RE: EPA Region 9 

Dave Brown 

to: 

Jordan Page 

01/04/2010 11:16 AM 

Cc: 

"'Karl Malamud-Roam'" 

Show Details 

Mr. Page 

The Mosquito and Vector Control Association of California (MVCAC) has developed a committee to work with the 

California State Water Resources Control Board (SWRCB) staff on developing the now required NPDES permit for 

mosquito control applications (larvicides and adulticides). This committee has representatives from every region 

of the state of California along with a member from the California Department of Public Health (CDPH). The 

committee recently had a meeting with the SWRCB staff in which the EPA Region 9 rep was present. Candidly, it 

appears Region 9 is driving the process of the California permit, which seems to be inconsistent with the direction 

of the national USEPA efforts as I know them. 

Of specific concern(s): 

1 The CDPH and the MVCAC have strongly recommended to the SWRCB that the industry needs a combined 

permit for both adulticides and larvicides, (in other words, a "vector control permit"). The SWRCB staff and the 

EPA Region 9 rep indicated to the committee that we would have two separate permits, one for larviciding 

activities and one for adulticiding activities. The rationale for two permits, at least as expressed by the Region 9 

rep, was that the residues after the pesticide is applied and the beneficial uses exhausted was of more concern 

for adulticides than larvicides . This rationale seems to be in direct conflict with the Sixth Circuit's ruling that now 

classifies ALL biological pesticides as pollutants (and therefore identifies many of the larvicides we use as 

pollutants, and not just their residues). If I am mistaken, please let me know. 

 

The SWRCB posted the draft permit on their website and solicited comments on the issue regarding separate 

permits versus a combined permit. The SWRCB staff indicated that they have not received any comments other 

than those initially submitted by the MVCAC and the CDPH (recommending a combined permit). The SWRCB 

staff seems to be ignoring the recommendations from the leaders in mosquito control in the state of California 

and the entities that would be most affected by the NPDES permit There seems to be a complete dismissal by 

water officials of the IPM approach to mosquito control (which does include adulticides). In fact, when it was 

mentioned that we may have districts simply not sign on to an adulticide permit (due to budget constraints) that 

would put the public at risk of mosquito-borne diseases, the response was "we need to protect our water as 

well". As an industry we understand this, but we do not see how separate permits minimize the protection of 

Califonia waterways unless the objective by the SWRCB staff (And EPA Region 9) is to eliminate adult mosquito 

control. 

2) There also does not seem to be any direction from Region 9 prompting the SWRCB staff to follow EPA's lead 

on the permitting process. While we know states can be more aggressive in developing a permit as long as they 

meet the federal standards, it would be helpful if there was more direction from Region 9 to our State Water 

Board to follow the outline of the general permit that the USEPA is developing at this time. 

 

Lastly, public health pesticides in California account for less than 1/3 of 1 percent of all pesticides reported. 

Despite having this information the SWRCB staff and the Region 9 rep seem solely directed at pursuing research 

monitoring protocols that our publicly funded Association may not be able to afford. It would be very prudent to 

follow EPA's lead on a general permit until this issue is sorted out a bit further and even more helpful if Region 9 

would take a more proactive role in prompting that to happen. 

Thank you for listening to my concerns and I look forward to your reply.....if I misunderstand something please 

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let me know. 

David Brown

Manager

SYMVCD

916-405-2059

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