"At the recent AMCA Interim Board Meeting, Joe Conlon was tasked to develop an AMCA policy document on Integrated Mosquito Management (IMM). This document is to be made available to EPA to help guide its deliberations regarding National Pollutant Discharge Elimination System (NPDES) permits. The IMM document is to consist of Best Management Practices (BMP) that, when practiced by mosquito control agencies, will serve to meet water quality standards stipulated by the Clean Water Act. A committee was formed to assist Joe in this process and Joe has solicited input from the committee members that has been incorporated in the draft policy document (attached). EPA wishes to receive our IMM policy draft input no later than December 2 of this year so that it can be fully vetted through the Agency prior to the April 2010 deadline for completion of the draft NPDES permit. This puts an exceedingly short fuse on this project.
The document has been specifically drafted to take into account widely divergent program funding levels and capabilities. Notice that very few, if any, "wills" and "shalls" are in the document as we have preferred the less prescriptive "should" and "to the maximum extent practicable" instead. This leaves a lot of leeway for programs to pick and choose which components of the BMPs to utilize that provide maximum return on investment of resources. You'll also notice that AMCA expects even the smallest control programs to adhere to at least minimal standards to avoid lawsuits and maintain credibility as professionals. Some method of surveillance, however crude, should be utilized in addition to proper calibration and record-keeping. At a minimum, these should be expected of all entities spraying technical grade pesticides into the environment.
AMCA solicits your input to this critical document and needs to receive your comments no later than Friday, November 27 so that changes can be finalized in the document prior to submittal to EPA by 2 December. We are particularly interested in comments from district manager/superintendents, who are most knowledgeable about what will be acceptable and actionable in their operations and who will be directly affected if EPA "gets it wrong".
In particular, please comment on the advisability of including verbiage to the effect that programs should draft an IMM plan of their own that states how they will comply with the BMPs. I have put a short phrase in the document, to wit: "Programs are encouraged to maintain documentation as to how they intend to employ the 9 BMP components listed below" and I need your guidance on its advisability. Please make your recommendations as specific as possible, to expedite revision, and forward them directly to Joe Conlon at conlonamcata@gmail.com. No doubt each person's take on what should be put in this document will vary widely and the ultimate product will not necessarily reflect each contributor's wishes. Nonetheless, all comments will be reviewed and utilized, where appropriate, to that make a better product.
Barring further judicial review, the NPDES permitting system will take effect on April 10, 2011. It is thus imperative that our profession do its best to ensure an outcome with which we can comfortably live."
BMPs For Mosquito Management