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Record Keeping

Emergency Preparedness NPDES Permitting

BMPs for IMMBMPs for IMM

•Mosquito SurveillanceMosquito Surveillance

•MappingMapping

•Action ThresholdsAction Thresholds

•Physical Control or Source Physical Control or Source ReductionReduction

•Biological ControlBiological Control

•Chemical ControlChemical Control

•Monitoring for Monitoring for Efficacy/ResistanceEfficacy/Resistance

•Education and Education and Community OutreachCommunity Outreach

•Record-Record-keeping keeping

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Vector control of rodents or insects when there is a serious health hazard.

Verification of the threat by the Federal Centers for Disease Control is required.

Need for good record-keeping.

www.fema.gov/government/grant/pa/9523_10.shtm

Emergency PreparednessEmergency Preparednessand Mosquito Controland Mosquito Control

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DocumentationDocumentation• Most important thing you can do to

assure reimbursement if monies become available– Overtime– Materials– Equipment

• Equipment and Personnel must match– Truck - 8 hours– Operator - 8 hours

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DOCUMENTS FOR VECTOR CONTROLDOCUMENTS FOR VECTOR CONTROL

Surveillance Data - Current data and past 3 years covering same time period

Operational Data - Including all info that support surveillance and control equipment personnel pesticide

Post Surveillance Data – Desired but not necessary

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Complete your own paperwork and do it immediately

Provide Proof at time of submittal

Document, Document, Document

Include Complaint Info and Larvicide handed out to Citizens

•Information helps show FEMA that the problem is too big for the county or the state to fix

THINGS TO CONSIDERTHINGS TO CONSIDER

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•FEMA will only reimburse for the increased operating cost for mosquito abatement. This is calculated by comparing the disaster related costs to the last three years of expenses for the same period.

•Evidence of higher levels of mosquitoes in the disaster area following the event is needed.

•FEMA will consult with the CDC Division of Vector-Borne Infectious Diseases to evaluate a State's request for assistance under this policy.

•You must be prepared to take action before You must be prepared to take action before reimbursement.reimbursement.

Other Important infoOther Important info

http://www.fema.gov/

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FEMA will only reimburse a portion of the difference in your vector control costs, if they reimburse anything at all

If control is needed, you can not wait for FEMA

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collecting the data

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Mosquito Surveillance Data

current mosquito population datainclude arboviral data

flood event

TRAP SITE

Ps. columbiae

Ps. ciliata

1 3728 14

2 1513 1

3 1649 5

4 928  

5 1876 22

6 2340  

arboviral data - http://oasis.state.ga.us/Arboviral/index_mosquito.asp

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3 Years of Mosquito Surveillance Data

Mosquito surveillance data AND(a) Arboviral information(b) Work orders for mosquito control(c) Labor - Employee hours(d) Equipment use documentation(e) Pesticide use

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POST-SPRAY SURVEILLANCE

Include Identification Data

flood event

control

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Other methods of collecting data

• Landing CountsInformation to Collect:

Collector's NameCountySite DateTimeLocation on Body

For counts of less than one minute, multiply to get landings per minute.

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ask your neighbors

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Emergency Mosquito Surveillance Trailer

EMERGENCY MOSQUITO SURVEILLANCE TRAILER USE PROTOCOLS

http://www.gamosquito.org/mosquitolinks.htm

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CONTROL

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Control Plan

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SUMMARY OF COMPLETED STORM RESPONSE WORK ORDERS

Work Order #Date Location Work Performed Labor Equipment Material Total Cost

4/1/2009 Route 1 Larvicide 04010021 $4,813 $3,636 $6,125 $14,574.004/2/2009 Route 2 Ground 04020022 $6,423.00 $5,236.00 $7,526.00 $19,185.004/2/2009 Route 3 Larvicide 04020030 $2,536.00 $1,526.00 $1,899.00 $5,961.004/3/2009 Route 4 Ground 04030060 $7,125.00 $6,523.00 $9,000.00 $22,648.004/3/2009 Route 5 Ariel 04030061 $5,269.00 $4,624.00 $5,796.00 $15,689.004/4/2009 Route 6 Ground 04040023 $7,200.00 $6,125.00 $3,654.00 $16,797.004/7/2009 Route 7 Ariel 04050065 $8,296.00 $7,695.00 $12,500.00 $28,491.004/7/2009 Route 8 Ground 04050066 $5,263.00 $4,100.00 $4,456.00 $13,819.004/8/2009 Route 9 Larvicide 04050070 $4,562.00 $3,879.00 $2,569.00 $11,010.004/9/2009 Route 10 Ground 04060080 $3,695.00 $3,100.00 $4,521.00 $11,316.00

Labor Equipment Materials TotalTotal Cost for Mosquito Control $55,182.00 $46,444 $53,525 $159,490.00

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WHEN IN DOUBT

• don’t be afraid to ask for help• know your local emergency

management director• talk to mosquito control in

surrounding counties• call the State entomologist

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START NOW

• the best way to be prepared for an emergency is to start now and hope you never need to use what you learn

• come to the Georgia Mosquito Control Association meetings to keep up with new methods of surveillance and control and to meet your peers and industry reps

Public Health Public Health Pesticides and the Pesticides and the Clean Water Act:Clean Water Act:NPDES PermittingNPDES Permitting

Joseph M ConlonJoseph M Conlon

Technical AdvisorTechnical Advisor

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History and Key Dates

• 19721972 Congress Passes Clean Water Congress Passes Clean Water Act (CWA) to restore & maintain Act (CWA) to restore & maintain chemical integrity of “Navigable chemical integrity of “Navigable Waters of the US”Waters of the US”

– Prohibits discharges of any pollutant Prohibits discharges of any pollutant into waters, except under NPDES permit. into waters, except under NPDES permit.

– States may also issue permits if States may also issue permits if authorized by EPAauthorized by EPA

– Ag runoff and irrigation return flow Ag runoff and irrigation return flow exemptexempt

2006 Final Rule and Challenge to Rule

• 11/26/06 - EPA Rule published, stating that the application of a pesticide directly to or over, including near, waters of the United States consistent with all relevant requirements under FIFRA does not require an NPDES permit.

• 12/8/06 – Petitions consolidated in the 6th Circuit.

• 01/07/09 - 6th Circuit vacates the 2006 Rule, stating that the rule was not a reasonable interpretation of the CWA.

• 06/08/09 - 6th Circuit grants EPA’s request and ordered a two-year stay of the mandate until 04/09/11.

• 08/03/09 - 6th Circuit rejects industry’s request for rehearing.

• On 11/03/09 - Industry petitions the Supreme Court for Writ of Certiorari.

EPA NPDES Permits• Individual and generalIndividual and general• Specifies acceptable level of a Specifies acceptable level of a

pollutant in discharge from “point pollutant in discharge from “point source”source”

• Limits on what can be discharged, Limits on what can be discharged, monitoring, and reporting monitoring, and reporting requirementsrequirements

• Requires public comment periodRequires public comment period• Time to Process is 6 months – 1 yearTime to Process is 6 months – 1 year• Permits last up to 5 years maximumPermits last up to 5 years maximum

AMCA 2/22/2010

• "Today, the US Supreme Court has announced that it has denied petitions to review the 6th Circuit Court of Appeals decision to vacate the EPA's ruling exempting mosquito control applications from Clean Water Act permitting requirements attendant to the National Pollutant Discharge Elimination System (NPDES). This means that responsible agencies will be required to abide by NPDES permitting requirements as of 9 April 2011. Be advised that EPA is in the process of drafting a general NPDES permit that will address mosquito control and is slated to publish it for public comment sometime in late April. …”

AMCA 2/22/2010

• …In the meantime, it would behoove all to begin marshaling resources to develop your own best management plans for Integrated Mosquito Management in your districts … and prepare for the eventuality that you will have to adhere to a state NPDES permit.

General Permit – Mosquito ControlGeneral Permit – Mosquito Control

• Monitoring – requiredMonitoring – required– ““visual monitoring” of “application area”visual monitoring” of “application area”– ““enhanced visual monitoring” for some enhanced visual monitoring” for some

applicationsapplications– Frequency and timingFrequency and timing– No ambient water quality testing foreseen – yetNo ambient water quality testing foreseen – yet

• Annual reportingAnnual reporting– Types, amounts, locations, etcTypes, amounts, locations, etc– Online using EPA-templatesOnline using EPA-templates– Accessible by publicAccessible by public

currently, no permit exists

Washington State

• The process is already started• There have already been issues

• http://www.ecy.wa.gov/programs/wq/pesticides/final_pesticide_permits/mosquito/mosquito_index.html

BOTTOM LINE: Without a permit, getting spray into surface water also leaves the spraying entity at risk of third party lawsuit under the federal Clean Water Act.

Additional Information• EPA NPDES Training Website EPA NPDES Training Website

www.epa.gov/npdes/training– click on “NPDES Permit Writers Training” click on “NPDES Permit Writers Training”

– ““Introduction to the NPDES Introduction to the NPDES Program”Program”

– ““Overview of the Clean Water Act Overview of the Clean Water Act and the NPDES Program”and the NPDES Program”

– ““Scope and Regulatory Framework Scope and Regulatory Framework of the NPDES Program”of the NPDES Program”

• AMCA - http://www.mosquito.org

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ANY QUESTIONS?ANY QUESTIONS?