"NPDES Applicator & Application Estimates" for Mosquito Adultici des and for Mosquito Larvicides Meredith William H. (DNREC)

to: William Jordan, Susan Lewis, Allison Wiedema n, Jack Faulk, Jennifer Chan, Jordan Page
11/03/2009 05:58 PM
Cc: 'Conlon Joseph'
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EPA Folks – re: draft “NPDES Applicator & Appl ication Estimates” for Mosq uito Adulticides and for Mosquito Larvicides (dated 9/23/09), per our EPA/State NPDES Workgroup conference call of
10/29/09.

I’m really not sure who within EPA might want or ne ed to see the input to follow, so I took sort of a “shotgun” approach at this by incl uding all 6 of you good folks above, and I trust that you’ll identify the right person to then possibly process this information further.

I discussed with the American Mos quito Control Association’s Technica l Advisor, Joe Conlon, some of the numbers and percentages now appearing in the EPA’s draft “NPDES Applicator & Application Estimates” document (dated 9/23/09) relative to Mosq uito Adulticides and to Mosquito Larvicides, and we constructively would like to of fer the following comments for your consideration and some possible tweaking in your tabulations:

• The AMCA Technical Advisor (J oe Conlon) believes that th ere are at least 734 named, organized MCDs/MADs around the country (as opposed to your i ndicating only 400); and that
there are at least another 1105 stat e-level, county-level, or munici pal-level agencies or programs that also perform mosquito control activiti es (as opposed to your indicating only 800), ranging from frequently active and extensive in scope to only infrequently sporadic and limited in effect or impact.

• EPA’s estimation of an average 180 acres larv icided per ground larvicide application is probably way too high. Most gr ound-applied larvicide applicat ions (whether via hand-tossed briquets, backpack sprayers, truck-mounted ditc h sprayers, etc.) only treat from a few dozen square feet up to but a few acres per treatment or application site. Your numbers also have the average acres for a ground larvicide treatment be ing the same as the average acres for a ground
adulticide treatment – this is way off base, with your estimation of the average acreage treated when ground larviciding probably being way too hi gh as pointed out above. But as to what the average acres treated either when ground larvic iding or ground adulticiding might actually be, the AMCA at present couldn’t say.

• Estimating that 23% of all adulticide or larvic ide “applications” (i.e. a pplication events?) are made by aircraft is probably way too high, in that a vast majority of mosquito control programs (whether MCDs/MADs or other state, county or municipal level agencies) do not have aerial application capabilities. But as to what the perc entages of aerial applications might actually be either for adulticiding or larviciding, the AMCA at present couldn’t say.

• In regard to any of th e other numbers or percentages shown by EPA relative to mosquito control operations in your tabulations, without the AM CA also delving into the same 6 source documents that EPA used to come up with your mosquito control figures, and with the AMCA also then probably wanting/needing to consid erably go beyond such sources to also avail ourselves of other pertinent data, all which would involve a si g nificant amount of time and work Page 1 of 2

5/12/2010 file://C:\Documents and Settin g s\ j faulk\Local Settin g s\Tem p \notesFCBCEE\~web4924.htmon the AMCA’s part that the Asso ciation can’t readily undertake at this point -in-time, the AMCA really can’t pass any judgment on our part (either for verifications or refutations) beyond simply saying that:

o It’s very hard to determine or judge the accu racy and validity of the EPA’s numbers and percentages, but we are quite sympathetic to how difficult such fi gures must be to try to compile or generate.

o If the EPA must provide such types of numbers for the sake of “showing some numbers” (for some purpose rela tive to the regulatory matters at hand?), then the EPA’s numbers are probably as good as any; but we also strongly need to reiterate here that in an absolute sense these figures might not be very accurate or good at all

.

o Finally, we’re not really sure what the true value or utility to generating and using these types of figures might actually be, which at this point-in-time probably only EPA really knows, so we don’t know how im portant it might really be (especially in terms of any NPDES permits for mosquitocide use yet-to-come) that the figur es presented or used here by EPA be accurate and valid (or even as ac curate and valid “as possible to be” via a cursory cut at things).

All constructively shared he re FWIW. And if you want to discuss this any further, please just give me a call at 302-739-9917, or catch me during any of our upcoming EPA/State NPDES Workgroup meetings
or conference calls.

Cheers, BILL Page 2 of 2

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