize pesticide discharges, or work with other jurisdictions to 

gain efficiencies and economies of scale. 

 

7 http://www.grounds-mag.com/mag/grounds_maintenance_weeds_overboard/

8 http://www.ecy.wa.gov/programs/wq/plants/management/aqua028.html
45 May 2010 

The level of any positive net incremental cost that entities will bear in determining whether 

alternative methods are feasible and cost-effective is speculative; the ability and willingness to 

incur increased control costs is likely related to income in the community and type of entity, 

among other factors. For example, given that pesticide use along right-of-way ditch banks 

typically covers large areas, either the selection of less targeted methods or no action may be 

more likely considering feasibility and cost effectiveness. In addition, information is lacking as 

to whether the current mix of methods will change under the permit. For example, NHDAMF 

(2009) suggests that methods that minimize pesticide discharges are currently being considered 

and employed where feasible. Similarly, available unit cost estimates vary by orders of 

magnitude, even for the same method, suggesting that site-specific conditions affect unit costs. 

Notwithstanding these uncertainties, Table 5-6 provides potential incremental cost estimates to 

government entities that are currently controlling aquatic weeds with pesticide use for lakes and 

ponds based on the assumption that the entities would be willing and able to bear a net 

incremental cost (i.e., cost difference between pesticide use and use of an alternative method) 

ranging from $50 per acre to $500 per acre on half of affected acres. The ability to incur such 

net incremental costs may be higher or lower depending on the specific entity and area treated. 

Costs to state departments of transportation responsible for right-of-way ditches are likely to be 

minimal based on the assumption that if more feasible or cost-effective methods were available 

they would already be in use. 

Table 5-6: Potential Affected Acres and Feasible Costs: Pest Management, Aquatic Weed and 

Algae Control1 

Net Incremental Cost 

($/yr)6

Area 

Potential 

Number of 

Affect 

Entities2

Percent of 

Entities not 

in 

Compliance3

Average 

Lake 

Size 

(acres)4

Potential 

Acres not in 

Compliance5 $50/acre $500/acre 

Alaska 0 0% 11 0 $0 $0 

Idaho 7 0% 8.3 29 $1,000 $15,000 

Massachusetts 26 0% 7.5 98 $5,000 $49,000 

New Hampshire 25 0% 7.6 95 $5,000 $48,000 

New Mexico 0 0% 3.4 0 $0 $0 

Oklahoma 60 23% 2.4 55 $3,000 $28,000 

District of Columbia 0 0% 2.4 0 $0 $0 

Territories 0 0% 11.9 0 $0 $0 

Tribes 17 0% 9.5 81 $4,000 $41,000 

Federal Facilities 9 0% NA 1128 $56,000 $564,000 

Total 144 - - 1,486 $74,000 $745,000 

NA: not applicable 

1. Illustrative cost; feasible controls and costs will be site specific. 

2. Includes only government entities (see Table 3-6 and 3.7); EPA assumes that entities responsible for right-of-way ditch bank 

applications are not likely to incur net incremental costs. 

3. Compliance estimates based on percentages in Table 4-2. 

4. Source: USGS (2009). 

5. Calculated based on assumption that each entity represents a single waterbody and multiplying number of entities/waterbodies by 

the average lake size (1% of waterbody acres for federal facilities), and assuming that only 50% of the acres are treated. 

6. Calculated based on assumption that entities would be willing and able to incur net incremental cost ranging from $50/acre to 

$500/acre.
46 May 2010 

Pesticide Use 

Section 2.2.2.3 of the draft PGP, Pesticide Use, requires the following: 

If a pesticide is selected to manage aquatic weeds or algae and application of the 

pesticide will result in a discharge to a water of the U.S., you must: 

Section 2.2.2.3.1 

Conduct surveillance prior to each pesticide application to assess the pest management 

area and to determine when the action threshold is met that necessitates the need for pest 

management; and 

Section 2.2.2.3.2 

Reduce the impact on the environment and non-target organisms by applying the 

pesticide only when the action threshold has been met. 

The potential for the draft PGP requirements regarding pesticide use to result in incremental 

compliance costs will depend on both the extent to which pesticides are used under the permit 

after selection of the most efficient/effective method to minimize pesticide discharges (Section 

2.2.2.2 of the draft PGP) and the extent to which pesticide applicators are currently conducting 

application surveillance. 

Potential Unit Costs 

ISDA (2009) indicates a range of $100 per acre to $1,000 per waterbody for surveillance 

monitoring of aquatic weed treatments. Under the draft PGP, applicators that are currently 

conducting surveillance and switch to other non-pesticide methods to minimize pesticide 

discharges will no longer incur costs. 
47 May 2010 

Total Potential Costs 

Table 5-7 presents potential costs associated with the draft PGP requirements for pesticide use 

assuming surveillance costs of approximately $100/acre (ISDA, 2009). In addition, right-of-way 

pesticide applicators using pesticides to control aquatic weeds and algae at surface water intakes 

are already in compliance with pesticide use requirements because such activities are necessary 

to successfully eradicate the pests and eliminate the problem. 

Table 5-7: Potential Costs: Pesticide Use, Aquatic Weed and Algae Control 

Area 

Number of 

Affected 

Entities1

Number of 

Entities Not in 

Compliance2

Average 

Lake Size 

(acres)3

Potential 

Acres not in 

Compliance4

Total 

Potential 

Costs ($/yr)5

Alaska 0 0 11 0 $0 

Idaho 7 4 8.3 33 $3,000 

Massachusetts 26 26 7.5 195 $20,000 

New Hampshire 25 0 7.6 0 $0 

New Mexico 0 0 3.4 0 $0 

Oklahoma 60 46 2.4 110 $11,000 

District of Columbia 0 0 2.4 0 $0 

Territories 0 0 11.9 0 $0 

Tribes 17 17 9.5 162 $16,000 

Federal Facilities 9 9 NA 2256 $226,000 

Total 144 102 - 2,756 $276,000 

NA: not applicable 

1. Illustrative cost; feasible controls and costs will be site specific. 

2. Includes only government entities (see Table 3-6 and 3-7); EPA assumes that right-of-way ditch bank pesticide applicators are 

not likely to incur net incremental costs. 

3. Compliance estimates based on percentages in Table 4-2. 

4. Source: USGS (2009) 

5. Calculated by assuming that each affected entity represents one waterbody, and multiplying the number of entities/waterbodies 

not in compliance with draft PGP requirements by the average lake size (in acres). For federal facilities, EPA assumes that 1% of 

waterbody acres on these lands would be treated for aquatic weeds. 

6. Estimated by multiplying number of potentially affected acres not in compliance with the draft PGP by unit cost of $100/acre

(Coble, 2009). 

5.1.2.3 Aquatic Nuisance Animal Control 

The following practices apply to pesticide applications for aquatic nuisance animal control. 

Identify the Problem 

Section 2.2.3.1 of the draft PGP, Identify the Problem, requires the following: 

Prior to the first pesticide application covered under this permit that will result in a 

discharge to waters of the U.S., and at least once each calendar year thereafter prior to 

the first pesticide application for that calendar year, you must do the following for each 

pest management area, as defined in Appendix A: 

Section 2.2.3.1.1 

Identify areas with aquatic nuisance animal problems and characterize the extent of the 

problems, including, for example, water use goals not attained (e.g. wildlife habitat, 

fisheries, vegetation, and recreation); 

Section 2.2.3.1.2 
48 May 2010 

Identify target aquatic nuisance animal species; 

Section 2.2.3.1.3 

Identify possible factors causing or contributing to the problem (e.g., nutrients, invasive 

species); and 

Section 2.2.3.1.4 

Establish past or present aquatic nuisance animal densities to serve as action 

threshold(s) for implementing pest management strategies. 

Section 2.2.3.1.5 

In the event there is no data for your pest management area in the past calendar year, see 

Part 5 for any documentation requirements regarding why current data are not available 

and the data you used to meet the permit conditions in Part 2.2.1.1. 

The extent to which requirements to identify the problem will result in incremental compliance 

costs depends on the extent to which affected entities are currently conducting such activities, 

and the cost of the actions. 

However, given the potential for current compliance with problem identification under state and 

national invasive species management plans (Section 4.3), incremental compliance costs 

associated with problem identification for aquatic nuisance animal control are unlikely. 

Pest Management 

Section 2.2.3.2 of the draft PGP, Pest Management, requires the following: 

Prior to the first pesticide application covered under this permit that will result in a 

discharge to waters of the U.S., and at least once each year thereafter prior to the first 

pesticide application during that calendar year, you must select and implement, for each 

pest management area, efficient and effective means of pest management that minimize 

discharges resulting from application of pesticides to control aquatic nuisance animals. 

In developing these pest management strategies, you must evaluate the following 

management options, considering impact to water quality, impact to non-target 

organisms, pest resistance, feasibility, and cost effectiveness: no action; prevention; 

mechanical/physical methods; biological control agents; pesticides. 

No Action: No action is to be taken, although an aquatic nuisance animal problem has been 

identified. This may be appropriate in cases where, for example, available control methods may 

cause secondary or non-target impacts that are not justified or no available controls exist. 

Prevention: Preventing introductions of possible nuisance species is the most efficient way to 

reduce the threat of aquatic nuisance animals (ANS Task Force, 2009). Identifying primary 

pathways of introduction and actions to cut off those pathways is essential to prevention. 

Through a better understanding of the transportation and introduction of aquatic nuisance 

animals, private entities (aquaculturists) and the public have the necessary knowledge to assist in 

local aquatic nuisance animal control by reducing conditions that encourage the spread of aquatic 

nuisance animals in their immediate surroundings. For example, recreational water users provide 

a pathway of unintentional introductions. Increasing public awareness of aquatic nuisance 

species, their impacts, and what individuals can do to prevent their introduction and spread is 
49 May 2010 

critical for prevention. Other examples of prevention include: better design of water holding 

sites, better management and maintenance of potential problem sites, and volunteer removal of 

pest species (e.g., fishing). Monitoring and detection also play important roles in the prevention 

of the spread and introduction of aquatic nuisance animals. 

Mechanical and Biological Control: Mechanical and biological controls will be the appropriate 

methods of control method in some cases, or a part of a combination of methods. Mechanical 

control techniques will vary depending on the pest. Examples include fishing, dewatering, 

netting, electrofishing, pressure washing, use of electric fences and abrasive scrubbing. 

Biological control of aquatic nuisance animals may be achieved through the introduction of 

diseases, predators, or parasites. While biological control generally has limited application for 

control of aquatic nuisance animals, operators should fully consider this option in evaluating pest 

management options. 

Pesticide: Chemical and biological pesticides, such as lampricides, molluscides, and piscicides, 

are registered for use to control aquatic nuisance animals. These pesticides are specifically 

formulated for use in water where aquatic nuisance animals occur. In some cases, pesticide use 

may impact non-target species. 

The potential for pest management requirements to result in incremental costs depends on the 

extent to which the plans described above are already in compliance with permit requirements to 

minimize pesticide discharges, and the net incremental cost associated with alternative methods 

of pest control. However, given the potential for current compliance with pest management 

under state and national invasive species management plans (Section 4.3), incremental 

compliance costs associated with pest management for aquatic nuisance animal control are 

unlikely. 

Pesticide Use 

Section 2.2.3.3 of the draft PGP, Pesticide Use, requires the following: 

If a pesticide is selected to manage aquatic nuisance animals and application of the 

pesticide will result in a discharge to a water of the U.S., you must: 

Section 2.2.3.3.1 

Conduct surveillance prior to each application to assess the pest management area and 

to determine when the action threshold is met that necessitates the need for pest 

management; and 

Section 2.2.3.3.2 

Reduce the impact on the environment and non-target organisms by evaluating site 

restrictions, application timing, and application method in addition to applying the 

pesticide only when the action threshold has been met. 

The potential for pesticide use requirements to result in incremental costs depends on the extent 

to which the plans described above are already in compliance with permit requirements, and the 

net incremental cost associated with alternative methods of pest control. 
50 May 2010 

However, given the potential for current compliance with pesticide use under state and national 

invasive species management plans (Section 4.3), incremental compliance costs associated with 

pesticide use for aquatic nuisance animal control are unlikely. 

5.1.2.4 Forest Canopy Pest Control 

The following practices apply to pesticide applications for forest canopy pest control 

Identify the Problem 

Section 2.2.4.1 of the draft PGP, Identify the Problem, requires the following: 

Prior to the first pesticide application covered under this permit that will result in a 

discharge to waters of the U.S., and at least once each calendar year thereafter prior to 

the first pesticide application in that calendar year, you must do the following for each 

pest management area, as defined in Appendix A: 

Section 2.2.4.1.1 

Establish target pest densities to serve as action threshold(s) for implementing pest 

management strategies; 

Section 2.2.4.1.2 

Identify target species to develop a species-specific pest management strategy based on 

developmental and behavioral considerations for each species; and 

Section 2.2.4.1.3 

Identify current distribution of the target pest and assess potential distribution in the 

absence of control measures. 

Section 2.2.4.1.4 

In the event there is no data for your pest management area in the past calendar year, see 

Part 5 for any documentation requirements regarding why current data are not available 

and the data you used to meet the permit conditions in Part 2.2.1.1. 

Potential Unit Costs 

The use of pesticides over the forest canopy necessitates a coordinated, controlled approach, 

including proper surveillance (e.g. identifying pests, identifying distribution of pests). Therefore, 

in the event that some forest canopy pest control is occurring in the unauthorized areas, 

incremental compliance costs associated with identifying the problem are unlikely. 

Total Potential Costs 

Incremental compliance costs associated with identifying the problem are minimal since any 

entities currently using pesticides for this use pattern will routinely conduct these activities as 

part of their tasks. Thus, total costs for identifying the problem for forest canopy pest control are 

likely minimal. 

Pest Management 

Section 2.2.4.2 of the draft PGP, Pest Management, requires the following: 
51 May 2010 

Prior to the first pesticide application covered under this permit that will result in a 

discharge to waters of the U.S., and at least once each calendar year thereafter prior to 

the first pesticide application for that calendar year, you must select and implement for 

each pest management area efficient and effective means of pest management that 

minimize discharges resulting from application of pesticides to control forestry pests. In 

developing these pest management strategies, you must evaluate the following 

management options, considering impact to water quality, impact to non-target 

organisms, pest resistance, feasibility, and cost effectiveness: no action; prevention; 

mechanical/physical methods; cultural methods; biological control agents; pesticides. 

No Action: No action is to be taken, although a forest canopy pest control problem has been 

identified. This may be appropriate in cases where available control methods may cause 

secondary or non-target impacts or where aesthetic/ economic losses are not anticipated.

 

Mechanical and Biological Control: Mechanical and biological controls will be the appropriate 

method of control method in some cases, or a part of a combination of methods. In some 

instances, the need for chemical pesticide use in and adjacent to the affected habitat can be 

reduced or virtually eliminated with proper execution of alternative strategies and proper best 

management practices. 

Mechanical control techniques will vary depending on the pest. An example of mechanical 

control in a forest canopy would be egg mass removal (gypsy moth). 

Biological control of forest canopy pests may be achieved through the introduction/enhancement 

of diseases, predators, or parasites. In addition, forest canopy pest control programs aimed 

specifically at insects may also utilize sterile insect release, mating disruption, and biological 

pesticides. While biological controls generally have limited applications for forest canopy pest 

control programs, they should be fully considered as an option in the development of an IPM 

plan. The latter two programs are often utilized when controlling for gypsy moth. 

Cultural Method: Cultural control methods are strategies that make the habitat unsuitable for a 

pest. An example of a cultural method to manage pests of the forest canopy would be to select a 

different species of tree to plant, or to plant resistant varieties of trees. Maintaining the trees in 

good health to discourage pests is another method of cultural control. 

Pesticide: Several chemical and biological pesticides are available that may be used to reduce 

defoliation of the trees. These pesticides are typically used when pest populations are high and 

the action threshold has been reached. These products are aerially applied. 

Potential Unit Costs 

For any use of forest canopy pest control in the unauthorized areas, incremental compliance costs 

associated with pest management depend on the extent to which affected entities switch away 

from pesticide use to minimize pesticide discharges, and the cost of the alternative method 

compared to the total cost associated with pesticide use. Given that forest canopy pest control 

covers larger areas than targeted control, selection of more targeted methods may be unlikely or 

no action may be more likely considering feasibility and cost effectiveness. 
52 May 2010 

Total Potential Costs 

There is a lack of information indicating that prevention, mechanical/physical methods, cultural 

methods, and biological control are likely to be feasible across large areas. Thus, incremental 

compliance costs associated with pest management for forest canopy pest control may be 

minimal. 

Pesticide Use 

Section 2.2.4.3 of the draft PGP, Pesticide Use, requires the following: 

If a pesticide is selected to manage forestry pests and application of the pesticide will 

result in a discharge to waters of the U.S., you must: 

Section 2.2.4.3.1 

Conduct surveillance prior to each application to assess the pest management area and 

to determine when the pest action threshold is met that necessitates the need for pest 

management; 

Section 2.2.4.3.2 

Assess environmental conditions (e.g. temperature, precipitation, and wind speed) in the 

treatment area to identify conditions that support target pest development and are 

conducive for treatment activities; 

Section 2.2.4.3.3 

Reduce the impact on the environment and non-target organisms by evaluating the 

restrictions, application timing, and application methods in addition to applying the 

pesticide only when the action thresholds have been met; and 

Section 2.2.4.3.4 

Evaluate using pesticides against the most susceptible developmental stage. 

For any use of forest canopy pest control in the unauthorized areas, incremental compliance costs 

associated with the pesticide use requirements depend on the extent to which affected entities are 

currently performing the required activities, and the cost of the requirements.

Potential Unit Costs 

There is no information on the potential cost of conducting surveillance using BMPs prior to 

each application, assessing environmental conditions as close to the treatment as possible, and 

using pesticides only when action thresholds are met and against the most susceptible 

developmental stages. However, the use of pesticides over the forest canopy necessitates a 

coordinated, controlled approach, including proper surveillance and assessment. Therefore, in 

the event that some forest canopy pest control is occurring in the unauthorized areas, incremental 

compliance costs associated with pesticide use are unlikely. 

Total Potential Costs 

Incremental compliance costs associated with pesticide use are minimal since any entities 

currently using pesticides for this use pattern will routinely conduct these activities as part of 

their tasks. Thus, total costs for pesticide use for forest canopy pest control are assumed to be 

minimal. 
53 May 2010 

5.1.3. Summary of Technology-Based Effluent Limitation Costs 

Table 5-8 shows the estimated unit costs of the permit requirements for each use pattern. As 

shown in the table, the availability and prevalence of cost data varies for each permit requirement 

and use pattern. For mosquito and other flying insect pest control, the potential unit costs 

provided are midpoints for ranges of potential costs. That is, for identifying the problem, small 

operators (most likely small municipalities) costs are expected to fall within the range of 

$15,000-$24,000 for all related activities. For larger operators (e.g. multi-county mosquito 

abatement districts), costs associated with identifying the problem are expected to be $15,000-

$369,000. The range of costs for pest management activities range from $7,000-$389,000 per 

entity. Given that a many of the entities are likely to be relatively small, EPA believes that most 

will incur costs more towards the lower end of the range of potential costs. However, to be 

conservative (i.e., erring on the side of greater impacts) the midpoint estimate will be used to 

reflect potential unit costs in this analysis. 

Table 5-8: Summary of Estimated Unit Costs 

Requirement Potential Unit Cost Description and Source 

Mosquito and Other Flying Insect Pest Control

Identify the problem: 

Species/target densities 

 

Mapping breeding sites 

Municipality-level costs 

$99,000/entity 

$112,000/entity 

$20,000/entity 

Midpoint of surveillance expenditures in 

mosquito control districts in MA (MADEP, 2009; 

MDAR, 2008). 

Midpoint of expenditures in mosquito control 

districts in MA (MADEP, 2009; MDAR, 2008) 

and costs estimated for Idaho ISDA (2009). 

Average annual cost for problem identification 

for municipalities in New Hampshire (McGregor, 

2009; NHDHHS, 2010) 

Pest management 

Regional-level costs 

Municipality-level costs 

$195,000/entity 

$800/entity 

Midpoint cost for implementing water 

management and vegetation and sediment 

removal in mosquito control districts in MA 

(MADEP, 2009; MDAR, 2008) 

Low end of range for implementing water 

management and vegetation and sediment 

removal in mosquito control districts in MA 

(MADEP, 2009; MDAR, 2008) 

Aquatic Weed and Algae Control

Identify the problem $100/acre Surveying costs; Coble (2009) 

Pest management $50/acre - $500/acre1

 Illustrative only; represents potential feasible 

cost difference between pesticide use and use 

of alternative method2

Pesticide use $100/acre Surveillance monitoring of aquatic weed 

treatments; ISDA (2009) 

Aquatic Nuisance Animal Control

NA NA NA 

Forest Canopy Pest Control

NA NA NA 

NA = not applicable (no incremental costs identified). 

1. Assumed for half of affected acres, for illustration. 

2. Actual unit costs of feasible alternatives to traditional pesticide use will be site- and entity-specific. 

EPA uses the unit costs and estimates of potentially affected facilities that would be required to 

implement the technology-based effluent limitation to estimate potential costs under each use 

pattern. The potential costs are summarized in Table 5-9. 
54 May 2010 

Table 5-9: Summary of Estimated Annual Technology-based Effluent Limitation Costs ($/yr) 

Area 

Mosquito and 

Other Flying 

Insect Pest 

Control1

Aquatic 

Weed and 

Algae 

Control1

Aquatic 

Nuisance 

Animal 

Control 

Forest 

Canopy 

Pest Control 

Total 

Alaska $0 $0 $0 $0 $0 

Idaho $4,017,000 

$7,000 - 

$21,000 $0 $0 

$4,024,000 - 

$4,038,000 

Massachusetts $0 

$25,000 - 

$69,000 $0 $0 

$25,000 - 

$69,000 

New Hampshire $35,000 

$10,000 - 

$53,000 $0 $0 

$45,000 - 

$88,000 

New Mexico $2,535,000 $0 $0 $0 $2,535,000 

Oklahoma $21,000 

$25,000 - 

$50,000 $0 $0 

$46,000 - 

$71,000 

District of Columbia $195,000 $0 $0 $0 $195,000 

Territories $0 $0 $0 $0 $0 

Tribes 

$104,000 - 

$354,000 

$36,000 - 

$73,000 $0 $0 

$140,000 - 

$427,000 

Federal Facilities $4,060,000 

$508,000 - 

$1,016,000 $0 $0 

$4,568,000 - 

$5,076,000 

Total 

$10,967,000 - 

$11,217,000 

$611,000 - 

$1,282,000 $0 $0 

$11,578,000 - 

$12,499,000 

1. Includes illustrative cost estimate for pest management based on potential feasible net incremental costs; actual costs will be siteand entity-specific.

As presented in Table 5-9, total potential costs of complying with the technology-based effluent 

limitations under the draft PGP could range from approximately $11.6 million to $12.5 million. 

Note that most of the costs are attributable to identifying the problem and pest management 

requirements under the mosquito control use pattern. These costs are highly uncertain and 

entity-specific; actual costs may be higher or lower than estimated. 

5.2. Administrative and Monitoring 

This section provides estimates of the potential costs that may be associated with the 

administrative and monitoring provisions of the draft PGP. 

To estimate potential administrative and monitoring costs, EPA identified the likely level of 

effort (e.g., number of hours) associated with performing each activity and the potential cost of 

that effort (e.g., average wage rate) based on best professional judgment. Labor categories likely 

to be involved in administrative and monitoring tasks include managerial, technical, and clerical. 

The Bureau of Labor Statistics (BLS) publishes base mean annual wage rates in its Occupational 

Employment Survey (OES, 2008), and an Employment Cost Index (ECI, 2009) to update the 

wage rates to 2009 values to account for inflation. As discussed in Section 3, entities may use 

their own employees for pesticide applications or contract out the services. EPA used average 

government and commercial wage rates to estimate administrative and monitoring costs 

assuming that each entity is equally likely to use either government or commercial labor. 

For state and local governments, EPA included employee benefits in the wage rate, and for 

commercial applicators, included benefits, overhead, and profit in estimating total labor rates. 

The BLS Employer Cost for Employee Compensation (ECEC, 2009) provides estimates for 

benefit markups for governments (benefits account for approximately 25% of the total labor 
55 May 2010 

rate), and PSMJ (2009) indicates that the wage rate multiplier is 3.05 for commercial/engineering 

firms. Table 5-10 presents the estimated labor cost by labor category; rates for managers reflect 

OES category 11-9121, Natural Sciences Managers; technical staff reflect OES category 9-4091, 

Environmental Science and Protection Technicians, Including Health; and clerical staff reflect 

OES category 43-0000, Office and Administrative Support Occupations State. 

Table 5-10: Estimated Labor Cost ($/hour) 

Labor Category State 

Government1

Local 

Government1 Commercial2 Average3 

Managers $51 $64 $167 $113

Technical $38 $38 $63 $51

Clerical $29 $28 $53 $41

Note: Detail may not add to total due to independent rounding. 

Sources: BLS OES (2008); BLS ECI (2009); BLS ECEC (2009). 

1. Mean annual 2008 wages, updated to 2009 dollars; includes cost of employee benefits. 

2. Mean annual 2008 wages, updated to 2009 dollars; includes cost of employee benefits, overhead cost, and profit 

(estimated based on a total wage rate multiplier of 3.05). 

3. Represents average of government rates (state and local government average) and commercial rate.

The following sections describe the estimated level of effort that may be necessary to comply 

with the various requirements, and the calculation of potential costs (both total and implied 

annual for activities performed once per permit term). 

5.2.1. Notice of Intent 

Entities must submit an NOI electronically. Given that potential entities will submit an NOI 

electronically, the burden associated with this requirement is likely two hours or less of technical 

and managerial staff time to identify a need and complete an accurate submission. Table 5-11 

shows the calculation of potential costs for submitting an NOI. 

Table 5-11: Potential Costs for NOI Submittal 

Labor Category Rate1 

($/hour) Hours Total Cost Average Annual Cost2

Managerial $113 1 $113 $23 

Technical $51 1 $51 $10 

Total na 2 $164 $33 

Note: detail may not add to total due to independent rounding. 

na: not applicable 

1. See Table 5-10. 

2. Total cost divided by the permit term (5 years). 

For this analysis, EPA assumed that affected entities submit no more than one NOI per use 

pattern. Affected state entities may submit separate NOIs by use pattern because there may be 

different agencies involved in the different activities. However, private entities are likely to 

submit only one NOI for all applicable use patterns (e.g., industrial facilities controlling both 

aquatic weeds and algae and aquatic nuisance animals at intake structures). 

5.2.2. Pesticide Discharge Management Plan 

PDMPs document the evaluation and selection of control measures to meet the technology-based 

effluent limitations and minimize discharges. These plans may cover one or more treatment 

areas within one plan, and can reference other documents (such as pre-existing integrated pest 

management plan). Thus, the cost to develop the PDMP will vary based on the extent of pest 
56 May 2010 

problems and pesticide use, as well as existing documentation that may be referenced to fulfill 

plan requirements. Entities that have been evaluating pest problems and alternative management 

methods, and commercial entities that apply pesticides and that can readily provide procedures 

including incident response plans, may have significant relevant material already compiled and 

available. 

Table 5-12 provides estimates of the average level of effort that might be required to prepare 

PDMPs; the actual level of effort may be higher or lower than shown depending on the number 

of treatment areas covered, the experience of the applicator in preparing PDMPs, and the amount 

of existing material available. The majority of this effort is likely to be performed by 

environmental science professionals (e.g., 90%), with managerial review (e.g., 5%) and clerical 

support (e.g., 5%). Table 5-13 presents the potential costs associated with these efforts 

(approximately $2,100 per plan). 

Table 5-12: Potential Level of Effort to Prepare PDMP 

Required Documentation Level of Effort (hours) 

PDMP Team: All staff working on pest management and PDMP 1

Pest Management Area Description: Pest problem description, action 

thresholds, map, and water quality standards 16

Control Measures Description: Documentation of evaluation of control 

measures, including active ingredients evaluated 14

Schedules and Procedures: Documentation pertaining to control 

measures and other actions to minimize discharges 8

Eligibility: Documentation of considerations under other federal laws 1

TOTAL 40

Table 5-13: Potential Cost to Produce PDMP 

Labor Category 

Rate1 

($/hour) Hours Total Cost Annual Cost2

Managerial $113 2 $226 $45

Technical $51 36 $1,836 $367

Clerical $41 2 $82 $16

Total na 40 $2,144 $429

Note: detail may not add to total due to independent rounding. 

na: not applicable 

1. See Table 5-10. 

2. Total cost divided by the permit term (5 years). 

5.2.3. Recordkeeping 

Since entities are likely to keep an electronic copy of the permit (and already have filing capacity 

for backup paper files including any correspondence with EPA), as well as prepare and save the 

PDMP, NOI, annual reports, and any adverse incident reports electronically, the level of effort 

associated with these recordkeeping requirements is not likely to exceed two hours of clerical 

staff time annually. 

The additional recordkeeping by entities required to submit an NOI will likely be kept by 

technical staff at the time of application, and incremental level of effort of may be approximately 

one-half of an hour. Thus, the total level of effort will depend on the number of pesticide 

applications, which will vary by entity. For example, Table 5-14 presents the potential annual 

cost based on an average of eight pesticide applications annually per entity (i.e., four hours for 
57 May 2010 

recordkeeping annually), which may cover more than one use pattern or only one use pattern, 

depending on the entity type and size. 

Table 5-14: Potential Recordkeeping Costs 

Category Level of Effort 

(Number of Hours)

Labor Rate1 

($/hour) Annual Cost 

Entities Submitting NOIs2 4 $51 $204

Entities not Submitting NOIs 2 $41 $82

1. See Table 5-10. 

2. Level of effort based on an average of eight pesticide applications per year per entity. 

5.2.4. Reporting 

Since annual reports may be submitted electronically and the records required for the report are 

also likely to be electronic, EPA assumes that the level of effort associated with this requirement 

may be approximately two hours of technical (or clerical staff) time per year. Table 5-15 

presents the potential annual cost assuming technical staff familiar with the records will submit 

the annual report. 

Table 5-15: Potential Reporting Cost 

Labor Category Rate1 

($/hour) Hours Annual Cost 

Technical $51 2 $102 

1. See Table 5-10. 

5.2.5. Site Monitoring 

Site monitoring may add an additional quarter hour per site monitored, and entities may monitor 

one or more sites per pesticide application. For consistency with the assumptions used to 

calculate potential recordkeeping costs, Table 5-16 presents the potential costs based on entities 

that exceed the threshold conducting an average of eight applications annually. For entities that 

do not exceed the threshold, pesticide applications are likely to be fewer; Table 5-16 presents 

costs based on an average of two applications per year. 

Table 5-16: Potential Site Monitoring Cost 

Category Level of Effort1

(Number of Hours)

Labor Rate2 

($/hour) Annual Cost 

Entities Submitting NOIs3 4 $51 $204

Entities not Submitting NOIs4 1 $51 $51

na: not applicable 

1. Based on 0.25 hours for monitoring per site. 

2. See Table 5-10. 

3. Based on two sites monitored per application, and an average of eight pesticide applications per year. 

4. Based on two sites monitored per application, and an average of two pesticide applications per year. 

5.2.6. Total Annual Costs 

Table 5-17 provides a summary of the potential annual administrative and monitoring costs. 

Entities that exceed annual treatment area thresholds may incur annual costs of approximately 

$960 per year. Entities that do not exceed annual treatment area thresholds may incur cost of 

approximately $130 annually. 
58 May 2010 

Table 5-17: Summary of Potential Annual Administrative and Monitoring Costs by Component 

Requirement Entities Exceeding 

Threshold 

Entities Not 

Exceeding 

Threshold 

NOI $30 NA

PDMP $430 NA

Recordkeeping $200 $80

Reporting $100 NA

Site Monitoring $200 $50

Total $960 $130

Numbers in table are rounded for ease of calculation. 

NA: not applicable 

NOI: Notice of Intent 

PDMP: Pesticide Discharge Management Plan 

The total magnitude of administrative and monitoring costs will depend on the total number of 

entities seeking coverage under the draft PGP, and the applicability of the different requirements. 

Based on the estimates of potentially affected entities and number likely to exceed the thresholds 

presented in Section 3, Table 5-18 shows the calculation of potential total administrative and 

monitoring costs by use pattern. 
59 May 2010 

Table 5-18: Administrative and Monitoring Costs ($/yr) 

Potential Annual Cost ($/yr)1 

Area Entities Above Threshold Entities Below Threshold Total Annual Costs 

Mosquito and Other Flying Insect Pest Control 

Alaska $0 $300 $300

Idaho $22,000 $0 $22,000

Massachusetts $9,000 $0 $9,000

New Hampshire $42,000 $0 $42,000

New Mexico $12,000 $0 $12,000

Oklahoma $1,000 $0 $1,000

District of Columbia $1,000 $0 $1,000

Territories $1,000 $0 $1,000

Tribes $5,000 - $16,000 $0 - $2,000 $5,000 - $18,000

Federal Facilities $10,000 $0 $10,000

Subtotal $103,000 - $114,000 $300 - $2,300 $103,000 - $116,000

Aquatic Weed and Algae Control 

Alaska $1,000 $42,000 $43,000

Idaho $8,000 $2,120,000 $2,128,000

Massachusetts $26,000 $275,000 $301,000

New Hampshire $25,000 $79,000 $104,000

New Mexico $1,000 $1,332,000 $1,333,000

Oklahoma $59,000 $488,000 $547,000

District of Columbia $1,000 $1,000 $2,000

Territories $6,000 $37,000 $43,000

Tribes $16,000 $9,000 $25,000

Federal Facilities $10,000 $0 $10,000

Subtotal $153,000 $4,383,000 $4,536,000

Aquatic Nuisance Animal Control 

Alaska $1,000 $2,000 $3,000

Idaho $1,000 $1,000 $2,000

Massachusetts $1,000 $3,000 $4,000

New Hampshire $1,000 $1,000 $2,000

New Mexico $1,000 $1,000 $2,000

Oklahoma $1,000 $9,000 $10,000

District of Columbia $1,000 $0 $1,000

Territories $6,000 $4,000 $10,000

Tribes $16,000 $1,000 $17,000

Federal Facilities $10,000 $0 $10,000

Subtotal $39,000 $22,000 $61,000

Forest Canopy Pest Control 

Alaska $1,000 $2,000 $3,000

Idaho $2,000 $6,000 $8,000

Massachusetts $2,000 $28,000 $30,000

New Hampshire $1,000 $11,000 $12,000

New Mexico $1,000 $3,000 $4,000

Oklahoma $2,000 $20,000 $22,000

District of Columbia $0 $0 $0

Territories $10,000 $0 $10,000

Tribes $48,000 $0 $48,000

Federal Facilities $28,000 $0 $28,000

Subtotal $95,000 $70,000 $165,000

Note: Detail may not add to total due to rounding. 

1. Calculated by multiplying estimates from Table 3-2, Table 3-7, Table 3-10, and Table 3-12 by $960 (exceed threshold) and $130 

(do not exceed threshold).
60 May 2010 

Table 5-19 provides a summary of the potential annual administrative and monitoring costs. 

Aquatic weed and algae control accounts for over 90% of the administrative and monitoring 

costs (approximately $4.5 million) due to the potential applicability of the draft PGP to operators 

of irrigated farms. However, as discussed in Section 3, there is substantial uncertainty 

surrounding the estimates of number of affected entities in this category. This uncertainty in turn 

translates to substantial uncertainty associated with the estimates of administrative and 

monitoring costs. 

Table 5-19: Summary of Potential Annual Administrative and Monitoring Costs ($/yr) 

Area 

Mosquito and 

Other Flying 

Insect Pest 

Control 

Aquatic Weed 

and Algae 

Control 

Aquatic 

Nuisance 

Animal Control

Forest 

Canopy Pest 

Control 

Total 

Alaska $300 $43,000 $3,000 $3,000 $49,300

Idaho $22,000 $2,128,000 $2,000 $8,000 $2,160,000

Massachusetts $9,000 $301,000 $4,000 $30,000 $344,000

New Hampshire $42,000 $104,000 $2,000 $12,000 $160,000

New Mexico $12,000 $1,333,000 $2,000 $4,000 $1,351,000

Oklahoma $1,000 $547,000 $10,000 $22,000 $580,000

District of Columbia $1,000 $2,000 $1,000 $0 $4,000

Territories $1,000 $43,000 $10,000 $10,000 $64,000

Tribes $5,000 - $18,000 $25,000 $17,000 $48,000 $95,000 -

$108,000

Federal Facilities $10,000 $10,000 $10,000 $28,000 $58,000

Total $103,000 - 

$116,000 $4,536,000 $61,000 $165,000 $4,865,000 -

4,878,000

Note: Detail may not add to total due to rounding. 

5.3. Summary of Costs 

Table 5-20 provides a summary of total technology-based effluent limitations and administrative 

and monitoring requirements for entities above and below annual treatment area thresholds for 

each use pattern. Table 5-21 provides a summary of the total annual costs across the 

unauthorized areas and use patterns. Since EPA did not identify any incremental technologybased effluent limitation requirements (due to estimated current compliance) for aquatic nuisance 

animal control and forest canopy pest control, total costs for these use patterns represent 

administrative and monitoring costs only. Approximately 40% of the total estimated costs 

represent administrative and monitoring costs. As discussed above, there is substantial 

uncertainty surrounding these costs. However, there are also substantial uncertainties associated 

with the estimation of the technology-based effluent limitation costs. The key uncertainties in 

the analysis are described further in Table 5-22. 
61 May 2010 

Table 5-20: Total Estimated Costs For Entities Above and Below Treatment Thresholds ($/yr)1

Mosquito and Other 

Flying Insect Pest 

Aquatic Weed and 

Algae 

Aquatic Nuisance 

Animal Forest Canopy 

Area Above Below Above Below Above Below Above Below 

Alaska $0 $300 $1,000 $42,000 $1,000 $2,000 $1,000 $2,000

Idaho $4,039,000 $0 $29,000 $2,120,000 $1,000 $1,000 $2,000 $6,000

Massachusetts $9,000 $0 $95,000 $275,000 $1,000 $3,000 $2,000 $28,000

New 

Hampshire $77,000 $0 $78,000 $79,000 $1,000 $1,000 $1,000 $11,000

New Mexico $2,547,000 $0 $1,000 $1,332,000 $1,000 $1,000 $1,000 $3,000

Oklahoma $22,000 $0 $109,000 $488,000 $1,000 $9,000 $2,000 $20,000

District of 

Columbia $196,000 $0 $1,000 $1,000 $1,000 $0 $0 $0

Territories $1,000 $0 $6,000 $37,000 $6,000 $4,000 $10,000 $0

Tribes $370,000 $2,000 $89,000 $9,000 $16,000 $1,000 $48,000 $0

Federal 

Facilities $4,070,000 $0 $1,026,000 $0 $10,000 $0 $28,000 $0

Total $11,331,000 $2,300 $1,435,000 $4,383,000 $39,000 $22,000 $95,000 $70,000

Note: Detail may not add to total due to rounding. 

1. Represents high end of cost ranges only.

Table 5-21: Summary of Total Estimated Costs ($/yr)1 

Area

Mosquito and 

Other Flying 

Insect Pest 

Control

Aquatic 

Weed and 

Algae Control

Aquatic 

Nuisance 

Animal 

Control

Forest 

Canopy 

Pest 

Control

Total

Alaska $300 $43,000 $3,000 $3,000 

$49,300 - 

$49,300 

Idaho $4,039,000 

$2,135,000 - 

$2,149,000 $2,000 $8,000 

$6,184,000 - 

$6,198,000 

Massachusetts $9,000 

$326,000 - 

$370,000 $4,000 $30,000 

$369,000 - 

$413,000 

New Hampshire $77,000 

$114,000 - 

$157,000 $2,000 $12,000 

$205,000 - 

$248,000 

New Mexico $2,547,000 $1,333,000 $2,000 $4,000 $3,886,000 

Oklahoma $22,000 

$572,000 - 

$597,000 $10,000 $22,000 

$626,000 - 

$651,000 

District of Columbia $196,000 $2,000 $1,000 $0 $199,000 

Territories $1,000 $43,000 $10,000 $10,000 $64,000 

Tribes 

$109,000 - 

$372,000 

$61,000 - 

$98,000 $17,000 $48,000 

$235,000 - 

$535,000 

Federal Facilities $4,070,000 

$518,000 - 

$1,026,000 $10,000 $28,000 

$4,626,000 - 

$5,134,000 

Total 

$11,070,000 - 

$11,333,000 

$5,147,000 - 

$5,818,000 $61,000 $165,000 

$16,443,000 - 

$17,377,000 

Note: Detail may not add to total due to rounding. 

1. See Table 5-9 and Table 5-19.
62 May 2010 

Table 5-22: Key Uncertainties of the Analysis 

Uncertainty/Assumption Comment 

All irrigated farms affected; no nonirrigated farms affected 

Information on the extent to which farmers treat ditch banks that 

lead to waters of the United States with pesticides for aquatic weed 

and algae control is not available. The estimated administrative and 

monitoring costs for irrigated farms comprise almost 25% of the 

total estimated costs. 

Number of private forest owners 

affected 

Information on the number of private forest owners in unauthorized 

areas, whether owners manage the forests using pesticides, and 

the number of acres treated is not available. 

Affected entities and current 

compliance in territories, tribal 

lands, and federal facilities 

Relatively little information was available regarding the use patterns 

in these areas. The analysis reflects illustrative estimates of 

affected entities and the assumption of no current compliance. 

Incremental costs to comply with 

technology-based effluent 

limitations 

Incremental costs will be highly site- and entity-specific. Majority of 

costs reflect expenditures associated with problem identification 

(mosquito control) and pest management (mosquito and aquatic 

weed control); actual unit costs may be substantially higher or 

lower. 

Number of right-of-way ditch banks 

potentially affected by the draft 

PGP. 

Sufficient information is not available on the location or number of 

right-of-way ditch banks; costs for these ditches could include 

surveillance and monitoring. 

Number of affected entities for 

aquatic weed control based on 

number of water acres treated and 

average water size in each state. 

Water sizes vary greatly. Thus, the actual number of potentially 

affected entities could be higher or lower than estimated. 

The estimated costs vary substantially by type of entity. Table 5-23 through Table 5-26 show 

potential average costs for the entities exceeding and not exceeding annual treatment area 

thresholds by use pattern; actual costs incurred by the different entities may be higher or lower 

than the averages shown. As illustrated by the tables, the highest costs are potentially borne by 

entities exceeding annual treatment area thresholds performing mosquito and other flying insect 

pest control. Costs associated with the draft PGP for mosquito and other flying insect pest 

control may be in the range of $200,000 to $400,000 annually, reflecting both costs to comply 

with technology-based effluent limitations and administrative and monitoring requirements. 

However, some areas (Massachusetts) may be largely in compliance and thus incur only minimal 

administrative and monitoring costs (approximately $1,000), while others may incur higher 

costs. For example, unit costs for federal facility mosquito control and aquatic weed control 

entities are higher because EPA assumes that none of the draft PGP requirements are currently 

being implemented (due to a lack of data to the contrary). Average entity-level costs for the 

other use patterns primarily reflect administrative and monitoring costs only. 
63 May 2010 

Table 5-23: Potential Average Entity Costs for Mosquito and Other Flying Insect Pest Control1

Average Cost/Entity ($/yr) Unauthorized Area Above Threshold Below Threshold 

Alaska $0 $200 

Idaho $175,600 $0 

Massachusetts $1,000 $0 

New Hampshire $1,800 $0 

New Mexico $195,900 $0 

Oklahoma $22,000 $0 

District of Columbia $196,000 $0 

Territories $1,000 $0 

Tribes $21,800 $200 

Federal facilities $407,000 $0 

Note: Detail may not add to total due to rounding. 

1. Based on dividing total potential costs from Table 5-20 by number of affected entities from Table 3-2 (high 

end of range only). 

Table 5-24: Potential Average Entity Costs for Aquatic Weed and Algae Control1 

Average Cost/Entity ($/yr) 

Area Above Below 

Alaska $1,000 $100

Idaho $3,600 $100

Massachusetts $3,500 $100

New Hampshire $3,000 $100

New Mexico $1,000 $100

Oklahoma $1,800 $100

District of Columbia $1,000 $100

Territories $2,000 $100

Tribes $5,200 $100

Federal Facilities $102,600 $0

Note: Detail may not add to total due to rounding. 

1. Based on dividing total potential costs from Table 5-20 

by number of affected entities from Table 3-7 (high end of range only).

Table 5-25: Potential Average Entity Costs for Aquatic Nuisance Animal Control1

Average Cost/Entity ($/yr) Unauthorized Area Above Threshold Below Threshold 

Alaska $1,000 $100 

Idaho $1,000 $100 

Massachusetts $1,000 $100 

New Hampshire $1,000 $100 

New Mexico $1,000 $100 

Oklahoma $1,000 $100 

District of Columbia $1,000 $0 

Territories $1,000 $100 

Tribes $900 $100 

Federal facilities $1,000 $0 

Note: Detail may not add to total due to rounding. 

1. Based on dividing total potential costs from Table 5-20 by number of affected entities from Table 3-10 (high 

end of range only). 
64 May 2010 

Table 5-26: Potential Average Entity Costs for Forest Canopy Pest Control1

Average Cost/Entity ($/yr) Unauthorized Area Above Threshold Below Threshold 

Alaska $1,000 $100 

Idaho $1,000 $100 

Massachusetts $1,000 $100 

New Hampshire $1,000 $100 

New Mexico $1,000 $100 

Oklahoma $1,000 $100 

District of Columbia $0 $0 

Territories $1,000 $0 

Tribes $1,000 $0 

Federal facilities $1,000 $0 

Note: Detail may not add to total due to rounding. 

1. Based on dividing total potential costs from Table 5-20 by number of affected entities from Table 3-12 (high 

end of range only). 
65 May 2010 

6. Small Entity Analysis 

6.1. Identification of Small Entities 

A small entity may be: 

• A small business according to SBA (Small Business Administration) size standards; 

• A small governmental jurisdiction that is a government of a city, county, town, school 

district, or special district with a population of less than 50,000; or 

• A small organization that is a not-for-profit enterprise that is independently owned and 

operated and is not dominant in its field. 

The SBA defines small businesses based on NAICS (North American Industry Classification 

System) codes and size standards expressed by the number of employees or annual receipts (13 

CFR §121.20). 

For each use pattern, EPA estimated the number of affected entities that meet the SBA definition 

of a small entity. 

For mosquito and other flying insect pest control, information available suggests that most 

entities are county and local governments. MADEP (2009) identifies the municipalities covered 

by each of its nine mosquito control districts. Based on municipality populations, Census data 

indicates that there are several towns within the districts that would not be considered small 

entities because their populations are greater than 50,000. However, even with size information, 

it is uncertain how the control costs would be apportioned to each municipality. Therefore, EPA 

assumes all the municipalities are small. There is no information on the specific entities 

responsible for mosquito control in Alaska, Idaho, New Hampshire, New Mexico, and the 

affected territories and tribes. Therefore, for screening purposes, EPA assumes that all of the 

entities are also small. Federal facilities do not represent small entities, and the District of 

Columbia and Tulsa, Oklahoma have populations over 50,000 and do not represent small 

entities. Thus, based on the information available, EPA estimates that there are potentially 115 

entities (not including the individual municipalities potentially covered by each control district) 

that could be small entities. 

For aquatic weed and algae control, the information available suggests that most of the entities 

required to implement the technology-based effluent limitations are municipalities, except in 

New Mexico where two state agencies are responsible for such activities. Because there is no 

information identifying which municipalities would be affected, for the purpose of this analysis, 

EPA assumes that all of the potentially affected governmental entities may be small (201 total), 

excluding New Mexico. Based on data in SDWIS on populations served, EPA also assumes that 

the potentially affected public drinking water utilities (1,312) may be small. There is no 

information available identifying the farms (31,636), industrial surface water intake facilities 

(427), and private land owners (263) that may be affected; thus, for this analysis, EPA also 

assumes that entities in these categories may be small entities. Because EPA assumes that rightof-way ditches are treated on a state-level by the Department of Transportation, these entities 

would not be small. Thus, based on the information available, EPA estimates that there are 

potentially 33,838 entities that could be small entities. 
66 May 2010 

For aquatic nuisance animal control, EPA assumes that governmental activities are more likely to 

be conducted at the state or territory level by a single entity rather than controlled by individual 

municipalities. Affected entities are likely to be large, even if on the county-level. However, 

there is no information identifying which tribes may be affected. For this analysis, EPA assumes 

that potentially affected tribal entities (17 under aquatic nuisance animal control) are small. 

Similar to above, EPA assumes that the potentially affected industrial facilities (43) and drinking 

water utilities (132) with surface water intakes are small. Thus, based on the information 

available, EPA estimates that there are potentially 192 entities that could be small entities. 

For forest canopy pest control, EPA assumes that governmental activities are more likely to be 

conducted at the state level by a single entity rather than controlled by individual municipalities. 

Consequently, these entities are likely to be large, even if on the county-level. However, there is 

no information identifying which particular tribes may be affected. For this analysis, EPA 

assumes that potentially affected tribal entities (33 under forest canopy pest control) are small. 

Private forest owners may be large or small entities, depending on sales; small business size 

thresholds vary based on the applicable industrial categories. There is no information available 

regarding the private forest owners that may be affected, their industrial classification, or sales. 

Thus, based on the information available, EPA estimates that there are potentially 33 

governments that may be small entities, and that some portion of the 574 potentially affected 

private forest owners may also be small entities. 

6.2. Evaluating Potential Economic Impact 

Because the specific entities that may be affected by the draft PGP is uncertain, evaluating the 

potential economic impact based on revenues or sales is not possible. However, EPA can 

estimate the applicable thresholds below which average per entity compliance costs could exceed 

a percentage of annual revenues/sales (Table 6-1 and Table 6.2). For this analysis, EPA used 

percentages of 1% and 3% of revenues/sales to characterize the potential for significant impacts 

on small entities. 
67 May 2010 

Table 6-1: Average Compliance Costs for Entities Exceeding Annual Treatment Area Thresholds 

and Potential Revenue Threshold Values for Characterizing Impacts to Small Governments 

Revenue Threshold Values2

Area 

Average Cost per 

Entity, Exceed 

Threshold 1% 3% 

Mosquito and Other Flying Insect Pest Control 

Idaho $175,600 $17,560,000 $5,853,333 

Massachusetts $1,000 $100,000 $33,333 

New Hampshire $1,800 $180,000 $60,000 

New Mexico $195,900 $19,590,000 $6,530,000 

Territories $1,000 $100,000 $33,333 

Tribes $21,800 $2,180,000 $726,667 

Aquatic Weed and Algae Control 

Alaska $1,000 $100,000 $33,333 

Idaho $3,600 $360,000 $120,000 

Massachusetts $3,500 $350,000 $116,667 

New Hampshire $3,000 $300,000 $100,000 

Oklahoma $1,800 $180,000 $60,000 

Tribes $5,200 $520,000 $173,333 

Aquatic Nuisance Animal Control 

Tribes $900 $90,000 $30,000 

Forest Canopy Pest Control 

Tribes $1,000 $100,000 $33,333 

ne: not estimated 

1. See Table 5-23, Table 5-24, Table 5-25, and Table 5-26. 

2. Average per entity costs would exceed 1% or 3% of revenues if revenues are less than the values shown.

Table 6-2: Average Compliance Costs for Entities that do not Exceed Annual Treatment Area 

Thresholds and Potential Revenue Threshold Values for Characterizing Impacts to Small 

Governments 

Revenue Threshold Values2

Unauthorized Area Average Cost/Entity1

1% 3% 

Mosquito and Other Flying Insect Pest Control

Alaska $200 $20,000 $6,667

Tribes $200 $20,000 $6,667

Aquatic Weed and Algae Control

Alaska $100 $10,000 $3,333

Idaho $100 $10,000 $3,333

Massachusetts $100 $10,000 $3,333

New Hampshire $100 $10,000 $3,333

Oklahoma $100 $10,000 $3,333

Tribes $100 $10,000 $3,333

Aquatic Nuisance Animal Control 

Tribes $100 $10,000 $3,333

Note: Detail may not add to total due to rounding. 

ne: not estimated 

1. See Table 5-23, Table 5-24, Table 5-25, and Table 5-26. 

2. Average per entity costs would exceed 1% or 3% of revenues if revenues are less than the values shown. 
68 May 2010 

For comparison, Table 6-3 shows the average revenues in municipalities and counties with 

populations of 50,000, 25,000, and 10,000 people for each of the affected areas (territory 

revenues calculated based on national average per capita estimates; there is no information on 

tribal revenues, particularly for smaller tribes, to include tribes in the table). 

Table 6-3: Municipality and County Revenues based on Average Per Capita Revenues1

50k Population 25k Population 10k Population 

Affected Area Per 

Capita 

Revenue 

Revenue 

Per 

Capita 

Revenue

Revenue 

Per 

Capita 

Revenue 

Revenue 

Municipalities 

Alaska2 $3,136 $156,800,000 $3,136 $78,400,000 $2,477 $24,770,000 

Idaho $836 $41,800,000 $594 $14,850,000 $774 $7,740,000 

Massachusetts3 $2,875 $143,750,000 $2,378 $59,450,000 $23,778 $237,780,000 

New Hampshire $2,062 $103,100,000 $2,375 $59,375,000 $2,192 $21,920,000 

New Mexico $1,841 $92,050,000 $1,458 $36,450,000 $1,299 $12,990,000 

Oklahoma $1,569 $78,450,000 $1,283 $32,075,000 $1,104 $11,040,000 

Territories $1,401 $70,050,000 $1,417 $35,425,000 $1,215 $12,150,000 

Counties 

Alaska $2,706 $135,300,000 $3,084 $77,100,000 $17,025 $170,250,000 

Idaho $641 $32,050,000 $620 $15,500,000 $1,258 $12,580,000 

Massachusetts4 $841 $42,050,000 $841 $21,025,000 $841 $8,410,000 

New Hampshire4 $456 $22,800,000 $456 $11,400,000 $456 $4,560,000 

New Mexico $532 $26,600,000 $1,559 $38,975,000 $879 $8,790,000 

Oklahoma $323 $16,150,000 $473 $11,825,000 $680 $6,800,000 

Territories $854 $42,700,000 $883 $22,075,000 $1,151 $11,510,000 

Source: U.S. Census Bureau (2002). 

1. Based on average per capita revenues for municipalities with populations between 49,999 and 25,000; 24,999 and 10,000; and 

less than 10,000, respectively. 

2. Revenue for 25k population based on average per capita revenue for municipalities with 24,999 to 50,000. 

3. Revenue for 10k population based on average per capita revenue for municipalities with 10,000 to 24,999. 

4. Revenue for all populations based on average per capita revenue for municipalities with 10,000 to 24,999. 

As shown by comparing values in Table 6-1 and 

Table 6-2 with those in Table 6-3, the relative magnitude of per entity compliance cost in 

comparison to estimated revenues of different size small governments varies by area. For 

example, for mosquito control in New Hampshire, average revenues for municipalities of each 

size category are above the revenue thresholds that would result in compliance costs being more 

than 1% and 3% of annual revenues. Based on average compliance costs and per capita revenues 

for municipalities with less than 10,000 people, small entities in New Hampshire exceeding 

treatment thresholds would have to serve populations less than 82 ($180,000/$2,192) for costs to 

exceed 1% of revenues and less than 27 ($60,000/$2,192) for costs to exceed 3% of revenues. 

In contrast, for mosquito control in Idaho, municipalities and counties with populations less than 

25,000 that exceed treatment thresholds could have compliance costs greater than 1% of annual 

revenues. Compliance costs could also exceed 1% or 3% of revenues for entities with larger 

populations if per capita revenues are less than average or compliance costs higher than average. 

Information from the 2007 Census of Agriculture indicates that average per farm revenues 

(market value of agricultural good sold) range from $113,916 to $433,901 for the affected areas 
69 May 2010 

(USDA, 2007). Per entity costs for farms may range from $100 to $200 (based on the 

assumption that all farmers have treatment areas below annual thresholds and would only incur a 

portion of the administrative and monitoring costs. These compliance costs could exceed 1% 

and 3% of sales if the annual value of goods sold is below $10,000 to $20,000 and $3,000 to 

$7,000 respectively. 

Similarly, private forest owners could incur compliance costs ranging from $100 to $1,000 per 

year, depending on treatment area size. For these compliance costs to exceed 1% and 3% of 

revenues, annual revenues for private forest owners would need to be below $10,000 to $100,000 

and $3,000 to $30,000, respectively. 

6.3. Summary 

There is very limited data available to identify the specific entities potentially affected by the 

draft PGP or to determine the exact number of entities considered to be small 

governments/businesses or their applicable revenues for comparison to potential compliance 

costs to determine the economic impact. 

Under a conservative (i.e., erring on the side of greater impacts) scenario, approximately 35,000 

small entities could incur compliance costs under the four use patterns, including those that 

would not incur costs associated with technology-based effluent limitations. Lack of revenue 

data precludes estimating the number of these entities for which compliance costs could 

represent a significant portion of revenues or sales. However, data on average revenues/sales for 

municipalities, counties, and irrigated farms provides some indication of the likelihood of level 

of impact, which varies across the unauthorized areas and by use pattern. 
70 May 2010 

7. Qualitative Discussion of Benefits 

This section provides discussion of the potential benefits of the draft PGP. Information is not 

available to quantify or monetize beneficial impacts. However, the published literature suggests 

that pesticides covered under the draft PGP may have adverse effects on aquatic ecosystems. As 

a result, reducing loadings of these pesticides through the IPM practices and pesticide use plans 

required under the draft PGP, may lead to ecological benefits and associated values. 

7.1. Potential for Reduced Loadings 

Although there is no information on baseline pollutant loadings under the four use patterns in the 

unauthorized areas9, or the extent to which these loadings will be reduced under the draft PGP, 

the permit may contribute to water quality related benefits if the actions taken lead to reduced 

loadings of pollutants associated with adverse effects on aquatic ecosystems. 

The draft PGP includes two types of requirements that could have the effect of reducing 

pesticide loadings: technology-based effluent limitations and administrative and monitoring 

requirements. The technology-based effluent limitation requirements include minimizing 

pesticide discharges to waters of the United States, and implementing IPM practices. IPM 

practices include alternatives to traditional pesticide use, if feasible, and consideration of 

environmental conditions when using pesticides. 

The administrative and monitoring requirements include developing PDMPs and site monitoring 

for adverse incidents. The evaluation and justification of practices surrounding pesticide use 

involved in developing PDMPs may result in changes to current pesticide use practices, and 

fewer discharges to waters of the United States. Monitoring for and reporting of adverse 

incidents may have the effect of reducing loadings to the extent that dischargers observe, report, 

and address adverse environmental impacts through changes in application practices. 

Information and data obtained through the reporting requirements may enable confirmation of 

such an effect in the future.10

7.2. Potential Adverse Effects Associated with Pesticides 

Pesticides, although typically designed to target a narrow range of species, nonetheless may have 

unintended adverse impacts on other aquatic species and plants. Information on the extent of 

adverse impacts on aquatic ecosystems associated with pesticide discharges under the four use 

patterns in the unauthorized area is not available. Many aquatic herbicides, which are introduced 

to water, do not persist for significant periods of time in aquatic environments. For example, this 

characteristic is shown in studies of copper herbicides which are 100-200% less toxic after one 

week than upon initial application (Mastin and Rodgers, 2000). 

However, the draft PGP covers a large number of active ingredients in pesticides across the four 

use patterns (see Appendix A). Presence of some of these pollutants in aquatic environments 

may lead to adverse effects on aquatic ecosystems. For example, Table 7-1 presents findings 

from the published literature regarding potential for adverse effects of several of the active 

ingredients. 

 

9

 Although total quantity sold of the various pesticides may be reported, information on the four use patterns covered 

by the draft PGP, and resulting discharges to waters of the United States, is lacking. 

10 Thus, there may also be information benefits stemming from the draft PGP. 
71 May 2010 

Table 7-1: Potential Toxic Effects of Pesticides 

Chemical Toxic Effects 

Adulticides 

Carbaryl1

 Branchial, hepatic, and renal lesions in fish (Gill et al., 1988) 

Chlorpyrifos1 Highly toxic to freshwater fish, aquatic invertebrates, and estuarine and 

marine organisms (EPA, 2002) 

Esfenvalerate1

 Interferes with salmonid sensory processes critical to migration 

(Sandahl, 2004) 

Ethofenprox Sublethal effects to freshwater fish including erratic swimming, 

changes in opercular movement, loss of equilibrium, mucus secretion. 

(Muniyan and Veeraraghavan, 1999) 

Malathion1

 Impacts on minnow growth and reproduction at sufficient 

concentrations (Mount and Stephan, 1967) 

Naled (DDVP) Liver impacts on fish even at very low doses (Sakaguchi, 1972) 

Permethrin1

 Toxicity to some invertebrates at <1 ug/L (McLeesc et al., 1980) 

Pyrethrins1

 Less than 1 u/g can be toxic to some freshwater fish in some 

formulations (Mauck et al., 1976) 

Resmethrin1

 Toxic to some fish and invertebrate species in the range of 0.22-15.0 

ug/L (Rand, 2002) 

Sumithrin (d-phenothrin) Concentrations as low as 1 ppb may be fatal to fish (Cox 2003) 

Larvicides 

Methoprene Sublethal impacts on endocrine processes of invertebrates at even 

very low concentrations (Olmstead and LeBlanc, 2001) 

Aquatic Herbicides 

2,4-D, 2-ethylhexyl ester Limited data available, but may be toxic effects on non-target species 

(APVMA, 2006) 

2,4-D, butoxyethyl ester Limited data available, but may be toxic effects on non-target species 

(APVMA, 2006) 

2-4,D1

 Liver, vascular, and neurological impacts on bluegills, with more severe 

effects at >5 ppm concentration (Cope et al., 1970) 

Copper ethanolamine complex Daphnia magna moderately sensitive to copper pesticides (Mastin and 

Rodgers, 2000) 

Copper ethylene diamine 

complex 

Daphnia magna moderately sensitive to copper pesticides (Mastin and 

Rodgers, 2000) 

Copper sulfate pentahydrate Daphnia magna moderately sensitive to copper pesticides (Mastin and 

Rodgers 2000) 

Diquat dibromide LC50 for some formulations has a 96-hr LC50 of 0.74-4.9 mg/L (Paul et 

al., 1994) 

Fluridone Mildly toxic to fish (LC50 for commercial formulations ranges 1.8-13 

mg/L) (Paul et al., 1994) 

Imazapyr Slightly toxic to aquatic invertebrates (Washington State Department of 

Agriculture, 2003) 

Penoxsulam Slightly toxic, NOAEC at 126 ppm, for the aquatic invertebrate 

Ramshorn snail (U.S. EPA, 2003) 

Triclopyr, triethylamine salt Moderately toxic to fish, mildly toxic to aquatic insects (Kreutzweiser et 

al., 1993) 

Fish Control 

Rotenone Substantial mortality at 17 μg/L in mysid (Naess et al., 1991); mortality 

impacts on white sucker at 9 to 14 μg/L (Holcombe et al., 1987); 

intoxication impacts on water flea at 2.5 to 5.5 μg/L (Rach et al., 1988).

1. Also used for forest canopy pest control. 

Several of these pesticides persist in sediment or in fish tissue, albeit with significant variability 

among pesticide types and formulations. The adulticides chlorpyrifos and esfenvalerate both 

persist in sediment, and chlorpyrifos may also persist in fish tissue (Adelsbach and Tjeerdema, 
72 May 2010 

2003; Extoxnet, 1993b). However, others, such as carbaryl and the larvacide methoprene, are 

less likely to persist (Fisher and Lohner, 1986; Des Lauriers, 2004). 

7.3. Environmental Benefits 

Reducing surface water loadings for pesticides associated with adverse effects on aquatic life 

could have a beneficial impact on aquatic ecosystems. These beneficial impacts may be 

associated with a variety of benefits. EPA broadly classifies the types of benefits that are 

typically associated with environmental policies into those that directly affect human welfare 

(e.g., human health improvements, improved amenities) and those that affect human welfare 

through ecological systems or processes (i.e., ecological benefits). Ecological benefits (Table 

 7-2) include those stemming from direct and indirect use of natural resources (e.g., recreation), 

as well as “nonuse” values derived from knowledge of the existence of clean resources and the 

desire to preserve resources for future generations. 

Table 7-2: Types of Benefits Associated With Environmental Policies: Ecological 

Improvements 

Benefit Category Examples 

Market products 

Recreation activities and aesthetics 

Valued ecosystem functions 

Nonuse values 

Harvests or extraction of food and other resources 

Wildlife viewing, fishing, boating, swimming, hiking 

Biodiversity, genetic library 

Values held for the existence of species, populations, 

communities, or ecosystems 

Source: EPA (2000; 2008) 

7.3.1. Ecological Benefits 

The primary impact of reducing pesticide loadings to waters of the United States will be 

improved water quality, which can have direct impacts on aquatic ecosystems. For example, 

many of the currently registered products covered by the draft PGP are used for eradicating adult 

mosquitoes (adulticides). As shown in Table 7-1, one laboratory study found that the freshwater 

fish Puntius conchonius, if given chronic exposure to the pesticide carbaryl, developed branchial, 

hepatic, and renal lesions (Gill et al., 1988). Another study found that the adulticide ethofenprox 

caused lethal adverse impacts on the freshwater fish Oreochromis mossambicus at concentrations 

of 2.849 ppm and sublethal impacts beginning at concentrations of 1.305 ppm. These sublethal 

effects included erratic swimming, changes in opercular movement, loss of equilibrium, mucus 

secretion, and chromatic changes to skin (Muniyan and Veeraraghavan, 1999). 

Other pesticide products covered under the draft PGP may also have adverse impacts on wildlife 

and vegetation. For example, the mosquito larvicide fungus Lagendidium giganeum is known to 

greatly inhibit the reproduction of water fleas (cladocera) (Helgen et al., 1987). Likewise, 

aquatic herbicides have the potential not only to impact plants other than those targeted by the 

application, but also aquatic wildlife. One study showed the aquatic herbicide copper sulfate to 

have an LC50 of 18.9 μg/L for seven aquatic test species, the most sensitive being Daphnia 

magna (Mastin and Rodgers, 2000). 

In addition to direct impacts on wildlife and vegetation, pesticide discharges may also impact 

overall ecosystem health and function. One example of this is the aforementioned impacts of the 

mosquito larvicide fungus Lagendidium giganeum on cladocerans. These small organisms are 
73 May 2010 

critical determinants of the structure of aquatic ecosystems as a whole, and reductions in their 

numbers can impact the entire food web (Carpenter et al., 1985). 

By minimizing discharges of the pesticides shown in Table 7-1 to waters of the United States, 

the PGP will limit the potential for adverse health and mortality impacts to aquatic wildlife. As 

some fish species are vulnerable to these pesticides, it is possible that pesticide loading 

reductions could have positive impacts on fisheries. For any pollutants that accumulate in the 

system (e.g., chlorpyrifos in sediments and fish tissue), reduced loadings will reduce the 

potential for accumulation and toxicity to aquatic life (from exposure to accumulated pesticides 

in sediments), and potential future remediation efforts. 

7.3.2. Ecological Benefit Values 

Estimating the value of reducing adverse impacts on aquatic ecosystems (or improvements in the 

health of aquatic ecosystems) that result from reductions in loadings under the draft PGP would 

require data and information that are not currently available, including: baseline pollutant 

loadings, change in loadings, environmental impact associated with the change in loadings, and 

the associated changes in ecological values (use and nonuse). Even if ecological effects of 

changes in pesticide loadings could be quantified, estimating the value of the types of ecological 

benefits likely to arise would be challenging for a number of reasons, including that benefits will 

primarily require estimation through nonmarket valuation techniques (e.g., travel cost methods 

for recreation demand; stated preference methods, which involve asking questions regarding 

individuals’ preferences for environmental quality, for nonuse benefits). Because such methods 

are time and resource intensive, analysts often utilize the practice of benefits transfer, or 

estimating the benefits of water quality improvements at one site based on the results of studies 

conducted for other sites and purposes. 

Studies in the published literature have identified values associated with benefits that can be 

expected to arise from improving water quality. As an example, Magat et al. (2000) estimate the 

value of a percentage increase in river miles or lake acres with “good” water quality, defined as a 

river or lake that is a safe place to swim, has fish that are safe to eat, and supports many plants, 

fish, and other aquatic life. The estimated values reflect a total value of the improvement, 

including use and nonuse benefit categories. Azevedo et al. (2001) estimated the willingness to 

pay to maintain the current water quality of a lake used for fishing and avoid future deterioration 

including low fish diversity. Reduced pesticide loadings under the draft PGP may also 

contribute to maintaining or improving water quality and associated values. Although current 

data and information is insufficient to identify the extent or potential magnitude of benefits that 

will result from reducing pesticide loads to waters of the U.S., information gathered from 

monitoring and reporting activities may enable such an effort in the future. 
74 May 2010 

References 

Adelsbach, T.L. and R.S. Tjeerdema. Chemistry and Fate of Fenvalerate and Esfenvalerate. 

2003. Review of Environmental Contamination and Toxicology. 176:137-154. 

Alaska Department of Environmental Conservation (ADEC). State Response for Aquatic Weed 

Control and Mosquito Control. Karin Hendrickson, Pesticide Program Coordinator. 2009. 

Alaska Department of Fish and Game (ADF&G). Alaska Aquatic Nuisance Species Management 

Plan. October 2002. Available electronically at: 

http://www.anstaskforce.gov/State%20Plans/ak_ansmp.pdf 

Australian Pesticides and Veterinary Medicines Authority (APVMA). 2000. Evaluation of the 

new active Imazamox in the products Raptor Herbicide and Raptor WG Herbicide. Available at: 

http://www.apvma.gov.au/registration/assessment/docs/prs_imazamox.pdf 

Australian Pesticides and Veterinary Medicines Authority (APVMA). 2006. Preliminary Review 

Findings (Environment) Part 1: 2,4-D Esters. Available at: 

http://www.apvma.gov.au/products/review/current/2_4_d.php 

Azevedo, C., J. Herriges, and C. Kling. 2001. Valuing Preservation and Improvements of Water 

Quality in Clear Lake. Staff Report 01-SR 94, Center for Agricultural and Rural Development, 

Iowa State University. March. 

Blankinship, Mike. President/CEO Blankinship & Associates, Inc. Personal Communication. 24 

August 2009. 

Birch, Thomas W. 1994. Private Forest-land Owners of the United States, 1994. United States 

Department of Agriculture, Forest Service. Northeastern Forest Experiment Station Resource 

Bulletin NE-134. Available electronically at: 

http://www.fs.fed.us/ne/newtown_square/publications/resource_bulletins/pdfs/scanned/OCR/ne_

rb134a.pdf. 

Bureau of Indian Affairs (BIA). 2005. 2005 Status of Forest Management Inventories and 

Planning. Available electronically at: 

http://www.itcnet.org/includes/downloads/4_atus_of_forest_inventories.pdf. 

Bureau of Labor Statistics. Employer Costs for Employee Compensation (ECEC). September 

2009 Release. Available electronically at: 

http://www.bls.gov/news.release/archives/ecec_12092009.pdf 

Bureau of Labor Statistics. Employment Cost Index (ECI). September 2009 Release. Available 

electronically at: http://www.bls.gov/news.release/archives/eci_10302009.pdf 

Bureau of Labor Statistics. Occupational Employment Statistics (OES). May 2008 Release. 

Available electronically at: http://www.bls.gov/OES/2008/may/oessrci.htm

Carpenter, S.R., J.F. Kitchell, and J.R. Hodgson. 1985. Cascading Trophic Interactions and Lake 

Productivity. BioScience. 35(10): 634-639. 

City of Davis. 2008. Integrated Pest Management Program 2008 Annual Report. Prepared by 

Martin Guerena and John McNerney. 

Coble, Harold. North Carolina State University. Personal communication 20 August 2009. 
75 May 2010 

Conlon, Joe. AMCA Technical Director. Personal Communication. 18 August 2009 

Cope, Oliver B., George H. Wallen, and Edward M. Wood. 1970. Transactions of the American 

Fisheries Society. 99:1-12. 

Cox, C. 2003. Insecticide Factsheet: Sumithrin (D-Phenothrin). Journal of Pesticide Reform. 

23(2):10-14. 

Des Lauriers, Angelune. 2004. The fate and transport of methoprene in an urban West Nile virus 

mosquito control program (abstract). Masters Abstracts International. 47(1, 130): p.2004. 

Executive Order 13112 of February 3, 1999. Available electronically at: 

http://www.invasivespecies.gov/home_documents/EO%2013112.pdf 

Extension Toxicology Network (EXTOXNET). 1993a. Atrazine. Project of Cooperative 

Extension Offices of Cornell University, Michigan State University, Oregon State University, 

and University of California at Davis. Available electronically at: 

http://pmep.cce.cornell.edu/profiles/extoxnet/24d-captan/atrazine-ext.html . Accessed April 15, 

2010. 

Extoxnet: The Extension Toxicology Network. 1993b. Pesticide Information Profile: 

Chlorpyrifos. Cooperative extension offices of Cornell University, Michigan State University, 

Oregon State University and University of California at Davis. Available electronically at: 

http://pmep.cce.cornell.edu/profiles/extoxnet/carbaryl-dicrotophos/chlorpyrifos-ext.html 

Fisher, S.W. and T.W. Lohner. Studies on the environmental fate of carbaryl as a function of pH. 

1986. Archives of Environmental Contamination and Toxicology. 15(6): 1432-0703. 

Florida Fish and Wildlife Conservation Commission (FWC). 2009. Freshwater Permits: Triploid 

Grass Carp. Available electronically at: 

http://www.myfwc.com/License/FreshwaterPermit_grasscarp.htm 

Food and Agricultural Organization of the United Nation (FAO). 2005. Global Forest Resources 

Assessment, 2005. Available electronically at: http://www.fao.org/forestry/fra/fra2005/en/ 

Gill, T.S., J.C. Pant, and J. Pant. 1988. Gill, liver, and kidney lesions associated with 

experimental exposures to carbaryl and dimethoate in the fish (Puntius conchonius ham.) Bull. 

Environmental Contamination and Toxicity. 41(1):71-78. 

Greenfield, Ben K. et al. Review of Alternative Aquatic Pest Control Methods for California 

Waters. San Francisco Estuary Institute, San Francisco, CA. April 2004. Available electronically 

at: http://www.sfei.org/apmp/reports/PestAlternatives_review.pdf 

Hamel, Kathy. Washington Department of Ecology. Personal Communication.21 August 2009. 

Health Canada. 2008. Proposed Registration Decision: Bispyribac-sodium. Pest Management 

Regulatory Agency. Available at: http://dsp-psd.pwgsc.gc.ca/collection_2008/pmra-arla/H113-9-

2008-2E.pdf 

Helgen, J.C., N.J. Larson, and R.L. Anderson. 1988. Responses of zooplankton and Chaoborus to 

temephos in a natural pond and in the laboratory. Earth and Environmental Science. 17(4): 459-

471. 
76 May 2010 

Holcombe, G.W., G.L. Phipps, A.H. Sulaiman, and A.D. Hoffman. Simultaneous Multiple 

Species Testing: Acute Toxicity of 13 Chemicals to 12 Diverse Freshwater Amphibian, Fish, and 

Invertebrate Families. Archives of Environmental Contamination and Toxicology. 16:697-710 

Idaho Invasive Species Council (IISC) Technical Committee. Idaho Aquatic Nuisance Species 

Plan. 2007. Available electronically at: 

http://www.anstaskforce.gov/State%20Plans/Idaho_ANS_Plan_2007.pdf 

Idaho State Department of Agriculture (ISDA) and Gem County Mosquito Abatement District, 

Emmett, Idaho. State Response for Mosquito Control. Robert Hays, Urban Pesticide Program 

Manager (ISDA) and Jason Kinley, Director of Gem County MAD. 2009. 

Idaho State Department of Agriculture (ISDA). State Response for Aquatic Weed Control. 

Thomas Woolf, Aquatic Plant Program Manager. 2009. 

Kreutzweiser, D.P., S.B. Holmes, and D.C. Eichenberg. 1994. Influence of exposure duration on 

the toxicity of triclopyr ester to fish and aquatic insects. Earth and Environmental Sciences. 

26(1):124-129. 

Magat, W., J. Huber, W.K. Viscusi, and J. Bell. 2000. An Iterative Choice Approach to Valuing 

Clean Lakes, Rivers, and Streams. Journal of Risk and Uncertainty, 21:1, 7-43. 

Massachusetts Aquatic Invasive Species (MA AIS) Working Group. Massachusetts Aquatic 

Invasive Species Management Plan. December 2002. Available electronically at: 

http://www.mass.gov/czm/invasives/docs/invasive_species_plan.pdf 

Massachusetts Department of Agricultural Resources (MDAR). Annual Operations Reports. 

2008. Available electronically at: http://www.mass.gov/agr/mosquito/annualreports.htm 

Massachusetts Department of Environmental Protection (MADEP). State Response for Aquatic 

Weed Control. Robert Kubit and Gary Gonyea, Environmental Engineer. 2009. 

Mastin, B.J. and J.H. Rodgers, Jr. 2000. Toxicity and Bioavailability of Copper Herbicides 

(Clearigate, Cutrine-Plus, and Copper Sulfate) to Freshwater Animals. Earth and Environmental 

Science. 39(4): 445-451. 

Mauck, W.L., L.E. Olson, L.L. Marking. 1976. Toxicity of natural pyrethrins and five 

pyrethroids to fish. Archives of Environmental Contamination and Toxicology. 4(1): 18-29. 

McGregor, Susan. Dragon Mosquito Control. Personal Communication. August 2009 

McLeesc, D.W., C.D. Metcalfe, and V. Zitko. Lethality of permethrin, cypermethrin and 

fenvalerate to salmon, lobster and shrimp. Bulletin of Environmental Contamination and 

Toxicology. 25(1):950-955. 

Mount, D.I. and C.E. Stephan. A method for establishing acceptable toxicant limits for fish--

malathion and the butoxyethanol ester of 2,4-d. Transactions of the American Fisheries Society. 

96: 185-193 

Muniyan, M. and K. Veeraraghavan. 1999. Acute toxicity of ethofenprox to the freshwater fish, 

Oreochromis mossambicus (Peters). Journal of Environmental Biology. 20(2): 153-155. 

Naess, T., K.E. Naas, and O.B. Samuelsen. Toxicity of Rotenone to Some Potential Predators on 

Marine Fish Larvae - an Experimental Study. Aquaculture Engineering. 10(3): 149-159. 
77 May 2010 

National Alliance of Forest Owners (NAFO). 2009. Aggregate Pesticide Use Statistics for Four 

Timber Companies. November 2009. 

National Invasive Species Council (NISC). 2008-2012 National Invasive Species Management 

Plan. August 2008. Available electronically at: 

http://www.invasivespecies.gov/home_documents/2008-

2012%20National%20Invasive%20Species%20Management%20Plan.pdf. 

New Hampshire Department of Agriculture, Markets, and Food (NHDAMF). Division of 

Pesticide Control. State Response for Aquatic Weed Control and Mosquito Control. Robert A. 

Wolff, Environmentalist 111 - Groundwater. 2009. 

New Hampshire Department of Environmental Services (NHDES). Plant Control Techniques. 

2009. Available electronically at: 

http://des.nh.gov/organization/divisions/water/wmb/exoticspecies/management.htm 

New Hampshire Department of Health and Human Services. Guidance for Towns and Cities: 

Response Plans and Funding for Mosquito Control. Available electronically at: 

http://www.dhhs.state.nh.us/DHHS/CDCS/West+Nile+Virus/wnv-eee-towns.htm 

New Hampshire Fish and Game Department (NHFGD). Communicating with the Public on 

Aquatic Nuisance Species (ANS) Final Report for the state of New Hampshire. March 2006. 

Available electronically at: http://www.protectyourwaters.net/ansreport/NHFinalReport.pdf 

New Mexico Aquatic Invasive Species Advisory Council (AISAC). New Mexico Aquatic 

Invasive Species Management Plan. October 2008. Available electronically at: 

http://www.wildlife.state.nm.us/documents/NMAISMgmt%20Plan_Final_Oct_08.pdf 

New Mexico Department of Agriculture (NMDA). State Response for Aquatic Weed Control 

and Mosquito Control. Cary C.S. Hamilton, Program Manager. 2009. 

New Mexico Department of Health (NMDOH). Mosquito Control Responsibilities. 2009. 

Available electronically at: 

http://www.health.state.nm.us/epi/documents/MOSQUITOCONTROLRESPONSIBILITIES_00

0.pdf 

Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990. Available electronically 

at: http://www.anstaskforce.gov/Documents/nanpca90.pdf 

Norton, G. and J. Maupin. Does IPM Adoption Reduce Pesticide Use? A National-level 

Accounting. July 2009. Poster Presentation at AAEA & ACCI 2009 Joint Annual Meeting. 

Oklahoma Department of Agriculture, Food and Forestry (ODAFF). State Response for Aquatic 

Weed Control and Mosquito Control. Quang Pham and Mike Vandeventer, Environmental 

Program Managers. 2009. 

Oklahoma Department of Wildlife Conservation (ODWC).Oklahoma Aquatic Nuisance Species 

Management Plan. July 2008. Available electronically at: 

http://southeastaquatics.net/uploads/document/d03eae47cb2a8739b0420d75eb87f61ae04f6c45.p

df. 

Olmstead, Allen W. and Gerald L. LeBlanc. 2001. Low Exposure Concentration Effects of 

Methoprene on Endocrine-Regulated Processes in the Crustacean Daphnia magna Toxicological 

Sciences. 62:268-273. 
78 May 2010 

Paul, E.A., H.A. Simonin, J. Symula, and R.W. Bauer. 1994. The toxicity of diquat, endothall, 

and fluridone to the early life stages of fish. Journal of Freshwater Ecology. 9(3):229-240. 

Puerto Rico Department of Health (PRDOH). Puerto Rico West Nile Response Plan. Available 

electronically at: 

http://www.salud.gov.pr/Datos/VirusDelNiloOccidental/Documents/prWNRP.pdf. 

PSMJ Resources, Inc. 2009. 2009 PSMJ A/E Financial Performance Survey, 29th Edition: CEO 

Snapshot. 

Rach, J.J., T.D. Bills, and L.L. Marking. Acute and Chronic Toxicity of Rotenone to Daphnia 

magna. Investigations in Fish Control No. 92, US Fish and Wildlife Service, U.S.D.I., 

Washington, D.C. :5 p. 

Rand, G.M. 2002. Hazard Assessment of Resmethrin: I. Effects and Fate in Aquatic Systems. 

Ecotoxicology. 11(2):101-111. 

Sakaguchi, H. On the effect of agricultural chemicals upon fish - I. Changes of chemical 

components in serum and liver of crap exposed to organophosphate compounds. Bull. Jap. Soc. 

Sci. Fish. 38(6): 555-560. 

Sandahl, J.F., D.H. Baldwin, J.J. Jenkins, and N.L. Scholz. 2004. Odor-evoked field potentials as 

indicators of sublethal neurotoxicity in juvenile coho salmon (Oncorhynchus kisutch) exposed to 

copper, chlorpyrifos, or esfenvalerate. Canadian Journal of Fisheries and Aquatic Sciences. 

61(3):404-413. 

Silver City. Silver City Vector Control Task Force. Available electronically at: 

http://www.townofsilvercity.org/vector/scienceofvector.html 

U.S. Geological Survey (USGS). 2009. National Hydrography Dataset (NHD). Available 

electronically at: http://nhd.usgs.gov/ 

United States Department of Agriculture (USDA) Forest Service. 2002. Guam’s Forest 

Resources, 2002. Available electronically at: http://www.fs.fed.us/pnw/pubs/pnw_rb243.pdf. 

United States Department of Agriculture (USDA) Forest Service. 2001. American Samoa’s 

Forest Resources, 2001. Available electronically at: 

http://www.fs.fed.us/pnw/pubs/pnw_rb244.pdf. 

United States Department of Agriculture (USDA) Forest Service. Recreational Activities List by 

State. Available electronically at: http://www.fs.fed.us/recreation/map/state_list.shtml. 

United States Environmental Protection Agency (USEPA). 2003. Data Evaluation Reports on the 

Acute Toxicity of XDE-638 on Freshwater Invertebrates. Available at: 

http://www.epa.gov/pesticides/chemical/foia/cleared-reviews/reviews/119031/119031.htm 

United States Environmental Protection Agency (USEPA). 2002. Registration Standard 

(Second Round Review) for the Reregistration of Pesticide Products Containing Chlorpyrifos. 

Office of Pesticide Programs, U.S. EPA, Washington, DC. June. 

Washington State Department of Agriculture. 2003. Ecological Risk Assessment of the Proposed 

Use of the Herbicide Imazapyr to Control Invasive Cordgrass (Spartina spp.) in Estuarine Habitat 

Of Washington State. Available at: 
79 May 2010 

http://www.ecy.wa.gov/programs/WQ/pesticides/final_pesticide_permits/noxious/risk_assessme

nt_Imazapyr.pdf 
80 May 2010 

Appendix A 

Table A-1: List of Active Ingredients: Mosquito (Larvicides and Adulticides) and Other 

Flying Insect Pest Control (Black Fly) 

Mosquito Adulticides 

bifenthrin 

Chlorpyrifos 

deltamethrin 

etofenprox 

malathion 

naled 

permethrin 

Pyrethrins 

resmethrin 

sumithrin 

tau-fluvalinate 

Mosquito Larvicides 

Bacillus thuringiensis israelensis 

Bacillus sphaericus 

methoprene 

mineral oil 

mono-molecular surface film 

petroleum distillate 

temephos 

Black Fly 

Bacillus thuringiensis israelensis 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

Herbicides 

1H-Pyrazole-3-carboxylic acid, 4,5-dihydro-5-oxo-1-(4-sulfophenyl)-4-((4-sulfophenyl)azo)-, trisodium 

salt 

2-(4,5-Dihydro-4-methyl-4-(1-methylethyl)-5-oxo-1H-imidazol-2-yl)-3-pyridinecarboxylic acid with 2-

propanamine (1:1) 

2,4-D, 2-ethylhexyl ester 

2,4-D, butoxyethyl ester 

2,4-D, dimethylamine salt 

2,4-D, isopropylamine salt 

2,4-D, sodium salt 

2,4-D, triisopropanolamine salt 

2-4,D 

2-Pyridinecarboxylic acid, 4-amino-3,5,6-trichloro-, compd. with 1,1',1''-nitrilotris(2-propanol) (1:1) 

3-Isopropyl-1H-2,1,3-benzothiadiazin-4(3H)-one-2,2-dioxide, sodium salt 

5-Bromo-3-sec-butyl-6-methyluracil, lithium salt 

Acetic acid, ((3,5,6-trichloro-2-pyridinyl)oxy)-, 2-butoxyethyl ester 

Acetic acid, (4-chloro-2-methylphenoxy)-, isooctyl ester 

Acid Blue 9 

Acrolein 
81 May 2010 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

Alachlor 

Atrazine 

Benfluralin 

Benzoic acid, 3,6-dichloro-2-methoxy-, compd with 2-propanamine (1:1) 

Benzoic acid, 3,6-dichloro-2-methoxy-, compd with N-methylmethanamine (1:1) 

Bromoxynil 

Bromoxynil octanoate 

Bronopol 

Carbamothioic acid, dipropyl-, S-ethyl ester 

Chloropicrin 

Chlorsulfuron 

Copper carbonate 

Cycloate 

DCPA (or chlorthal-dimethyl?) 

Dicamba 

Diquat dibromide 

Dithiopyr 

Diuron 

Endothal-dipotassium 

Endothall, mono(N,N,-dimethyl alkyl amine) salt 

Ethalfluralin 

Fluridone 

Glyphosate 

Glyphosate-isopropylammonium 

Heptanoic acid, 2,6-dibromo-4-cyanophenyl ester 

Hexazinone 

Imazapyr 

Linuron 

MCPA (and salts and esters) 

MCPA, dimethylamine salt 

Mecoprop-P 

Metam-sodium 

Metolachlor 

Metribuzin 

Metsulfuron 

Molinate 

Napropamide 

Norflurazon 

Oryzalin 

Oxyfluorfen 

Pendimethalin 

Prometon 

Prometryn 

Propanoic acid, 2-(4-((5-(trifluoromethyl)-2-pyridinyl)oxy)phenoxy)-, butyl ester, (R)- 

Propyzamide 

Pyrazon 

Simazine 

Sodium bromide 
82 May 2010 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

Sodium chlorate 

Sulfometuron 

Telone 

Triallate 

Triclopyr 

Triclopyr, triethylamine salt 

Trifluralin 

Algaecides 

Acrolein 

Alkyl* dimethyl benzyl ammonium chloride 

Alkyl* dimethyl ethylbenzyl ammonium chloride 

Ammonia 

Bacillus licheniformis 

Bacillus thuringiensis Subsp. Kurstaki, 

Basic cupric sulfate 

Bromine chloride 

1-Bromo-3-chloro-5,5-dimethylhydantoin 

Bronopol 

Calcium hypochlorite 

Chlorine 

5-Chloro-2-methyl-3(2H)-isothiazolone 

Chlorothalonil 

Copper as metallic (in the form of chela 

Copper carbonate 

Copper ethanolamine complex 

Copper hydroxide 

Copper oxychloride 

Copper sulfate pentahydrate 

Copper triethanolamine complex 

Deltamethrin 

2,2-Dibromo-3-nitrilopropionamide 

1,3-Dibromo-5,5-dimethylhydantoin 

Didecyl dimethyl ammonium chloride 

Dioctyl dimethyl ammonium chloride 

Diquat dibromide 

Diuron 

Dodecylguanidine hydrochloride 

Endothal-dipotassium 

Endothall, mono(N,N,-dimethyl alkyl amine) salt 

Erioglaucine 

Etridiazole 

Fluridone 

Glutaral 

Hydrogen peroxide 

Mancozeb 

Maneb 

Methanone 
83 May 2010 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

2-Methyl-3(2H)-isothiazolone 

Methylene bis(thiocyanate) 

Nonanoic acid 

Octanoic acid 

Octyl decyl dimethyl ammonium chloride 

Peroxyacetic acid 

Poly(oxyethylene(dimethyliminio)ethylene 

Propiconazole 

Sodium bromide 

Sodium chlorate 

Sodium chlorite 

Sodium dichloro-s-triazinetrione 

Sodium dichloroisocyanurate dihydrate 

Sodium hypochlorite 

Sodium percarbonate 

Tartrazine 

Tetrakis(hydroxymethyl)phosphonium sulphate 

2-(Thiocyanomethylthio)benzothiazole 

p-Tolyl diiodomethyl sulfone 

Trichloro-s-triazinetrione 

Xylene 

Ditchbanks 

2-(4,5-Dihydro-4-methyl-4-(1-methylethyl)-5-oxo-1H-imidazol-2-yl)-3-pyridinecarboxylic acid with 2-

propanamine (1:1) 

2,4-D, 2-ethylhexyl ester 

2,4-D, butoxyethyl ester 

2,4-D, diethanolamine salt 

2,4-D, dimethylamine salt 

2,4-D, isopropylamine salt 

2,4-D, triisopropanolamine salt 

2-4,D 

2-Methyl-3(2H)-isothiazolone 

2-Pyridinecarboxylic acid, 4-amino-3,5,6-trichloro-, compd. with 1,1',1''-nitrilotris(2-propanol) (1:1) 

3,6-Dichloro-2-pyridinecarboxylic acid, alkanolamine salts (of ethanol and isopropanol series) 

3-Pyridinecarboxylic acid, 2-(4,5-dihydro-4-methyl-4-(1-methylethyl)-5-oxo-1H-imidazol-2-yl)-5-methyl-, 

monoammonium salt, (.+-.)- 

3-Quinolinecarboxylic acid, 2-(4,5-dihydro-4-methyl-4-(1-methylethyl)-5-oxo-1H-imidazol-2-yl)-, 

monoammonium salt 

4-Amino-3,6-dichloropyridine-2-carboxylic acid, potassium salt 

5-Bromo-3-sec-butyl-6-methyluracil, lithium salt 

5-Chloro-2-methyl-3(2H)-isothiazolone 

9H-Fluorene-9-carboxylic acid, 2,7-dichloro-9-hydroxy-, methyl ester 

Acephate 

Acetic acid, ((3,5,6-trichloro-2-pyridinyl)oxy)-, 2-butoxyethyl ester 

Asulam, sodium salt 

Atrazine 

Bacillus thuringiensis subspecies israelensis Strain BMP 144 solids, spores and insecticidal 

toxins 
84 May 2010 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

Bacillus sphaericus 

Benzamide, 2-chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-pyrimidinyl]-4-fluoro-N-

[[methyl(1-methylethyl)amino]sulfonyl]- 

Benzoic acid, 3,6-dichloro-2-methoxy-, compd with 2-(2-aminoethoxy)ethanol (1:1) 

Benzoic acid, 3,6-dichloro-2-methoxy-, compd with N-methylmethanamine (1:1) 

Boric acid (HBO2), sodium salt 

Bromacil 

Carbaryl 

Carfentrazone-ethyl 

Chevron 100 

Chlorflurenol, methyl ester 

Clopyralid 

Clopyralid, triethanolamine 

Diazinon 

Dicamba 

Dicamba, sodium salt 

Difethialone 

Diflubenzuron 

Diphacinone 

Diquat dibromide 

Diuron 

Fluroxypyr 

Fluroxypyr 1-methylheptyl ester 

Glufosinate 

Glutens, corn 

Glycine, N-(phosphonomethyl)- potassium salt 

Glycine, N-(phosphonomethyl)-, ammonium salt 

Glycine, N-(phosphonomethyl)-, compd. with N-methylmethanamine (1:1) 

Glycine, N-(phosphonomethyl)-, diammonium salt 

Glyphosate 

Glyphosate-isopropylammonium 

Hexazinone 

Hydrogen peroxide 

Imazapic 

Imazapyr 

Imidacloprid 

Isooctyl 2-(2,4-dichlorophenoxy)propionate 

MCPA, dimethylamine salt 

Mecoprop (and salts and esters) 

Methyl 9-hydroxyfluorene-9-carboxylate 

Metsulfuron 

Mineral oil - includes paraffin oil from 063503 

MSMA (and salts) 

Nonanoic acid 

Octhilinone 

Oryzalin 

Oxyfluorfen 

Pendimethalin 
85 May 2010 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

POE isooctadecanol 

Prodiamine 

Prometon 

Propanoic acid, 2-(2,4-dichlorophenoxy)-, (R)-, compd. with N-methylmethanamine (1:1) 

Propanoic acid, 2-(2,4-dichlorophenoxy)-, 2-ethylhexyl ester 

Propanoic acid, 2-(4-chloro-2-methylphenoxy)-, (R)-, compd. with N-methylmethanamine (1:1) 

Pyraflufen-ethyl 

Pyriproxyfen 

Rimsulfuron 

S-Methoprene 

Sodium chlorate 

Sulfentrazone 

Sulfometuron 

Sulfosulfuron 

Tebuthiuron 

Topramezone 

Triclopyr 

Triclopyr, triethylamine salt 

Triisopropanolamine salt of aminopyralid 

Zinc phosphide (Zn3P2) 

Rights Of Way 

(Z)-6-Heneicosen-11-one 

1,2-Benzisothiazolin-3-one 

1-Decanaminium, N-decyl-N,N-dimethyl-, chloride 

2-(4,5-Dihydro-4-methyl-4-(1-methylethyl)-5-oxo-1H-imidazol-2-yl)-3-pyridinecarboxylic acid with 2-

propanamine (1:1) 

2,4-D, 2-ethylhexyl ester 

2,4-D, butoxyethyl ester 

2,4-D, diethanolamine salt 

2,4-D, dimethylamine salt 

2,4-D, isopropylamine salt 

2,4-D, triisopropanolamine salt 

2-4,D 

2-Cyclohexen-1-one, 2-{1-{{(3-chloro-2-propenyl)oxy}imino}propyl}-3-hydroxy-5-(tetrahydro-2H-pyran-4-

yl)-,(E,?)- 

2-Ethylhexyl (R)-2-(2,4-dichlorophenoxy)propionate 

2-Pyridinecarboxylic acid, 4-amino-3,5,6-trichloro-, compd. with 1,1',1''-nitrilotris(2-propanol) (1:1) 

3,6-Dichloro-2-pyridinecarboxylic acid, alkanolamine salts (of ethanol and isopropanol series) 

3-Isopropyl-1H-2,1,3-benzothiadiazin-4(3H)-one-2,2-dioxide, sodium salt 

3-Methyl-2-cyclohexen-1-one 

3-Pyridinecarboxylic acid, 2-(4,5-dihydro-4-methyl-4-(1-methylethyl)-5-oxo-1H-imidazol-2-yl)-5-methyl-, 

monoammonium salt, (.+-.)- 

3-Pyridinecarboxylic acid, 2-{1-{{{(3,5-difluorophenyl)amino}carbonyl}hydrozono}ethyl}-, monosodium 

salt 

3-Quinolinecarboxylic acid, 2-(4,5-dihydro-4-methyl-4-(1-methylethyl)-5-oxo-1H-imidazol-2-yl)-, 

monoammonium salt 

4-Amino-3,6-dichloropyridine-2-carboxylic acid, potassium salt 

5-Bromo-3-sec-butyl-6-methyluracil, lithium salt 
86 May 2010 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

9H-Fluorene-9-carboxylic acid, 2,7-dichloro-9-hydroxy-, methyl ester 

Abamectin 

Acetamide, N-(2,4-dimethyl-5-(((trifluoromethyl)sulfonyl)amino)phenyl)-, compd. with 

2,2'iminobis(ethanol) (1:1) 

Acetamiprid 

Acetic acid, ((3,5,6-trichloro-2-pyridinyl)oxy)-, 2-butoxyethyl ester 

Acetic acid, (2,4-dichlorophenoxy)-, compd. with methanamine (1:1) 

Alkyl* dimethyl benzyl ammonium chloride *(50%C14, 40%C12, 10%C16) 

Amitrole 

Ammonium salt of (+/-)-2-(4,5-dihydro-4-methyl-4-(1-methylethyl)-5-oxo-1H-imidazol-2-yl)-5-ethyl-3-

pyridinecarboxylic acid 

Asulam, sodium salt 

Atrazine 

Azadirachtin 

Bacillus thuringiensis subspecies kurstaki strain SA-12 solides, spores, and insecticidal toxins, 

ATCC # SD - 1323 

Bacillus thuringiensis subsp. kurstaki 

Benfluralin 

Benzamide, 2-chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-pyrimidinyl]-4-fluoro-N-

[[methyl(1-methylethyl)amino]sulfonyl]- 

Benzoic acid, 3,6-dichloro-2-methoxy-, compd with 2-(2-aminoethoxy)ethanol (1:1) 

Benzoic acid, 3,6-dichloro-2-methoxy-, compd with 2-propanamine (1:1) 

Benzoic acid, 3,6-dichloro-2-methoxy-, compd with N-methylmethanamine (1:1) 

Bifenazate 

Bifenthrin 

Boric acid 

Boric acid (HBO2), sodium salt 

Bromacil 

Butylated hydroxytoluene 

Carbaryl 

Carfentrazone-ethyl 

Chevron 100 

Chlorflurenol, methyl ester 

Chlorophacinone 

Chlorpyrifos 

Chlorsulfuron 

Chondrostereum purpureum isolate PFC 2139, ATCC 60854 

cis-7,8-Epoxy-2-methyloctadecane 

Clethodim 

Clopyralid 

Cypermethrin 

Deltamethrin 

Dicamba 

Dicamba with 2,4-D 

Dicamba, sodium salt 

Dichlobenil 

Dichlorvos 

Diflubenzuron 

dimethenamide-P 
87 May 2010 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

Diphacinone 

Diquat dibromide 

Dithiopyr 

Diuron 

d-trans-Chrysanthemum monocarboxylic ester of dl-2-allyl-4-hydroxy-3-methyl-2-cyclopenten-1-one 

Ethylene 

Fenoxaprop-p-ethyl 

Ferric HEDTA 

Fipronil 

Flumioxazin 

Fluroxypyr 

Fluroxypyr 1-methylheptyl ester 

Fosamine 

Glufosinate 

Glutaraldehyde 

Glycine, N-(phosphonomethyl)- potassium salt 

Glycine, N-(phosphonomethyl)-, ammonium salt 

Glycine, N-(phosphonomethyl)-, compd. with N-methylmethanamine (1:1) 

Glycine, N-(phosphonomethyl)-, diammonium salt 

Glyphosate 

Glyphosate-isopropylammonium 

Halosulfuron-methyl 

Hexazinone 

Hydramethylnon 

Imazamox 

Imazapic 

Imazapyr 

Imazethapyr 

Imidacloprid 

Indoxacarb 

Isooctyl 2-(2,4-dichlorophenoxy)propionate 

Isoxaben 

lambda-Cyhalothrin 

Maleic hydrazide, potassium salt 

MCPA (and salts and esters) 

MCPA, 2-ethylhexyl ester 

MCPA, dimethylamine salt 

Mecoprop (and salts and esters) 

Mecoprop, dimethylamine salt 

Mecoprop-P 

Metaldehyde 

Methyl 9-hydroxyfluorene-9-carboxylate 

Metribuzin 

Metsulfuron 

Mineral oil - includes paraffin oil from 063503 

MSMA (and salts) 

N-(2,4-Dimethyl-5-(((trifluoromethyl)sulfonyl)amino)phenyl)acetamide, potassium salt 

Napropamide 
88 May 2010 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

Nonanoic acid 

Norflurazon 

Oryzalin 

Oxadiazon 

Oxyfluorfen 

Paclobutrazol 

Pendimethalin 

Permethrin 

Phosphoric acid, iron(3+) salt (1:1) 

Picloram 

Picloram-potassium 

Piperonyl butoxide 

Prodiamine 

Prometon 

Propanoic acid, 2-(2,4-dichlorophenoxy)-, (R)-, compd. with N-methylmethanamine (1:1) 

Propanoic acid, 2-(2,4-dichlorophenoxy)-, 2-ethylhexyl ester 

Propanoic acid, 2-(4-((5-(trifluoromethyl)-2-pyridinyl)oxy)phenoxy)-, butyl ester, (R)- 

Propanoic acid, 2-(4-chloro-2-methylphenoxy)-, (R)-, compd. with N-methylmethanamine (1:1) 

Propoxur 

Pyraflufen-ethyl 

Pyrethrins 

Pyriproxyfen 

Quinclorac 

Resmethrin 

Rimsulfuron 

Sethoxydim 

Simazine 

S-Methoprene 

Sodium chlorate 

Spinosad (Naturally occurring mixture of spinosyn A, pc code 110003 , CAS Reg. No. 131929-60-7 ; & 

spinosyn D, pc code 110004, CAS Reg. No. 131929-63-0) With CAS Reg. No. 168316-95-8 by 

SPINOSAD itself. 

Starlicide 

Sucrose 

Sulfentrazone 

Sulfometuron 

Sulfonic acids, C14-16-alkane hydroxy and C14-16-alkene, sodium salts 

Sulfosulfuron 

Tebuthiuron 

Tetramethrin 

Thiazopyr 

Thiodicarb 

Thiram 

Topramezone 

Triclopyr 

Triclopyr, triethylamine salt 

Trifluralin 

Triisopropanolamine salt of aminopyralid 
89 May 2010 

Table A-2: List of Active Ingredients: Aquatic Weed (Herbicides) and Algae (Algaecides) 

Control (Ditch Banks and Rights of Way)

Triticonazole 

Vinegar 

Yellow mustard seed (Brassica hirta) 

Zeta-Cypermethrin 

Zinc phosphide (Zn3P2) 

Table A-3: List of Active Ingredients: Aquatic Nuisance Animals (Fish, Lamprey, and 

Mollusk)

Fish 

Antimycin A 

Calcium hypochlorite 

Cube Resins other than rotenone 

Piperonyl butoxide 

Rotenone 

Sodium hypochlorite 

Mollusk 

Sodium chlorate 

Lamprey 

Niclosamide 

Phenol, 4-nitro-3-(trifluoromethyl) 

Table A-4: List of Active Ingredients: Forest Canopy Pest Control (Forestry)

Forestry 

(Z)-6-Heneicosen-11-one 

.beta.-D-Allofuranuronic acid, 5-((2-amino-5-O-(aminocarbonyl)-2-deoxy-L-xylonoyl)amino)-1-(5-

carboxy-3,4-dihydro-2,4-dioxo-1(2H)-pyrimidinyl)-1,5-dideoxy-, zinc salt (1:1) 

1,2,4-Triazin-3(2H)-one, 4,5-dihydro-6-methyl-4-{(3-pyridinylmethylene)amino}-, (E)- 

1,2-Benzisothiazolin-3-one 

11-Tetradecen-1-ol, acetate, (E)- 

2-(4,5-Dihydro-4-methyl-4-(1-methylethyl)-5-oxo-1H-imidazol-2-yl)-3-pyridinecarboxylic acid with 2-

propanamine (1:1) 

2,4-D, 2-ethylhexyl ester 

2,4-D, butoxyethyl ester 

2,4-D, diethanolamine salt 

2,4-D, dimethylamine salt 

2,4-D, triisopropanolamine salt 

2-4,D 

2-Butanone, 4-(4-(acetyloxy)phenyl)-, acetate 

2-Ethylhexyl (R)-2-(2,4-dichlorophenoxy)propionate 

2-Methyl-3(2H)-isothiazolone 

2-Pyridinecarboxylic acid, 4-amino-3,5,6-trichloro-, compd. with 1,1',1''-nitrilotris(2-propanol) (1:1) 

3,6-Dichloro-2-pyridinecarboxylic acid, alkanolamine salts (of ethanol and isopropanol series) 

3,7-Dimethyl-6-octen-1-ol 

3-Buten-2-one, 4-(2,6,6-trimethyl-2-cyclohexen-1-yl)-, (E)- 

3-Methyl-2-cyclohexen-1-one 
90 May 2010 

Table A-4: List of Active Ingredients: Forest Canopy Pest Control (Forestry)

4-Amino-3,6-dichloropyridine-2-carboxylic acid, potassium salt 

5-Chloro-2-methyl-3(2H)-isothiazolone 

9,10-Anthracenedione 

9,11-Tetradecadien-1-ol, 1-acetate, (9E, 11E)- 

9,11-tetradecadien-1-ol, acetate, (9E, 11Z)- 

9H-Fluorene-9-carboxylic acid, 2,7-dichloro-9-hydroxy-, methyl ester 

Abamectin 

Acephate 

Acequinocyl 

Acetamiprid 

Acetic acid, ((3,5,6-trichloro-2-pyridinyl)oxy)-, 2-butoxyethyl ester 

Alkyl*-N,N-bis(2-hydroxyethyl)amine *(100% C12-C18) 

Asulam, sodium salt 

Atrazine 

Azadirachtin 

Azinphos-Methyl 

Azoxystrobin 

Bacillus thuringiensis subspecies kurstaki strain SA-12 solides, spores, and insecticidal toxins, 

ATCC # SD - 1323 

Bacillus firmus strain I-1582 

Bacillus pumilus strain QST 2808 

Bacillus subtilis GB03 

Bacillus subtilis var. amyloliquefaciens Strain FZB24 

Bacillus thuringiensis subsp. kurstaki 

Bacillus thuringiensis subsp. kurstaki strain BMP123 

Bacillus thuringiensis subsp. kurstaki strain EG2348 

Bacillus thuringiensis subsp. kurstaki strain EG2371 

Bacillus thuringiensis Subsp. Kurstaki, Strain ABTS-351 

Bacillus thuringiensis subspecies kurstaki strain EG7841 Lepidopteran active toxin 

Bacillus thuringiensis subspecies kurstaki, strain EG7826 Lepidopteran active toxin 

Bacillus thuringiensis, subsp. strain ABTS 1857 

Basic copper sulfate 

Beauveria bassiana ATCC 74040 

Beauveria bassiana GHA 

Benfluralin 

Benzamide, 2-chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-pyrimidinyl]-4-fluoro-N-

[[methyl(1-methylethyl)amino]sulfonyl]- 

Benzoic acid, 3,6-dichloro-2-methoxy-, compd with 2-(2-aminoethoxy)ethanol (1:1) 

Benzoic acid, 3,6-dichloro-2-methoxy-, compd with N-methylmethanamine (1:1) 

Bergamot oil 

beta-cyfluthrin 

Bifenazate 

Bifenthrin 

Borax (B4Na2O7.10H2O) 

Boric acid 

boscalid 

Buprofezin 

Capsaicin 

Carbamic acid, butyl-, 3-iodo-2-propynyl ester 

Carbamothioic acid, dipropyl-, S-ethyl ester 
91 May 2010 

Table A-4: List of Active Ingredients: Forest Canopy Pest Control (Forestry)

Carbaryl 

Carbofuran 

Carbon 

Carfentrazone-ethyl 

Chenopodium ambrosioides var. ambrosioides 

Chlorantraniliprole 

Chlorflurenol, methyl ester 

Chlorophacinone 

Chloropicrin 

Chlorothalonil 

Chlorpyrifos 

Chondrostereum purpureum isolate PFC 2139, ATCC 60854 

Cinnamaldehyde 

cis-7,8-Epoxy-2-methyloctadecane 

Clethodim 

Clofentezine 

Clothianidin 

Copper hydroxide 

Copper oxychloride (Cu2Cl(OH)3) 

Copper sulfate pentahydrate 

Cryolite 

Cyclopropanecarboxylic acid, 3-(2-chloro-3,3,3-trifluoro-1-propenyl)-2, 2-dimethyl-, cyano(3-

phenoxyphenyl)methyl ester, [1R-[1 alpha(S*), 3 alpha(Z)]]- 

Cyfluthrin 

Cytokinin (as kinetin) 

D-Alanine, N-(2,6-dimethylphenyl)-N-(methoxyacetyl)-, methyl ester 

Dazomet 

Deltamethrin 

D-Glucitol, octanoate 

Dicamba 

Dicamba with 2,4-D 

Dicamba, sodium salt 

Dichlobenil 

Dicloran 

Diclosulam 

Diflubenzuron 

Diiodomethyl p-tolyl sulfone 

dimethenamide-P 

Dimethoate 

Dinotefuran 

Diphacinone 

Diquat dibromide 

Disulfoton 

Diuron 

Egg solids 

Emamectin benzoate 

Endosulfan 

Esfenvalerate 

Ethaneperoxoic acid 
92 May 2010 

Table A-4: List of Active Ingredients: Forest Canopy Pest Control (Forestry)

Ethephon 

Ethyl 1-naphthaleneacetate 

Ethylene 

Etoxazole 

Farnesol 

Fenbutatin-oxide 

Fenpropathrin 

Fenpyroximate 

Ferbam 

Fipronil 

Flucarbazone-sodium 

Flufenacet 

Flumioxazin 

Fluopicolide 

Fluroxypyr 1-methylheptyl ester 

Fosamine 

Fosetyl-Al 

Garlic oil 

Gas cartRidge (as a device for burrowing animal control) 

Geraniol 

Gibberellic acid 

Gibberellin A4 mixt. with Gibberellin A7 

Gliocladium catenulatum strain J1446 

Glufosinate 

Glycine, N-(phosphonomethyl)- potassium salt 

Glycine, N-(phosphonomethyl)-, ammonium salt 

Glycine, N-(phosphonomethyl)-, compd. with N-methylmethanamine (1:1) 

Glycine, N-(phosphonomethyl)-, diammonium salt 

Glyphosate 

Glyphosate-isopropylammonium 

Halosulfuron-methyl 

Harpin alpha beta protein 

Hexazinone 

Hexythiazox 

Hydramethylnon 

Hydrogen peroxide 

Imazapyr 

Imazaquin 

Imidacloprid 

Indole-3-acetic acid 

Indole-3-butyric acid 

Indoxacarb 

Iprodione 

Isooctyl 2-(2,4-dichlorophenoxy)propionate 

Isoxaben 

Kaolin clay 

Lactofen 

lambda-Cyhalothrin 

Limonene 
93 May 2010 

Table A-4: List of Active Ingredients: Forest Canopy Pest Control (Forestry)

Malathion 

Mancozeb 

Maneb 

MCPA, 2-ethylhexyl ester 

MCPA, dimethylamine salt 

Metalaxyl 

Metarhizium anisopliae strain F52 spores 

Methane, iodoMethidathion 

Methyl 9-hydroxyfluorene-9-carboxylate 

Methyl bromide 

Metribuzin 

Metsulfuron 

Mineral oil - includes paraffin oil from 063503 

Mono- and di- potassium salts of phosphorous acid 

MSMA (and salts) 

Muscodor albus strain QST 20799 

Myclobutanil 

Napropamide 

Nerolidol 

Nonanoic acid 

Octhilinone 

Oil of citronella 

Oil of lemongrass 

Oil of mustard 

Oil of orange 

Oil of thyme 

Oil of wintergreen 

Oryzalin 

Oxadiazon 

Oxydemeton-methyl 

Oxyfluorfen 

Paclobutrazol 

Paraquat dichloride 

Pendimethalin 

Permethrin 

Phosmet 

Picloram 

Picloram-potassium 

Piperonyl butoxide 

Polyhedral inclusion bodies of Douglas fir tussock moth nucleopolyhedrosis virus 

Polyhedral inclusion bodies of gypsy moth nucleopolyhedrosis virus 

Potassium laurate 

Potassium phosphate, monobasic 

Potassium silicate 

Prodiamine 

Propamocarb hydrochloride 

Propanoic acid, 2-(2,4-dichlorophenoxy)-, (R)-, compd. with N-methylmethanamine (1:1) 

Propanoic acid, 2-(2,4-dichlorophenoxy)-, 2-ethylhexyl ester 
94 May 2010 

Table A-4: List of Active Ingredients: Forest Canopy Pest Control (Forestry)

Propanoic acid, 2-(4-((5-(trifluoromethyl)-2-pyridinyl)oxy)phenoxy)-, butyl ester, (R)- 

Propargite 

Propiconazole 

Propyzamide 

Pyraclostrobin 

Pyraflufen-ethyl 

Pyrethrins 

Pyridaben 

Pyriproxyfen 

QST 713 strain of bacillus subtilis 

Resmethrin 

Rimsulfuron 

Sethoxydim 

Silicon dioxide 

Simazine 

S-Methoprene 

Sodium cyanide 

Sodium hypochlorite 

Sodium nitrate 

Soybean oil 

Spinetoram 

Spinosad (Naturally occurring mixture of spinosyn A, pc code 110003 , CAS Reg. No. 131929-60-7 ; & 

spinosyn D, pc code 110004, CAS Reg. No. 131929-63-0) With CAS Reg. No. 168316-95-8 by 

SPINOSAD itself. 

Spirodiclofen 

Spirotetramat 

Streptomyces griseoviridis strain K61 

Strychnine 

Sucrose octanoate 

Sulfentrazone 

Sulfometuron 

Sulfonic acids, C14-16-alkane hydroxy and C14-16-alkene, sodium salts 

Sulfosulfuron 

Sulfur 

Sulfuric acid 

Tall oil fatty acids, potassium salts 

Tebuconazole 

Tebufenozide 

Telone 

Terbufos 

Thiamethoxam 

Thiodicarb 

Thiophanate-methyl 

Topramezone 

Tralomethrin 

Triadimefon 

Trichoderma polysporum (ATCC 20475) 

Trichoderma viride (ATCC 20476) 

Triclopyr 
95 May 2010 

Table A-4: List of Active Ingredients: Forest Canopy Pest Control (Forestry)

Triclopyr, triethylamine salt 

Trifloxystrobin 

Triflumizole 

Trifluralin 

Triisopropanolamine salt of aminopyralid 

Trinexapac-ethyl 

Verbenone 

Yellow mustard seed (Brassica hirta) 

Zeta-Cypermethrin 

Zinc phosphide (Zn3P2) 

Ziram