East Bay Municipal Utility District Integrated Pest ......Jan 04, 2018 · The East Bay Municipal Utility District (“District”) practices Integrated Pest Management (IPM) across

Prepared for:

East Bay Municipal Utility District 375 11th Street

Oakland, CA 94607

Contact: Chandra Johannesson

Prepared by:

Blankinship & Associates, Inc. 1615 5th Street

Davis, CA 95616

Contact: Mike Blankinship

January 4, 2018

East Bay Municipal Utility District

Integrated Pest Management Program Review and Recommendations

EBMUD IPM Program Review and Recommendations

Page 1 Blankinship & Associates, Inc. January 4, 2018

TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................ 1 LIST OF APPENDICES ............................................................................................................. 1 LIST OF ABBREVIATIONS ....................................................................................................... 2 1. Introduction .................................................................................................................. 3

1.1. About the Authors ........................................................................................................... 3 2. Scope, Breadth, and Program Review Process ......................................................... 4 3. Summary of IPM Survey, Interviews, and Observations ............................................ 4

3.1. Pest Control Objectives .................................................................................................. 5 3.2. Pest Identification ........................................................................................................... 5 3.3. Pest Thresholds ............................................................................................................. 5 3.4. Pest Management Strategies ......................................................................................... 6 3.5. Monitoring ...................................................................................................................... 7 3.6. Recordkeeping and Reporting ........................................................................................ 7 3.7. Training .......................................................................................................................... 8 3.8. Pesticide Application Observations ................................................................................. 8

4. Comparison of District IPM Practices with Those of Similar Agencies .................... 9 5. IPM Policy Recommendations ..................................................................................... 9 6. Resource Needs Assessment.................................................................................... 10 7. Conclusions and Program Recommendations ........................................................ 11 8. Additional Resources ................................................................................................. 15 9. References .................................................................................................................. 17

LIST OF APPENDICES

A: Comparison of EBMUD IPM Practices with Those of Similar Agencies

B: Sample EBMUD IPM Decision Flow Chart

C: Sample EBMUD IPM Activity Log

LIMITATIONS

Services provided by Blankinship and Associates, Inc. were done in a manner consistent with the level of care and skill ordinarily exercised by other professional consultants under similar circumstances at the same time the services were performed. No warranty, expressed or implied, is included. This report is solely for East Bay Municipal Utility District’s use and information. Any reliance on this report by a third party is at such party’s sole risk.



LIST OF ABBREVIATIONS

AAIE Association of Applied IPM Ecologists

APMS Aquatic Plant Management Society

AQD Aqueduct Work Unit

BMP Best Management Practice

CAC County Agricultural Commissioner

Cal-IPC California Invasive Plant Council

CAPCA California Association of Pest Control Advisers

CCA Certified Crop Adviser

CCR California Code of Regulations

CDFW California Department of Fish and Wildlife

CNDDB California Natural Diversity Database

CWSS California Weed Science Society

District East Bay Municipal Utility District

DPR California Department of Pesticide Regulation

FAC Facilities Maintenance Work Unit

IPM Integrated Pest Management

MKW Mokelumne Watershed Work Unit

NPDES National Pollutant Discharge Elimination System

PAPA Pesticide Applicators Professional Association

PAR Pardee-Camanche Recreation Work Unit

PCA Pest Control Adviser

PPE Personal Protective Equipment

PRESCRIBE Pesticide Regulation's Endangered Species Custom Realtime Internet Bulletin Engine

PUR Pesticide Use Report

QAC Qualified Applicator Certificate

QAL Qualified Applicator License

SDS Safety Data Sheet

UC IPM University of California Statewide Integrated Pest Management Program

UCCE University of California Cooperative Extension

USEPA U.S. Environmental Protection Agency

WEB Watershed East Bay Work Unit



1. Introduction

The East Bay Municipal Utility District (“District”) practices Integrated Pest Management (IPM) across all of its properties to safely and effectively control pests while minimizing risk of adverse impacts to non-target receptors. The District’s raw water aqueducts bring water from the Mokelumne Watershed and travel across 90 linear miles of District property to the East Bay. Furthermore, the District manages approximately 270 facilities in 20 cities and 15 unincorporated communities in parts of Alameda and Contra Costa counties. The District also manages about 28,000 acres in the Mokelumne Watershed and 28,000 acres in the East Bay Watershed. District properties are used to preserve drinking water quality while offering habitat for plants and animals as well as providing recreational areas for the public.

IPM is a pest management process that involves determining appropriate control methods based on the pest and site-specific conditions. IPM focuses on managing pests with minimum impact to human health, the environment, and non-target organisms by requiring that a variety of non-pesticide control methods be considered in addition to pesticide controls.

The District implements its IPM program in the following four main divisions: watershed and recreational areas, pipeline aqueduct rights-of-way, grounds maintenance, and facility maintenance. Watershed areas are managed by rangers, the aqueduct rights of way are managed by maintenance specialists, and the grounds maintenance areas are managed by gardeners. Structural pests are handled by contractors. Pesticide applications for the aqueduct rights-of-way and grounds maintenance are the highest pesticide use areas by volume.

1.1. About the Authors

Since 2000, Blankinship & Associates has been applying its knowledge of environmental science and engineering to evaluate and solve problems related to pesticide risk, water quality, environmental compliance, aquatic weed management, and human and ecological health.

Blankinship staff has extensive training and expertise in IPM, plant science, water quality, environmental toxicology, chemistry, biology, and environmental planning and includes a licensed professional engineer, a Pest Control Adviser (PCA), a Certified Crop Adviser (CCA), and Qualified Applicator License (QAL) holder. Mike Blankinship has prepared or reviewed multiple IPM plans ranging from linear rail and irrigation infrastructure projects to golf courses. His firm is actively involved with the California Association of Pest Control Advisers (CAPCA), California Weed Science Society (CWSS), Pesticide Applicators Professional Association (PAPA), and California Invasive Plant Council (Cal-IPC).

Blankinship staff regularly attends and speaks at professional meetings that address vegetation management and pesticide risk. These meetings are held by various organizations including the Farm Bureau, the Aquatic Plant Management Society (APMS), CWSS, and the UC Davis Aquatic Weed School. Through these meetings, they keep abreast of new and innovative IPM techniques.



2. Scope, Breadth, and Program Review Process

An evaluation of the District’s IPM program was completed by considering factors such as typical pests, product cost and efficacy, application sites and surrounding habitats, available resources, treatment efficacy, human health and safety, and environmental impacts.

The District’s IPM Program was evaluated in four ways:

First, a meeting was held with District IPM staff to explain the project and introduce the concept of a questionnaire and gather feedback on example questions. The questionnaire was then revised and distributed to each of the five District work units. The table below summarizes the groups and the number of respondents:

Work Unit # Respondents % of Total

Aqueduct (AQD) 4 11

Facilities Maintenance (FAC) 13 37

Mokelumne Watershed (MKW) 6 17

Pardee-Camanche Recreation Unit (PAR) 8 23

Watershed East Bay (WEB) 4 11

Total: 35

Survey participants included 11 Gardeners, 9 Ranger/Naturalists, 5 Ranger Supervisors, 4 Maintenance Supervisors, 2 Gardener Foremen, 2 Maintenance Specialists, 1 Superintendent, and 1 Manager of Watershed and Recreation. Survey respondents answered 40 questions related to IPM such as staff training and certification, pest identification, target pests, threshold levels, treatment methods, recordkeeping, etc.

Second, between one and three interviews with each work unit was conducted to gain further insight to survey responses and gather additional information. Seven interviews consisting of a total of 14 individuals were conducted.

Third, two separate pesticide applications were observed to evaluate methodology and approach.

Information from the aforementioned three steps was used to provide an overview of District’s IPM program and to provide both practice and policy recommendations for elements to consider in a formal IPM District policy.

Fourth, IPM policy and practice documents from other agencies that are similar to the District were surveyed, compiled, and compared to information gathered in steps 1 through 3.

Details of each of these steps is presented below.

3. Summary of IPM Survey, Interviews, and Observations

A summary of survey and interview findings pertaining to various aspects of IPM is provided below.



3.1. Pest Control Objectives

Most survey respondents describe their management sites as open space, facility, recreational, right-of-way, or rangeland. In general, work unit objectives for pest control are as follows, in descending order of importance: fire hazard reduction, employee and public safety, infrastructure maintenance, regulatory drivers, aesthetics, threatened and endangered species, habitat management, and flood control. For all work units, compliance with local and state fire code(s) are a a primary objective for pest control. The 2016 California Fire Code is based on the 2015 International Fire Code published by the International Code Council and described in 24 CCR Part 9 (2017). Information on fire hazard severity zones in California is available on the California Department of Forestry and Fire Protection (2017) webpage: http://www.fire.ca.gov/fire_prevention/fire_prevention_wildland_zones_maps.

The priority of individual pest control objectives varies by work unit and appear to be infrequently memorialized; however, the Mokelumne Watershed Master Plan (EBMUD, 2008) utilized by the MKW and PAR work units has a comprehensive list of Mokelumne Watershed land use management goals, strategies, and objectives which is accessible to all work unit staff and the public.

3.2. Pest Identification

Commonly identified plant pests include: star thistle, French broom, stinkwort, Scotch broom, medusahead, and artichoke thistle. When conducting pest control for fire hazard reduction, identification of specific species of plant pests is limited. In some instances, a Pest Control Adviser (PCA) visits a site to aid in plant pest identification or advise staff based on photos of the plant pest in question. Work units obtain limited guidance on plant pest identification from the University of California Cooperative Extension (UCCE), local University of California Statewide Integrated Pest Management Program (UC IPM) seminars, or seminars hosted by the Pesticide Applicators Professional Association (PAPA) or the California Association of Pest Control Advisers (CAPCA).

Because staff do not do IPM fulltime and have multiple other duties, scouting activity often takes place during completion of these other duties. Some staff report scouting for plant pests weekly or more in the course of their work, although it is unclear whether this frequency reflects scouting done at each site or encompasses all scouting events. Others report scouting on a monthly or quarterly basis, or on a seasonal basis based on the target pest.

Tracking and recording of plant pests is done on a limited basis and only within some work units. Many staff rely on observation, site familiarity, historical knowledge of site conditions, and verbal communication with other staff to keep abreast of new or existing pest populations. No centralized repository for tracking data exists. When data is recorded, personal notebooks or electronic tablets are sometimes used. For example, field notes are used to create maps to track the size and location of plant pests in MKW and PAR work units.

3.3. Pest Thresholds

Commonly, pest plant height exceeding approximately 3 inches is the threshold for fire hazard reduction per Fire Marshal or local fire department requirements (Contra Costa County Fire Protection District, 2017). Other work unit action thresholds are not typically established or necessarily well defined. For example, aesthetics is often a criterion that is used, but is not

http://www.fire.ca.gov/fire_prevention/fire_prevention_wildland_zones_maps



uniformly defined. Often plant pest thresholds are based on weed size and is influenced by factors such as the nature and topography of the site, proximity to structures or roadways, and life cycle stage. In some work units, citizen complaints may also prompt control actions.

3.4. Pest Management Strategies

Vegetation is the primary target of pest control and is largely managed by District staff. Contract grazing by tenant cattle ranchers is also an important plant management tactic. Vertebrate pests are commonly controlled by outside contractors. As needed, insect pests are treated with pyrethrin aerosol sprays or bait stations by District staff. Work unit supervisors typically determine when cultural control (e.g., grazing) will be undertaken to control plant pests. Most District staff make independent decisions on pesticide use timing and locations. To varying degrees, mechanical vegetation control is implemented across all work units. Work units often make an effort to incorporate mechanical control with chemical control, while the applicability of biological control methods is largely dependent on site characteristics such as fencing and sloping.

Consistent with the highly variable nature of the District’s properties and the staff assigned to manage them, understandably, there is a large person-to-person variation in control method selection (e.g., mechanical control versus chemical control) and rationale (e.g., erosion control, pest reduction versus eradication, treatment to open space versus fence lines). Further, variation exists in the selection and use of post-emergent herbicides like glyphosate and its integration, if any, with pre-emergent herbicides like Ronstar Flo. Generally speaking, selection of pest control techniques for most staff is influenced by consideration of potential impacts to non-target organisms and appropriate timing to maximize treatment effectiveness. Other factors, such as wind speed and proximity to aquatic features, are also considered in order to prevent spray drift and protect water quality. A combination of control techniques is employed to meet pest control objectives in most examples discussed during interviews. Often, the pest life cycle, availability of staff to conduct control activities, and time of the season necessitates implementation of more than one control method (e.g., pre-emergent herbicide and mowing) to meet control objectives. Interestingly, no interviewees brought the issue of cost as a determining factor in selection of control methodology.

District wildlife biologists are available for consultation at any time during the pest management process. Presence of special status species or their habitat varies widely among District properties. While not consistently utilized by all work units, wildlife biologists are contacted by some work units prior to events such as ground disturbing activities, tree removal, and pest control activities in riparian areas or areas located near water bodies. Citizen complaints regarding vertebrate pests such as coyotes may also prompt biologist consultation.

Pest control through grazing is based on the personal judgement of work unit supervisors and coordination with livestock operators or UCCE specialists. District biologists also report reviewing annual grazing plans for Watershed work units. Some work units implement cultural control methods by encouraging native grasses to out-compete non-native or non-desirable plants and by utilizing mulch and woodchips to control pest plant populations in plant beds. Mechanical control methods consist primarily of brush cutting, mowing, sawing, weed whacking, and pruning. Prescribed burns are used by some work units. While non-chemical control is often preferred to chemical control, there is general staff agreement that relying entirely on non-chemical pest control is not always feasible for meeting pest control objectives due primarily to limited staff.



There is an informal decision-making process for pesticide product selection. A primary driver for product selection is a “Caution” signal word or lower (i.e., no signal word) for most applicators, although it is not a District requirement. Certain products meeting this criterion are often favored based on the experience of District colleagues. Interactions with the public may also influence product selection. For example, the AQD work unit offers a mailing list for residents who wish to receive a summary of products that may be used in the following year. For products not previously used, test plots are often constructed to determine the efficacy of the proposed treatment.

Herbicides most commonly used by District staff include glyphosate, triclopyr, aminopyralid, and oxadiazinon, and are applied via mechanically pressurized spray, boom, or backpack depending on the size of the intended treatment area. Variations exist in the frequency and extent of equipment calibration. All work units obtain a label, Safety Data Sheet (SDS), and written PCA recommendation for each product used. Because the PCA typically does not make site visits, the PCA recommendations provide only general guidance rather than site-specific guidance. Most communication with PCAs occurs by way of phone or email.

In some publicly accessible areas, no herbicides are sprayed based on requests from and agreements with adjacent property owners. Such agreements include the requirement that the property owners maintain that area of District property. The locations of these areas may be kept in written form, discussed internally, or simply committed to memory.

To protect water quality, buffer zones are established around filter beds, sedimentation basins, and surface water for terrestrial pesticide applications. The District holds a National Pollutant Discharge Elimination System (NPDES) permit for aquatic pesticide applications to Waters of the U.S. Applicators observe limitations on wind speed and other environmental and weather conditions in an effort to reduce the potential for adverse impacts to non-target organisms. Pesticide mixing and storage occur in areas where spillage can be easily contained if needed. In the FAC work unit, applicators also carry an emergency spill decision tree and relevant emergency contact information in the event of an incident.

3.5. Monitoring

Post-application efficacy monitoring is infrequently recorded and based primarily on memory. It commonly occurs via drive-by inspection or visual scan when staff return to the treatment site to perform other job duties. Some work units create maps of certain plant pest populations to evaluate the previous year’s treatment success. When monitoring reveals that treatment was not efficacious, other control methods are considered. Such changes are discussed verbally within the work unit and are not typically recorded.

3.6. Recordkeeping and Reporting

Recorded details on specific locations of herbicide applications and their efficacy are inconsistent, but pesticide use reporting is generally compliant with County Agricultural Commissioner (CAC) Pesticide Use Report (PUR) requirements. Several District staff use tools such as daily application logbooks to record information on the products and quantities applied. In some instances, staff members were unsure of the reporting requirements for certain products (i.e., store-bought pesticides) or of the most appropriate method for reporting specific formulations (i.e., aerosol sprays). Note that public agencies must report all pesticide use, including general use pesticides, to local CACs per 3 CCR § 6627 (2009). Notebooks are used



by some staff to record weather conditions; however, notes on target pest, other treatment methods considered or previously attempted, and treatment efficacy are generally not recorded.

The decision-making process or criteria for selection of pest control methods is not recorded. While most individuals have a sense for which pests occur in their assigned management areas, there are often no maps or written records about pest identity, tolerance thresholds and location. The MKW work unit, however, works with UCCE to track plant pests. Similarly, pest maps illustrating post-treatment efficacy are used by some work units to track problem pests from year to year. Although the pest control decision-making process is not recorded, staff are generally aware of certain areas that consistently receive specific types of treatment (e.g., grazing, mowing, pre-emergent applications, post-emergent applications). Pesticide inventory management in the FAC work unit is premised largely on the ability to purchase product on an as-needed basis which prevents accumulation and the need to store unused materials.

The location of pesticide applications as reported to local CACs on monthly PURs only requires a general description of the location of use. The exact location of pesticide use and the locations and estimated acreage of other non-pesticide treatment methods are not always recorded. To address this, some work units map or log areas receiving pest control, including non-pesticide treatments, to aid in evaluating treatment success and train new employees. Several work units expressed a willingness to engage in more recordkeeping responsibilities, provided that a standardized, streamlined reporting process is established.

3.7. Training

Most survey respondents report having over 10 years of experience in pest control and recent training in pesticide usage and handling. About half of the respondents currently hold Department of Pesticide Regulation (DPR) Qualified Applicator Certificates (QACs) in the landscape or right-of-way categories. Although not required for non-restricted use pesticides by regulation, QAC certification is often required or encouraged within individual work units regardless of the pesticide being applied. Some District staff are also certified arborists. Staff with the QAC credentials appear to rely primarily on PAPA or CAPCA seminars to satisfy their continuing education requirements and keep abreast of relevant pest control topics. Pesticide vendor PCAs host annual laws and regulations training.

District wildlife biologists also hold annual threatened and endangered species training for all work units. Species maps are provided and specific situations warranting biologist consultation are discussed. Other types of training are emphasized within work units based on supervisor recommendations or utilization of certain pest control techniques (e.g., firefighting, mechanical control, weed identification). For new employees, a product labels and recommendations overview training is provided by some work units. Individuals without proper training are not permitted to make pesticide applications.

3.8. Pesticide Application Observations

Blankinship staff met with District staff in Walnut Creek from the AQD work unit on October 31 and the FAC unit on November 17. After touring the AQD pesticide storage area, reviewing label and SDS binders, and PCA recommendations, the District applicator made a demonstration application using water to the storage yard to simulate a right-of-way application of a pre- or post-emergent herbicide to an aqueduct access road. A handgun application to represent a bare-ground pre-emergent herbicide application was also made. The pesticide



storage area had appropriate signage, was clean, well-organized and had a secondary containment system in case of accidental spills, leaks, or container failure. No equipment calibration was observed.

During the applications observed at the Walnut Creek Water Treatment Plant, FAC staff was conducting trial applications of a new pre-emergent herbicide (Specticle Flo) at two rates alongside an application of the routinely used product (Ronstar Flo) at its standard application rate. District staff measured and marked off 1,000 square foot areas for the trial. Applications were made with a handgun from a spray truck and with a backpack sprayer. Applicators were aware of environmental conditions, and changed spray directions when necessary due to shifts in wind direction. No equipment calibration was observed.

In both applications, labels and SDSs were available for all products observed and PCA recommendations were on hand for all products currently being applied. Tank sprayers and service containers were properly labeled, and good housekeeping practices were evident during mixing, loading, and cleanup. Applicators wore appropriate PPE, were familiar with labels, PCA recommendations and the environmental conditions that would influence the application (e.g., soil moisture and wind). The pesticide handling, application and storage practices observed were consistent with the standard of care in the industry and it appears that District pesticide applicators have received sufficient training and on-the-job experience.

4. Comparison of District IPM Practices with Those of Similar Agencies

District IPM practices were compared to similar agencies and presented in Appendix A. These agencies include:

• City of San Francisco (2011, 2016);

• East Bay Regional Park District (1987, 2017); and

• Midpeninsula Regional Open Space District (2014a, 2014b, 2014c). While the District generally practices IPM in a manner similar to the agencies above, additional program recommendations are provided in Section 7 as potential measures for the District to consider when updating its IPM program.

5. IPM Policy Recommendations

IPM policy goals of similar agencies were compiled for District review and consideration. These agencies include:

• California Invasive Plant Council (2008);

• UC IPM Program (2017);

• City of Boulder (2002);

• City of San Francisco (2011);

• Contra Costa County (2012);



• East Bay Regional Park District (1987); and

• Midpeninsula Regional Open Space District (2014a).

Additional policy statement examples are provided in Appendix A. Furthermore, we suggest creating a policy that is generally consistent with widely the accepted UC IPM (2017) definition:

IPM is an ecosystem-based strategy that focuses on long-term prevention of

pests or their damage through a combination of techniques such as biological

control, habitat manipulation, modification of cultural practices, and use of

resistant varieties. Pesticides are used only after monitoring indicates they are

needed according to established guidelines, and treatments are made with the

goal of removing only the target organism. Pest control materials are selected

and applied in a manner that minimizes risks to human health, beneficial and

nontarget organisms, and the environment.

While the District generally practices IPM in a manner similar to the agencies above, additional program recommendations are provided in Section 7 as potential measures for the District to consider when updating its IPM policy.

6. Resource Needs Assessment

A preliminary assessment of resources used to manage pests using pesticide and non-pesticide control methods was conducted based on the results of the IPM survey. Survey respondents were asked to estimate the hours per week of manpower and acres treated per week for each control category (i.e., pesticide and non-pesticide controls) throughout the year. Respondents were asked to select a range of hours (i.e., 0-10 hours/week, 10-20 hours/week, 20-30 hours/week, 30-40 hours/week) spent, and corresponding range of acres treated (i.e., 0-25 acres/week, 25-50 acres/week, >50 acres/week) per control category per season.

For each work unit, season, and control category, the hours per week of manpower and acres treated per week were determined by taking the median value of the hour and acreage ranges selected by the largest percentage of work unit respondents. For example, if most work unit respondents reported spending 0-10 hours per week to treat 0-25 acres per week using pesticide control methods, a median value of 5 hours per week and 13 acres per week was selected for the analysis. A normalized effort per season per control category was calculated by dividing the number of hours spent by the number of acres treated. The seasonal normalized efforts were then added to calculate the normalized effort per year per control category.

Initial interpretation of this data suggests that for AQD and FAC, the use of pesticides as part of the IPM program is more efficient as measured on an hours/acre basis compared to non-pesticide techniques. For MKW, PAR and WEB, this data suggests that the amount effort is the same for both pesticide and non-pesticide techniques. Note, however, that staff interviews sometimes didn’t corroborate information provided in the IPM survey responses. For example, in some cases staff indicated that pesticide use was nominal and that mechanical methods were more commonly employed. Specifically, several staff indicated that they only spray herbicides in areas where they cannot mow. Furthermore, sites managed by work units such as FAC are often smaller and more topographically challenging to address than sites managed by other



work units. Flatter, larger areas can be mowed with larger mowing equipment, reducing time spent per acre.

Although data on hours spent was estimated, this may not be a true reflection of total overall cost for plant pest treatment. Further, the quantity and cost of materials used was not obtained. Later phases of this resource needs assessment may include incorporating details such as equipment capital costs and depreciation, materials cost, worker’s compensation claims, permits, and training.

7. Conclusions and Program Recommendations

Information provided in the IPM survey and follow-up interviews, as well as the comparison of District IPM practices versus those of similar agencies, suggest that the District’s IPM program shares many similarities to other programs in Northern California. District staff are knowledgeable about a wide array of pest management concepts and implement IPM while also considering limitations on time, funding, and staff availability and sensitive resources in proximity to pest plants. Observation of pesticide applications and demonstrations suggest that applications occur in compliance with relevant state and federal regulations, and pesticide safety and good housekeeping measures are implemented.

While a strong foundation of trained and experienced staff supports a functional IPM program, we recommend that the District consider the following suggested areas of improvement. In all cases, implementation of these recommendations should be scaled to the specific needs and resources of individual work units:

1. Enhance training

➢ Recommendation 1: Standardize training for all staff with pest management responsibilities. An annual training event should include the following: topics such as basic steps and practices of IPM, the District’s current IPM standards described in the Environmental Compliance Manual, laws and regulations, public communication and outreach, equipment calibration, chemical modes of action, interpreting product labels, recordkeeping requirements, worker protection, and other IPM-related Best Management Practices (BMPs). The training could be used to obtain DPR continuing education credits for QAC holders and satisfy the required annual pesticide handler training, pursuant to 3 CCR § 6724 (2017). Concurrent sessions could be offered so that staff can pick area(s) of interest or weakness and attend those sessions. Work units may also benefit from an open forum portion of the training where each can share with other work units information on treatment efficacy of new products or control methods, proposed treatment strategies for the following year, new and emerging pest problems, and BMPs for preventing impacts to non-target organisms.

➢ Benefit: By creating more uniformity in training requirements, work units with unique priorities and protocols are joined by common goals and approaches to manage pests in a way maximize efficacy and compliance and minimizes risks to non-target organisms and the environment. Such training also aids staff in making informed pest control decisions. Dialogue between units sharing experimental, effective, or ineffective control strategies for problem pests will help



work units learn from each other and may lead to new pest control strategies. Last, staff will gain tools to help communicate principals of IPM when they interact with members of the public.

2. Enhance communication with pest control contractors (e.g., PCAs, pesticide suppliers, pest control operators), District biologists, and the public

➢ Recommendation 2: Require that PCAs make site visits and interview staff familiar with the pest prior to preparation of a written recommendation. Have the PCA attend the annual IPM training described in Recommendation 1. For pesticides commonly used in a tank mix, request a written recommendation for the mix in addition to recommendations for the individual products. Have PCAs present alternative control approaches, discuss timing and application rate, equipment, etc. When selecting or considering using new pesticides at District facilities, obtain a new PCA recommendation that evaluates potential efficacy, non-target effects, public health and safety concerns, resource availability, potential impacts to water resources and wildlife, and tendency to move or persist in the environment. District staff or its licensed pest control contractors must obtain a product label, SDS, and written PCA recommendation prior to any pesticide application.

➢ Recommendation 3: To enhance knowledge of and protect sensitive species, involve District biologists in pest management. Work units are encouraged to create a project planning timeline to help keep biologists up-to-date on upcoming and ongoing projects. Biologists may also wish to provide staff with a list of known and potential threatened and endangered species/habitats in each work unit and a decision tree or flow chart including guidelines on when to contact biologists for consultation, resources to check for information, and responsible parties. Online resources such as DPR’s (2017b) Pesticide Regulation's Endangered Species Custom Realtime Internet Bulletin Engine (PRESCRIBE), the California Department of Fish and Wildlife’s (2017) California Natural Diversity Database (CNDDB), and the U.S. Environmental Protection Agency webpage (USEPA, 2017) are also available for information on threatened and endangered species, including local occurrences and protective measures.

➢ Recommendation 4: Improve communication with the public by providing resources that help them understand the District’s IPM program. Consider publicizing the IPM program by putting it on the District website to share the District’s pest management goals, achievements, and current challenges. Prepare a one-page handout that describes the District’s IPM policy and procedures and give this to all applicators so that they can give it to members of the public as needed. At areas where neighbors have expressed concern or sensitivity to pesticide applications, consider sending mailers to adjacent property owners with a short summary of the District’s IPM approach and the role that pesticides play, and who to contact for more information.

➢ Benefit: Engaging in a more communicative approach to pest control can help reassure staff and the public that the District has a thorough understanding of its pest problems and is taking appropriate actions to manage pests in a responsible



manner. On-site consultations with PCAs will help in proper pest identification and will refine appropriate timing and product selection and use. Consultation with District biologists plays a role in proactively reducing potential impacts to non-target organisms. Improving communication with the public can help educate them about IPM and the role that pesticides play. Education and information may also help enhance the public’s understanding of, and tolerance for, a particular pest or control activity.

3. Create recordkeeping consistency

➢ Recommendation 5: Maintain a list of known and identified pests in each management area. Include for each pest information on its location(s), life cycle, action thresholds, and approved treatment methods. Note that action thresholds may need to be tailored to address specific pest control objectives (e.g., fire hazard reduction, aesthetics) or site features (e.g., rights-of-way, open space, proximity to facilities or riparian habitat). Records of the pest population density and geographic distribution may aid in prioritizing pest control activities. When applicable, record relevant pest prevention mechanisms (e.g., vehicle wash-off when leaving sites hosting problem weeds, implement techniques to allow native grasses to out-compete the weed).

➢ Recommendation 6: Document decision-making criteria for IPM program implementation. Refer to Appendix B for an example flow chart/decision tree. Phase in selection criteria for difference pest control techniques (e.g., biological, mechanical, chemical). Keep records of IPM activity and neighbor complaints and document areas where pesticides are not typically applied or requests have been made that residents are notified prior to applications. Refer to Appendix C for an example of an IPM activity log. When hiring pest control contractors, consider including language in contract specifications that requires the contractors to read and follow the District’s IPM program.

➢ Recommendation 7: When using pesticides, only use pesticides that are registered by the USEPA and DPR. Do not use household products as pesticides. For example, household vinegar contains approximately 5% acetic acid and is not recommended for use as an herbicide for a number of reasons. Household vinegar is not registered as a pesticide by either USEPA or DPR and does not have a pesticide product label. Due to the lack of a label, the use rate, application type and frequency, PPE and efficacy is not known. A PCA recommendation cannot be prepared for a product without a label. Alternatively, there are several registered pesticides that have the acetic acid as the active ingredient (e.g., Vinagreen, Weed Pharm, Nature’s Wisdom 20% Vinegar Herbicide). Upon receipt of a PCA recommendation, review of the label by a QAC and those that work under the QAC, and use of appropriate PPE, such products can be used.

➢ Recommendation 8: Pesticide application details and IPM activity should be recorded on standardized forms for each work unit. Refer to Appendix C for an example of an IPM activity log. In addition to the information required for monthly PURs, details of site conditions like weather, soil saturation, wind, and



temperature, and application notes on rate, coverage, speed, target pest(s), target size and density, etc. at the time of application can be recorded. Results of follow-up monitoring after treatment and evaluation of application efficacy should also be documented. At minimum, all equipment should be calibrated in accordance with manufacturer specifications or as often as needed to maintain consistent output rates and coverage. For example, calibration may be necessary when there are changes in tubing, valves, nozzles, or other related parameters occur, or when equipment performance degrades.

➢ Recommendation 9: Establish a streamlined reporting process for logging and archiving pest management activities and efficacy, including pesticide and non-pesticide data. Use activity logs like the one presented in Appendix C. Consider adopting an electronic database system to easily store, view, and analyze data. In addition, the use of structured PDF forms which prompt staff to input specific pest management-related information should be considered. Such forms can be made interactive for rapid import to an electronic database or spreadsheet application and may be developed for tasks such as scouting, pest treatment, and efficacy evaluation. If compatible with existing systems, the use of mobile devices such as iPads or Microsoft Surface Pros to log data should be considered.

➢ Recommendation 10: Document the system used to evaluate the effectiveness of the IPM program. This can be done on the District- or work unit-level and may include tracking of hours spent on planning and control activity, acreage treated/grazed/mowed/etc., efficacy of the control activity, and material and/or labor costs for each pest control method employed. The amount of pesticides applied may vary from year to year based on any number of factors such as resources available, weather, type of pests, extent of infestations, product type (e.g., concentrations, application rates), and changes in target concentration or treatment site. Therefore, sole reliance on metrics such as gallons of pesticide use per acre is not recommended as tool to measure IPM success. Alternatively, evaluate more integrated metrics such as acres managed and resources spent. Modify the IPM program as needed in response to factors such as changes in pests, the environment, and policy. Share areas of success, failure, and challenges faced along the way with District staff.

➢ Benefit: Supplemental recordkeeping can help educate applicators, other District staff, and the public about when and why specific pest control methods are used, and can help pest management staff make more informed decisions in the future. It also gives program managers and staff a way to more thoroughly evaluate and update their IPM programs, review efficacy of control activity, document their responsible approach to pest control, and train new staff. By developing streamlined forms for recording data, the District can achieve greater consistency in the content and quality of pest control information that will inform future work.

4. Standardize, to the extent feasible, pest control personnel qualifications, decisions, and activities



➢ Recommendation 11: Implement a District-wide standard that anyone making a pesticide application on District property is a District employee or contractor and is a QAC or supervised by a QAC, in accordance with current State regulations. All non-QAC staff should receive annual pesticide handler training pursuant to 3 CCR § 6724 (2017) and be knowledgeable about new and existing laws and regulations related to pest control.

➢ Recommendation 12: Develop a written set of District-level Standard Operating Procedures or guidance documents that incorporate control technique selection flow charts or decision trees and outlines pros and cons of various pest control strategies as well as protocols for activities such as calibration, grazing, and reporting. Work unit-specific details can be added as needed. Keep track of suggested modifications to the program and consider incorporating them into an updated guidance document.

➢ Benefit: The knowledge gained from getting and maintaining the QAC credential allows staff to make informed decisions about pest control and keep abreast of new laws and regulations. Further, because the QAC is more knowledgeable, he/she is more able to communicate IPM techniques the public. Last, staff who hold a QAC are more informed on mixing/loading/applying pesticides and are less prone to making mistakes, and as a result are acting in a loss prevention capacity. Implementation of a pest management protocol provides District-wide consistency for the IPM program and will assist in training of new staff and enhance the sharing of institutional knowledge. Regular review of the District’s IPM policy and practices demonstrates responsiveness to staff and public concerns, changes in pests or the environment, and changes in pest control practices.

The tasks outlined above should be prioritized, effort scaled according to need and resources and refined as needed to fit the District’s IPM Program goals, and implemented with a schedule that allows for continued enhancement of the program while not interfering with District activities.

8. Additional Resources

To learn more about IPM or developing IPM programs, refer to the resources below:

• California Invasive Plant Council (Cal-IPC) Best Management Practices (BMPs) for Wildland Stewardship: http://www.cal-ipc.org/docs/bmps/dd9jwo1ml8vttq9527zjhek99qr/BMPHerbicide.pdf

• University of California Cooperative Extension (UCCE) Establishing Integrated Pest Management Policies and Programs: A Guide for Public Agencies: http://anrcatalog.ucanr.edu/pdf/8093.pdf

• University of California Statewide Integrated Pest Management Program (UC IPM) website: http://ipm.ucanr.edu/

• California Department of Pesticide Regulation (DPR) Model Program School IPM Guidebook 3rd Edition: http://apps.cdpr.ca.gov/schoolipm/managing_pests/guidebook.cfm

http://www.cal-ipc.org/docs/bmps/dd9jwo1ml8vttq9527zjhek99qr/BMPHerbicide.pdf

http://www.cal-ipc.org/docs/bmps/dd9jwo1ml8vttq9527zjhek99qr/BMPHerbicide.pdf

http://anrcatalog.ucanr.edu/pdf/8093.pdf

http://ipm.ucanr.edu/



• U.S. Environmental Protection Agency (USEPA) website: https://www.epa.gov/managing-pests-schools

• Association of Applied IPM Ecologists (AAIE) website: http://www.aaie.net/

• California Weed Science Society (CWSS) website: http://www.cwss.org/

• California Association of Pest Control Advisers (CAPCA) website: https://capca.com/

• Pesticide Applicators Professional Association (PAPA) website: https://www.papacalifornia.com/

http://www.aaie.net/

http://www.cwss.org/

https://capca.com/



9. References

2016 California Fire Code, 24 CCR Part 9 (2017).

California Department of Fish and Wildlife (CDFW). 2017. CNDDB Maps and Data. Retrieved from: https://www.wildlife.ca.gov/data/cnddb/maps-and-data (Accessed: December 8, 2017).

California Department of Forestry and Fire Protection (Cal Fire). 2017. California Fire Hazard Severity Zone Map Update Project. Retrieved from: http://www.fire.ca.gov/fire_prevention/fire_prevention_wildland_zones_maps (Accessed: December 19, 2017).

California Department of Pesticide Regulation (DPR). 2017a. Pesticide Safety Train-the-Trainer Programs for those Working in the Production of an Agricultural Plant Commodity. Retrieved from: http://www.cdpr.ca.gov/docs/license/trainers.htm (Accessed: December 19, 2017).

California Department of Pesticide Regulation (DPR). 2017b. PRESCRIBE Online Database Application. Retrieved from: http://www.cdpr.ca.gov/docs/endspec/prescint.htm (Accessed: December 8, 2017).

California Invasive Plant Council (Cal-IPC). 2008. Cal-IPC Policy on Integrated Weed Management (IWM). Retrieved from: http://www.cal-ipc.org/wp-content/uploads/2017/10/Cal-IPC-Policy-on-IWM.pdf (Accessed: December 1, 2017).

City of Boulder. 2002. Integrated Pest Management Policy. Retrieved from: https://www-static.bouldercolorado.gov/docs/ipm-policy-1-201305221037.pdf?_ga=2.184736815.747155746.1510874475-1769531522.1506713037 (Accessed: November 16, 2017).

City of San Francisco. 2011. San Francisco Environment Code, Chapter 3: Integrated Pest Management Program. Retrieved from: http://library.amlegal.com/nxt/gateway.dll/California/environment/chapter3integratedpestmanagementprogram?f=templates&fn=default.htm&3_0=&vid=amlegal%3Asanfrancisco_ca (Accessed: November 16, 2017).

City of San Francisco. 2016. SF Integrated Pest Management (IPM) Program Compliance Checklist for City Properties and Reduced Risk Pesticide List. Retrieved from: https://sfenvironment.org/sites/default/files/fliers/files/sfe_th_ipm_checklist_2016_rrpl_2016-03-14.pdf (Accessed: November 16, 2017).

Contra Costa County. 2012. Contra Costa County Integrated Pest Management Policy. Retrieved from: http://cchealth.org/ipm/committee/pdf/ipm_policy.pdf (Accessed: December 1, 2017).

Contra Costa County Fire Protection District. 2017. Minimum Weed Abatement Standards. Retrieved from: http://www.cccfpd.org/pdfs/WA-2-minimum-standards-17.pdf (Accessed: December 19, 2017).

East Bay Municipal Utility District (EBMUD). 2006. Mokelumne Watershed & Recreation Division Best Management Practice – Integrated Pest Management.

http://www.fire.ca.gov/fire_prevention/fire_prevention_wildland_zones_maps

http://www.cdpr.ca.gov/docs/license/trainers.htm

http://www.cdpr.ca.gov/docs/endspec/prescint.htm

https://www-static.bouldercolorado.gov/docs/ipm-policy-1-201305221037.pdf?_ga=2.184736815.747155746.1510874475-1769531522.1506713037



http://library.amlegal.com/nxt/gateway.dll/California/environment/chapter3integratedpestmanagementprogram?f=templates&fn=default.htm&3_0=&vid=amlegal%253Asanfrancisco_ca

http://library.amlegal.com/nxt/gateway.dll/California/environment/chapter3integratedpestmanagementprogram?f=templates&fn=default.htm&3_0=&vid=amlegal%253Asanfrancisco_ca

https://sfenvironment.org/sites/default/files/fliers/files/sfe_th_ipm_checklist_2016_rrpl_2016-03-14.pdf

https://sfenvironment.org/sites/default/files/fliers/files/sfe_th_ipm_checklist_2016_rrpl_2016-03-14.pdf

http://cchealth.org/ipm/committee/pdf/ipm_policy.pdf

http://www.cccfpd.org/pdfs/WA-2-minimum-standards-17.pdf



East Bay Municipal Utility District (EBMUD). 2008. Mokelumne Watershed Mater Plan. Retrieved from: http://www.ebmud.com/recreation/protecting-natural-habitat/ (Accessed: November 15, 2017).

East Bay Municipal Utility District (EBMUD). 2010. EBMUD Environmental Compliance Manual: Chapter 7.0 Integrated Pest Management. Retrieved from: http://www.ebmud.com/recreation/east-bay/east-bay-watershed-master-plan-update/ (Accessed: December 8, 2017).

East Bay Municipal Utility District (EBMUD). 2016. FMC-East Landscaping Response to IPM Program Information Request 2016.

East Bay Regional Park District. 1987. Pest Management Policies and Practices for East Bay Regional Park District. Retrieved from: http://www.ebparks.org/Assets/_Nav_Categories/Park_Planning/Master+Plan/Policies/Pest%20Management%20Policies%20and%20Practices%20-%20Oct%201987.pdf (Accessed: November 16, 2017).

East Bay Regional Park District. 2017. Annual Integrated Pest Management Report 2016. Retrieved from: http://www.ebparks.org/Assets/files/2016+Annual+Pesticide+Use+Report+-+05-11-2017.pdf (Accessed: November 16, 2017).

Handler Training, 3 CCR § 6724 (2017).

Midpeninsula Regional Open Space District. 2014a. Resource Management Policies. Retrieved from: https://www.openspace.org/sites/default/files/Resource_Management_Policies.pdf (Accessed: November 15, 2017).

Midpeninsula Regional Open Space District. 2014b. Midpeninsula Regional Open Space District Integrated Pest Management Program Guidance Manual. Retrieved from: https://www.openspace.org/sites/default/files/IPM_Guidance_Manual.pdf (Accessed: November 16, 2017).

Midpeninsula Regional Open Space District. 2014c. Midpeninsula Regional Open Space District Integrated Pest Management Program Draft Environmental Impact Report. Retrieved from: https://www.openspace.org/sites/default/files/IPM_EIR.pdf (Accessed: November 16, 2017).

Monthly Summary Pesticide Use Reports, 3 CCR § 6627 (2009).

University of California Agriculture & Natural Resources Statewide Integrated Pest Management Program (UC IPM). 2017. What is Integrated Pest Management (IPM)? Retrieved from: http://www2.ipm.ucanr.edu/WhatIsIPM/ (Accessed: November 15, 2017).

U.S. Environmental Protection Agency (USEPA). 2017. Protecting Endangered Species from Pesticides. Retrieved from: https://www.epa.gov/endangered-species (Accessed: December 8, 2017).

http://www.ebmud.com/recreation/protecting-natural-habitat/

http://www.ebmud.com/recreation/east-bay/east-bay-watershed-master-plan-update/

http://www.ebparks.org/Assets/_Nav_Categories/Park_Planning/Master+Plan/Policies/Pest%2520Management%2520Policies%2520and%2520Practices%2520-%2520Oct%25201987.pdf

http://www.ebparks.org/Assets/_Nav_Categories/Park_Planning/Master+Plan/Policies/Pest%2520Management%2520Policies%2520and%2520Practices%2520-%2520Oct%25201987.pdf

http://www.ebparks.org/Assets/files/2016+Annual+Pesticide+Use+Report+-+05-11-2017.pdf

http://www.ebparks.org/Assets/files/2016+Annual+Pesticide+Use+Report+-+05-11-2017.pdf

https://www.openspace.org/sites/default/files/Resource_Management_Policies.pdf

https://www.openspace.org/sites/default/files/IPM_Guidance_Manual.pdf

https://www.openspace.org/sites/default/files/IPM_EIR.pdf

http://www2.ipm.ucanr.edu/WhatIsIPM/

https://www.epa.gov/endangered-species

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Appendix A Comparison of EBMUD IPM Practices

with Those of Similar Agencies


Appendix A - Comparison of District IPM Practices with Those of Similar Agencies

Comparison of District IPM Practices with Those of Similar Agencies

Organization

City of San Francisco

(2011) Environment Code, Ch 3:

IPM Program

• Set for each pest at each siteand identify in an IPMimplementation plan, aninjury level, based on howmuch biological, aesthetic oreconomic damage the sitecan tolerate

•

•

•

•

•

Consider a range of potential treatments for the pest problem. Employ nonpesticide management tactics first. Consider the use of chemicals only as a last resort and select and use chemicals only within an IPM program and in accordance with the provisions of this Chapter. No pesticides may be used on or applied to property owned by the City and County of San Francisco, except for pesticides granted an exemption under Section 303.Any City department planning to apply pesticides to outdoor areas must first obtain a written recommendation from a person holding a valid Agricultural PCA license issued by DPR. Written recommendations shall be consistent with the IPM plan for the site and state the period for which they are valid.Any City department that performs landscape pesticide applications must do so by or under the supervision of a person holding a valid QAL/QAC certificate under state law.Posting & Notification Requirements


(2016) SF IPM Compliance

Checklist

••

Prevention comes firstIdentify your pests

•••

•

•••

•

••••

Use non-chemical control methods if availablePest-specific "What to Do"/Who to Contact sectionWritten PCA recommendations are required for all landscape and rights-of-way pest control (email to Environmental Specialist if PCA is not a City staff)Use Bay Friendly Landscaping Guidelines which: Are suited to our local climate, soils and topography; Reduce waste and help meet recycling goals; Reduce water use on landscapes by 50% or more; Prevent or reduce storm water pollution to our local creeks and bay; Lower maintenance associated with mowing and shearing; Reduce GHG emissionsOnly use SF Reduced-Risk PesticidesThreatened/Endangered Species - Follow Pesticide Restrictions for Red-Legged Frog HabitatDue to the concern over primary and secondary poisoning, the type of rodenticide and the manner in which it is applied will be determined by the general site characteristics (site-specific table provided with detail on acceptable treatment methods for each)Conditions of Use for "Most Hazardous" Herbicides: General Requirements (treatment areas marked for 4 days post-treatment, indicator dye for sprays, contractor briefing/training on SF IPM ordinance/requirements/policies, supervision of PCA/QAL/QAC), General Prohibitions (buffer zones around public paths/red-legged frog habitat, prohibited application locations), Allowed UsesLink to guidelines for pest prevention in and around buildingsSample contractor and lease languagePosting & Notification Requirements for various situationsPesticide disposal guidelines

Pest ID Thresholds Treatment

Page A-11/4/2018 Blankinship & Associates, Inc.


Organization

East Bay Regional Park District (1987)

Pest Mgmt Policies & Practices

•

•

Identify (recognize and describe) legitimate pest situations & consider biological and social implications."Within [EB Park's] priorities (public and employee health and safety, economic or structural losses and aesthetics) there are 3 main types of pests. These are:..."

•

•

•

How [the public] feels about chemicals and pest damage also has to be considered and balanced against scientific evidence that a pest species may have reached a damaging threshold.Injury Level - Consider damage and action thresholds with District priorities in mind: 1) public and employee health and safety, 2) economic or structural losses, and 3) aesthetics or cosmetics.Action Level - Techniques to determine pest reduction activity is an ongoing effort.

•

••

•

•••

•

••

•

Staff will take into consideration the many interactions between key pests, beneficial insects, potential pest control measures, and other living and non-living factors. A long-term resource management approach will be encouraged.Pest control methods must be the least disruptive and chemical control the least desirable technique.Possible treatment strategies: Human behavior changes, Habitat modification, physical control, plant selection, biological control, chemical controlOnly registered effective materials with the least acute toxicity and potential environmental effects shall be employed. Exceptions may be made with Board approval for pesticides used to control a public health pest for which the benefits outweigh potential risks and no alternatives exist. Potential pesticides should be reviewed for their effects on surface and groundwaters. Only QALs/QACs shall use pesticides on District lands.Any use of chemical controls must be justified and approved (prior to use) by the Park District employee proposing its use. The approved methods must be reviewed (Appendix B) and an IPM Checklist and PUR must be prepared. The only Category I material approved by these policies is copper sulfate for aquatic algae and snail control.Safety & Environmental Concerns/ConsiderationsPosting & Notification - Notices of a chemical application shall be posted prominently by the park supervisor or other responsible individual at locations exterior to the treated area but at sites that typically would be considered entrances to that treated area. (sample in Appendix F)Appendix A - IPM POLICIES AND PRACTICES - DECISION TABLE


Annual IPM Report 2016

•

••

•

•

Site characteristics, biological timing, pest species, environmental considerations, level of desired control and efficacy factors dictate the strategies selected.If a chemical pesticide application is required, the IPM specialist, PCA, provides a prescriptionMechanical and Cultural methods are difficult to quantify but comprise the majority of district vegetation management activitiesMechanical methods used in the district include: propane torching of seedlings, mechanical brush removal (pulling and grubbing), mechanical mowing, line trimmers, scythes and weed whips.Chemical control around critical infrastructure like pumps stations, overflow preventers and fencing is used when it is difficult or excessive to treat with other methods.

Midpeninsula Regional Open Space District

(2014a) Resource

Management Policies: IPM

Section

• Identify the pest, determine its life cycleand disruptive potential, and identifyrelevant site conditions prior toimplementing a pest control activity.

• Develop and implementtolerance levels for pestswithin each of the WorkCategories to determinewhen to undertake pestcontrol.

•

•

Choose site-specific strategies and times of treatment that provide the best combination of protecting preserve resources, human health, and non-target organisms and that are efficient and cost effective in controlling the target pest. Whenever feasible, direct the control method narrowly at vulnerable points in the target organism’s life cycle to avoid broad impacts.Use the least harmful method(s) to control identified pests. Where the use of pesticides is necessary, apply according to the label using all safety precautions and take all measures needed to protect the environment, the health and safety of visitors, employees, neighbors, and the surrounding natural areas including water and soil resources




Organization


(2014a) Resource


Section (Continued)

• Review pest controlobjectives for consistencywith other site goals

••

•

•

•

Plan for repeat treatments as indicated by the pest’s regenerative capabilities.Coordinate and cooperate with adjacent landowners, neighbors, and other responsible agencies to control pests and limit secondary effects.If eradication of a pest from a distinct location is not feasible, apply measures to achieve containment, sustained control, slow down a pest’s rate of spread, or minimize pest damage.Develop specific pest management strategies and priorities that address each of the five work categories.Pest Prevention - Take appropriate actions to prevent the introduction of new pest species to District preserves, especially new invasive plants in natural areas, rangelands, and agricultural properties.


(2014b) IPM Guidance Manual

••

(Pest ID training requirement)(Pests specified in work category-specific pest management programs)

• (Pest tolerance levelsspecified in work category-specific pest managementprograms)

•

••

The District will ensure that all pest control contractors working on District lands comply with the Guidance Manual, including restricting use of pesticides to products on the District’s List of Approved Pesticides(Treatment options specified in work category-specific pest management programs)Posting & Notification Procedures


(2014c) IPM Program EIR:

BMPs & Mitigation Measures

•

•

•

•

•

•

••••

•••

•

All pesticide use shall be implemented consistent with Pest Control Recommendations prepared annually by a licensed PCAAppropriate non-toxic colorants or dyes shall be added to the herbicide mixture to determine treated areas and prevent over-sprayingEstablishment of buffer zones around aquatic features, red-legged frog habitat, nesting birds, special-status plantsApplication of herbicides shall be conducted in accordance with the California Red-Legged Frog InjunctionWhere appropriate, equipment modifications, mowing patterns, and buffer strips shall be incorporated into manual treatment methods to avoid disturbance of grassland wildlifeFor each pest management action under the IPMP, the treatment action (e.g., preventive; retrofit; maintenance; cultural control; habitat modification; and manual, mechanical or chemical control) and treatment timing would be site-specific and based on various factors (i.e., infestation size and density, the life cycle of the pest, the type and sensitivity of the site to be treated, the potential for the presence of special-status species habitat to occur in proximity to the treatment site, and the availability of labor).Pesticide Application Requirements - equipment settings & weather conditionsHerbicide storage, loading, and mixing guidelinesPosting & notification criteriaAll applications shall adhere to label directions for application rates and methods, storage, transportation, mixing, and container disposal.Suitable onsite disposal areas shall be identified to prevent the spread of weed seeds.Erosion Control and Revegetation RequirementsMitigation measures for impacts to special-status amphibians, reptiles, fish, invertebrates, bats, San Francisco dusky-footed woodrat, Santa Cruz kangaroo ratWhen conducting chemical treatments within or with potential to affect waters and with the potential to discharge directly or indirectly to waters of the United States, District must consult with the San Francisco Bay RWQCB which may require the District to submit a Notice of Intent to Discharge, develop an Aquatic Pesticide Application Plan




Organization

EBMUD (2016) FMC-East

Landscaping Response to IPM Program Information

Request

• Primary weed pests for FMC-East areaare mostly broad-leafed invasive speciessuch as Spiny Clotbur, Yellow StarThistle, Purple Star Thistle, Stinkwort,Puncturevine, various Mustard species,Scotch Thistle and re lated thistles,Fennel, Mare's Tail or Horseweed, as wellas some annual grasses. Some PoisonOak is treated when it encroaches onfacility structures or access roads orpathways.

• Action threshold for weedcontrol depends on thenature of the site,topography, weed proximityto structures or roadways,size of the weeds, stage ofweed life-cycle, and thedictates of local fire-suppression regulations.

•

•

•

•

•

•

At many sites we employ mechanical weed control only (weed-whackers and mowers), timed for most efficient control in May and June. When invasive weed species emerge in summer after mechanical control has been completed, a follow-up spot treatment with herbicide may be done to prevent intrusion. Spraying is usually done when new weeds are shorter than 6 inches tall in order to prevent the need to recut weeds. Some weed-prevention spraying may be done in February or March before weeds emerge, in limited areas along driveways or near structures where mechanical removal would be problematic.Evaluation of treatment effectiveness - Short-term evaluation of the effectiveness of spray treatment is ongoing, as the crew goes to each site to do other landscape maintenance tasks. Long-term evaluation of effectiveness is done annually at a staff meeting each fall as the crew discusses specific herbicides used the previous season, problem sites, and plans strategies for weed control for the upcoming season.Non-target Impacts - These effects are not specifically monitored, but care is taken by our applicators to avoid non-targets.PPE - proper personal protective equipment is used by applicators to prevent exposure

EBMUD (2006) Mokelumne

Watershed & Recreation

Division BMPs for IPM

••

•

•

••

•

•

•••

Applicators shall have a PCA recommendation for all herbicide applicationsThe least toxic herbicide that will adequately achieve IPM goals shall be used, taking into consideration the overall risk to the applicator and to the environment.Application of herbicides shall only be conducted during calm weather conditions. Spray will not be allowed to drift outside the target area, and in any case, foliar treatments will not be conducted when wind speeds exceed five miles per hour.All herbicide applications shall be in accordance with existing pest control recommendations and product labeling, including mixing rates and noted hazards and/or restrictions.Establishment of buffer zones around reservoirs or tributary creeksWhen applying herbicide over a large area, the use of a colorant such as Highlight Blue is recommended to better direct and track the application.Posting & Notification - Adjacent landowners are identified and given prior notification of any application of herbicides. If there is likely to be public contact within the area to be sprayed with an herbicide, adequate notification or posting must be providedApplicator safety specifications (change of clothes, emergency wash, medical information, good hygiene) & PPEPesticide storage, disposal, transportation guidelinesWater Protection - Pesticide mixing guidelinesContractor limitations: mark/ID prescribed treatment area within which spray should be confined, supervised storage of products/equipment, presence of QAL/QAC at all times during spray applications, adhere to DPR and Dept. of Agriculture requirements




Organization

EBMUD Environmental

Compliance Manual (2010) IPM Section

•

•

All personnel having pest management responsibilities for pest management shall be trained to accurately identify major pests and the damage that such pests may cause. Field manuals and other resources shall be made available to staff to assist in pest identification, as necessary.Review the history of a site and determine pest conditions.

•

•

District staff shall determine the infestation levels that will be intolerable or that will cause unacceptable damage at different times of the year, during various plant growth stages, and for other situations.Action Threshold Triggers

••

•

•

•

•

•

••

•••

••

No restricted use pesticidesECS staff reviews the use of pesticides on new projects, ensures that the work unit uses the pesticides in an appropriate manner, and that alternatives to chemical applications are used to the extent possible. Pesticides are applied in a 1% solution, and consist primarily of Roundup Pro, Surflan, and smaller amounts of other Class 3 pesticides. Use chemical controls to achieve an acceptable maintenance level for the identified pest, and then to use a combination of chemicals and physical methods to keep the pests under control.If chemical pesticides/herbicides are used, use the least toxic pesticide/herbicide that will adequately achieve IPM goals. Take into consideration overall risk to the applicator and impact to the environment.Physical methods include using brush rakes, chain saws, disking, and in the case of controlling star thistle, actual removal by hand. Use horse, cattle, and occasionally goat grazing as a means of pest control, including the use of draft horses for removing eucalyptus trees. Controlled burns are conducted for both weed control and fire fighting training.Apply pesticides at the appropriate time and under adequate weather conditions to maximize their effectiveness on the target organism and minimize the likelihood of discharging non‐degraded pesticides in storm water runoff.Establishment of buffer zones around water bodies, except for spot treatmentsPesticide mixing, storage, and disposal guidelinesWater Protection & Erosion Control - Select pesticides and application techniques along roadsides that will retain some vegetative cover, if possible.Calibrate field equipment regularly to ensure the desired application rate.Posting & Notification - If there is likely to be public contact within the area to be sprayed with a pesticide, adequate notification or posting must be provided.




Organization


(2011) Environment Code, Ch 3:

IPM Program

•

•

Monitor each pest ecosystem to determine pest population, size, occurrence, and natural enemy population, if present. Identify decisions and practices that could affect pest populations. Keep records of such monitoring.Monitor treatment to evaluate effectiveness. Keep monitoring records and include them in the IPM implementation plan.

•

•

•

••

•

••

•

The Department shall maintain a data bank of information concerning pesticide use by City departments and the efficacy of alternatives used by City departments. Each City department that uses pesticides shall keep records of all pest management activities. Each City department that uses pesticides shall submit the pest management record to the Department on a monthly basis. The Department may reduce the submittal frequency.Pest management records shall be made available to the public upon request.The Department shall maintain on its website an up-to-date list of all exemptions approved by the Department under Section 303. Department-specific IPM implementation plansThe Department shall establish a mechanism for collecting complaints from City residents regarding inappropriate pesticide use on City properties. The Department shall conduct any necessary investigations and respond to the complaints within 30 days of their receipt.Public Education - Inform the public of the City's attempt to reduce pesticide use and respond to questions from the public about the City's pest management practices. The Department shall disseminate public educational information about IPM plans and programs and the City's IPM Policy.

• Acquaint staff with pest biologies, the IPM approach,new pest management strategies as they becomeknown, and toxicology of pesticides proposed for use


(2016) SF IPM Compliance

Checklist

• Monitor the success of your treatments •

•

Enter data monthly to the online Pesticide Use Reporting System (PURS). You can print and send it to the County Agricultural Commissioner Reduced risk pesticides list

••

Annual Pesticide Safety TrainingsMonthly SF IPM Technical Advisory Committee (TAC) meetings to: Help set the City's IPM priorities, Suggest/remove products in the SF Reduced-Risk Pesticide List, Network with City pest control staff, Get trained in the latest IPM practices, Get Continuing Education Units.



• The District's IPM programs and treatments willnot be made according to a predeterminedcalendar schedule, they will be made only whenthis policy manual authorizes pest control andwhen monitoring has indicated that the pest willcause unacceptable safety, health, economic,or functional damage. The use of chemicals forcontrolling pests for solely aesthetic purposeswill not be allowed.

•

••

Treatment strategies will be developed for each identified pest on a Districtwide basis and then incorporated into an overall written pest management program for each parkland.Documentation of pesticide use [by staff or contractors] is a high priorityYearly chemical inventory, mapping and assessment for continued need or maintenance level control of specific pest problems by individual parks can constitute adequate annual documentation and should be viewed as the initial step in that parks preparation of an IPM plan.

•

•

Involved field personnel shall receive: 1. Instructions in the safe use of approved pesticides, herbicides and other alternative, methods of control; 2. Instruction concerning protection of the environment from harmful agents; 3. Instructions for maintaining safe working conditions where pesticides and herbicides are present.Training on the recognition of pest species and management strategies for specific problems will be developed.

Monitoring Record Keeping & Reporting Staff Training



Organization



(Continued)

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Not only must the population size and life stage of key pests and their natural enemies be recorded, but other potential pest populations and their natural enemies may also need to be observed regularly.Monitoring temperature continues to be important in the use of models that correlate temperature with pest population growth. The District should consider developing a day-degree management program for some park units. This management tool can help supervisors prepare in advance for potential pest problems.

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The following guidelines will be used to develop the monitoring and record keeping system: determine the PURPOSE of the monitoring, determine WHICH POPULATIONS are to be sampled, decide on the FREQUENCY of the visits, decide WHICH SITES should be inspected, determine the NUMBER of plants or locations to be sampled at each site, decide upon a PRECISE SAMPLING METHOD, devise a RECORD KEEPING SYSTEM that is easy to use in the field, develop a system of DISPLAYING the field data for ease in decision making, EVALUATE the IPM system, and MAKE CORRECTIONS in the overall process.Prior to implementation of any pest management action authorized by this policy manual, the park supervisor undertaking the pest control action will fill out the IPM Checklist (Appendix D), forward the completed checklist to the District's IPM Specialist as prescribed in the Decision Table (Appendix A) and the instruction memo (Appendix C). In cases where a pesticide is to be used a Pesticide Use Report (PUR) must be completed (Appendix E).Evaluation System - Constant feedback is required to fine tune the IPM Program and relative costs of treatment strategies will be assessed and accounted for in future budgets.The IPM Specialist will prepare annual reports to the Pest Management Advisory Committee and the Ecology CommitteeAppendix B - APPROVED METHODS [site- and pest-specific]Appendix D - IPM CHECKLISTAppendix G - LIST OF APPROVED PESTICIDES

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Field training programs will be emphasizedThe District's IPM program will incorporate the findings of entomologists, plant pathologists, landscape architects, agronomists, wildlife specialists, health specialists, soil scientists, etc. Education and training programs for field park employees must also provide this wide spectrum of information. Every effort will be made to extend this education effort to the park visitor as well.The concepts of and the methods for implementation of the District's adopted IPM Program will be made available to all personnel as needed in future years to keep District employees up to date on new advances and approved practices.A "hands-on" ecological pest management pilot program will be implemented to train park rangers in dealing with the major pest problems in the District


Annual IPM Report 2016

• IPM staff perform site visits to offer:assessment, prescription development andimplementation guidance on a variety of pestmanagement activities and restorative actionsthroughout the District.

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Pest Control Request: IPM staff require park staff to submit a detailed description of the problem, history, and desired objective of pest problemsPesticide Use Report (PUR): Park staff (and their contractors) report all pesticide use to the IPM department; detailing the amount and type of pesticide applied.Annual IPM Report: IPM staff compiles, analyzes and presents in an annual report form a summary of pest management projects, narrative and analysis of mechanical/cultural methods and pesticide use and trends within District parklands.Acreage owned vs acreage treated with herbicidesStatistics on reasons for applications, locations of applicationsHours spent on various pest control methodsDescription of ongoing pest management projectsSummaries of location-specific and pest-specific treatments & current status of control

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Annual Integrated Methods & Safety Training (mandatory): ecology and biology of pests, ecosystem approaches to pest problems and best science updates as it pertains to pest and vegetation management.Sustainable Practices Training (supplemental): training on alternative pest control strategies that focus on mechanical and cultural techniques. These include alternate years of training on vertebrate trapping techniques, developing volunteer programs and Bay Friendly Landscape Maintenance training, among others.




Organization


(2014a) Resource


Section

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Monitor results and modify control methods over time as site conditions and treatment techniques change and as needed to obtain an effective level of control.Monitor pest occurrences and results of control actions and use adaptive management to improve results.

• Develop and implement an IPM Guidance Manual to standardize pestmanagement and IPM procedures across all District Lands.


(2014b) IPM Guidance Manual

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Prepare an Annual IPM Work Plan each year that describes planned pest control projects in the upcoming yearProvide a brief projection of routine minor pest control activities (these are primarily non-chemical methods)Ongoing pest control projects will be summarized in the Annual Work Plan and tracked for staffing, costs, and adaptive management (effectiveness of selected pest control) purposes. Staff will provide a projection of ongoing pest control projects in a spreadsheet or similar format and will specifically note any changes that are to be made to specific ongoing projects in the upcoming year (e.g. change in treatment method, change in level of effort, requirements for periodic pre-treatment surveys).Prepare a description of newly proposed projects and will specifically note how the recommended treatment is consistent with the IPM Guidance Manual, best management practices and mitigation measures.Prepare an Annual IPM Report each year that describes past pest control activities (both chemical and non-chemical) on District LandsKeep records of annual pesticide safety training for 2 yearsAssess the IPM Program Using Adaptive ManagementDevelopment of an IPM Implementation PlanPest management programs for all five work categories describe at minimum: definition and purpose, types of pests, pest ID, prevention, damage assessment, tolerance levels/threshold for action, treatment optionsApproved Pesticides List

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Pest Identification Training Annual Pesticide Safety Training




Organization


(2014c) IPM Program EIR:

BMPs & Mitigation Measures

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A District biologist shall survey all treatment sites prior to work to determine whether any aquatic features are located onsite, determine site conditions, and develop any necessary site-specific measures.On a repeating basis, grassland treatment sites shall be surveyed once every five years and brushy and wooded sites shall be surveyed once every three years. Brush removal on rangelands will require biological surveys before work is conductedSite inspections shall evaluate existing conditions at a given treatment site including the presence, population size, growth stage, and percent cover of target weeds and pests relative to native plant cover and the presence of special-status species and their habitat, or sensitive natural communities.District staff shall monitor IPM activities within two months after treatment (except for routine minor maintenance activities which can be evaluated immediately after treatment) to determine if the target pest or weeds were effectively controlled with minimum effect to the environment and non-target organisms.Prior to the start of the winter storm season, these sites shall be inspected to confirm that erosion control techniques are still effective.Monitoring and treatment considerations for nesting birds

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Table 3-1 identifies treatment actions associated with each management category under the IPMP, and where relevant, method of application, anticipated annual acres of treatment, and type and amount of pesticide used in a typical future year.In order to comprehensively evaluate the potential safety of the selected pesticides, each candidate chemical (active ingredient or product) was reviewed and evaluated for its reported fate and transport in the environment and toxicity to humans and non-target wildlife and vegetation in a detailed toxicological analysisList/descriptions of work category-specific and pest-specific control treatment options & preventative measures

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All staff, contractors, and volunteers shall be properly trained to prevent spreading weeds and pests to other sitesWorker environmental awareness training shall be conducted for all treatment field crews and contractors for special-status species and sensitive natural communities: brief review of life history, field identification, and habitat requirements for each special-status species, their known or probable locations in the vicinity of the treatment site, potential fines for violations, avoidance measures, and necessary actions if special-status species or sensitive natural communities are encountered.All District staff, volunteers or contractors who will implement treatment actions shall receive training from a qualified biologist on the identification of dusky-footed woodrat, Santa Cruz kangaroo rat, and their nests.To avoid impacts to special-status invertebrates from pyrethrin spray, all District staff and contractors using pyrethrin spray will be trained in the identification of problem wasps and special-status invertebrates to ensure that proper species are being targeted.

EBMUD (2016) FMC-East

Landscaping Response to IPM Program Information

Request

• Most East Area reservoir and pumping plantfacilities are inspected by the landscape crewon a monthly or quarterly basis, and decisionsfor action depend on the specific conditions ofeach site.

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There is an official procedure to document a spill if one should occur (spill kits carried in applicator trucks)Training records are held at the FMC Gardener Foreman's office for 3 years

• All staff members working at LandscapeMaintenance East hold QAC issued by DPR. Eachperson must document 20 hours of continuingeducation credits every two years to maintain theircertification. They do so by attending classes held byPAPA or CAPCA.

EBMUD (2006) Mokelumne

Watershed & Recreation

Division BMPs for IPM

• Pesticide training records for each employee shall be kept on file forreview by District and County personnel

• All District herbicide applicators shall have attendedan annual pesticide safety course.




Organization

EBMUD Environmental

Compliance Manual (2010) IPM Section

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A monitoring plan must be devised for detecting intolerable pest infestation levels and determining when to implement control actions.Pest Monitoring Program ObjectivesMonitor success of the pesticide treatment and adjust usage based on monitoring.

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Each work unit develops annual reports summarizing the types, quantities, and locations of pesticide and herbicide usage throughout the District.Written monitoring reports shall be prepared by each of the work units performing IPM activities so that management strategies can be reliably evaluated. All reports shall include date, time, location, observed pest species, and degree of the pest problem.Each work unit shall develop a List of Acceptable Management Strategies for Individual Sites, Types of Sites, and PestsEach work unit is responsible for maintaining written records that include the following information, which should be reviewed and updated annually: list of ID'd pests, description of unacceptable injury levels/action thresholds, list of acceptable management strategiesWritten records shall be kept of observations of the management areaEach District Division or Department that uses pesticides shall produce an Annual PUR: product name, quantity, locations usedWork units shall maintain records of staff that received the [general IPM] training for at least three yearsThe monitoring and observation records for a given management area should be kept for a minimum of five years and filed with the work units conducting IPM.Approved pesticides list

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All personnel having pest management responsibilities for pest management shall be trained to accurately identify major pests and the damage that such pests may cause. Spill response trainingPesticide applicators shall obtain a QAL/QAC or work under the direction of an employee who has obtained the state certification.Pesticide applicators shall be trained annually in general IPM practices, the safe use of pesticides and proper inspection of applicator equipment to prevent accidental pesticide leaks, spills, and potential hazards to applicators and the environment. The work unit shall maintain records of staff that received the training for at least three years. New employees shall not apply pesticides until they have received the appropriate training or until their supervisor confirms that they have skills and knowledge equivalent to the training.



Appendix B Sample EBMUD IPM Decision

Flow Chart


Appendix B – Sample EBMUD IPM Decision Flow Chart

Page B-1 Blankinship & Associates, Inc. 1/4/2018

Sample EBMUD IPM Decision Flow Chart

ASSESS current pests, potential pests, problem areas

SET pest presence threshold

MONITOR for pest presence

DETERMINE management technique and IMPLEMENT

treatment

NO

NO

NO YES

NO

YES

YES

Do you know your pest?

Consult UCCE, PCA, or other knowledgeable

resource

Pest presence threshold

exceeded?

Treatment effective?


Appendix C Sample EBMUD IPM Activity Log


Appendix C - Sample EBMUD IPM Activity Log

Sample EBMUD IPM Activity Log

Name Date Location Vegetation Insect

Pest Presence

(1-5)(B)

Threshold

Criteria(C) No Action Graze MowWeed

EatDisc

Pesticide(D) Other

Area Treated

(Ac)

Mgt Time (Hr)

Date

Pest Presence

(1-5)(E)

John Smith 7/2/2017Lafayette Reservoir

Entrance RdStar Thistle 4 FR, AC X X 1 1 1/2/2018 1

John Smith 7/3/2017San Pablo Reservoir

RestroomsWasps 4 SF X Traps Hung 0.1 3 1/3/2018 3

John Smith 7/4/2017San Pablo Reservoir

Dam FaceX 5 IN X 2 3 1/4/2018 3

Staff Comments:___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Notes:(A). Identify pest(s), if known.(B). Assign score based on type and/or density of pest. Scale is 1 (acceptable) to 5 (unacceptable). Scores >4 require management.(C). Threshold Criteria: FR: Fire IN: Inspection ER: Erosion DR: Drainage AC: Access AS: Aesthetics SF: Safety

(D). Always read and follow label instructions and complete a PUR every month.(E). If inspection indicates threshold exceedence, employ management practices as needed.

Follow-upMonitoringWho/When/Where Pest ID(A) Threshold Management Practice(s) Employed Level of Effort

Page C-11/4/2018 Blankinship & Associates, Inc.

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