Florida Fish and Wildlife Conservation Commission Comments on DRAFT Reporting 

Requirements for the PGP 

 

9.1 Annual Report 

If you are required to submit an NOI as identified in Part 1.2.2, you must submit an annual report 

electronically to EPA that includes the following information: 

- Permittee’s name 

- NPDES permit tracking number(s) 

- Permittee’s mailing address 

- Contact person name, title, and phone number 

- For the calendar year: 

o Name(s) of products used and active ingredients of those products For each 

product, 

 Location (e.g., county, city, town village) where applied 

 Quantity applied directly to waters 

 Quantity applied over or near waters 

 Pests targeted 

o Description(s) of locations treated, including identification of any waterbodies 

to which pesticides were applied directly 

EPA strongly recommends that you submit this report electronically using the Annual Reporting 

Form provided as Appendix H. You must submit the annual report to EPA no later than February 15 of the 

following year for all pesticide activities occurring January through December 31. The appropriate 

address for the report are Identified in Part 11.0. Operators obtaining permit coverage within 30 days of 

the end of the calendar year are not required to submit an annual report for that first partial year but must 

submit annual reports thereafter. 

9.2 Adverse Incident Reporting 

You must immediately notify EPA and the appropriate state wildlife or natural resources agency 

and submit an incident report if you become aware or have been informed that an adverse incident has 

occurred in connection with a discharge from your pesticide application. See Part 5.3.1. You must provide 

an electronic report of the adverse incident to the appropriate EPA address listed in Part 11 and to the State 

Lead Agency for pesticide regulation (see http://npic.orst.edu/state1.htm ) within 14 days when the adverse 

effects were first observed. Contents of the written incident report must include: 

• Name of permittee, mailing address, and telephone number 

• Name, address, and telephone number of contact person 

• Date permittee became aware of the incident 

• Date of incident (if appropriate, list start and end dates) 

• Location of incident (city, county, state, waterbody name) 

• Product Name and EPA Registration Number 

• Formulation, if known

• Evidence the label directions were not followed (e.g., yes, no, unknown) 

• A brief description of the circumstances of the incident 

• Symptoms or adverse effects 

• Magnitude of the effect (e.g. aquatic square area or total stream distance affected) 

• Pesticide application rate, intended use site (e.g., banks, above, or direct to water), and 

method of application 

• Description of the habitat and the circumstances under which the incident occurred 

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Comment [b1]: To reduce confusion 

and duplication, the EPA Registration 

Number should be the only requirement. 

Active ingredient can be determined from 

this information. 

Comment [b2]: How detailed of a 

location description will be required. It 

seems that the use of general terms such 

as lake, river, stream, pond, reservoir, 

etc., along with the name of the 

waterbody (if available) should be 

sufficient. 

Comment [b3]: What would 

constitute and “adverse incident”?

Temporary, non-lethal symptoms may 

occur in non-target plants after aquatic 

herbicide applications to control 

comingled invasive plants. While there 

may be temporary impacts to non-target 

native plants they usually recover and 

ultimately flourish in the absence of 

stress or competition from invasive 

plants. In rare cases, a small-scale fish 

kill (due to low dissolved oxygen) may 

occur following an application made in

accordance with label directions. In 

Florida, fish kills are fairly common, 

especially in summer months attributed to 

low dissolved oxygen content in the 

water. While investigations usually look 

first at pesticide applications as the cause, 

reasons are mostly the result of excessive 

algae or vascular plants in the water, 

organic loads flushed into waters from 

heavy rainfall, or prolonged cloudy days 

causing respiration to exceed 

photosynthesis. Would these occurrences 

need to be reported even if it is evident 

from the outset that a fish kill is not the 

result of a pesticide application? It should 

also be noted that many non-pesticidal 

management techniques (mechanical 

harvesting for aquatic weeds, water draw 

downs for plant management, nonselective feeding by herbivorous fish, 

etc.) can have significant non-target 

effects also. Should non-target plants and

animals that perish during the course of 

an aquatic plant harvesting or water level 

drawdown event be estimated and 

reported to EPA as well?

Comment [b4]: Its assumed EPA 

means to list the active ingredient and not 

whether its liquid, pellet or wettable 

powder formulation. If the purpose is to 

list active ingredient, this information is 

available through the EPA Registration 

Number. 
• If plants were impacted, the type of plant life affected (i.e., crop, forest, orchard, home 

garden, ornamental foliage, etc) 

• If laboratory tests were performed, indicate what test(s) were performed and provide a 

summary of the test results. 

• Actions to be taken to prevent recurrence of incident. 

• All requirements listed in 8.1.4