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One-point-three million dollars a year. That's the estimated cost of compliance on a new environmental permit under the Clean Water Act for the more than 65 mosquito and vector control agencies in California that are charged with protecting the public's health from vectors and vector-transmitted diseases. As of November 1 of this year, these governmental agencies can no longer apply public health pesticides to control and abate disease-carrying insects near or over U.S. waters without a pricey National Pollutant Discharge Elimination System (NPDES) permit and crippling monitoring requirements.
What U.S. legislators failed to acknowledge when they fell short of acting on H.R. 872, the "Reducing Regulatory Burdens Act" is that all applications of public health pesticides made by mosquito and vector control agencies are already applied according to their EPA-approved label under strict regulations by the Federal Insecticide, Fungicide, Rodenticide Act (FIFRA). H.R. 872 would have amended the Clean Water Act and exempted mosquito and vector control agencies from the NPDES permitting requirements. The redundant regulations provide no apparent additional environmental benefit and merely inflict further financial and administrative constraints upon public health entities.
Yes, some legislators on Capitol Hill understood the importance of addressing this overwhelming financial burden for public health pesticide applicators but it did not stir enough urgency in the Senate to bypass a hold placed on H.R. 872.
Alas, the compliance deadline came and went and the vector control agencies and State Water Resources Control Board are bracing for an administrative and paperwork nightmare.
The $1.3 million cost estimate includes fees, staff hours, chemical application monitoring programs, and related expenses. "Our members are already seeing reduced revenues from decreasing property values," says Bob Gay, President of the Mosquito and Vector Control Association of California (MVCAC). "This permit is not only expensive, but may prohibit our members from doing their job and the public is likely to suffer."
Mosquito and vector control agencies were formed in California to combat the malaria outbreaks in the early 1900s. Since then, these service entities have been protecting the health of Californians from insects and animals capable of transmitting diseases such as West Nile virus, encephalitis, typhus, plague, and Lyme disease. This authority granted by the State Health and Safety Code has been taken with great humility and care, not carte blanche license to spray pesticides wherever and whenever it is deemed efficacious. What pesticide applicators have learned over the years is that the constituency will ask questions and will want to know what products are being used and what their impacts are to human health and the environment.
Modern public health pesticides are formulated specifically to reduce or completely eliminate impacts on non-target organisms. Many products are used at less than one ounce of active ingredient per acre. Vector control districts are staffed with biologists, ecologists, and medical entomologists and they, along with their constituency, want to ensure that the products being used are safe.
In the past decade, there has been a social and political movement towards becoming more environmentally sensitive. It is no wonder that cultural sentiment would induce the 6th Circuit Court of Appeals to overturn the EPA's exemption of pesticides from the NPDES permitting requirements. But when applied to public health pesticides such as those used by vector control agencies, it's like cramming the proverbial square peg into a round hole. Vector control agencies do not fit the profile. They already abide by a rigorous integrated vector management framework and adhere to the California Department of Public Health's Best Management Practices for their operations, including pesticide applications.
MVCAC joined a national coalition to push for an amendment to the new federal permit requirements. Members lobbied to have public health pesticide applications exempted. But, even with bipartisan support, exemption proposals such as H.R. 872 failed before the November 1 deadline.
So long as the new ruling remains intact, the conundrum persists-do vector control agencies make pesticide applications when there is a disease threat and be forced to pass the buck to the taxpayers who must pay for the permits, monitoring requirements, and higher operating costs, or do they stop all applications and jeopardize their mission to protect human health from the diseases and ailments that have decimated less developed populations, currently and historically?
Congress can still act to protect public health pesticide applications, but it will require vocal advocacy from the constituency to compel our nation's leaders into addressing this public health burden.
If you would like to do more to support mosquito and vector control services that protect your family and community from diseases and other public health threats, contact your local and state representatives and make your voices heard.
MVCAC represents more than 65 special districts and other subdivisions of local government responsible for mosquito and vector control, surveillance of West Nile virus and other vector-borne diseases, and public education programs to help Californians protect themselves from disease. MVCAC advocates safe, effective and environmentally friendly methods of mosquito and vector control.
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