1MOSQUITO CONTROL- Responses by Florida Department of Agriculture and Consumer ServicesQuestionsTechnologically andEconomically FeasibleCurrent ComplianceCostActivity1YourEstimateSources/CommentsYourEstimateSources/CommentsUnitCurrentCostEstimateYour EstimateSources/CommentsEstablish mosquitodensities and identifymosquito species.2(continued)100%All mosquito controldistricts conductthis activity to somedegree.100%Required understate law todeterminepopulation levels.VariableCost:a. Numberof traps perdistrictb. Cost pertrapc. Laborhours andwage rateto set trapper districtd. Numberof districtsdoing theactivityVariableCost:$200/trap5.00/trap for dryice3 hrs per trapset/1 hour topick trapup/26.38 perhour60Recent trap pricepurchaseIdentifyand record ona mapknown andpotential breedingsites for sourcereduction.3100%Can beaccomplished.Resourceconstraints do notallow all districts tocomplete thisactivity.40%Only districts withsufficient personnelcan conduct thisactivity.VariableCost:Cost ofmappingper vectorcontroldistrict$56,889/DistrictOne FTE at26.38/hour (salaryand benefits)2Technologically andEconomically FeasibleCurrent ComplianceCostActivity1YourEstimateSources/CommentsYourEstimateSources/CommentsUnitCurrentCostEstimateYour EstimateSources/CommentsRemove, drain,and/or preventmosquito entry tosubstrates used foroviposition and larvaldevelopment (e.g.,containers, tires,etc.).4100%This is achievablefor substrates thatare accessible andsubject to control ofthe district. It is notachievable for allsuch substrates,and is noteconomicallypossible for allsubstrates.100%All districts conductthis activity to someextent. No districtconducts thisactivity for all thepotential substratesin their district.VariableCost:a. Laborhours andwage rateto set trapper districtb. Numberof districtsdoing theactivityVariableCost:Zero to 270,000Highly variableactivity. This istypicallyaccomplishedthrough educationof public to controlcontainer breedingmosquitoes on theirown properties. Insome cases(example dengue inKey West) thisbecomes a majoractivity for districtstaffPerform watermanagementpractices (e.g.,improving drainage,periodic draining,ditching, impounding,frequency andduration of flooding,water circulation,water depthmanagement(predator habitat),etc.).100%This activity isfeasible for somesituations, but notfeasible for others.For many districts,such tactics havealready beencompleted (e.g.impoundments onFlorida’s EastCoast). For others,they are not anoption (e.g. districtssurroundingEvergladesNational Park)VariableCost:Cost ofactivity perdistrictVariableCost:Cannot beestimated.Entirelydependent oneach districtssituation.3Technologically andEconomically FeasibleCurrent ComplianceCostActivity1YourEstimateSources/CommentsYourEstimateSources/CommentsUnitCurrentCostEstimateYour EstimateSources/CommentsPerform vegetationmanagementpractices to eliminateor reduce mosquitohabitat (e.g. mowing,grazing, aquaticherbicides).5This activity isfeasible for somesituations, but notfeasible for others.For many districts,such tactics havealready beencompleted (e.g.impoundments onFlorida’s EastCoast). For others,they are not anoption (e.g. districtssurroundingEvergladesNational Park)VariableCost:a. cost ofactivity peracreb. numberof managedacres perdistrictVariableCost:Cannot beestimated.Entirelydependent oneach districtssituationMaintain and promotebiological control byencouraging sitespecific predatorpopulations (e.g.larvivorous fish),growth regulators(e.g. methoprene),and bacteria (e.g.Bti).100%Use of existing oraugmentedbiological controlsis inherent indistrict activity.Since applicationsare made onlywhen populationlevels dictateaction, populationlevels are normallymaintained byexisting biologicalcontrols.Pleasenote thatmethoprene andBti are notbiologicalcontrols but areregisteredpesticides theapplication of100%Every district usesthese to someextent.VariableCost:a. cost offishb. numberof fish perpond orlakeVariableCost:$1.75 per fish,or $20/hour tocapture andrelocateNo set numberof fish perreceiving bodyUtilization ofnaturallyoccurringpredaceous fishis a benefit ofproper watermanagement inimpoundments.4Technologically andEconomically FeasibleCurrent ComplianceCostActivity1YourEstimateSources/CommentsYourEstimateSources/CommentsUnitCurrentCostEstimateYour EstimateSources/Commentswhich is dictatedby IPMprinciples.Manage mosquitoesbreeding sites inwaters such aspuddles, farm ponds,or roadside ditches,etc., that are notwaters of the UnitedStates to reducemigration to nearareas.6VariableCost:a. cost peracreb. cost pervectorcontroldistrictVariableCost:Conduct and analyzelarvae, adult, disease,resistance, andenvironmentalconditions (i.e.,temperature,precipitation, andwind speed intreatment area)surveillance.7100%This is technicallyfeasible, but thedegree to which itis conducted isdependent oneconomicresources ofdistrictVariableCost:a. cost pervectorcontroldistrictVariableCost:No costestimate.Entirelydependent ondistrictconditions.Requirestrained andexperiencedstaff.Use larvicides as theprimary pesticide formosquito control.Not applicable –larvacides shouldnot be designatedas “primary” meansof mosquito control.It is moreappropriate todesignate this asuse of larvacidesas appropriate.VariableCost:a. cost peracre orapplicationof switchingtolarvacidesas primarycontrolVariableCost:a..b. EPAassumesrelativelylowfeasibilityand cost,Cots varies asto type oflarvacide anddistance to andsize of areascovered.Rangesreported from$4.00 to$125/acreReports by FloridaDistrictsNumbers of acresper district attachedbelow. The largestcomponent of costfor larvaciding isthe fact that ratesper acre treated arerelatively high – for5Technologically andEconomically FeasibleCurrent ComplianceCostActivity1YourEstimateSources/CommentsYourEstimateSources/CommentsUnitCurrentCostEstimateYour EstimateSources/Commentsb. numberof acres orapplicationsper districtc. numberof districtsbut needsspecificdata.example –Btiformulations areapllied at 2.5 to 10lbs per acreresulting in feweracres that can becovered per aircraftor truck mission(adulticides areapplied at a fractionof an ounce peracre)Use adulticides onlywhere the adultaction threshold hasbeen met and/orunder emergencycondition (e.g.flooding, diseaseoutbreak).100%All districts treatwhen populationlevels are reachedthat requiretreatment.100%All districts treatwhen populationlevels are reachedthat requiretreatmenta.Inadequateinformationon the costand use ofadulticides.b. EPAassumesrelativelyhighcompliance,but needsspecificdata.Cost varies butnot as much asfor larvaciding.Costs arereported in the$0.50 to $ 1.00per acre rangefor aerialadulticiding, and$10 to $ 40 permile for groundadulticidingAdulticiding costsorders ofmagnitude less peracre due to lowapplication rates(for example naledis applied at 0.66fluid ounce peracre,resulting inone aircraft loadbeing able to treat25,600 acres permission).6Technologically andEconomically FeasibleCurrent ComplianceCostActivity1YourEstimateSources/CommentsYourEstimateSources/CommentsUnitCurrentCostEstimateYour EstimateSources/CommentsCalibrate andmaintain equipmentto ensure effectiveapplication andcontrol; performregular maintenanceactivities to minimizepotential for leaks,spills, andunintended/accidentalrelease of pesticidesfrom both pesticidecontainers andapplication equipmentto waters.100%VariableCost:cost perdistrictVariableCost:Cost is stafftime. Dependson amount ofequipment.Equipmentmanufacturersand pesticidevendors oftenprovidetechnicalsupport at nocost.Provide mosquitocontrol information toresidents in thetreatment areathrough one or moreof the followingmethods: communitynewspaper,communitynewsletter, web site,television and/orradio.100%100%All districts provideinformation to someextent.VariableCost:per capitacost ofprovidingeducationmaterialsVariableCost:No costestimateavailable.Minimize the use ofboth larvicides andadulticides formosquito controlwhen the actionthresholds have beenmet.100%Pesticides areexpensive and willnot be used unlessthere is ademonstratedpresence ofmosquitoes.100%Required by statelaw.a.Inadequateinformationon the costand use ofadulticidesandlarvacides.b. EPAassumesNo costestimateavailable.7Technologically andEconomically FeasibleCurrent ComplianceCostActivity1YourEstimateSources/CommentsYourEstimateSources/CommentsUnitCurrentCostEstimateYour EstimateSources/Commentsrelativelylow costand highcompliance,but needsspecificdata.Ensure that pesticideapplicators aretrained in properapplications ofpesticides and inproper response toadverse incidents.8100%Training is part ofcertificationprocess100%Required by statelaw.a.Inadequateinformationon theextent oftraining andcost oftraining.b. EPAassumeshighcomplianceforapplicators.No costestimateavailable.Licensing isprovided at nocost to districtby FloridaDepartment ofAgriculture andConsumerServices.Maintain pesticideapplicator records.8100%100%Required by statelaw.Inadequateinformationon theextent andcost ofmaintainingapplicationrecords.No costestimateavailable.8Technologically andEconomically FeasibleCurrent ComplianceCostActivity1YourEstimateSources/CommentsYourEstimateSources/CommentsUnitCurrentCostEstimateYour EstimateSources/CommentsConduct postapplication monitoringof waters of the US.9100%100%Post applicationmonitoring isroutine as partof the effort todetermineefficacy of theapplication andto determine isreapplication isnecessary.Inadequateinformationon theextent andcost ofpostapplicationmonitoring.No costestimateavailable.1What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/citiesin state)currently appliesmosquito adulticides/larvacides?Please be specific as possible.All organized programs use mosquito pesticides as part of their programs.2Are mosquito population densities and species identification determined at the same time or at different times? Please explainhow these activitiesare typically conducted.a.Does species testing utilize the same traps used for density trapping, or are differenttraps in different areas deployed?Different traps are used for different species/ trapping situations. The same traps are usedhowever for species identification andspecies numbers. Traps are selected based on the species ofinterest. For example, CDC traps baited with dry ice are typically usedfor Culex spp., while Bates traps are used for Aedes spp.3If entities responsible for discharging adulticides and/or larvacides into WOUS were asked to conduct mapping responsibilities, what percentage ofapplicators would use computer-based mapping system(e.g. GIS/GPS) versus hard copy mapping?a. Can you provide an estimate of the cost of hard mapping of mosquito sites?b. Can you provide an estimate of the costof mapping mosquito sites using a computer-based mapping system (e.g. GIS/GPS)?94What are the typical types of source reduction activities commonlyemployed when controlling for mosquitoes in vector controldistricts/counties/cities in the state/region/territory/tribal region/federal facility (e.g. grading, removing refuse, weed removal)?a.Do these activities vary by region? If so, what activities areperformed in what regions?b.What is your estimate of the average numberof hours dedicated toeach activity, annually?c.What is your estimate of the duration and frequency of these activities?d.What is your estimate of the cost ofequipment necessary for these activities?e.What is your estimate of the probability that each of these activities being employed in each state/territory/tribal region/federal facility?5On average, out of all water bodies to which pesticides for mosquito control are applied in state/region/territory/tribal region/federal facility, what isyour estimate of the proportion of waterbodies treated for vegetation management?6Do you think that an estimate of, on average, 0.05% of all areas being sprayed for mosquito control can be considered “non-waters” of the UnitedStates (i.e., roadside ditches, farm ponds, puddles etc)?7EPA is assuming that the time to conduct surveillance activities for mosquito control is reduced significantly in the year after a program isestablished.a.What is your estimate of the time to conduct surveillance in year 1, year 2, year 3, year 4 and year 5 of the permit?b.What is your estimate of the current compliance with mosquito (adult and larval) disease surveillance?Costs for surveillance in mosquitocontrol districts are constant. The major component is staff time.EPA should not assume a drop in cost for surveillance in out years. Depending on the district,surveillance activities constitute 30 to60% of staff activity year round.8Out of all mosquito control applicators in your state/region/territory/tribal region/federal facility, what is your estimate ofthe proportion that have arestricted use pesticide applicator certification?10How many mosquito control applicators are there in your state/region/territory/tribal region/federalfacility?**1360 certified public health pest control applicators,178 commercial businesses providing mosquito control,59 organized districts** a.Out of all mosquito control applicators, what proportion are commercial applicators? What proportion of the commercial applicators arecertified applicators and have taken the certified pesticide applicator training?b.Are there other (non-commercial) mosquito control applicators inyour state/region/territory/tribal region/federal facility? Whatproportion are certified pesticide applicators?c.What is your estimate of the number (or proportion) of non-certified commercial applicators that would require training?8What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/citiesin state) currently maintainspesticide application records?a. What is the cost of recording and maintaining the information?No cost estimates available9What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/cities in state) currently conductspost application monitoring?a. What is the cost to conduct the monitoring?Post application monitoring is routine aspart of the effort to determine efficacyof the application and to determine is reapplication isnecessary.11AQUATIC WEED CONTROLBackground:On January 7, 2009 the U.S. Sixth Circuit Court of Appeals held in National Cotton Council, et al, v. EPA that Clean Water Actpermits arerequired for all biological pesticide applications and chemical pesticide applications that leave a residue in water when suchapplications aremade in or over, including near, waters of the U.S (WOUS). EPA is developing an NPDES pesticides general permit (PGP) for pesticideapplications. As part of the permit development, EPA is conducting an economic analysis to estimate the effect of the permit on the industry.Several data gaps exist that prevent determining the extent ofimpact that this permit will have on pesticide applicators covered under thepermit. In order to fill these data gaps, we ask that you respond to the following questionsto the best of your ability.Directions:The following table provides a list of questions that are designed to determine estimates on the feasibility, current compliance, and cost ofspecific activities that are being considered for inclusion in the PGP. Regardingthe technologic and economic feasibility ofeach activity,please provide your estimate of the proportion of current aquatic pesticide applicators that would be ableto complete the activity.1If theactivity in question is already being practiced by applicators, please assume that itis both technologically and economicallyfeasible. Inmaking these estimates you should consider (1) those areas that donot currently have a pesticide control program as being infeasible for theactivities, and (2) for those areas that do have a program, what are the technological and economic limitations that would makethe activityinfeasible. For example, if you know that50% of the counties in yourstate do not currently conduct aquatic pest control activities due tolimited access or low populations, etc., your estimate of feasibility is reduced by half.In addition, if you know that of theremaining 50% ofcounties that have aquatic pest control programs, 5% are located in areas which limit their technological ability to do an activity, thefeasibility of the activity is reduced another 5% (to 45% feasible). An activity can stillbe technologically and economicallyfeasible despitethe fact that some additional costs are imposed in comparison to what the applicatoris facing in the status quo. Please provide any sources orcomments you may have in determining these estimates.In the current compliance column, please provide your estimate ofthe proportion of aquatic pesticide applicators that are currently incompliance. That is, if an activity is already being practiced by all applicators, assume that current compliance with the activity is 100%.However, if, for example, you estimate that only half of applicators are in compliance with an activity, indicate as such by recording 50% inthe current compliance column for the respective activity. Please provideany sources or comments you may have in determining theseestimates.Finally, estimates for the costs of the activities are needed. Currently, the EPA has cost estimates for some of the activitieslisted. However,these estimates may need refinement and may not reflect the costof the activity in your specific state or region. The first cost column, “unit”indicates the unit associatedwith the cost estimate (e.g. county-wide or per-water body). The second column, “current cost estimate”,1Technologically feasible refers to the ability of applicators to complete an activity given that they have the necessary equipment, manpower, and processes in place.Economical feasibility refers to whether or not an applicator would be able to afford to complete the activity.12provides the actual unit cost estimate. If you feel that EPA’s current estimates reflect what applicators in your state or regionare/would incurfor such activities, please indicate so in the sources/commentscolumn. However, if you have analternative cost estimate, please provide yourcost estimate in the “your estimate” column, and provide any sources/comments about your estimatein the “sources/comments” column. Ifyou are unsure of the answer at any point,please indicate so in the sources/commentscolumns. Ranges are acceptable if you areunable toprovide a precise estimate.Note that for some of the activities, footnotes are referenced. These footnotes will direct you to questions that are associated with thatparticular activity. Please answer these questions to the best of your ability. As inthe case of the questions in the table, if you are unsure ofthe answer to a particular question, please indicate so and, if possible, provide a rangeof possible valuesthat you feel is realistic. Also, notethat the first row is an example of the typeof information that we would like to have.If you have any questions, please call or email Elizabeth Hill at 703-347-87080 or hill.elizabeth@epa.govQuestions1Technological andEconomical FeasibilityCurrent ComplianceCostActivityYourEstimateSources/CommentsYourEstimateSources/CommentsUnitCurrent CostEstimateYourEstimateSources/CommentsExample: Identify problem weedareas, application areas, targetweed species, and possiblesources of problem; establishpast or present weed densities.100%[insertsources/comments]50%-100%[insertsources/comments]Variable Cost:a. supplies forconductinglimnological studyb. labor cost forscouting waterbodiesVariable cost:a. No estimateavailableb. $100 peracre for asmall pond to$1,000 perday for alarger lake.[insertsources/comments asto why yourestimatedifferedfrom thecurrentestimate]Identify problem weed areas,application areas, target weedspecies, and possible sourcesof problem; establish past orpresent weed densities.2Variable cost:a.labor cost forscouting waterbodiesb. supplies forconductinglimnological studyVariable cost:a.$100 peracre for asmall pond to$1,000 perday for alarger lake.b. no estimateavailable13Implement mechanical controls(e.g. weed removal by hand ormachine).3Variable cost:cost per acre formechanicalharvestingVariablecost:$460 to 3,075per acreMaintain, enhance, and promotebiological control(s) prior topesticide application.4Variable cost:a. cost of fishb. number of fishper pond or lakec. cost per wateracreVariableCost:a.$5-$15 perfish,b. 3-200 peracre of waterc. range ofcost is $15-$3,000 perwater acreUse habitat modificationpractices (e.g. light attenuation,bottom barriers) prior topesticide application.5LightAttenuation:Variable Cost:a. Cost per acrefor lightattenuationBottom Barrier:Variable Cost:a. cost per acreofmaterials135489250b. Cost per acreto install bottombarrierc. total cost peracreLightAttenuation:VariableCost:a. $50-$500per wateracre.BottomBarrier:Variable cost:a. $4,400-$26,200 peracre formaterials.b. $10,900-$21,800 peracre forinstallationc. $15,300-$50,000 peracre in total14Calibrate and maintainequipment to ensure effectiveapplication and control; performregular maintenance activities tominimize potential for leaks,spills, andunintended/accidental release ofpesticides from both pesticidecontainers and applicationequipment to waters.Variable Cost:Maintenance andcalibration of allequipment, bycountyVariableCost:$7,500-$25,000Communicate information, atleast once a year, to userssurrounding the treatment areaconcerning aquatic weedpesticide applications through atleast one of the following:community newspaper,community newsletter, web site,pamphlet, television and/orradio.Variable Cost:County-wideinformation andeducationprograms, perpersonVariableCost:$0.01 - $0.68per personEnsure that pesticideapplicators are trained in properapplications of pesticides and inproper response to adverseincidents6Inadequateinformation onthe extent andcost of trainingfor applicators.EPA assumeshighcompliance forapplicatorsMaintain pesticide applicatorrecords.7Inadequateinformation onthe extent andcost ofmaintainingapplicationrecords.15Conduct post-applicationmonitoring of waters of the US.8Inadequateinformation onthe extent andcost of postapplicationmonitoring.1How many states/regions/territories, tribal regions/federal facilities (and/or counties/cities in state) currently make aquaticweed applications? Canyou provide their names? Please be as specific as possible.a.What region(s) of [state(s)]do you think will primarily be affected by this permit?b.What is your estimate of the proportion of water bodies withinstates/regions/territories, tribal regions/federal facilities (and/orcounties/cities in state) that control for aquatic weeds that are actually treated?c.What is your estimate of the number of irrigation systems within states/regions/territories, tribal regions/federal facilities(and/orcounties/cities in state) that use aquatic herbicides that are actually treated?i.For these irrigation systems, what is the average acreage treated with aquatic herbicides?ii.What is the total number and average size of ditch banks inagricultural drainage systems in the state/region/territory,tribal region/federal facility (and/or counties/cities in state)?2For water bodies with aquatic weed problems, what are thetypical methods used to identify the source of the problem (e.g., a full limnologicalstudy)?3What types of mechanical control(s) [do/does states/regions/territories, tribal regions/federal facilities (and/or counties/cities in state) conduct forcontrolling aquatic weeds?a.Do these activities vary by regions within the state? If so, what activities are performed in what regions?b.What is your estimate of the average number ofhours dedicated to each activity, annually?f.What is your estimate of the duration and frequency of these activities?g.What is your estimate of the cost ofequipment necessary for these activities?h.What is your estimate of the probability that each of these activities being employed in each state/territory/tribal region/federal facility(and/or counties/cities in state)?16i.The cost listed is for mechanical harvesting. Other types mechanical control (and range of cost) includes: sediment tilling ($1,500 to$3,000 per acre), hydro-raking ($350 to $2,500 per acre), rototilling ($1,350 to 1,850 per acre), digging ($87,120 to $130,680per acre),handpulling ($500 to $2,400 per water body), diver assisted handpulling ($1,600 per acre).4What types of biological control(s) [do/does states(s)/territory/tribal region/federal facility] conduct for controlling aquatic weeds?a.What proportion of water bodies in each states(s)/territory/tribalregion/federal facility that control for aquatic weeds are implementingbiological control measures?b.Do these biological controls vary by region? Ifso, which controls are used in what regions?c.What is your estimate of the average number of hours states/regions/territories, tribal regions/federal facilities (and/or counties/cities instate) dedicate to each activity, annually (e.g.,restocking Triploid Carp)?j.How many units of each biological control are necessary in each water body for controlling weeds?k.What is your estimate of the probability that each of biologicalcontrols are being employed in each state/territory/tribal region/federalfacility (and/or counties/cities in state)?5What types of habitat modification practices do states/territories/tribal regions/federal facilities (and/or counties/cities in state)conductfor controllingaquatic weeds?a.Do these activities vary by regions within the state? If so, what activities are performed in what regions?b.What is your estimate of the average number ofhours dedicated to each activity, annually?6Out of all [aquatic weed control applicators] in your state/territory/tribal region/federal facility (and/or counties/cities in state), what is your estimateof the proportion that have a restricteduse pesticide applicator certification?a.How many aquatic weed pesticide applicators are there inyour state/region/territory/tribal region/federal facility?b.Out of all aquatic weed control applicators, what proportion are commercial applicators? What proportion of the commercial applicatorsare certified applicators and have taken thecertified pesticide applicator training?c.Are there other (non-commercial) aquatic weed control applicators in your state/region/territory/tribal region/federal facility? Whatproportion are certified pesticide applicators?17d.What is your estimate of the number (or proportion) of non-certified commercial applicators that would require training?7What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/citiesin state) currently maintainspesticide application records?a. What is the cost of recording and maintaining the information?8What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/cities in state) currently conductspost-application monitoring?What is the cost to conduct the monitoring?18WIDE AREA PEST CONTROLBackground:On January 7, 2009 the U.S. Sixth Circuit Court of Appeals held in National Cotton Council, et al, v. EPA that Clean Water Actpermits arerequired for all biological pesticide applications and chemical pesticide applications that leave a residue in water when suchapplications aremade in or over, including near, waters of the U.S (WOUS). EPA is developing an NPDES pesticides general permit (PGP) for pesticideapplications. As part of the permit development, EPA is conducting an economic analysis to estimate the effect of the permit on the industry.Several data gaps exist that prevent determining the extent ofimpact that this permit will have on pesticide applicators covered under thepermit. In order to fill these data gaps, we ask that you respond to the following questionsto the best of your ability.Directions:The following table provides a list of questions that are designed to determine estimates on the feasibility, current compliance, and cost ofspecific activities that are being considered for inclusion in the PGP. Regardingthe technologic and economic feasibility ofeach activity,please provide your estimate of the proportion of current wide area pesticide applicators that would be able to complete the activity.2If theactivity in question is already being practiced by applicators, please assume that itis both technologically and economicallyfeasible. Inmaking these estimates you should consider (1) those areas that donot currently have a pesticide control program as being infeasible for theactivities, and (2) for those areas that do have a program, what are the technological and economic limitations that would makethe activityinfeasible. For example, if you know that50% of the counties in your state do not currently conduct wide area pest control activities due tolimited access or low populations, etc., your estimate of feasibility is reduced by half.In addition, if you know that of theremaining 50% ofcounties that have wide area pest controlprograms, 5% are located in areas which limit their technological ability to do an activity, thefeasibility of the activity is reduced another 5% (to 45% feasible). An activity can stillbe technologically and economicallyfeasible despitethe fact that some additional costs are imposed in comparison to what the applicatoris facing in the status quo.Please provide any sources orcomments you may have in determining these estimates.In the current compliance column, please provide your estimate ofthe proportion of wide area pesticide applicators that are currently incompliance. That is, if an activity is already being practiced by all applicators, assume that current compliance with the activity is 100%.However, if, for example, you estimate that only half of applicators are in compliance with an activity, indicate as such by recording 50% inthe current compliance column for the respective activity. Please provideany sources or comments you may have in determining theseestimates.Finally, estimates for the costs of the activities are needed. Currently, the EPA has cost estimates for some of the activitieslisted. However,these estimates may need refinement and may not reflect the costof the activity in your specific state or region. The first cost column, “unit”indicates the unit associatedwith the cost estimate (e.g. county-wide or per-water body). The second column, “current cost estimate”,provides the actual unit cost estimate. If you feel that EPA’s current estimates reflect what applicators in your state or regionare/would incur2Technologically feasible refers to the ability of applicators to complete an activity given that they have the necessary equipment, manpower, and processes in place.Economical feasibility refers to whether or not an applicator would be able to afford to complete the activity.19for such activities, please indicate so in the sources/commentscolumn. However, if you have analternative cost estimate, please provide yourcost estimate in the “your estimate” column, and provide any sources/comments about your estimatein the “sources/comments” column. Ifyou are unsure of the answer at any point,please indicate so in the sources/comments columns. Ranges are acceptable if you areunable toprovide a precise estimate.Note that for some of the activities, footnotes are referenced. These footnotes will direct you to questions that are associated with thatparticular activity. Please answer these questions to the best of your ability. As inthe case of the questions in the table, if you are unsure ofthe answer to a particular question, please indicate so and, if possible, provide a rangeof possible valuesthat you feel is realistic. Also, notethat the first row is an example of the typeof information that we would like to have.If you have any questions, please call or email Elizabeth Hill at 703-347-87080 or hill.elizabeth@epa.govQuestionsCurrent ComplianceTechnologically andEconomically FeasibleCostActivity1YourestimateSources/CommentsYourestimateSources/CommentsCurrentestimate5YourestimateSources/CommentsEstablish target pest densities which serve asaction threshold for pesticide application.No currentEPA estimateof costIdentify target species in order to develop abest control strategy based on developmentaland behavioral considerations for eachspecies.No currentEPA estimateof costIdentify current distribution of the target pestand assess potential distribution in absenceof control measures.2No currentEPA estimateof costConduct surveillanceusing best industrypractices prior to each pesticide application toassess the treatmentarea and to determinewhen pre-established conditions (pest actionthreshold) are met which necessitate theneed for pest control measures.3No currentEPA estimateof cost20Monitor environmental conditions (e.g.temperature, precipitation, and wind speedimpacting the treatment area) in the treatmentarea from a weather station(s) as close to thetreatment area(s) as possible to identifyconditions which support target pestdevelopment and are conducive for controlmeasures.No currentEPA estimateof costConduct post application surveillance.No current EPAestimate ofcostUse pesticides against the most susceptibledevelopmental stage.No currentEPA estimateof costUse pesticides only where the actionthreshold has been met and/or underemergency condition (e.g. invasive species).No currentEPA estimateof costEnsure that pesticide applicators are trainedin proper applications of pesticides and inproper response to adverse incidents.No currentEPA estimateof costPerform regular maintenance activities tominimize potential for leaks, spills, andunintended/accidental release of pesticidesfrom both pesticide containers and applicationequipment to waters of the United States.No currentEPA estimateof costCalibrate and maintainequipment relative toensure effective application and control.No currentEPA estimateof costAt least once a year information concerningaquatic weed pesticide applications isprovided to residents in the treatment areathrough at least one of the following:community newspaper, communitynewsletter, web site, pamphlet, televisionand/or radio.4No currentEPA estimateof cost21Maintain pesticide applicator records.7No currentEPA estimateof costConduct post-application monitoring of watersof the US.8No currentEPA estimateof cost1How many states/regions/territories, tribal regions/federal facilities (and/or counties/cities in state) currently make wide are pesticide applications?Can you provide their names? Please be as specific as possible.a. What region(s) of [state(s)] do you thinkwill primarily be affected by this permit?b. What is your estimate of the number of wide-area insect suppression programs in the state/region/territory/tribal region/federal facility?c. What is your estimate of the number of forest control programs and the water bodies that theyencompass in the state/region/territory/tribalregion/federal facility?d. What is your estimate of the proportion of water bodies within states/regions/territories, tribal regions/federal facilities(and/orcounties/cities in state) that receive wide area pesticide treatment?2If entities responsible for discharging adulticides and/or larvacides into waters of the United States were asked to conductmapping responsibilities,what percentage of applicators would use computer-basedmapping system (e.g. GIS/GPS) versus hard copy mapping?a. Can you provide an estimate of the cost of hard mapping of wide area pesticide application sites?b. Can you provide an estimate of the cost of mapping wide area pesticide application sites using a computer-based mapping system (e.g.GIS/GPS)?3EPA is assuming that the time to conduct surveillance activities for wide area pest control is reduced significantly in the year after a program isestablished.c.What is your estimate of the time to conduct surveillance in year 1, year 2, year 3, year 4 and year 5 of the permit?d.What is your estimate of the current compliance with wide area pest surveillance?224Out of all wide area pesticide applicators in your state/territory/tribal region/federal facility (and/or counties/cities in state), what is your estimate ofthe proportion that have a restricted use pesticide applicator certification?a.How many wide area pesticide applicators are there in your state/region/territory/tribal region/federal facility?b.Out of all wide area pesticide applicators, what proportion arecommercial applicators? What proportion of the commercial applicators arecertified applicators and have taken the certified pesticide applicator training?c.Are there other (non-commercial) wide area pesticide applicatorsin your state/region/territory/tribal region/federal facility?Whatproportion are certified pesticide applicators?d.What is your estimate of the number (or proportion) of non-certified commercial applicators that would require training?5EPA is still in the process of collectinginformation on cost for these activities.6What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/citiesin state) currently maintainspesticide application records?a. What is the cost of recording and maintaining the information?7What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/cities in state) currently conductspost application monitoring?a. What is the cost to conduct the monitoring?