### 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 Formatted: Strikethrough

Formatted: Strikethrough

Formatted: Strikethrough 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 drawdowns 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