EPA Deliberative Draft - Do Not Distribute, Copy, or Cite (BAT Workgroup)

Created on November 25, 2009 1 

## BAT WORKGROUP EDITS AS OF November 20, 2009

2.0.Technology-Based Effluent Limitations: Minimize Pesticide Discharges into Waters of the United States.

You must implement control measures to minimize the discharge of pesticides [Suggest adding the phrase – “resulting in excess pestic ide or pesticide residues” to make this consistent with 6 th Circuit Court ruling] to waters of the United States. The term “minimize” means to reduce and/or eliminate pesticide discharges to waters of the United States to the extent achievable using control measures consistent with best management practices that are technologically available and economically practicable and achievable. To minimize the discharge of pesticides into waters of the United States, all permittees must do the following:

1. Use the effective amount of pesticide pr oduct per application and lowest number of application per season [This phrase should be replaced with “optimum rate and frequency of applications”] necessary to [effectively ] control the target pest.

Some applications are not seasonally based. Suggest deletion of “per season”.

2. Perform regular maintenance activities to minimize potential for leaks, spills, and unintended/accidental release of pesticides fr om both pesticide containers and application equipment to waters of the United States.

3. Calibrate and maintain equipment to ensu re effective pesticide application and pest control.

2.1.Technology-Based Effluent Limitations: Integrated Pest Management Practices.

[General Comment: Since we have lumped the uses together, we need to more explicitly explain who is covered. Consider adding a little more language in the permit and then even more in the fact sheet. I defer to OECA on how much they need to make the permit enforceable.]

All permittees must evaluate, select, and implement control measures. Control measures are the specific actions taken to comply with the technology-based effluent limits. The evaluation, selection, and implementation of these control measures must be in accordance with [applicable] best management practices. No te that you may deviate from best management practices if the best ma nagement practices are not technologically available or economically practicable. If y ou are required to draft and maintain an IPM plan and you deviate from best management practices stated in that plan, you must provide justification for such deviation in your plan. [See Part 6 [IPM Plan]]. If you or EPA finds that your control measures are not minimizing pollutant discharges, you must modify these control measures as expeditiously as practicable. See Part 5, Corrective Formatted: Underline Formatted: Superscript

Formatted: Underline

Comment [SD1]: Some applications are not seasonally based. Suggest deletion of “per season”.

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Comment [mlk2]: Note: if they don’t provide a justification it is only a record keeping violation not an effluent violation.

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Created on November 25, 2009 2 Action. In addition to the technology-based e ffluent limitations contai ned in Part 2, there are documentation and recordkeeping permit conditions in Parts 6 [IPM Plan] and 10 [Recordkeeping].

2.1.1.Mosquito Control (Larvicides and Adulticides) and Aquatic Nuisance Insect Control 2.1.1.1.Identify the Problem . The following permit conditions apply to you if
you are a Public Entity, Quasi-Public Entity, or a For-Hired Applicator. [Are these categories indepe ndent of the NOI threshold? “For Hired” should be “Commercial” these comments apply to subsequent sections where this language is used.] Prior to the first pesticide application covered under this permit and prior to the first pesticide application, at a minimum, each year you must do the following for each treatment area: [-What is the definition of a “treatment area”? – Recommend that it be geographically based – such as boundaries of the mosquito control district] 2.1.1.1.1.: Establish targeted densities for larval and adult mosquito or aquatic nuisance insect populations which serve as action threshold for implementing pest management strategies. 2.1.1.1.2. Identify mosquito or aquatic nuisance [target] insect species in order to develop a [species specific] best control strategy based on developmental and behavioral considerations for each species.

. 2.1.1.1.3. Identify known and potential breeding sites for source reduction, larval control program, and habitat management. [To what extent must this be done? Potential breeding sites could number in the tens of thousands. Recommend a narrative description of types of sites within the district that would be inspected and receive control measures.]

2.1.1.1.4. Analyze existing surveillance data to identify new/unidentified sources of mosquito or aquatic nuisance insect production as well as sites that have recurring pest problems.

In the event site data are not availabl e to identify the pest problem at your treatment area, you must document why it is not available and the assumptions you used to develop your management strategies and action threshold for the treatment area. (See Part 6, IPM Plan)

2.1.1.2.Pest Management . The following permit conditions apply to you if you

are a Public Entity, Quasi-Public Entity, or a For-Hired Applicator. Prior to the first application covere d under this permit and prior to the first application, at a minimum, each year you must select and implement for each treatment area the most efficient and effective means of pest management options, including pesticides and non-pesticide methods. In developing your pest management strategies, you must Formatted: Indent: Before: 0.5" Comment [SD3]: 2.1.1.1. What is the definition of a “treatment area”? – Recommend that it be geographically based – such as boundaries of the mosquito control district.

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Created on November 25, 2009 3 evaluate the following management options considering human health and ecological impact, pest resistance, feasibility, and cost effectiveness:

• No action.

• Prevention [NOTE: includes source reduction ]

• Mechanical/physical methods.

• Cultural methods.

• Biological control agents.

• Pesticides. 2.1.1.3. Comment Pesticide Use The following permit conditions apply to you if you are a Public Entity, Quasi-Public Entity, or a For-Hired Applicator. If pesticide is selected for managing mosquitoes or aquatic nuisance insects and pesticide will be discharged on or over, including near water of the United States, you must: 2.1.1.3.1. Conduct larval and/or adult surveillance using best management practices prior to each pesticide application toassess the treatment area and to determine when preestablished conditions (pest action threshold) are met which necessitate the need for pest management. 2.1.1.3.2. Assess environmental conditions prior to each pesticide application (e.g. temperature, pr ecipitation, and wind speed in the treatment area from a weather station(s) as close to the treatment area(s) as possible to identify conditions which support development of pest populations and are suitable for control activities. 2.1.1.3.3. Minimize the impact on the environment and non-target organisms by applying larvicides and adulticides for pest control only when the action thresholds have been met or disease is present. 2.1.1.3.4. Use larvicides as [a means of] mosquito or aquatic nuisance insect control [where/when appropriate based on use of IPM principles. 2.1.1.3.5. Use adulticides only where the adult action threshold has been met and/or under emergency condition (e.g. flooding, disease outbreak). 2.1.1.3.6. Do not apply adulticides over waters of the United States, except when necessary to target areas where adult mosquitoes or insect pests are present, and when weather conditions will facilitate movement of pesticide product away from the water to minimize incidental deposition into the water body. [NOTE: Fact sheet could include a discussion of unavoidable as incidental deposition.]

2.1.2.Aquatic Weed Control in Lakes, Po nds, Rivers, Streams, Irrigation Canals and Drainage Systems Formatted: Bullets and Numbering Comment [SD4]: • Mosquito Control Districts can not provide control everywhere and decisions must be made up front as to what regions or areas will receive control activities and to what
extent.

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Deleted: the primary

Deleted: p esticide fo r Comment [SD5]: This is not a valid statement. Larvacides should not be identified as the "primary" pesticide for mosquito control. Larvacides should be used when/where appropriate when technically and economically feasible. They may be the "primary" method in some situations, or not used at all in others. Suggest changing this to read - Use larvacides when and where appropriate based on use of IPM principles.

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Created on November 25, 2009 4 2.1.2.1.Identify the Problem. The following permit conditions apply to you if
you are a Public Entity, Quasi-Public Entity, Commercial, Regional Association, Farmer, or a For-Hired Applicator. Prior to the first application covered under this permit and prior to the first application, at a minimum, each year you must do the following for each treatment

area: 2.1.2.1.1. Identify problem weed areas and application areas, including water use goals not attained (e.g. wildlife habitat, fisheries, vegetation, and recreation); 2.1.2.1.2. Identity targeted weed species; 2.1.2.1.3. Identify possible sources of the problem (e.g., nutrients, invasive species, etc); and 2.1.2.1.4. Establish past or present pest weed densities which serve as action threshold for implementing pest management strategies.

In the event site data are not availabl e to identify the pest problem at your treatment area, you must document why it is not available and the assumptions you used to develop your management strategies and action threshold for the treatment area. (See Part 6, IPM Plan)

2.1.2.2.Pest Management. The following permit conditions apply to you if you

are a Public Entity, Quasi-Public Entity, Commercial, Regional Association, Farmer, or a For-Hired Applicator. Prior to the first pesticide application covered under this permit and prior to the first pesticide application, at a minimum, each year you must select and implement for each treatment area the most efficient and effective means of pest management options, including pesticides and non-pesticide methods. In developing your pest management strategies, you must evaluate the following management options considering human health and ecological impact, pest resistance, feasibility, and cost effectiveness:

• No action.

• Prevention

• Mechanical/physical methods.

• Cultural methods.

• Biological control agents.

• Pesticides.

2.1.2.3.Pesticide Use. The following permit conditions apply to you if you are

a Public Entity, Quasi-Public Entity, Commercial, Regional Association, Farmer, or a For-Hired Applicator. If pesticide is selected for managing weeds in lakes, ponds, rivers, streams, irrigation canals or drainage systems and pesticide will be discharged on or over, including near water of the United States, you must: 2.1.2.3.1. Conduct surveillance using best management practices prior to each pesticide application to assess the treatment area and to determine when pre-established conditions (pest action Deleted: November 25, 2009

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Created on November 25, 2009 5 threshold) are met which necessitate the need for pest management; 2.1.2.3.2. Conduct surveillance using best management practices after each pesticide application to determine effectiveness of the
treatment. 2.1.2.3.3. Minimize the impact on the environment and non-target organisms by minimizing the use of pesticides for aquatic weed control when the action thresholds (see Part 2.1.2.1.2) have been met. 2.1.2.3.4. For managing weeds in rivers, streams, or irrigation canals, do not apply herbicides over waters of the United States, except when necessary to target areas where weeds are present, and when weather conditions will facilitate movement of pesticide product away from the water to minimize incidental deposition into the water body.

2.1.3.Area Wide Pest Control (Insect, Weed, and Pathogen) and Forestry [ This needs more definition – we assume you are referring to government programs to control invasive or pestiferous species that have a statewide or national impact, such as mediterranean fruit fly, gypsy moth, citrus canker, etc. In all of these cases the “permittee” will be a government agency that may use its own resources or hire commercial applicators operating under government supervision. Inclusion of “Forestry” in this category is confusing – does it mean all forestry operations or only “wide area” type operations?]

2.1.3.1.Identify the Problem . The following permit conditions apply to you if
you are a Public Entity, Quasi-Public Entity, or a For-Hired Applicator. Prior to the first application covered under this permit and prior to the first application, at a minimum, each year you must do the following for each treatment area: 2.1.3.1.1. Establish target pest densities which serve as action threshold for implementing pest management strategies. 2.1.3.1.2. Identify target species in order to develop a best control strategy based on developmental and behavioral considerations for each species. 2.1.3.1.3. Identify current distribution of the target pest and assess potential distribution in absence of control measures.

In the event site data are not availabl e to identify the pest problem at your treatment area, you must document why it is not available and the assumptions you used to develop your management strategies and action threshold for the treatment area. (See Part 6, IPM Plan)

2.1.3.2.Pest Management. The following permit conditions apply to you if you

are a Public Entity, Quasi-Public Entity, or a For-Hired Applicator. Deleted: November 25, 2009

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Created on November 25, 2009 6 Prior to the first pesticide application covered under this permit and prior to the first pesticide application, at a minimum, each year you must select and implement for each treatment area the most efficient and effective means of pest management options, including pesticides and non-pesticide methods. In developing your pest management strategies, you must evaluate the following management options considering human health and ecological impact, pe st resistance, feasibility, and cost effectiveness:

• No action.

• Prevention

• Mechanical/physical methods.

• Cultural methods.

• Biological control agents.

• Pesticides.

2.1.3.3.Pesticide Use. The following permit conditions apply to you if you are a Public Entity, Quasi-Public Enti ty, or a For-Hired Applicator. If Pesticide is selected to manage area wide pests and pesticide will be discharged on or over, including near waters of the United States, you
must: 2.1.3.3.1. Conduct surveillance using best management practices prior to each application to assess the treatment area and to determine when pre-established conditions (pest action threshold) are met which necessitate the need for pest management. 2.1.3.3.2. Conduct surveillance using best management practices after each pesticide application to determine effectiveness of the
treatment. 2.1.3.3.3. Assess environmental conditions (e.g. temperature, precipitation, and wind speed) in the treatment area from a weather station(s) as close to the treatment area(s) as possible to identify conditions which support target pest development and are conducive for treatment activities. 2.1.3.3.4. Minimize the impact on the environment and non-target organisms by minimizing the use of pesticides when the action thresholds have been met. 2.1.3.3.5. Use pesticides against the most susceptible developmental stage. [as practical and economically viable – when pest populations “escape” early control efforts, other methods have to be used, such as adulticides against mosquitoes] 2.1.3.3.6. Use pesticides only where the action threshold has been met and/or under emergency condition (e.g. invasive species). 2.1.3.3.7. Do not apply pesticide over waters of the United States, except when necessary to target areas where target pests are present, and when weather conditions will facilitate movement of pesticide product away from the water to minimize incidental deposition into the water body. Deleted: November 25, 2009

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Created on November 25, 2009 7 2.1.4.Aquatic Nuisance Animals Control in Lakes, Ponds, Rivers, and Streams (Fish, Lamprey, and Mollusk)

2.1.4.1.Identify the Problem. The following permit conditions apply to you if
you are a Public Entity, Quasi-Public Entity, or a For-Hired Applicator. Prior to the first application covered under this permit and prior to the first application, at a minimum, each year you must do the following for each treatment area: 2.1.4.1.1. Identify problem aquatic nuisanc e animal areas and application areas, including water use goals not attained (e.g. wildlife h a bitat, fisheries, vegetation, and recreation); 2.1.4.1.2. Identify targeted aquatic nuisance animal species; 2.1.4.1.3. Identify possible sources of the problem (e.g., nutrients, invasive species, etc.); and 2.1.4.1.4. Establish past or present aquatic nuisance animal densities which serve as action threshold for implementing pest management strategies.

In the event site data are not available to identify the pest problem at your treatment area, you must document why it is not available and the assumptions you used to develop your management strategies and action threshold for the treatment area. (See Part 6, IPM Plan)

2.1.4.2.Pest Management. The following permit conditions apply to you if you

are a Public Entity, Quasi-Public Entity, or a For-Hired Applicator. Prior to the first pesticide application covered under this permit and prior to the first pesticide application, at a minimum, each year you must select and implement for each treatment area the most efficient and effective means of pest management options, including pesticides and non-pesticide methods. In developing your pest management strategies, you must evaluate the following management options considering human health and ecological impact, pe st resistance, feasibility, and cost effectiveness:

• No action.

• Prevention

• Mechanical/physical methods.

• Cultural methods.

• Biological control agents.

• Pesticides.

2.1.4.3.Pesticide Use. The following permit conditions apply to you if you are

a Public Entity, Quasi-Public Entity, or a For-Hired Applicator. If pesticide is used to control aquatic nuisance animals in lakes, ponds, rivers and streams and pesticide will be discharged on or over, including near waters of the United States you must: Deleted: November 25, 2009

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Created on November 25, 2009 8 2.1.4.3.1. Conduct surveillance using best management practices prior to each application to assess the treatment area and to determine when pre-established conditions (pest action threshold) are met which necessitate the need for pest management; 2.1.4.3.2. Conduct surveillance using best management practices after each pesticide application to determine effectiveness of the
treatment. 2.1.4.3.3. Minimize the impact on the environment and non-target organisms by minimizing the use of pesticides for aquatic nuisance animal control in lakes, ponds, rivers, and streams when the action thresholds have been met.

6.0. Integrated Pest Management (IPM) Plan If you are required to submit an NOI, you must prepare an IPM plan for each treatment area or for several similar tr eatment areas within the same watershed before submitting your NOI for permit coverage. [The “treatment area” covered by an IPM plan should be the operational or jurisdictional area of the permittee, e.g. the boundaries of a mosquito control district] The IPM plan does not contain effluent limitations; the limitations are contained in Parts 2.0 and 3.0 of the permit. The IPM plan is intended to document the evaluation and selection of control measures . The additional documentation requirements (see Part 10, Recordkeeping) are intended to document the implementation (including inspection, maintenance, monitoring, and corre ctive action) of the permit requirements.

6.1 Contents of Your IPM Plan For coverage under this permit, you must docum ent in your IPM Plan all of the following elements: 1. IPM Team 2. Problem Description 3. Control Measures Description 4. Pest Surveillance 5. Spill Prevention and Response Procedures 6. Adverse Incident Response Plan 7. Pesticide Monitoring 8. Documentation to Support Eligibility Considerations Under Other Federal Laws. 9. Signature Requirements.

Where your IPM plan refers to procedures in other documents, such as spill control plans, copies of the relevant portions of those documents must be kept with your IPM plan.

6.1.1 IPM Team

You must identify the staff members (by name or title) that comprise the team as well as their individual responsibilities, including:

a. Staff member(s) responsible for managing pests in relation to the treatment area described below; b. Staff member(s) responsible for de veloping and revising the IPM plan; Comment [SD6]: How will these be defined?

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Created on November 25, 2009 9 c. Staff member(s) responsible for taking corrective actions where required; and d. Staff member(s) or for-hire applicator responsible fo r pesticide applications. 6.1.2 Problem Description

You must document the following:

a. Site Description; b. Objective;

c. Pest biology; d. Action threshold(s) [NOTE: may include disease status report as threshold.]

e. Description of the geographic boundaries and waterbodies to which the plan applies, including the applicable water quality standards; and f. A general location map (e.g., USGS quadr angle map, a portion of a city or county map, or other map) with enough detail to identify the geographic boundaries of the area to which the plan applies and location of the treatment area and waters of the United States.
g. Source of the data and any assumptions used to meet conditions in Parts 2.1.1.1, 2.1.2.1., 2.1.3.1., 2.1.4.1., and 2.1.5.1 6.1.3 Control Measures Description [All most all of these evaluations will be the same from year to year. The conditions that result in pest problems (weed pressure, mosquito populations) are not likely to substantially change over the course of a permit] You must document the management tools evaluated and control measures selected to minimize pesticide discharges into waters of the United States. The evaluation must include the following management tools and considering human health [including pest transmitted diseases] and ecological impact, pest resistance, feasibility, and cost effectiveness:

a. No action b. Prevention

c. Mechanical/physical methods d. Cultural methods

e. Biological control agents f. Pesticides For mosquito control and aquatic nuisance insect control, you must document why larviciding is not the primary pesticide to manage mosquitoes [See Part 2.1.1.3.4.] [Larvaciding is only appropriate and effective in specific situations and will not be the “primary” means except in specific circumstances. We object strongly to this wording. Selection of larvaciding as a control measure should only be as a result of review of options and application of IPM principles. It is antithetical to IPM principles
to a priori assign one control measure as the “primary” means of control of a pest.

The Agency should also be aware that larvaciding is orders of magnitude more expensive than adulticiding (up to $125/acre versus $1.00/acre or less for adulticiding) and, often much less efficacious than adulticiding due to timing and environmental factors. 6.1.4 Pest Surveillance

You must document pre and post pest surveillance procedures. ’[NOTE: allow to reference surveillance work other groups have done in the area.] Formatted: Font: Bold Comment [SD7]: How specific does this need to be? There may be thousands of sites in a district. For the purposes of the IPM the plan for mosquito control districts, the "site" is the district.
Comment [SD8]: The biology of the mosquito species of concern is available in published sources. Why does it need to be reiterated in a written IPM plan. It should be acceptable to reference a document for the species of concern, similar to the reference allowed in the Spill Control Section (6.1.5.1)
Comment [SD9]: Again – this is the MC district boundary
Comment [SD10]: District boundary.

Comment [mlk11]: Do we want the name, etc. we should specify what we want here instead of just saying pesticides. Maybe “Name of Pesticide Product used with its corresponding EPA Registration Number,”
Comment [SD12 R 11]: EPA registration number is sufficient. “name of pesticide” is vague.
Comment [SD13]: Once again, larvicides should not be cited as the “primary” means. Larvacides should only be used when application of IPM principles result in selection of larvacides as the best method.
Comment [mlk14]: I think this is supposed to be for mosquitoes only? The sentence includes aquatic nuisance n the beginning but focuses on mosquito at the end.

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Created on November 25, 2009 10 6.1.5 Schedules and Procedures You must document the following schedules and procedures in your IPM plan:

6.1.5.1 Spill Prevention and Response Procedures – Procedures for preventing and responding to spills and leaks. In lieu of drafting your own spill prevention and response procedures, you may reference the existence of other plans for spill prevention that were developed for pesticide application, provided that you keep a copy of that other plan with your IPM plan and make it available for review consistent with Part 6.3. 6.1.5.2 Adverse Incident Response Plan - Procedures for responding to adverse incident resulting from pesticide applications. You must identify and document the following:

• Course of action or responses to any incident resulting from pesticide

applications;

• Chain of command notification for the incident, both internal to your

agency/organization and external;

• Timelines of the response;

• State/Federal contacts with phone numbers;

• Name, location, and telephone of ne arest emergency medical facility;

• Name, location, and telephone of ne arest hazardous chemical responder

(including police and fire department); and

• Name and telephone number for the National Pesticide

Telecommunications Network at 800-858-7378. 6.1.5.3 Pesticide Monitoring – You must document the procedures for monitoring consistent with the requirements in Part 8.0 including:

 The process for determining the location of any monitoring;

 A schedule and procedures for any monitoring;

 The person (or position) responsible for conducting monitoring; and

 Procedures for documenting an y incidents of noncompliance observed. 6.1.6 Documentation to Support Eligibility Considerations Under Other Federal Laws. [to be determined] 6.1.7 Signature Requirements. You must sign and date your IPM plan in accordance with Appendix B, Subsection B.11.

6.2 IPM Plan Modifications You must modify your IPM plan whenever n ecessary to address any of the triggering conditions for corrective action in Part 5.1 to en sure that they do not reoccur, or to reflect changes implemented when a review following the triggering conditions in Part 5.1 indicates that changes to your control measures are necessary to meet the effluent limits in this permit. Changes to your IPM plan must be made in accordance with the corrective action deadlines in Parts 5.2 and 5.3, and mu st be signed and dated in accordance with Appendix B, Subsection B.11 Comment [mlk15]: Shouldn’t we require, not the permittee determine when to respond to an incident in so many hours????

Comment [mlk16]: Consider breaking this up into a couple of sentences, slightly confusing as is.

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Created on November 25, 2009 11 You must review your IPM plan at a minimum once per year or whenever necessary to address any new pest problem at your treatment area(s).

6.3 IPM Plan Availability You must retain a copy of the current IPM plan, along with all supporting maps and documents, at the address provided on the NOI and it must be immediately available to EPA; a State, Tribal, or local agency governing pesticide applications; and representatives of the U.S. Fish and Wild life Service (USFWS) or the National Marine Fisheries Service (NMFS) upon request. EPA may provide access to portions of your IPM plan to a member of the public upon request. Confidential Business Information (CBI) may be withheld from the public, but ma y not be withheld from those staff cleared for CBI review within EPA, USFWS, or NMFS.

10. Recordkeeping [ This section should only apply to permittees that meet the NOI threshold. As written it appears to apply to everyone. This section also needs substanitial modifications to make it practical and economically possible for permittees to meet. It creates an entirely new recordkeeping burden that pesticide applicators do not currently have to meet. The proposed “Pest Management Log” is poorly defined and will impose a substantial record keeping burden on the public. The records that are included in this sectio n are typically kept in separate locations – for example surveillance actvities records and results are kept by the surveillance section of mosquito control districts, while pesticide application records are kept separately. Records of other control activities, such as container breeding mosquito campaigns, will be kept in a different location . As described in this section, districts and other permittees will have to employ on e or more full time st aff just to compile this “log”. We suggest deletion of the requirement for a “pest management log” and replacement with requirements that the rec ords be kept, with the understanding that they can be kept separately for review by the enforcement agency as needed. 10.1.You are required to keep the following documentation. These records are to be complete and maintained at your facility, so as to demonstrate your full compliance with the conditions of this permit. 1. A copy of this permit (an electronic copy easily available is also acceptable) 2. A Pest Management log. Your log mu st be completed within 5 days of pest management activities. You must maintain records of the following information: 1. The name(s) of the recordkeeper; 2. Times and date(s) of pest management activities; 3. The location(s) of the management area(s) (e.g., waterbody, or map coordinates); 4. Target Pest; 5. Pest management strategies used and what action threshold has been met 6. Pesticide used: a. Kinds and amounts of pesticides used, including EPA registration number b. Any observed non-target impacts resulting from your discharge; c. When the application equipment was calibrated; Comment [mlk17]: Not sure what this means – application of pesticides or each time you complete a condition of the
p ermit?

Comment [mlk18]: Technically – if they don’t use a pesticide they don’t need a permit. Made some edits.

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Created on November 25, 2009 12 d. For mosquito control and aquatic nuisance insect control, if applicable, why larviciding is impractical.

10.2. If you are required to submit an NOI, as identified in Part 1.2.2, you are alsorequired to keep the following documentation. These records are to be complete, up-todate, and maintained so as to demonstrate your full compliance with the conditions of this permit:

• A copy of the NOI submitted to EPA along with any correspondence exchanged between you and EPA specific to coverage under this permit;

• A copy of the acknowledgment letter you received from the NOI Processing Center or eNOI system assigning your permit tracking numbers;

• An IPM Plan as detailed in Part 6.0

10.3.You must retain copies of documentation outlined in Part 10.1 and, if applicable, Part 10.2 (including any modifications made to the IPM plan during the term of this permit), annual reports, adverse incident reports, corrective action reports, and any monitoring information required in Part 8 for a period of at least 3 years from the date that your coverage under this permit expires or is terminated. Comment [SD19]: The Agency appears to be pushing larvaciding as the primary means of mosquito control. Why has the Agency taken this position?

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