MOSQUITO CONTROL- Responses by Florida Department of Agriculture and Consum

Questions 

Technologically and 

Economically Feasible 

Current Compliance 

Activity1 Your 

Estimate 

Sources/Comments Your 

Estimate

Sources/Comments Unit Current 

Cost Estimate 

Yo

Establish mosquito densities and identify mosquito species.2  (continued)

100% All mosquito control 

districts conduct 

this activity to some 

degree.

100% Required under 

state law to 

determine 

population levels. 

Variable Cost: a. Number of traps per district b. Cost per trap c. Labor hours and wage rate to set trap per district d. Number of districts doing the activity 

Variable Cost: 

5

Identify and record on a map known and potential breeding sites for source reduction.3

100% Can be 

accomplished. 

Resource 

constraints do not 

allow all districts to 

complete this 

activity. 

40% Only districts with 

sufficient personnel 

can conduct this 

activity. 

Variable Cost: Cost of mapping per vector control district 

 $
Technologically and 

Economically Feasible 

Current Compliance 

Activity1 Your 

Estimate 

Sources/Comments Your 

Estimate

Sources/Comments Unit Current 

Cost Estimate 

Yo

Remove, drain, and/or prevent mosquito entry to substrates used for oviposition and larval development (e.g., containers, tires, etc.).4

100% This is achievable 

for substrates that 

are accessible and 

subject to control of 

the district. It is not 

achievable for all 

such substrates, 

and is not 

economically 

possible for all 

substrates. 

100% All districts conduct 

this activity to some 

extent. No district 

conducts this 

activity for all the 

potential substrates 

in their district. 

Variable Cost: a. Labor hours and wage rate to set trap per district b. Number of districts doing the activity

Variable Cost: 

Z

Perform water management practices (e.g., improving drainage, periodic draining, ditching, impounding, frequency and duration of flooding, water circulation, water depth management (predator habitat), etc.). 

100% This activity is 

feasible for some 

situations, but not 

feasible for others. 

For many districts, 

such tactics have 

already been 

completed (e.g. 

impoundments on 

Florida’s East 

Coast). For others, 

they are not an 

option (e.g. districts 

surrounding 

Everglades 

National Park) 

Variable Cost: Cost of activity per district 

Variable Cost: 
Technologically and 

Economically Feasible 

Current Compliance 

Activity1 Your 

Estimate 

Sources/Comments Your 

Estimate

Sources/Comments Unit Current 

Cost Estimate 

Yo

Perform vegetation management practices to eliminate or reduce mosquito habitat (e.g. mowing, grazing, aquatic herbicides).5

This activity is 

feasible for some 

situations, but not 

feasible for others. 

For many districts, 

such tactics have 

already been 

completed (e.g. 

impoundments on 

Florida’s East 

Coast). For others, 

they are not an 

option (e.g. districts 

surrounding 

Everglades 

National Park) 

Variable Cost: a. cost of activity per acre b. number of managed acres per district 

Variable Cost: 

Maintain and promote biological control by encouraging sitespecific predator populations (e.g. larvivorous fish), growth regulators (e.g. methoprene), and bacteria (e.g. Bti). 

100% Use of existing or 

augmented 

biological controls 

is inherent in 

district activity. 

Since applications 

are made only 

when population 

levels dictate 

action, population 

levels are normally 

maintained by 

existing biological 

controls. Please 

note that 

methoprene and 

Bti are not 

biological 

controls but are 

registered 

pesticides the 

application of 

100% Every district uses 

these to some 

extent. 

Variable Cost: a. cost of fish b. number of fish per pond or lake 

Variable Cost: 

p

m

im
Technologically and 

Economically Feasible 

Current Compliance 

Activity1 Your 

Estimate 

Sources/Comments Your 

Estimate

Sources/Comments Unit Current 

Cost Estimate 

Yo

which is dictated 

by IPM principles.

Manage mosquitoes breeding sites in waters such as puddles, farm ponds, or roadside ditches, etc., that are not waters of the United States to reduce migration to near areas.6

Variable Cost: a. cost per acre b. cost per vector control district 

Variable Cost: 

Conduct and analyze larvae, adult, disease, resistance, and environmental conditions (i.e., temperature, precipitation, and wind speed in treatment area) surveillance.7

100% This is technically 

feasible, but the 

degree to which it 

is conducted is 

dependent on 

economic 

resources of 

district 

Variable Cost: a. cost per vector control district 

Variable Cost: 

Use larvicides as the primary pesticide for mosquito control. 

Not applicable – 

larvacides should 

not be designated 

as “primary” means 

of mosquito control. 

It is more 

appropriate to 

designate this as use of larvacides 

as appropriate. 

Variable 

Cost: a. cost per acre or application of switching to larvacides as primary control 

Variable Cost: a.. b. EPA assumes relatively low feasibility and cost, 

d
Technologically and 

Economically Feasible 

Current Compliance 

Activity1 Your 

Estimate 

Sources/Comments Your 

Estimate

Sources/Comments Unit Current 

Cost Estimate 

Yo

b. number of acres or applications per district c. number of districts 

but needs specific data. 

Use adulticides only where the adult action threshold has been met and/or under emergency condition (e.g. flooding, disease outbreak). 

100% All districts treat 

when population 

levels are reached 

that require 

treatment. 

100% All districts treat 

when population 

levels are reached 

that require 

treatment 

a. Inadequate information on the cost and use of adulticides. b. EPA assumes relatively high compliance, but needs specific data. 

C

n

fo

r

$

p

ad

$

m
Technologically and 

Economically Feasible 

Current Compliance 

Activity1 Your 

Estimate 

Sources/Comments Your 

Estimate

Sources/Comments Unit Current 

Cost Estimate 

Yo

Calibrate and maintain equipment to ensure effective application and control; perform regular maintenance activities to minimize potential for leaks, spills, and unintended/accidental release of pesticides from both pesticide containers and application equipment to waters. 

100% Variable 

Cost: cost per district 

Variable Cost: 

t

Provide mosquito control information to residents in the treatment area through one or more of the following methods: community newspaper, community newsletter, web site, television and/or radio. 

100% 100% All districts provide 

information to some 

extent. 

Variable Cost: per capita cost of providing education materials 

Variable Cost: 

Minimize the use of both larvicides and adulticides for mosquito control when the action thresholds have been met. 

100% Pesticides are 

expensive and will 

not be used unless 

there is a 

demonstrated 

presence of 

mosquitoes.

100% Required by state 

law. 

a. Inadequate information on the cost and use of adulticides and larvacides. b. EPA assumes 

Nesav
Technologically and 

Economically Feasible 

Current Compliance 

Activity1 Your 

Estimate 

Sources/Comments Your 

Estimate

Sources/Comments Unit Current 

Cost Estimate 

Yo

relatively low cost and high compliance, but needs specific data. 

Ensure that pesticide applicators are trained in proper applications of pesticides and in proper response to adverse incidents.8

 100% Training is part of 

certification 

process 

 100% Required by state 

law. 

a. Inadequate information on the extent of training and cost of training. b. EPA assumes high compliance for applicators. 

 NesavLiprcoby DAgCSe

Maintain pesticide applicator records. 8

100% 100% Required by state 

law. 

Inadequate information on the extent and cost of maintaining application records. 

Nesav
Technologically and 

Economically Feasible 

Current Compliance 

Activity1 Your 

Estimate 

Sources/Comments Your 

Estimate

Sources/Comments Unit Current 

Cost Estimate 

Yo

Conduct postapplication monitoring of waters of the US. 9

100% 100% Post application 

monitoring is routine as part of the effort to determine efficacy of the application and to determine is reapplication is necessary. 

Inadequate information on the extent and cost of postapplication monitoring. 

Nesav

1 What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/citi

mosquito adulticides/larvacides? Please be specific as possible. 

All organized programs use mosquito pesticides as part of their programs. 

2 Are mosquito population densities and species identification determined at the same time or at different times? Ple

are typically conducted.

a. Does species testing utilize the same traps used for density trapping, or are different traps in different areas 

Different traps are used for different species/ trapping situations. The same traps are used however for 

species numbers. Traps are selected based on the species of interest. For example, CDC traps baited w

for Culex spp., while Bates traps are used for Aedes spp. 

3 If entities responsible for discharging adulticides and/or larvacides into WOUS were asked to conduct mapping resp

applicators 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 cost of mapping mosquito sites using a computer-based mapping system 
4 What are the typical types of source reduction activities commonly employed when controlling for mosquitoes in ve

districts/counties/cities in the state/region/territory/tribal region/federal facility (e.g. grading, removing refuse, weed re

a. Do these activities vary by region? If so, what activities are performed in what regions? 

b. What is your estimate of the average number of hours dedicated to each activity, annually? 

c. What is your estimate of the duration and frequency of these activities?

d. What is your estimate of the cost of equipment necessary for these activities? 

e. What is your estimate of the probability that each of these activities being employed in each state/territory/

5 On average, out of all water bodies to which pesticides for mosquito control are applied in state/region/territory/tribal 

your estimate of the proportion of water bodies treated for vegetation management?

6 Do you think that an estimate of, on average, 0.05% of all areas being sprayed for mosquito control can be considered 

States (i.e., roadside ditches, farm ponds, puddles etc)? 

7 EPA is assuming that the time to conduct surveillance activities for mosquito control is reduced significantly in the ye

established. 

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 

b. What is your estimate of the current compliance with mosquito (adult and larval) disease surveillance?

Costs for surveillance in mosquito control districts are constant. The major comp

EPA should not assume a drop in cost for surveillance in out years. Depending on surveillance activities constitute 30 to 60% of staff activity year round. 

8 Out of all mosquito control applicators in your state/region/territory/tribal region/federal facility, what is your estima

restricted use pesticide applicator certification? 
How many mosquito control applicators are there in your state/region/territory/trifacility? 1360 certified public health pest control applicators,178 commercial businesse

control,59 organized districts 

a. Out of all mosquito control applicators, what proportion are commercial applicators? What proportion of t

certified applicators and have taken the certified pesticide applicator training? 

b. Are there other (non-commercial) mosquito control applicators in your state/region/territory/tribal region/f

proportion are certified pesticide applicators? 

c. What is your estimate of the number (or proportion) of non-certified commercial applicators that would req

8 What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/ci

pesticide application records? 

a. What is the cost of recording and maintaining the information? 

No cost estimates available 

9 What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/ci

post application monitoring? 

a. What is the cost to conduct the monitoring? Post application monitoring is routine as part of the effort to determine efficacy of the application and to 

necessary. 
AQUATIC WEED CONTROL 

Background: On January 7, 2009 the U.S. Sixth Circuit Court of Appeals held in National Cotton Council, et al, v. EPA that C

required for all biological pesticide applications and chemical pesticide applications that leave a residue in water made in or over, including near, waters of the U.S (WOUS). EPA is developing an NPDES pesticides general pe

applications. As part of the permit development, EPA is conducting an economic analysis to estimate the effect Several data gaps exist that prevent determining the extent of impact that this permit will have on pesticide applipermit. In order to fill these data gaps, we ask that you respond to the following questions to the best of your abil

Directions: The following table provides a list of questions that are designed to determine estimates on the feasibility, curren

specific activities that are being considered for inclusion in the PGP. Regarding the technologic and economic feplease provide your estimate of the proportion of current aquatic pesticide applicators that would be able to comp

activity in question is already being practiced by applicators, please assume that it is both technologically and ecmaking these estimates you should consider (1) those areas that do not currently have a pesticide control program 

activities, and (2) for those areas that do have a program, what are the technological and economic limitations tha

infeasible. For example, if you know that 50% of the counties in your state do not currently conduct aquatic pest 

limited access or low populations, etc., your estimate of feasibility is reduced by half. In addition, if you know thcounties that have aquatic pest control programs, 5% are located in areas which limit their technological ability tfeasibility of the activity is reduced another 5% (to 45% feasible). An activity can still be technologically and ecthe fact that some additional costs are imposed in comparison to what the applicator is facing in the status quo. P

comments you may have in determining these estimates. In the current compliance column, please provide your estimate of the proportion of aquatic pesticide applicators compliance. That is, if an activity is already being practiced by all applicators, assume that current compliance w

However, if, for example, you estimate that only half of applicators are in compliance with an activity, indicate athe current compliance column for the respective activity. Please provide any sources or comments you may havestimates. Finally, estimates for the costs of the activities are needed. Currently, the EPA has cost estimates for some of the these estimates may need refinement and may not reflect the cost of the activity in your specific state or region. T

indicates the unit associated with the cost estimate (e.g. county-wide or per-water body). The second column, “cu

1 Technologically feasible refers to the ability of applicators to complete an activity given that they have the necessary equipment, manp

Economical feasibility refers to whether or not an applicator would be able to afford to complete the activity. 
provides the actual unit cost estimate. If you feel that EPA’s current estimates reflect what applicators in your stafor such activities, please indicate so in the sources/comments column. However, if you have an alternative cost 

cost estimate in the “your estimate” column, and provide any sources/comments about your estimate in the “souryou are unsure of the answer at any point, please indicate so in the sources/comments columns. Ranges are accepprovide a precise estimate. Note that for some of the activities, footnotes are referenced. These footnotes will direct you to questions that are particular activity. Please answer these questions to the best of your ability. As in the case of the questions in the the answer to a particular question, please indicate so and, if possible, provide a range of possible values that you that the first row is an example of the type of 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.gov Questions1 

Technological and 

Economical Feasibility 

Activity Current Compliance 

Your Estimate 

Sources/Comments 

Your Estimate 

Sources/Comments 

Unit Current 

Estimate 

Example: Identify problem weed areas, application areas, target weed species, and possible sources of problem; establish past or present weed densities. 

100% [insert 

sources/comments] 

50%-100% 

[insert sources/comments] 

Variable Cost: a. supplies for conducting limnological studyb. labor cost for scouting water bodies

Variable a. No esavailable b. $100 acre for small po$1,000 pday for a larger la

Identify problem weed areas, application areas, target weed species, and possible sources of problem; establish past or present weed densities.2

Variable cost: a. labor cost for scouting water bodies b. supplies for conducting limnological study 

Variable a. $100 acre for small po$1,000 pday for a larger lab. no esavailable 
Implement mechanical controls (e.g. weed removal by hand or machine).3

Variable cost: cost per acre for mechanical harvesting 

Variabl

cost: $460 to per acre 

Maintain, enhance, and promote biological control(s) prior to pesticide application.4

Variable cost: a. cost of fish b. number of fish per pond or lake c. cost per water acre

Variable Cost: $5-$15 pfish, b. 3-200 acre of wc. range cost is $$3,000 pwater ac

Use habitat modification practices (e.g. light attenuation, bottom barriers) prior to pesticide application.5

Light Attenuation: Variable Cost: a. Cost per acre for light attenuation Bottom Barrier: Variable Cost: a. cost per acre of materials135489250b. Cost per acre to install bottom barrier c. total cost per acre 

Light AttenuaVariable Cost:a. $50-$per wateacre. Bottom Barrier: Variable a. $4,40$26,200 acre for materialb. $10,9$21,800 acre for installatic. $15,3$50,000 acre in t
Calibrate and maintain equipment to ensure effective application and control; perform regular maintenance activities to minimize potential for leaks, spills, and unintended/accidental release of pesticides from both pesticide containers and application equipment to waters. 

Variable Cost: Maintenance and calibration of all equipment, by county 

Variable Cost: $7,500-$25,000 

Communicate information, at least once a year, to users surrounding the treatment area concerning aquatic weed pesticide applications through at least one of the following: community newspaper, community newsletter, web site, pamphlet, television and/or radio. 

Variable Cost: County-wide information and education programs, per person 

Variable Cost: $0.01 - $per pers

Ensure that pesticide applicators are trained in proper applications of pesticides and in proper response to adverse incidents6

Inadequinformatthe extecost of tfor appliEPA asshigh compliaapplicato

Maintain pesticide applicator records. 7

Inadequinformatthe extecost of maintainapplicatrecords. 
Conduct post-application monitoring of waters of the US. 8

Inadequinformatthe extecost of papplicatmonitori

1 How many states/regions/territories, tribal regions/federal facilities (and/or counties/cities in state) currently make aqu

you 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 within states/regions/territories, tribal regions/fede

counties/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/fe

counties/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 in agricultural drainage systems i

tribal region/federal facility (and/or counties/cities in state)? 

2 For water bodies with aquatic weed problems, what are the typical methods used to identify the source of the problem 

study)? 

3 What types of mechanical control(s) [do/does states/regions/territories, tribal regions/federal facilities (and/or countie

controlling 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 of hours 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 of equipment necessary for these activities? 

h. What is your estimate of the probability that each of these activities being employed in each state/territory/

(and/or counties/cities in state)? 
i. The cost listed is for mechanical harvesting. Other types mechanical control (and range of cost) includes: 

$3,000 per acre), hydro-raking ($350 to $2,500 per acre), rototilling ($1,350 to 1,850 per acre), digging ($8

handpulling ($500 to $2,400 per water body), diver assisted handpulling ($1,600 per acre). 

4 What types of biological control(s) [do/does states(s)/territory/tribal region/federal facility] conduct for controlling aq

a. What proportion of water bodies in each states(s)/territory/tribal region/federal facility that control for aqu

biological control measures? 

b. Do these biological controls vary by region? If so, which controls are used in what regions? 

c. What is your estimate of the average number of hours states/regions/territories, tribal regions/federal facili

state) 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 biological controls are being employed in each state/te

facility (and/or counties/cities in state)? 

5 What types of habitat modification practices do states/territories/tribal regions/federal facilities (and/or counties/cities 

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 of hours dedicated to each activity, annually? 

6 Out of all [aquatic weed control applicators] in your state/territory/tribal region/federal facility (and/or counties/cities 

of the proportion that have a restricted use pesticide applicator certification? 

a. How many aquatic weed pesticide applicators are there in your state/region/territory/tribal region/federal fa

b. Out of all aquatic weed control applicators, what proportion are commercial applicators? What proportion 

are certified applicators and have taken the certified pesticide applicator training? 

c. Are there other (non-commercial) aquatic weed control applicators in your state/region/territory/tribal regio

proportion are certified pesticide applicators? 
d. What is your estimate of the number (or proportion) of non-certified commercial applicators that would req

7 What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/ci

pesticide application records? 

a. What is the cost of recording and maintaining the information?

8 What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/ci

post-application monitoring? What is the cost to conduct the monitoring? 
WIDE AREA PEST CONTROL

Background: On January 7, 2009 the U.S. Sixth Circuit Court of Appeals held in National Cotton Council, et al, v. EPA that Crequired for all biological pesticide applications and chemical pesticide applications that leave a residue in water made in or over, including near, waters of the U.S (WOUS). EPA is developing an NPDES pesticides general pe

applications. As part of the permit development, EPA is conducting an economic analysis to estimate the effect Several data gaps exist that prevent determining the extent of impact that this permit will have on pesticide applipermit. In order to fill these data gaps, we ask that you respond to the following questions to the best of your abi

Directions: The following table provides a list of questions that are designed to determine estimates on the feasibility, curren

specific activities that are being considered for inclusion in the PGP. Regarding the technologic and economic feplease provide your estimate of the proportion of current wide area pesticide applicators that would be able to coactivity in question is already being practiced by applicators, please assume that it is both technologically and ecmaking these estimates you should consider (1) those areas that do not currently have a pesticide control program 

activities, and (2) for those areas that do have a program, what are the technological and economic limitations tha

infeasible. For example, if you know that 50% of the counties in your state do not currently conduct wide area plimited access or low populations, etc., your estimate of feasibility is reduced by half. In addition, if you know thcounties that have wide area pest control programs, 5% are located in areas which limit their technological ability 

feasibility of the activity is reduced another 5% (to 45% feasible). An activity can still be technologically and ecthe fact that some additional costs are imposed in comparison to what the applicator is facing in the status quo. Pcomments you may have in determining these estimates.In the current compliance column, please provide your estimate of the proportion of wide area pesticide applicatocompliance. That is, if an activity is already being practiced by all applicators, assume that current compliance wHowever, if, for example, you estimate that only half of applicators are in compliance with an activity, indicate athe current compliance column for the respective activity. Please provide any sources or comments you may havestimates. Finally, estimates for the costs of the activities are needed. Currently, the EPA has cost estimates for some of the these estimates may need refinement and may not reflect the cost of the activity in your specific state or region. T

indicates the unit associated with the cost estimate (e.g. county-wide or per-water body). The second column, “cu

provides the actual unit cost estimate. If you feel that EPA’s current estimates reflect what applicators in your sta

2 Technologically feasible refers to the ability of applicators to complete an activity given that they have the necessary equipment, manp

Economical feasibility refers to whether or not an applicator would be able to afford to complete the activity. 
for such activities, please indicate so in the sources/comments column. However, if you have an alternative cost 

cost estimate in the “your estimate” column, and provide any sources/comments about your estimate in the “souryou are unsure of the answer at any point, please indicate so in the sources/comments columns. Ranges are accepprovide a precise estimate. Note that for some of the activities, footnotes are referenced. These footnotes will direct you to questions that are particular activity. Please answer these questions to the best of your ability. As in the case of the questions in the the answer to a particular question, please indicate so and, if possible, provide a range of possible values that you that the first row is an example of the type of 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.gov Questions 

Current Compliance Technologically and 

Economically Feasible 

Activity1 Your 

estimate 

Sources/ 

Comments 

Your 

estimate 

Sources/ 

Comments 

Curren

estimat

Establish target pest densities which serve as action threshold for pesticide application. 

 No currenEPA estimof cost 

Identify target species in order to develop a best control strategy based on developmental and behavioral considerations for each species. 

 No currenEPA estimof cost 

Identify current distribution of the target pest and assess potential distribution in absence of control measures. 2

 No currenEPA estimof cost 

Conduct surveillance using best industry practices prior to each pesticide application to assess the treatment area and to determine when pre-established conditions (pest action threshold) are met which necessitate the need for pest control measures.3

 No currenEPA estimof cost 
Monitor environmental conditions (e.g. temperature, precipitation, and wind speed impacting the treatment area) 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 control measures. 

 No currenEPA estimof cost 

Conduct post application surveillance. No curren

estimate ocost 

Use pesticides against the most susceptible developmental stage. 

 No currenEPA estimof cost 

Use pesticides only where the action threshold has been met and/or under emergency condition (e.g. invasive species). 

 No currenEPA estimof cost 

Ensure that pesticide applicators are trained in proper applications of pesticides and in proper response to adverse incidents. 

 No currenEPA estimof cost 

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

 No currenEPA estimof cost 

Calibrate and maintain equipment relative to ensure effective application and control. 

 No currenEPA estimof cost 

At least once a year information concerning aquatic weed pesticide applications isprovided to residents in the treatment area through at least one of the following: community newspaper, community newsletter, web site, pamphlet, television and/or radio.4

 No currenEPA estimof cost 
Maintain pesticide applicator records. 7 No curren

EPA estimof cost 

Conduct post-application monitoring of waters of the US. 8

 No currenEPA estimof cost 

1 How many states/regions/territories, tribal regions/federal facilities (and/or counties/cities in state) currently make wi

Can you 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 number of wide-area insect suppression programs in the state/region/territory/tr

c. What is your estimate of the number of forest control programs and the water bodies that they encompass in 

region/federal facility? d. What is your estimate of the proportion of water bodies within states/regions/territories, tribal regions/federa

counties/cities in state) that receive wide area pesticide treatment? 

2 If entities responsible for discharging adulticides and/or larvacides into waters of the United States were asked to co

what percentage of applicators 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 wide area pesticide application sites? 

b. Can you provide an estimate of the cost of mapping wide area pesticide application sites using a computer-b

GIS/GPS)? 

3 EPA is assuming that the time to conduct surveillance activities for wide area pest control is reduced significantly in 

established. 

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 

d. What is your estimate of the current compliance with wide area pest surveillance? 
4 Out of all wide area pesticide applicators in your state/territory/tribal region/federal facility (and/or counties/cities in 

the 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 facil

b. Out of all wide area pesticide applicators, what proportion are commercial applicators? What proportion of 

certified applicators and have taken the certified pesticide applicator training? 

c. Are there other (non-commercial) wide area pesticide applicators in your state/region/territory/tribal region

proportion are certified pesticide applicators? 

d. What is your estimate of the number (or proportion) of non-certified commercial applicators that would req

5 EPA is still in the process of collecting information on cost for these activities.6 What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/citie

pesticide application records? 

a. What is the cost of recording and maintaining the information?

7 What proportion of the state/region/territory/tribal region/federal facility (and/or vector control districts/counties/citie

post application monitoring? 

a. What is the cost to conduct the monitoring?