"NPDES Applicator & Application Estimates" for Mosquito Adulticides and for Mosquito Larvicides

Meredith William H. (DNREC) 

to: 

William Jordan, Susan Lewis, Allison Wiedeman, Jack Faulk, Jennifer Chan, Jordan Page 

11/03/2009 05:58 PM 

Cc: 

'Conlon Joseph' 

Show Details 

EPA Folks – re: draft “NPDES Applicator & Application Estimates” for Mosquito 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 need to see the input to follow, so I took sort of a 

“shotgun” approach at this by including 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 Mosquito Control Association’s Technical 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 Mosquito Adulticides and to Mosquito Larvicides, and 

we constructively would like to offer the following comments for your consideration and some possible 

tweaking in your tabulations: 

 

• The AMCA Technical Advisor (Joe Conlon) believes that there are at least 734 named, 

organized MCDs/MADs around the country (as opposed to your indicating only 400); and that 

there are at least another 1105 state-level, county-level, or municipal-level agencies or programs 

that also perform mosquito control activities (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 larvicided per ground larvicide application is 

probably way too high. Most ground-applied larvicide applications (whether via hand-tossed 

briquets, backpack sprayers, truck-mounted ditch 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 being 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 high as pointed out above. But as to what the 

average acres treated either when ground larviciding or ground adulticiding might actually be, 

the AMCA at present couldn’t say. 

 

• Estimating that 23% of all adulticide or larvicide “applications” (i.e. application 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 percentages of aerial applications might actually be 

either for adulticiding or larviciding, the AMCA at present couldn’t say. 

 

• In regard to any of the other numbers or percentages shown by EPA relative to mosquito control 

operations in your tabulations, without the AMCA 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 considerably go beyond such sources to also avail 

ourselves of other pertinent data, all which would involve a significant amount of time and work 

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on the AMCA’s part that the Association 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 accuracy and validity of the EPA’s numbers and 

percentages, but we are quite sympathetic to how difficult such figures 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 relative 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 important it might really be (especially in terms of any 

NPDES permits for mosquitocide use yet-to-come) that the figures presented or used here 

by EPA be accurate and valid (or even as accurate and valid “as possible to be” via a 

cursory cut at things). 

 

All constructively shared here 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 

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