### Florida Department of Environmental Protection Comments on Preliminary PGP

Coram, Phil

to:

Virginia Garelick, Jack Faulk

01/25/2010 05:00 PM

Show Details

Virginia and Jack,

Attached are the Florida Department of Environmental Protection’s comments on the preliminary draft of EPA’s NPDES

Pesticide General Permit (PGP).

Our suggested revisions are shown in the track changes mode of MS Word. Comments are also embedded in the document

using the comment function of MS word.

Our most substantial suggested revisions deal with two items:

z We suggest that homeowners who apply pesticides to waters should be eligible for the PGP. At the Dallas

meeting with the co

‐ regulators we noted that Florida issues about 7000 state permits per year for aquatic plant

control, most to homeowners. Not covering homeowners would subject them to significant CWA liability,

including citizen suits, and homeowners are unlikely to have the resources and sophistication to apply for an

individual NPDES permit.

z The application thresholds should be the primary factor in determining who needs to file NOI, prepare a Pesticide

Management Plan, keep a Pesticide Management log, maintain certain records, and to submit an annual report.

Making a small city who might apply a pesticide infrequently to a two acre lake subject to the full suite of IPM

practices and maintenance of a pesticide management log seems overly onerous.

Florida’s Department of Agricultural and Consumer Services and the Florida Fish and Wildlife Conservation Commission will

be submitting comments separately.

We also plan to send a separate email on potential obstacles in having a Florida NPDES PGP issued by April 2011.

Overall we believe EPA has done a commendable job in crafting the PGP to provide meaningful environmental protections

without being overly burdensome to the regulated community. We appreciate the opportunities we have had to meet as

co

‐ regulators and provide input on the PGP.

**********************************************************************

Phil Coram, P.E.

Deputy Director

Division of Water Resource Management

2600 Blair Stone Road

MS 3500

Tallahassee, Flor ida 32399-2400

tel 850 245-8337

fax 850 245-8686 

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**********************************************************************

The Department of Environmental Prot ection values your feedback as a customer. DEP Secretary Michael W.

Sole is committed to continuously assessing and improvi ng the level and quality of se rvices provided to you.

Please take a few minutes to comment on the quality of service yo u received. Copy the url below to a web

browser to complete the DEP survey: http://survey.dep.state.fl.us/?ref email=Phil.Coram@dep.state.fl.us Thank

you in advance for completing the survey. 

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