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HomeMy WebLinkAbout2017-12-05; City Council; ; Receive a staff report on Integrated Pest Management, consider available options on city owned or operated properties and rights of way, and adopt a Resolution providing direction to staff as appropriateHistorically, the creation, establishment, and maintenance of these sites has included the application of selective pesticides, in accordance with the relevant local, state and federal regulations and applicable permits. As defined in California Food and Agriculture Code Section 12753, "Pesticide" includes any of the following: (a) any spray adjuvant; (b) any substance, or mixture of substances which is intended to be used for defoliating plants, regulating plant growth or for preventing, destroying, repelling or mitigating any pest ... which may infest or be detrimental to vegetation, man, animals, or households, or be present in any agricultural or nonagricultural environment whatsoever. By this definition, the term pesticides includes organic products and chemical products. Insecticides, herbicides, fungicides and rodenticides are all considered pesticides. As a standard practice, the selection and application of these pesticides, by both staff and contractors, are to be performed according to an 1PM Plan. The general purpose of an 1PM Plan is to direct health conscious and environmentally sensitive pest management strategies. These strategies are consistent with the Carlsbad Community Vision core values of Sustainability, and Open Space and the Natural Environment. Specific to the city's ongoing operations, its 1PM Plan (also referred to as its 1PM Guidelines) was last updated on Dec. 16, 2003. As a result of staff's routine monitoring of industry changes in regulations and best management practices, and of concerns expressed by several citizens regarding the application of certain chemical pesticides on city owned or operated properties and public rights of way, staff drafted an update to the city's 1PM Plan for City Council review. Under the update to the 1PM Plan, staff and contractors would focus on the prevention and suppression of pest issues with the least impact on human health, the environment, and non- target organisms. 1PM typically uses a variety of pest control tactics in a compatible manner. A combination of several control tactics is usually more effective in minimizing pest damage than any single control method. The type of control(s) selected will likely va ry on a case-by-case basis due to differing site conditions. The primary pest control tactics to choose from include: • Cultural • Mechanical • Environmental/Physical • Biological • Pesticide Each of these pest control tactics is detailed in the update to the I PM Plan. Per the update to the 1PM plan, pesticide controls may be used when other methods fail to provide adequate control of pests and before pest populations cause unacceptable damage. When pesticides are to be used, considerations should be given for how/when to apply them the most effectively and sparingly. Pesticides that are broad-spectrum and persistent are to be avoided, since they can cause more environmental damage and increase the likelihood of pesticide resistance. The overuse of December 5, 2017 Item #11 Page 2 of 53 pesticides can cause beneficial organisms to be killed and pest resistance to develop. In addition, considerations should be given to the proximity to water bodies, irrigation schedules, weather, etc., that may result in the pesticide being moved off-site, into the environment. The following topics on pesticide controls are further addressed in the update to the 1PM Plan: • Criteria for Selecting Treatment Strategies • Selection of Appropriate Pesticides • Prioritized Use of Pesticides • Certification and Permitting • Employee Training • Record Keeping • Materials for Use -Least Toxic Pesticides • Notification Signs The use of chemical pesticides on city owned or operated properties and public rights of way would be significantly reduced, based on the guiding principles of the update to the 1PM Plan: 1. Emphasize the initial use of organic pesticides. 2. Limit the use of chemical pesticides where the general public congregates. 3. Use EPA Toxicity Category pesticides in a targeted manner by a certified pest control applicator, and only if deemed necessary by supervisory staff-to protect public safety; to prevent threats to sensitive species or native habitats; to assist in meeting regulatory compliance requirements; or to prevent economic loss -when pests cannot be managed by other tactics. The majority of the recent concerns expressed by citizens regarding the application of certain chemical pesticides have pertained to school sites, parks and similar recreational areas. The Parks & Recreation Department maintains and operates portions of 10 school sites in the city, under Joint Use Agreements with three school districts. As an informal pilot program, over the last 15 months, staff directed the contractor maintaining the sites to forego the use of chemical pesticides. Only non-chemical pest control tactics were used on these sites during this period. The effectiveness of these tactics has been modest. In particular, a greater number of weeds and burrowing rodents has been evident on the school sites. These conditions had a moderately negative effect on the aesthetics of the school sites' landscapes, and in particular, on the playability of the athletic fields. To date, however, the number of complaints received by staff on the landscape and field conditions at these school sites has been relatively low. The increased maintenance costs for this 15 month program have been approximately $10,000. December 5, 2017 Item #11 Page 3 of 53 Options The options available to the City Council regarding integrated pest management on city owned or operated properties include the following: Option 1: Expand 1PM Pilot Program -Specific Sites with Immediate Implementation This option would expand the referenced pilot program, under the provisions of the update to the 1PM Plan, to include parks, community centers and libraries -for a period of one year. The city would maintain current practices/operations (related to 1PM} on the balance of city owned or operated properties and public rights of way. The initial expenses related to the immediate expansion of the pilot program would be absorbed within the existing FY 2017-18 and pending FY2018-19 operating budgets. Staff would return to City Council at the end of the one year period with a report analyzing the results, impacts and costs associated with the program. • Pros: Allows for review of benefits, impacts and costs of the pilot program on a greater number of sites, before considering adoption of the update to the 1PM Plan. Limits costs until additional data/information is obtained. • Cons: Impacts aesthetics/playability of high touch sites. • Estimated Costs: Second half of FY 2017-18 -$250,000 for Parks & Recreation; $75,000 for Public Works. First half of FY 2018-19 -$250,000 for Parks & Recreation; $75,000 for Public Works. Option 2 Option 2a -Adopt Update to the 1PM Plan -Specific Sites with Phased Implementation This option recommends adoption of the update to the 1PM Plan with a phased implementation over the balance of FY 2017-18 -on school sites, parks, community centers and libraries. The City would absorb initial expenses related to the phased implementation within the existing FY 2017-18 operating budgets and prepare enhancement requests for the FY 2018-19 operating budgets to be included with the Citywide Budget submittal. The city would also maintain current practices/operations (related to 1PM) on the balance of city owned or operated properties and public rights of way. • Pros: Reduces use of chemical pesticides on high-touch sites in a phased manner. • Cons: Impacts aesthetics/playability of high-touch sites. Increases costs. • Estimated Costs: Second half of FY 2017-18 -$200,000 for Parks & Recreation; $50,000 for Public Works. Annually as of FY 2018-19 -$500,000 for Parks & Recreation and $150,000 for Public Works. December 5, 2017 Item #11 Page 4 of 53 Option 2b: Adopt Update to the 1PM Plan -Specific Sites with Immediate Implementation This option is similar to Option 2a above, with the exception of immediate implementation. • Pros: Reduces use of chemical pesticides on high-touch sites immediately. • Cons: Impacts aesthetics/playability of high-touch sites. Increases costs. • Estimated Costs: Second half of FY 2017-18 -$250,000 for Parks & Recreation; $75,000 for Public Works. Annually as of FY 2018-19 -$500,000 for Parks & Recreation and $150,000 for Public Works. Option 3 Option 3a: Adopt Update to the 1PM Plan -All Sites with Phased Implementation This option recommends adoption of the update to the 1PM Plan with a phased implementation on all city owned or operated public properties and rights of way. The city would absorb initial expenses related to the phased implementation within the existing FY 2017-18 operating budgets and prepare enhancement requests for the FY 2018-19 operating budgets to be included with the Citywide Budget submittal. • Pros: Reduces the use of chemical pesticides on all sites in a phased manner. • Cons: Impacts aesthetics/playability of all sites. Increases costs. • Estimated Costs: Second half of FY 2017-18 -$300,000 for Parks & Recreation; $90,000 for Public Works. Annually as of FY 2018-19 -$750,000 for Parks & Recreation and $225,000 for Public Works. Option 3b: Adopt Update to the 1PM Plan -All Sites with Immediate Implementation This option is similar to Option 3a above, with the exception of immediate implementation. • Pros: Reduces the use of chemical pesticides on all sites immediately. • Cons: Impacts aesthetics/playability of all sites. Increases costs. • Estimated Costs: Second half of FY 2017-18 -$375,000 for Parks & Recreation; $112,500 for Public Works. Annually as of FY 2018-19 -$750,000 for Parks & Recreation and $225,000 for Public Works. Option 4: Suspend 1PM Pilot Program and Halt Efforts to Update the 1PM Plan -All Sites This option would suspend the referenced pilot program on school sites, and halt further efforts to update the 1PM Plan. The city would absorb expenses related to the pilot program, and the refurbishment of the school sites, within the existing FY 2017-18 operating budget and continue current practices/operations (related to 1PM) on all city owned or operated properties and public rights of way. • Pros: Returns or retains present aesthetics/playability of all sites. Limits costs. • Cons: Resumes or continues historical use of chemical pesticides on all sites. • Estimated Costs: FY 2017-18 -$50,000 for Parks & Recreation. December 5, 2017 Item #11 Page 5 of 53 The above options were developed to identify potential 1PM benefits, impacts and costs on city owned or operated properties and rights of way. The actual 1PM benefits, impacts and costs are unknown at this time, and will not be known until after one of the options is implemented. Fiscal Analysis There is no direct fiscal impact associated with the receipt of this report on 1PM. Potential fiscal impacts will vary substantially, dependent upon City Council's direction to staff. The exact fiscal impact for full the implementation of the update to the 1PM Plan is unknown, but preliminary estimates indicate the increased annual expenditures may exceed $750,000 for the Parks & Recreation Department and $225,000 for the Public Works Department. Several of the pest control tactics noted -aside from pesticides -carry substantial costs for materials, equipment, and/or labor costs. In addition, organic pesticides are typically more expensive, and require greater quantities per dilution and a higher frequency of application -than chemical pesticides. These higher frequencies of application in turn require additional labor and equipment to perform the associated work. Many of the costs will not be established until it is determined which of the pest control tactics are most effective. Although there would be an internal cost to any implementation of the update to the 1PM Plan, the majority of the increased annual expenditures would be expected from the rise in cost of services of the various maintenance contractors under agreements with the Parks & Recreation Department and Public Works Department. Generally, higher costs of contractual maintenance services such as these can be addressed via amendments to the existing services agreements, within the authority of the City Manager -as designated by the Carlsbad Municipal Code. Next Steps Potential next steps will vary substantially, dependent upon City Council's direction to staff. It is staff's intent to ultimately maintain city owned or operated properties and rights of way at a very high quality standard, similar to that which the community and visitors presently expect. Environmental Evaluation (CEQA) The project is exempt from the California Environmental Quality Act (CEQA} per State CEQA Guidelines Section 15308 -actions by regulatory agencies for protection of the environment. Public Notification This item was noticed in accordance with the Ralph M. Brown Act and was available for public viewing and review at least 72 hours prior to the scheduled meeting date. Exhibits 1. Resolution providing direction to staff for Integrated Pest Management on city owned or operated properties and rights of way 2. City of Carlsbad, Public Works/Parks 1PM Guidelines, dated Dec. 16, 2003 3. City of Carlsbad, Parks & Recreation/Public Works Draft 1PM Plan, dated Nov. 30, 2017 December 5, 2017 Item #11 Page 6 of 53 RESOLUTION NO. 2017-229 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA, PROVIDING DIRECTION TO STAFF FOR INTEGRATED PEST MANAGEMENT ON CITY OWNED OR OPERATED PROPERTIES AND RIGHTS OF WAY. WHEREAS, the Parks & Recreation Department is currently responsible for the maintenance of approximately 183 acres of community parks and school athletic fields; 139 acres of passive parks and facilities landscapes; 90 acres of streetscapes, medians, and parkways; 137 acres of undeveloped park sites, urban forests, trailheads/planters; 594 acres of open space preserves; 19,000 trees; an 18-hole golf course, and 47 miles of trails; and WHEREAS, the Public Works Department is currently responsible for the creation, establishment, and maintenance of approximately 11 acres of habitat mitigation sites; the maintenance of 15 acres of vegetation control and 3 acres of vegetation monitoring; and the maintenance of 58 various buildings; and WHEREAS, historically, the maintenance of these sites has included the application of selective pesticides, in accordance with relevant local, state and federal regulations and applicable permits; and WHEREAS, as defined in California Food and Agriculture Code Section 12753, "Pesticide" includes any of the following: (a) any spray adjuvant; (b) any substance, or mixture of substances which is intended to be used for defoliating plants, regulating plant growth or for preventing, destroying, repelling or mitigating any pest ... which may infest or be detrimental to vegetation, man, animals, or households, or be present in any agricultural or nonagricultural environment whatsoever; and WHEREAS, by this definition, the term pesticides includes organic products and chemical products. Insecticides, herbicides, fungicides and rodenticides are all considered pesticides; and WHEREAS, as a standard practice, the selection and application of these pesticides, by both staff and contractors, are to be performed according to an Integrated Pest Management {1PM} Plan; and December 5, 2017 Item #11 Page 7 of 53 WHEREAS, the general purpose of an 1PM Plan is to direct health conscious and environmentally sensitive pest management strategies; and WHEREAS, these strategies are consistent with the Carlsbad Community Vision core values of Sustainability, and Open Space and the Natural Environment; and WHEREAS, specific to the city's ongoing operations, its 1PM Plan (also referred to as its 1PM Guidelines) was last updated on Dec. 16, 2003; and WHEREAS, as a result of staff's routine monitoring of industry changes in regulations and best management practices, and of concerns expressed by several citizens regarding the application of certain chemical pesticides on city owned or operated properties and public rights of way, staff drafted an update to the city's 1PM Plan for City Council review; and WHEREAS, staff presented several available options of 1PM on city owned or operated properties and rights of way for City Council consideration. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as follows: 1. That the above recitations are true and correct. 2. That the City Council hereby selects Option ______ 3_a _________ _ PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City of Carlsbad on the 5th day of December, 2017, by the following vote, to wit: AYES: NOES: ABSENT: M. Hall, K. Blackburn, C. Schumacher, M. Schumacher, M. Packard. None. None. December 5, 2017 Item #11 Page 8 of 53 ,.'. CITY OF CARLSBAD PUBLIC WORKS DEPARTMENT/PARKS DIVISION IPM GUIDELINES EXHIBIT 2 1.1 Model Integrated Pest Management, Pesticides and Fertilizer Guidelines 1.1.1 Introduction Fertilizers and pesticides are a primary tool of plant health and pest management. Used . properly, fertilizers provide important nutrients for plants, and pesticides help to protect plants from potential harm due to insects, mites, plant diseases, nematodes, vertebrates (such as gophers and rats) and weeds. Used improperly, fertilizers and pesticides may, among other things, impair surface and groundwater supplies. Careless management activities such as application, mixing, transportation, storage and disposal can allow these chemicals to enter surface and groundwater through runoff and infiltration. These practices may also endanger human and/or environmental health through the exposure to these potentially toxic chemicals. Due to these inherent risks even under ideal conditions, and the importance of professional planning and management, the Management Guidelines for the Use of Fertilizers and Pesticides were developed to provide the City of Carlsbad with: • A process by which it can effectively evaluate the approach to using fertilizers and pesticides as needed and begin to move toward reducing the dependence on them by developing a comprehensive Integrated Pest Management Program; • A program framework for reducing the adverse impacts that the use of fertilizers and pesticides may have on water quality; and • General guidelines that can be used in conjunction with the BMP 's in order to minimize the potential threat to human health and environmental resources. The overall objective of this manual is to provide the City of Carlsbad with general guidelines for the management activities associated with integrated pest management, pesticide and fertilizer applications. If desired, the guidelines may also be used to develop a comprehensive Integrated Pest Management (IPM) Program. Ultimately, the guidelines may be used and encouraged on a broader scale. They are based on th.e laws, management guidelines, research-based recommendations and "management measures and practices" established by other federal, state and local agencies and universities and they recognize that the safe management of fertilizers and pesticides is a shared responsibility between applicators, handlers and management. In addition, general training for this program element will be conducted annually as a part of the overall M1micipal Activities Program Manual. The Management Guidelines for Integrated Pest Management, Pesticides, and Fertilizers training module is generally targeted for stormwater program managers and addresses the overall program framework, objectives and approach so that they may gain a broader understanding of how the program was developed and should be implemented at a local level. City of Carlsbad Stormwater Program 12/16/2003 December 5, 2017 Item #11 Page 9 of 53 The training generally focuses on the proper application and handling of fertilizers and pesticides and the implementation of integrated pest management practices for management and municipal staff performing these activities. The training will be in a classroom setting, provided rumually and approximately 2-3 hours in length. Additional training modules will be developed as needed. Additional details on the overall frrunework and approach of the training modules are included in the Municipal Activities Program Manual. For the purpose of these guidelines: • Fertilizers may be referred to as "nutrients" or "soil nutrients"; • "Pesticides" will encompass all herbicides, insecticides, fungicides and rodenticides; • The California Food and Agricultural Code (FAC) and the California Code of Regulations, Title 3 (3 CCR), constitute the laws and regulations referred to in these guidelines. They are referenced often and usually referred to as the ".State Laws"; • The Pennittees are referred to as "public agencies", and employees working for these public agencies and responsible for the handling and/or application of fertilizers and pesticides will be referred to as "public employees". 1.1.2 Integrated Pest Management 1.1.2.1 Background on Pesticide Use and Integrated Pest Management For most of the last 55 years, the trend in pest management has been toward a greater reliance on chemical pesticides. The result has been not only a tremendous increase in the use of many dangerous chemicals, but also an increase in the number of pests that are resistant to the pesti~ides or new organisms becoming pests. Additionally, some pesticides used for terrestrial pest management have been found in waterways causing additional problems in the environment. Pest control managers are now moving away from their reliance on pesticides alone toward an integrated approach that combines limited pesticide use with more environmentally friendly pest control techniques. This system is know as integrated pest management (IPM), a strategy that focuses on the long-term prevention of pests or their damage through a combination of techniques, including preventative, cultural, mechanical, environmental, biological, and chemical control tactics (figure 1. 7). The techniques .are utilized simultaneously to control pest populations in the most effective manner possibk Developing a comprehensive Integrated Pest Management (IPM) Program and approach allows the primary efforts to focus on pollution prevention by monitoring and preventing pests as well as minimizing heavy pest infestations which reduces the need for chemicals and/or multiple applications. · City of Carlsbad Stonnwater Progrrun 2 12/16/2003 December 5, 2017 Item #11 Page 10 of 53 1.1.2.2 Scope of lPMGuidelines IPM practices are encouraged over the sole use of pesticides as the primary means of pest management (Table 1.14). As a part of the Municipal Activities Program Manual, the public agencies and their contractors should evaluate the non-chemical components ofIPM before intensive use of pesticides. The goal ofIPM is not to eliminate all pests, but to keep their populations at tolerable levels. Pesticides may be part of an 1PM program, but they should only be used after the pests exceed established thresholds and only applied in the affected area. In general, pest control strategies should be those that are least disruptive to biological control organisms (natural enemies), least hazardous to humans and the environment (including non-target organisms), and have the best likelihood oflong-term effectiveness. Pesticides should not be applied until pests are approaching dan:iaging levels. Because this requires early detection of the pests, monitoring on a regular basis is extremely irnpo1tant and should be used to determine if natural enemies are present and adequately controlling the pest. If possible, a person should be trained and designated to scout the sites on a regular basis. Table 1.14 Advantages and Disadvantages of a Pesticide-Based P rogram Versus. an IPl\1-Based Pest Control Program. · ,------Pesticide Based-Pesic:::O,iii:01·------·-·--r IPl\'l 13:iscd Pest Control ------· j-----..... -·-· .. -., zj · ..•. ••··• -··-·········-· -·--······-----; ·---··----·-····-·-·-·--···--·-··· --····-· .··---------------- 0 dvanlt!._gl'-S ·---~---·-···-·-01~_a!lyant~ges ! Adv;a!!_!~~s 01_s:1dv~_!i!~':':'?~.-~---·-·-- j Qnick suppresskm Df Loss ofnau.inil Long-term control. Training is required to i posts. controls. identity pests and . ~<~l1~~i~i~-oniy t~-;:-···-----·Not long-term s~1rcr to the . {~;,~~~~;J~~~~;~~Jc ag~---11 ! sp mying. cnviroDrnunt. ; ofp0stid dos and rh.;ir I ; effects on other ; L ___________ ! ______________________ organisms. I Not nrnch prcpnraiion i More pesticld(•g in i Pesticide.;; can b;: usL,d Must majntai1J a . i or follow-t1p Ill;'.cded. environ mc11L 1 (only used us last record~kecping i ------···· ··-·-··----·-·-·--·-·-··--___ -----------!'0St1ru~ ··-----· .. -·-·-------· _$VS tem. ____________ _j Ccmtarni.nation of Reduces disn1ption of J !\,:lust scout regularlv. ! water bodies Ii'()m natura l enemies. i ·· f i runoff. l i 1------------~-----------fJ:>;;,8Liei d~-~~~foty lb;-·---, l{~;}uc·c.~-------··----·--------j--r.,";~{);~:f;;-~0Zjl:jj~~eJ·1~);:---~-1 I l npplic.1t0rs, pub.lie. ! conlmnin;tiion from I n1011ilDr1ng. i ! ! animals. i nuwff. I ! ;-·--···-·--------------···---------·' ---------·-------------i ------------····-~---... ----... ·-·--..... ____ .-------.-··-·------·------,--i ; I Ofren get ourbrcnk-; o f / Lcsi> cxposnre 1u / / ~----·---------··"'·--.! .. ot)Jerpcsts . ___________ J peslici de~ -------------l _____________________ ! I i i Can be proactive in i I L.. ----------·----------____ /_ __________ ' -------.... JJ:~~\'.!.E~?!,l~[~ l L~t;t!.£~:§.:_,_ I_._ ·-·· -·-···-·------·-· __ __! City of Carlsbad Stonnwater Program 4 12/16/2003 December 5, 2017 Item #11 Page 12 of 53 I 1.1.2.3 Compone.nts of an 1PM Program An IPM program is a long-term, multi-faceted system to manage pests (Figure 1. 7). Use of pesticides is a short-term solution to pest problems and should be used only when the other components fail to maintain_the pests or their drun~ge below an acceptable level. · Successful IPM practitioners are knowledgeable about the biology of the plants and pests and successful IPM programs primarily use combinations of cultural practices as well as a combination of physical, mechanical and biological controls. 1.1.2.4 Pest Identification It is important to learn to identify all stages of common pests at each site. For example, if you cru.1 identify weed seedlings, you can control them before they become larger and more difficult to control and before they flower, disseminating seeds throughout the site. It is also importru.1t to be sure that a pest is actually causing the problem. Often damage such as wilting is attributed to root disease but may actually be caused by under watering or wind drunage. · 1.1.2.5 Prevention Good pest prevention practices are critical to any IPM program, and can be very effective in reducing pest incidence. Numerous practices can be used to prevent pest incidence and reduce pest population buildup such as the use bf resistant varieties, good sanitary practices and proper plant culture. Examples of prevention include choosing an appropriate location for planting, making sure the root system is able to grow · adequately ru.1d selecting plants that are compatible with the site's environment. 1.1.2.6 Monitoring The basis ofIPM is the development and use of a regular monitoring or scouting program. Monitoring involves examining plants and su1Tounding areas for pests, examining tools such as sticky traps for insect pests and quantitatively or qualitatively measuring the pest population size or injury. This information can be used to determine if pest populations are increasing, decreasing, or staying the same and to determine when to use a control tactic. City of Carlsbad Stonnwater Program 5 12/16/2003 December 5, 2017 Item #11 Page 13 of 53 It is important to use a systematic approach. For example you should examine the same section of a plant each time you check for pests, rather than looking at the lower leaves on some plants and the upper ones on others. Otherwise, randomly looking at a plant or a section of a growing area does not allow you to track changes in pest population or damage over time. Figure 1.8 illustrates an example of a form used to record monitoring or scouting information collected in the field. It is important to establish and maintain a record-keeping system to evaluate and improve your 1PM program. Records should include information such as date of · examination, pests fom1d, size and extent of the infestation, location of the infestation, control options utilized, effectiveness of the control options, labor and material costs. City of Carlsbad Stonnwater Program 6 12/16/2003 December 5, 2017 Item #11 Page 14 of 53 In order to have a way to determine when a control measure should be taken, injury levels and action thresholds must be set for each pest. An injury level is the pest population size where unacceptable damage occurs. Action thresholds are the set of conditions required to trigger a control action. 1.1.2.8 Pest Control Tactics Integrated pest management programs use a variety of pest control tactics in a compatible manner that minimizes adverse effects to the environment. A combination of several control tactics is usually more effective in minin1izing pest damage than any single control method. The type of control that an agency selects will likely vary on a case-by-case basis due to the varying site conditions. The primary pest control tactics to choose from include: • Cultural • Mechanical • Environmental/Physical • Biological • Pesticide 1.1.2.9 Cultural Controls Cultural controls are modifications of normal plant care activities that reduce or prevent pests .. In addition to those methods used in the pest preventions, other cultural control methods include adjusting the :frequency and amount of irrigation, fertilization, and mowing height. For example, spider mite infestations are worse on water-stressed plants, over-fe11:ilization may cause succulent growth which then.encourages aphids, too low of a mowing height may thin turf and allow weeds to become established. 1.1.2.10 Mechanical Controls Mechanical control tactics involve the use of manual labor and machinery to reduce or eliminate pest problems using methods such as handpicking, physical barriers, or machinery to reduce pest abundance indirectly.· Examples include hand-pulling or hoeing and applying mulch to control weeds, using trap boards for snails and slugs, and use of traps for gophers. City of Carlsbad Storm water Program 8 12/16/2003 December 5, 2017 Item #11 Page 16 of 53 1.1.2.11 Environmental/Physical Controls The use of environmental manipulations that indirectly control or prevent pests by altering temperature, light, and humidity can be effective in controlling pests. Although in outdoor situations these tactics are difficult to use for most pests, they can be effective in controlling birds and mammals if their habitat can be modified such that they do not choose to live or roost in the area. Exan1ples include removing garbage in a timely manner and using netting or wire to prevent bird from roosting. 1.1.2.12 Biological Controls Biological control practices use living organisms to reduce pest populations. These organisms are often also referred to as beneficials, natural enemies or biocontrols. They act to keep pest populations low e_nough to prevent significant economic damage. Biocontrols include pathogens, parasites, predators, competitive species, and antagonistic organisms. Beneficial organisms can occur naturally or can be purchased and released. The most common organisms used for biological c.ontrol in landscapes are predators, parasites, pathogens and herbivores. • Predators are organisms that eat their prey (e.g. Ladybugs). • Parasites spend part or all of their life cycle associated with their host. Common parasites lay their eggs in or on their host and then the eggs hatch, the larvae feed on the host, killing it (e.g. Tiny stingless wasps for aphids and whiteilies). • Pathogens are microscopic organisms, such as bacteria, viruses, and fungi that cause diseases in pest insects, mites, nematodes, or weeds (e.g. Bacillus thuringiensis or BT). • Herbivores are insects or animals that feed on plants. These are effective for weed control. Biocontrols for weeds eat seeds, leaves, or tunnel into plant stems ( e.g. goats and some seed and stem borers). ·· In order to conserve naturally occurring beneficials, broad-spectrum pesticides should not be used since the use of these types of pesticides may result in secondary pest outbreak due to the mortality of natural enemies that may be keeping other pests under control (Figure L9). City of Carlsbad Stonnwater Program 9 12/16/2003 · December 5, 2017 Item #11 Page 17 of 53 1.1.3 Pesticide Management -Planning Pesticides are defined as any substance or mixture of substances designed to prevent, destroy, repel, or mitigate any pest. Used incorrectly or carelessly they are potentially dangerous. A heightened public awareness about pesticides and their use has created an increased concern that they be used according to the directions on the label. This ensures that the pesticides are used correctly and safely.· When products are used illegally, i.e. against label directions, it is more likely that regulatory activity on a federal and state level will increase. Although safety concerns and the cost of complying with new regulations have encouraged some public agencies to reduce the use of pesticides, they are still used in certain situations, therefore guidelines for their proper use, handling, and storage are essential. In certain situations pesticides may be the most appropriate method. For example, pesticide use by public agencies often involves herbicide applications to keep flood control channels and roadways clear or to minimize health and safety hazards of disease-bearing rodents and insects. In landscape and turf maintenance, pesticides may be used to control pests that can reduce the aesthetic value of the site. 1.1.3.1 General Considerations There are extensive federal and state laws and regulations that all public agencies must be in compliance with at all times. · The California Food and Agricultural Code (FAC) and the California Code of Regulations, Title 3 (3 CCR), constitute the laws and regulations referred to in these guidelines. They are referenced often and usually referred to as the "State Laws". 1.1.3 .2 Pesticide Labels and Material Safety Data Sheets (MSDS) Without exception, pesticide labels provided by the manufacturer of each pesticide are the first source of recommendations and Instructions for chemical use. The label is the law. Whenever a pesticide is to be used by a worker or a contractor of a public agency, the user must read the label instructions and requirements. If the worker does not understand the label, they cannot handle or· apply the pesticide uptil the information is explained. As described in the 3CCR, section 6242, the label must appear on the immediate container of the pesticide and include, in prominent, bold type, the appropriate statement according to its toxicity classification: Danger or Poison, Warning, or Caution. If a chemical is transfened to another container, a copy of the la]?el must be transferred withit. Figure 1.10 depicts a portion of a typical pesticide label. City of Carlsbad Stormwater Program 11 12/16/2003 December 5, 2017 Item #11 Page 19 of 53 The section of the label entitled 'Precautionary Statements' contains information on the environmental hazards associated with use of the pesticide, such as toxicity to wildlife and . aquatic organisms. Particular attention should be given to the application of pesticides near surface waters or inlets to surface waters, especially if the hazard is listed on the label. Workers should never handle a container that does not have a label attached, and the supervisor in . charge should be immediately advised of the situation. If a label is badly damaged and cannot be read, the supervisor must replace it. City of Carlsbad Storm water Progran1 12 12/16/2003 December 5, 2017 Item #11 Page 20 of 53 Material Data Safety Sheets (MSDS) Workers using pesticides must have the Material Safety Data Sheets (MSDSs) for each chemical they are using readily available. Although the MSDS is a form that may vary in appearance for different chemicals, the information is the same, as required by law. Sintilar to the chemical labels, these sheets contain information necessary to handle each chemical safely, and all workers should be familiar with the information. MSDS sheets include chemical identifications, hazardous ingredients, physical data, fire and explosion data, health hazards, reactivity data, spill or leak cleanup procedures, special protection and special precautions. The MSDS also contains information on the toxicity (LD50 and LC50) of the pesticide to various test animals, providing the user with the pesticide's toxicity to off- target organisms, especially those in aquatic environments. General Requirements Following is a list of general requirements that should be followed when storing, using and transporting pesticides. 1. Thoroughly investigate and consider all least toxic pest management practices. 2. Maintain a complete list of all pestici<les used and the use sites. (3CCR, section 6624 - unless exempt under FAC, section 11408). 3. Use pesticides only according to label instructions. (FAC, section 12973). 4. Consider weather conditions that could affect application. For example, wind conditions affect spray drift; rain may wash pesticide off ofleaves. (3CCR, section 6614) 5. Do not apply pesticides where there is a high chance of movement into water bodies; for example, they shouldn't apply near wetlands, streams, lakes, ponds or storm drains unless it is for an approved maintenance activity. (3CCR, section 6614). 6. In most cases, triple-rinse empty pesticide containers before disposal. Particular information on the proper disposal of the pesticide and its container can be found on the label. For specific requirements see 3 CCR, section 6684. 7. Never clean or rinse pesticide equipment and containers in the vicinity of storm drains or other open water areas. 8. Store pesticides in areas with cement floors and in areas insulated from temperature extremes. 9. Secure chemicals and equipment during transportation to prevent tipping or excess jarring. (3CCR, section 6682). City of Carlsbad Stonnwater Prngram 14 12/16/2003 December 5, 2017 Item #11 Page 22 of 53 10. Pesticides must be transported completely isolated from people, food and clothing, for exan1ple, in the bed of the truck rather than in the passenger compartment. (3CCR, section 6682). 11. Inspect pesticide equipment, storage containers and transportation vehicles frequently. (3CCR, sections 6702 & 6742). 12. Develop a plan for dealing with pesticide spills and accidents. 13. Unless their safety is compromised, workers must immediately clean up any chemical spills according to label instructions and notify the appropriate supervisors and agencies. 14. Pesticide applications on public property, which take place on school grounds, parks, or other public rights-of-way where public exposure is possible; shall be posted with warning signs. The specific criteria for the signage can be found in FAC, section 1W78. Pesticide applications by the Department of Transportation on public highway rights-of- way are exempt. City of Carlsbad Storm water Program 15 12/16/2003 December 5, 2017 Item #11 Page 23 of 53 1.1.3 .3 Selection of Appropriate Pesticides When selecting pesticides, public agencies should rely on recommendations from a state-licensed pest control advisor (PCA) in order to ensure that the most appropriate pesticide is selected. Additional advice for pest identification and control strategies are also available from the San Diego County Agricultural Commissioner (714) 44 7-7100, University of California Cooperative Extension (714) 708-1606 from other professionals and/or through professional publications. The use ofrestricted pesticides and all other Category I pesticides should only be used under special circumstances and where other treatment options did not or could not work well. 1.1.3.4 Certification, Licensing and Permitting Restricted use pesticides should only be applied by or under the direct supervision of an individual with a qualified applicators certificate (QAC). To receive a QAC, a person must take a test administered by DPR. To obtain test materials, test schedules, and an application, see http://www. cdpr. ca. gov I docs/licens e/liccert.htm. Pesticides listed as "restricted" in the State of California may be used only under a restricted materials permit (3CCR, section 6142) issued by the San Diego County Agricultural Commissioner. The permit must be renewed annually for continued use. For more information, contact the Commissioner's office at (714) 44 7-7100. · AU other guidelines concerning permits, licensing and certification requirements to be followed before pesticide application are detailed in FAC, sections 12971-12988 and 1.1.3. 5 Employee _Training Employees must know the information on the chemical label and its MSDS · before using or handling pesticides. In addition they should be trained annually or whenever a new pesticide is to be used. The applicators should know: • The immediate and long-tem1 health hazards posed by chemicals to be used, the common symptoms of chemical poisoning and the ways poisoning could occur; and • The safe work practices to be followed, including the appropriate protective clothing, equipment, mixing, transportation, storage, disposal and spill cleanup procedures that apply to the specific chemicals being used. City of Carlsbad Storm water Program 16 12/16/2003 December 5, 2017 Item #11 Page 24 of 53 In addition to the training and annual continuing education required for licensing and certification as specified in 3CCR, section 6511, public employees are encouraged to participate in the annual Municipal Activities Program training (see Municipal Activities Program Manual) and continuing pesticide education programs whenever the programs are available. Supervisors are encouraged to conduct or· schedule pesticide education programs for their workers more frequently than required by law. 1.1.3.6 Accident and Spill Mitigation Public agencies using pesticides should have plans for dealing with potential accidents before they happen. These plans should consider: · 1. Labels and MSDS Sheets --All workers handling pesticides must be familiar with these instructions. The steps for accident mitigation are spelled out on chemical labels and MSDS sheets. 2. Spill Cleanup Kits --Any time pesticides are being handled, there must be a cleanup kit on hand in case of an accident-This means there should always be a cleanup kit located in pesticide storage areas, on vehicles used to transpmt pesticides and on location where the chemicals are being applied. Although these kits may vary in what they contain depending on the chemical type and the situation, at a minimum they should include: • Written spill-control procedures • A five gallon drum with seal-able lid • A dust pan and broom • A squeegee • A shovel • Protective goggles, gloves, boots, coveralls • A tarp (for covering dry spills) • Detergent and water ( check label or MSDS for proper use) • Barricade tape, florescent traffic safety cones or string to cordon off an area • Large sponges, containment booms or other absorbent material 3. Cleanup Procedures --Spilled pesticides must be prevented from entering the local surface and/or groundwater supplies. Specific recommendations for spill cleanup should be available on the pesticide label or MSDS. Specific recommendations for the sequence of procedures may also vary depending on the situation. Figure 1.11 provides a flowchart of the general steps that a worker should follow in case of a spill: A good overview of spill containment procedures can be found in the book "The Safe and Effective Use of Pesticides" (see Reference section). r.itv nfr-arlsbad Stormwater Program 17 12/16/2003 December 5, 2017 Item #11 Page 25 of 53 1.1.3. 7 Emergency Medical Care Accident situations requiring emergency medical care are likely to involve acute exposure to potentially toxic chemicals. Instructions for handling these exposures appear on the pesticide label. Workers should: 1. Be aware of the symptoms of acute exposures for each pesticide being used. 2. Have a predetermined strategy for dealing with exposure scenarios, including knowing the label recommendations for dealing with acute exposures and the nearest medical facility where emergency care is available. 1.1.3.8 Equipment and Equipment Maintenance All equipment for the handling of pesticides should be inspected and cleaned by workers each day before use, to ensure that there are no problems that could lead to chemical leaks, spills or accidents during the day's work (3CCR., section 6742). The calibration of equipment should be done routinely to ensure that the proper amount of pesticide is applied. The maintenance of application rates within label recommendations also reduces the risk of surface and ground water contamination. 1.1.3.9 Groundwater and Surface Water Protection The main factors determining the rate at which pesticides enter groundwater and surface water systems are chemical mobility, solubility and persistence and the soil type. For example, potentially dangerous chemicals are likely to have a high solubility and an extremely long half-life, and they are not likely to be easily absorbed into the soil. Therefore, pesticides that decompose rapidly may be preferred under certain conditions. However, it should be noted that if a less dangerous pesticide is chosen, but then applied two or three times as often, it may.not make sense from a transportation and application risk standpoint to choose the pesticide. Therefore, because of these factors, regardless of the category of pesticides being used, pesticide advisors should always be aware of the compatibility of the pesticide with the characteristics of the site of application (soil type, slope, proximity to a water body, vegetation) before recommending pesticides for a specific area. For example, recommended Surf LAN rates vary according to the amount of organic matter in the soil. Fmthem1ore, because the effect of these uses is not always immediately apparent, public agencies should periodically test areas where frequent pesticide applications occur and the area is identified as particularly vulnerable to contamination or deterioration. City of Carlsbad Sto1mwater Progran1 19 12/16/2003 December 5, 2017 Item #11 Page 27 of 53 PesticideWis_e (http://www.pw.ucr.edu/WO_Homep.asp) is an, informational database that public agencies can utilize to determine various properties of pesticides and their potential risk to water quality. 1.1.3.10 Pesticide Use in Aquatic Environments · The application of pesticides to aquatic environments for the control of pests requires coverage under the NPDES permit program. A General Pennit, with January 31, 2004 expiration, was issued by the State Water Resources Control Board to authorize the application of pesticides directly to waters. The permit allows the application of aquatic pesticides by public entities as long as certau1 requirements are meet. These requirements state that dischargers must: 1. Comply with all pesticide label instructions, DPR and Department of Health and Safety regulations, and any Use Permits issued by the local Agricultural Commissioner; 2. Identify and implement BMPs to minimize adverse effects to the environment; 3. Submit technical and monitoring reports as required by the local RWQCB. Specific details on these requirements can be found in the General Permit available at the following link: · htt:p: I /www.swrcb.ca.gov/ resdec/wqorders/2001/ wqo/wqo2001-12.doc Further information on the direct application of pesticides to aquatic environments can be fowid in the University of California Division of Agriculture and Natural Resources publication titled 'Aquatic Pest Control' (see the references section). In addition, the publication entitled 'Pesticides and Aquatic Animals: A Guide to Reducing Impacts on Aquatic Systems' provides a review of aquatic pesticide management practices. 1.1.4 Application of Pesticides In cases where State Laws require supervision of pesticide applications, supervision must be handled by a state-licensed or certified pesticide applicator. For all other pesticide applications, workers with equivalent training may handle supervision. Public agencies that contract for pest control should periodically inspect contracted work crews to be certain that contractors are following the same or more stringent pesticide management guidelines as required by the County agencies. Public agencies handling their ovm applications should likewise inspect their work crews on a regular basis to ensure that safety standards are being met. · City of Carlsbad Storm water Program 20 12/16/2003 December 5, 2017 Item #11 Page 28 of 53 1.1.4.1 Proper Techniques The pesticide label must be attached to the container and available on site. The label contains information regarding how to safely use the product. It is important that the applicator and handlers read the label carefully and follow application instructions exactly. Special attention should be paid to the list of pests that the pesticide will control to ensure that the right chemical is being used for the right job. When a range ofrates is given on the pesticide label, the applicator should use the lowest rate unless there are circumstances that warrant using a higher rte. These circumstances are provided on the label. State regulations mandate that no pesticide application shall be made or continued when: (a) There is a reasonable possibility of the pesticide contacting the body or clothing of persons not involved in the application process; (b) There is a reasonable possibility of damage to non-target crops or animals; and ( c) There is a reasonable possibility of contamination of non-target public or private property. (3CCR, section 6614). Weather conditions are a major factor in determining the likelihood of offsite movement from the application target (i.e. drift), and therefore must be incorporated into the planning of pesticide applications. This information can be found dn the product label or supplemental labeling. 1.1.4.2 User Safely and Protection The following is a list of suggestions for user safety and protection: 1. Have equipment on hand personal protective equipment (PPE) for application of pesticides. This would include eye protection, gloves, and respiratory gear and impervious full-body, chemical resistant clothing when called for by the chemical label. 2. Workers should avoid inhaling pesticide spray arid dust at all times. 3. Avoid working alone, especially at night. Ifit is necessary to work alone at night, the worker should be in contact with a supervisor via a phone or radio. City of Carlsbad Storm water Program 21 12/16/2003 December 5, 2017 Item #11 Page 29 of 53 4. Equipment should be cleaned at least at the end of the day's applications, The equipment should not be rinsed in an area where the wash water can . contaminate surface or ground water. Workers doing the cleaning must wear the same safety equipment as required on the pesticide label, e.g., eye protection, gloves. 5. Use of removable coveralls, gloves and shoes/boots is required when stated on the label, under PPE, when applying certain pesticides. Use of these protections is recommended for most applications, especially if the applicator does not have the opportunity to change clothes prior to driving or riding in a vehicle or eating or drinking. In this wly, the applicator's clothing is less likely to become contaminated. The applicator should also wash his or her hands thoroughly after each application even though gloves are worn. (3CCR, sections 6736 and 6738) 6. State laws regarding re-entry into areas that have recently been treated with pesticides should be followed (3CCR, section 6770). For the most part, pesticides used for landscape and turf pest control allow entry after the product has dried. Nevertheless, treated areas must be blocked off or otherwise isolated until re- entry is allowed in order to reduce human exposure to the pesticide. 7. Before workers come in contact with pesticides they need to be trained about the specific pesticides being used, including how to properly handle them, the dangers involved in their use, and proper training and safety procedures of the pesticides. 8. Keep current records including a complete list of pesticides being used in their jurisdiction. This should include the pesticide name, amount in storage, dates, use site, and rate of applications and pests controlled with each application. 9. Keep all relevant label and MSDS info1mation for each pesticide updated and readily available at all times to workers handling the materials. 1.1.4.3 Storage, Disposal and Transportation Storage of pesticides should be away from living areas and in a covered area that is well- insulated from temperature extremes; they should have a cement floor and good ventilation. Also, storage areas should be clearly marked according to state standards and be securely locked at all times when not in use. Signs, visible from any direction of probable approach, must be posted around all storage areas where containers that hold, or have held pesticides required to be labeled with the signal words "wanling" or ".danger". City of Carlsbad Stonnwater Program 22 12/16/2003 December 5, 2017 Item #11 Page 30 of 53 Each sign should be of such size that it is readable at a distance of 25 feet and contain the following statements: DANGER POISON STORAGE AREA ALL UIVA UTHORIZED PERSONS KEEP OUT KEEP DOOR LOCKED WHEIVNOTIN USE The notice shall be repeated in an appropriate language other than English when it may reasonably be anticipated that persons who do not understand the English language will come to the enclosure (3CCR, section 6674), · Pesticide labels on pesticides being stored or used shguld be kept in good condition and attached to all containers holding pesticides (3CCR, section 6676 and 6678) and storage equipment and containers should be inspected frequently for leaks or defects before being taken on the job. Containers should also be inspected before storing at the end of the day. Proper Disposal Following are recommendations that should be followed in order to ensure the proper dispo.sal the pesticide containers; l. Pesticide containers should be triple-rinsed before disposal (3CCR, section 6684 ). 2. Cleaned containers should be sent back to the manufacturer for recycling whenever possible. However, once triple-rinsed most haulers will take them to most landfills. · 3. Leftover rinse water should be used as spray. 4. Surplus or out-of-date pesticides should be given to a licensed hazardous waste hauler for disposal. Safe Transportation Methods Following is a list ofrecommendations that should be followed to ensure that workers utilize safe transportation 1nethods when traveling to and from worksites; 1. Pesticide containers should be tightly sealed and secured from tipping or excess jarring (3CCR, section 6682). 2. Pesticide transportation compartments on vehicles should be isolated from the compartment carrying people, food and clothing (3CCR, section 66~2) and should be securely locked. City of Carls bad Storm water Program 23 12/16/2003 December 5, 2017 Item #11 Page 31 of 53 3. Only the amount of pesticide needed for the day should be transported to the site. If the pesticide is transferred to another container, a copy of the label or a service label must be attached. (3CCR, sections 6676 and 6678). In no case shall a pesticide be placed or kept in any container of a type comrfzonly used for food, drink or household products. (3CCR, section 6680). 4. Appropriate pesticide labels and MSDS sheets, a spill cleanup kit, and a first aid kit should always be brought along when transporting pesticides. Additionally, the location of an emergency medical care center should be known. 5. All vehicles used for pesticide transportation should include radio or cellulai· communications for contacting help in case of a spill or some other emergency. 1.1.5 Fertilizer Mai1agement Fertilizers are nutrients applied to soil or plants to promote plant growth or health. Fertilizers commonly used in landscapes contain both: • Nitrogen (N); and • Phosphorus (P) Soluble forms of nitrogen and phosphorus can leach through soils or move off-site in surface runoff causing algal blooms or eutrophication within the local waterways. Fertilizers also play an important role in promoting plant growth that protects soil from erosion and enhances landscape aesthetics. Because of the necessity for soil nutrients and the potential for adverse effects on local waterways due to the loss of these nutrients through runoff and leaching, management guidelines are necessary as a means of reducing the loss of fertilizers into water bodies. I. I . 5.1 State and Federal Law Fertilizer use is not regulated under state and federal law, as its use does not pose an immediate danger to public health and safety. However, it is well known that the misuse of fertilizers poses risks to the environment. As a result, various organizations have ~eveloped management guidelines for fertilizer use on specific crops. The California Plant Hea:lth Association (http://www.cpha.net) maintains a listing of fertilizer manufacturers, distributors, and associations that provide technical information on the proper use of fertilizer on their web site. City of Carlsbad Stormwater Program 24 12/16/2003 December 5, 2017 Item #11 Page 32 of 53 / 1.1.5.2 General Recommendations The following is a list of general recommendations that should be followed when storing, applying and transporting fertilizers: 1. Whenever possible use foliar and/or soil nutrient testing before applying fertilizers to verify application timing and rate. ·I 2. Use a higher percentage of fertilizers containing slow-release N, such as IBDU and sulfur-coated urea. Be aware that organics (i.e·. bone meal) and some slow- release fertilizers are dependent on microbial activity for the release of nitrogen; therefore low soil temperature will decrease the release of nitrogen available for plant uptake. 3. If highly soluble-N fertilizers are use, apply smaller amounts on a more frequent basis. 4. Incorporate fertilizer directly into the soil arnund the piant, where possible, to minimize potential surface runoff. 5. Although fertilizers must be watered in the soil in order to work, the watering in should occur with light irrigation just after the application. Due to the unpredictability of rain events, it is recommended that fertilizers not be applied in the rain or on the same day that rain is expected: 6. Irrigation application rates and schedules should be adjusted to minimize surface runoff, especially ii:nmediately following the application of a fertilizer. 7. Immediately clean up any spill of fertilizers using dry methods of cleanup such as by sweeping or scooping up the material. 8. Fertilizer storage facilities should be covered and have an impenneable foundation so that potential spills cannot runoff into surface water or leach into groundwater systems . . 9. Fe1iilizers must be securely covered in the vehicle before being transported to application sites to avoid spillage or loss during transport. City of Carlsbad Stonnwater Program 25 12/16/2003 December 5, 2017 Item #11 Page 33 of 53 1.1.5.3 Nutrient and Soi/Assessment Soluble fertilizers can easily leach through soil and potentially contan1inate groundwater following excess irrigation, after heavy rains and where the water table is high. Generally, the most signilicant loss of fertilizer is from nitrat~-nitrogen, but there is some evidence that phosphorus leaching can be significant in soils that have received regular applications of soluble phosphorus. Foliar and soil analysis should be utilized whenever possible to assist in the determination of the nutrient status of plants and the soil where they are growing. Nutrient testing can be an important management tool for determining baseline nutrient levels in order to adjust application rates appropriately. Generally, soil testing is done only for newly developed sites, but valuable information can be obtained on established sites as well. For example, the chemical and physical properties of the soil affect the availability of nutrients. Figure 1.12 illustrates the range of nutrient availability as pl-I of the soil increases or decreases. Nutrient analyses are often accompanied with an interpretation and recommendation from the testing laboratory in order to assist the applicator in choosing the proper type and rate of fertilizer. Fertilizer recommendations should be based on the type of plant material (i.e. mature tree versus groundcover), the growth stage, overall health of the plant, and the current nutrient status of the soil. If a public employee y.,ith expertise in plant nutrition is not available, the testing laboratory or a Certified Crop Advisor (CCA) with expertise in urban horticulture.should be able to provide a useful interpretation of a foliar or soil analysis. City of Carlsbad Stonnwater Program 26 12/16/2003 December 5, 2017 Item #11 Page 34 of 53 1.1.5.4 Fertilizer Types Inorganic;: and Synthetic Fertilizers The most widely used fertilizers are inorganics characterized as being relatively low in cost, easy to apply, and quick releasing. However, over use of inorganic fertilizers can result in increased soil salinity and the need to leach soils_to avoid salt damage to plants (i.e. leaf burn). Inorganic fertilizers are also available as slow-release fertilizers, hut at a much higher cost. The main advantage in using slow-release fertilizers is theft ability to provide nitrogen to the root zone at rates that more closely match the growth of the plant, thereby minimizing the amount of nitrogen available for leaching below the root zone. One disadvantage is theft use on steep slopes, where broadcast fertilizer p:i:ills (capsules) may easily become mobile during irrigation and storm events. Organic Fertilizers Manures and organic concentrates such as blood and fish meal are considered organic fertilizers and offer the advantage ofreleasing nitrogen at a slower rate. A significant advantage to the use of organic fertilizers is that many of them are also classified as soil amendments due to their effect on the soil's physical properties. Disadvantages include high salt content, presence of weed seeds, varying nutrient content, _and a higher cost per pound than inorganic fertilizers rendering them cost ineffective for municipal use. It should also be noted that recent studies have indicated that organic fertilizers and amendments may be significant sources of fecal coliform in irrigation and storm water rnnoff. In contrast to the traditional assumption that fecal bacteria only multiply within the digestive tracts of warm-blooded animals, recent research suggests that fertilizers may contribute to propagation of fecal bacteria in the watm, moist and dark environments the storm drain infrastructure. Although State regulations require commercial composters to reduce fecal bacteria in manure-composted materials, green waste materials are not currently regulated for fecal bacteria and may contain incidental amounts of animal waste, such as from pets br wild birds. In addition, uncomposted animal manures and yard trimmings can have fecal coliform concentrations as high as Class B sewage biosolids. City of Carlsbad Stonnwater Program 28 12/16/2003 December 5, 2017 Item #11 Page 36 of 53 Prior to choosing the type of fertilizer, the following should be taken into consideration: l. Ability of the plant material to uptake and utilize nitrogen (soil temperature, species, growth rate). 2. Leaching requirements due to soil salinity. 3. Severity of slope and potential for runoff to carry fertilizer. 4. Proximity to stotm drains or hard surfaces. 5. Receiving water impainnents (such as bacteriological impairments) 6. Type of irrigation and scheduling. 1.1.5.5 Application Rates and Timing The amount of fertilizer needed for different applications depends on a number of factors. The following factors should be considered prior to the application: 1. Rooting characteristics of the vegetation (turf, shrubs, and trees). 2. The growth stage of the plant. 3. The ability of the plant to uptake the nutrients from the soil (temperature, water status, pH of the soil, salinity, etc.). 4. The current nutrient content of the soil. 5. Additional sources of nutrients (i.e. composts, reclaimed water, atmospheric deposition). 6. Potential for loss of nutrients by leaching. 7. Method of irrigation. 8. Chemical properties of fertilizer being applied. The application: of fertilizers should coincide with the growth stage requirements of the plant. For mixed plantings having different growth stages, fertilizer applications should be divided into several applications targeting each of the growth stages. The vegetation being managed should be researched and fertilizers applied only according to the amounts and at the time intervals recommended by the manufacturer or a public employee qualified to make fertilizer recommendations. This should minimize the waste offertilizer and reduce the risk of water contamination. Although recommendations for the application of fertilizers to turf are well researched, there is more uncertainty in the rate and timing of the application of fertilizer to landscapes consisting of a mixture of trees, shrubs, turf, and gro1mdcovers. As a result, foliar and soil nutrient testing should be used as a tool to assist in the detenniii.ation of application rates and timing until more information is available. City of Carlsbad Stonnwater Program 29 12/16/2003 December 5, 2017 Item #11 Page 37 of 53 \, 1.1.5.6 Application Methods of Fertilizers This section details the most common methods for application of fertilizers, however, these are not the only acceptable methods of fertilizer application since every application has its own circumstances and variables to consider. Table 1.15 provides a summary of the major advantages and disadvantages of_.each application method. The types of application methods included in this section are: • Banding · • Sidedressirig • Foliar Fertilization • Broadcast Application Regardless of what type of application method is chosen, the method should strive to deliver nutrients to the location where maximum plant uptake and utilization occurs and the chosen method should take into account the potential for surface runoff, dust, leaching into groundwater and the volatilization of materials. Proper calibration of application equipment insures that fertilizer is delivered at the recommended rate and record keeping for the amount applied, the location of the application, and the frequency of the application will assist in tracking fertilizer use and refining application timing and rates. • Banding of Fertilizer This method involves physically working small amounts of feiiilizer into the soil in a band beneath and/or around the sides of a plant. It allows new roots to efficiently use the nutrients and minimizes potential nutrient loss to surface runoff. Banding is particularly useful for new planting-, however, given the labor involved, banding may not be practical for some fertilizer applications. • Sidedressing Similar to the banding method of fertilizer application, sidedressing involves the placement. of dry fertilizer in a band directly next to actively growing plants. Sidedressing is particularly effective for applying fertilizer to established plantings during critical growth stages. Although this method is labor intensive, it delivers nutdents directly to growing loots and minimizes the potential for fertilizer move in surface runoff. City of Carlsbad Stormwater Program 30 12/16/2003 December 5, 2017 Item #11 Page 38 of 53 • Foliar Fertilization This type of application refers to fertilizer that is applied in liquid form directly to the leaves and stems. However, runoff problems may occur where the spray is allowed to drip off the leaves onto the ground or irrigation and rainfall occur immediately after the application. This method can reduce nutrient leaching into the soil when applied correctly and can often be performed at the same time as pesticide applications to avoid spraying twice (if this is done, it is important to check that the materials are compatible for spraying). In this case, the guidelines for pesticide applications must also apply and the pesticide label checked for appropriateness of this method. • Broadcast Application The most common method utilized by public agencies is the application of dry or liquid fertilizer uniformly spread over the soil surface. This is often done mechanically with a: o Drop Spreader o Rotary Spreader and Belly-Grinder o Spray Booms o Spinning Disks Drop Spreader -The simplest of mechanical applicators, the drop spreader, is commonly mounted on wheels and pushed by hand or pulled by vehicle to drop granular fertilizer out of the hopper. The use of a drop spreader in that situation reduces the potential for off-target application offertilizers. Rotary Spreaders and Belly Grinders -generally operate by "throwing" fertilizer in front of the spreader. This type of spreader should not be utilized to fertilize vegetation adjacent to hardscapes, such as streets and sidewalks. Spray Booms -for liquid fertilization. As with the use a rotary spreader, this method does not offer much control over fertilizer drift in adverse weather, conditions and care should be taken to avoid spreading fertilizer onto impermeable surfaces such as sidewalks and driveways. If fertilizer lands on these types of surfaces, sweep or blow the material onto the vegetation or into a container for later use. Spinning Disks -mounted on a moving vehicle in a manner allowing for the throwing of dry fertilizer into the air. As with the use a rotary spreader, this method does not offer much control over fertilizer drift in adverse weather conditions and care should be taken to avoid spreading fertilizer onto impermeable surfaces such as sidewalks and driveways. If fertilizer lands on these types of surfaces, sweep or blow the material onto the vegetation or into a container for later use. City of Carlsbad Stonnwater Program 31 12/16/2003 December 5, 2017 Item #11 Page 39 of 53 Table 1.1 5 Advantages and Disadvantages of Common Fertilizer Application Methods l -·-··-·····--·--·-----· --·-A!lvn n1a.gcs ---·---·--r Disa1hantages ---1 I Fertilizer Application Methods I 1····-·--·--··"""'"'-"""""'"" ................................................. _ .. ,................................ • .......................................... _ .. ____ .. ............ .. ......................... -, .... , .. ~-·-·····-·····-·-------.. -! ~utrient"s placed Labor in1c.nsive. / Brinding dl!'eclly near roots. I , . . . _ Ge110ra.l ly <Jniy i [; lVluum17.e5 nu1Tk'Dl ui ilized fo r new ! .. -------· --·------·-----··--·-·-----·----------:.:: .. ~; c'.:: .. -i: .. ~~::~ .. ~c'.:~1 t 1;: .... 1:f. -: t:~:~:'.}t~·:.~11sive -··------· Si.dedressing . of nutrients to J · · growing roots in · -----------------------------.. ·-----·--------. es1ab.lishcd pfanti:ngs. __ -----------·--·-·-·-·----1 ! RGdUt.'-DS k ndiing .. High pntcufo1l for I i po1 .. en .. 1i;-d of nn1rrc:nis nuAri<:nts tel b~ wash0d JI j bd ow the mot zone. fn1rn pl1mt surfaces I dming irriga.tio.u. :tvfay be applied wiih .!, p0stkides under Adh,rse rnnditions ce1ta in ci rcu msta nccs. stwh as wind may cause ddft on lo hard i surfaces.· ---------------------------------r--------·-------- j Broadcast Off-target application i Coverage of large i:; minimiztd. areas is time consumiuu.. ,. Bm,c of application. Off-targeiopplication J ,·-----------··-----------! Drop Sprc11dtr l-·-·-· ···---··-··-.. ·-~ .. --.. ----···----·---~-·------Roimy Sprnadm: or Bclly Grinder 1 =•cc:css t.o difficl1H ! I of krliJizcrs to hard l l Covers large areas I surfaces is common. I i quickly an d provides ! I !-Spray Bomn::: ---------......... ·--------------·-·· -----~~::~~I for · fo li1.1r ______ ll l\ncntfal for drift ! ! application;g ovi:'f wider adverse wculber / : lnr12e arnu:;. condition;;. I I Spinning Disks Al ki?'s !•ir fL·nili2;cr 1· OJ-J--t-a-r.-~,i;-,t-,-'.f-}J-Jl-ic_'_l-tt-il--,11 j applic:altons over lo hrml smbccs is 1 : large arens q 1iiL k!y : rnmmu:1. L ________ .. _ ... ---------------------·--·-··--_ ·-----. __ J_.(l!!~l_~1~ilY: --------~ __ _j ________ ---------- City of Carlsbad Storm water Program 32 12/16/2003 December 5, 2017 Item #11 Page 40 of 53 / 1.1. 5. 7 Storage and Handling of Fertilizers Although fertilizers present no hazard to the user's health when stored and handled properly, employees responsible for the storage and handling of fertilizers should be aware that some fertilizers have properties that can result in dangerous chemical reactions if mixed with other substances or under unusual circumstances. Therefore, a dehumidifier may be necessary for storage areas where sensitive fertilizers are stored such as ammonium nitrate. In addition, since most fertilizers tend to be corrosive to metals, concrete structures are preferred for fertilizer storage facilities. These problems can be minimized by only purchasing those quantities that will be used in the immediate future. instead of storing materials for long periods. • Dry Fertilizer In most cases, dry fertilizers are safe to store, transport and handle. However, because some fertilizers have unique, potentially dangerous properties, it is advisable for public agencies to consult a qualified individual having lmowledge of the safest storage and handling procedures for specific fertilizers. Fertilizer supplies are an excellent source of information on the proper handling and storage of fertilizers. In general, the following precautions should be taken when storing and handling fertilizers: Keep away from open flame. Keep chemicals separate from each other to avoid cross contamination. Proper disposal of empty fertilizer bags. Sweep up and dispose of all contaminated material (Do not wash with water). Store in a cool dry facility. • Liquid Fertilizer Since fertilizers in liquid form are potentially more hazardous than dry fertilizer, employees responsible for storage and handling need to be aware of the specific properties of each liquid fertilizer in use, including corrosiveness and tolerable temperature and pressure ranges. In addition, protective equipment rriay be necessary for workers handling fertilizers such as sulfuric or phosphoric acid. Fe1iilizers suppliers should be consulted for recommending the safest handling and storage procedures for specific liquid fertilizers. (;itv of Carl shad Stonnwater Program 33 12/16/2003 December 5, 2017 Item #11 Page 41 of 53 1.1.6 References Literature California Department of Food and Agriculture, Nitrate Working Group. Nitrate and Agriculture in California 1989. California Department of Food and Agriculture, Pesticides and Pest Control Operations. Barclays Official California Code of Regulations-1992. California Fertilizer Association (California Plant Health Association) Western Fertilizer Handbook 2nd Horticulture Edition 1998. California Regional Water Quality Control Board, Santa Ana Region, Order No. R-8-2002-0010, NPDES No. CA5618030. 2002. County of Orange, Environmental Resources Division. Drainage Area Management Plan, Final Draft. 1991. County of Orange, Environmental Resources Division. Drainage Area Management Plan 1993. County of Orange, Environmental Resources Division. Draft of Drainage Area Management Plan 2000 .. Wyoming Agricultural Extension Weeds of the West, 5th Edition 1996. University of California, Division of Agriculture and Natural Resources Aquatic Pest Control, Pesticide Application Compendium, Volume 5 2001 University of California, Division of Agriculture and Natural Resources. The Safe and Effective Use of Pesticides, 2nd Edition 2000. University of California, Division of Agriculture and Natural Resources. Pests of Landscape Trees and Shrubs: An Integrated Pest Management Guide 1994. University of California, Division of Agdculture and Natural Resources. Natural Enemies Handbook: The Illustrated Guide to Biological Pest Control 1998. University of California, Division of Agriculture and Natural Resources. 1PM in Practice: Principles and Methods oflntegrated Pest Management 2001 . . University of California, Division of Agriculture and Natural Resources. Turfgrass Pests 1989. City of Carlsbad Storm water Program 34 12/16/2003 December 5, 2017 Item #11 Page 42 of 53 ,· University of California, Division of Agriculture and Natural Resources. UC 1PM Pest Management Guidelines for Turfgrass 2000. University of California, Division of Agriculture and Natural Resources. Pests of the Garden and Small Farm: A Grower's Guide to Using Less Pesticide 1998. University of California, Division of Agriculture and Natural Resources. Fertilizing Landscape Trees 2001. University of California, Division of Agriculture and Natural Resources. California Master Gardener Handbook 2002. Websites California Department of Pesticide Regulation -www.cdpr.ca gov · California Fertilizer Foundation {CFF) -http://www.calfertilizer.org/ The mission of the foundation is to enhance awareness of plant nutrients and agriculture in California through educational outreach such as a school garden grants program .. The California Plant Health Association (CPHA) -http://www.cpha.net/ An organization represents the interests of the fertilizer and crop protection manufacturers, distributors, formulators and retailers in California, Arizona and Hawaii. CPHA members market commercial fertilizers, soil amendments, agricultural minerals and crop protection products. The purpose of the organization is to promote the environmentally sound use and handling of plant health products and services for the production of safe and high quality food, fiber and horticultural products. The California Department of Food and Agriculture Fertilizer Research and Education Program (CDFA-FREP) -http: I /www.cdfa.ca.gov/is/frep/index.htm Group created to advance the environmentally safe and agronomically sound use and handling of fertilizer materials. Most ofFREP's current work is concerned specifically with nitrate contamination of groundwater. FREP facilitates and coordinates research-and demonstration projects by providing funding, developing and disseminating information, and serving as a clearinghouse on information on this topic. FREP serves growers, agricultural supply and service professionals, extension personnel, public agencies, consultants, and other interested parties University of California Statewide 1PM Program -http://www.iprn.ucdavis.edu The Fertilizer Institute -http://v-rww.tfi.org/ An organization that provides educational information on fertilizers and a reference guide on public policy issues affecting the use of fertilizers. PesticideWise-http:///www.pw.ucr.edu/ Searches a comprehensive EPA-USDA database and presents critical information on a pesticides properties and water quality risks. Citv of Carlsbad Storm water Program 35 12/16/2003 December 5, 2017 Item #11 Page 43 of 53 1.1 . 7 Glossary California Code of Regulations, Title 3, Division 6 (3 CCR) California State Code regulating pesticides and pest control operations. http://www.calregs.com Equivalent Training A term refening to municipal employees dealing with the application of pesticides who have not received a qualified applicator's license or certificate (QAL or QAC) from the State of California, but who has completed a training course in pesticide application offered by the County of Orange. Eutrophication A response to an increase in the nutrient status (nitrogen and phosphorus) of a water body. The result is an increase in the growth of vegetation (usually algae), a decrease in dissolved oxygen, increased turbidity, and a general degradation in water quality. Food and Agricultural Code, Divisions 6, 7 & 13 (FAC) California state statutes relating to pesticides. Laws passed by the California Legislature. Provides the authority for the Department of Pesticide Regulation (DPR) and 3CCR. Integrated Pest Management (1PM) A sustainable approach to pest management that combines the use of prevention, avoidance, monitoring and suppression strategies in a way that minimizes economic, health, and environmental risks. Maximum Extent Practicable (MEP) MEP means taking into account equitable considerations of competing factors, including, but not limited to, the gravity of the problem, fiscal feasibility, public health risks, societal concern and social benefit. Materials Data Safety Sheet (MSDS) These sheets contain all information necessary for the sale handling of pesticides. They include chemical identifications, hazardous ingredients, physical data, fire and explosion data, health hazards, reactivity data, spill or leak cleanup procedures, special protection and special precautions. Federal law requires them to be kept on file for every pesticide or other hazardous material stored or used. Pest Control Advisor (PCA) Any person who offers a recommendation on any agricultural use (includes landscape and turf maintenance), who holds him or herself forth as an authority on any agricultural use, or who solicits services or sales for any agricultural use, must possess a valid Agricultural Pest Control Adviser License. To obtain a license the applicant must meet ce1tain educational requirements and successfully complete exan1inations relating to knowledge of pests, pesticides and laws and regulations concerning pesticide use. Officials of federal, state, and county departments of agriculture, and University of California personnel engaged in duties relating to agricultural use are not required to be licensed. A PCA must also register with the County Agricultural Commissioner (CAC). City of Carlsbad Stormwater Program 36 12/16/2003 December 5, 2017 Item #11 Page 44 of 53 ,, ·---- Pesticide Labels In California, all pesticide use is regulated through federal and state laws and regulations. Food and Agricultural Code (F AC), section 12973, states: 'the use of any pesticide shall not conflict with the registered label'. In other words "the label is the law". No pesticide can be used in California until the Department of Pesticide Regulation (DPR) has registered it. The approved pesticide label contains all the regulations regarding the use of the particular product. This includes: the EPA registration number, the active ingredient and percentage of inert ingredients, the allowed use sites, the solution and dilution rates, the personal protection equipment (PPB) needed, as well as precautionary statements, environmental hazards, m;e requirements and directions for use. To use a product in a manner inconsistent with its label is against the law. As required by federal law, manufacturers of pesticides must provide labels on the. containers of all pesticides intended for sale and distribution. Qualified Applicator's Certificate (QAC) A certificate obtained from the State of California after demonstrating adequate knowledge of the proper techniques for handling, storing, transporting and applying pesticides. Any person who uses or supervises the use of federally restricted use pesticides or state restricted materials for any purpose or on any property other than that provided by the definition of "private applicator" must have a QAC. A QAC is obtained by passing the Laws, Regulations, and Basic Principles examination and at least one pest control category examination. Qualified Applicator's License (QAL) Any person who supervises pesticide applications made by a licensed Pest Control Business and who is responsible for the safe and legal operation of the pest control business must obtain this license. Those persons who supervise the use of federal or state restricted materials for any purpose ( and on any property) other than that provided by the definition provided under "private applicator" must also obtain a QAL. Restricted Materials Permit A permit that must be acquired by any public agency before application of the pesticides listed as restricted in 3CCR, section 6000. In Orange County, this permit must be obtained from the County Agricultural Commissioner. A list of restricted materials can be found at http://www.cdpr.ca.gov/docs/license/pr-pml-013a.pdf or Agricultural Commissioner's Office. State Laws The California Food and Agricultural Code (PAC) and the California Code of Regulations, Title 3 (3CCR), constitute the laws and regulations referenced in these guidelines. They are referenced often and usually are referred to as "State Laws". Toxicity Classification The Environmental Protection Agency (EPA) groups pesticides into three categories according to their toxicity or potential to cause injury to people. Categ01y I pesticides are often the most hazardous because they are the most toxic and their use is normally restricted; they will carry the word "danger" or "danger-poison" with the skull and crossbones on the label. Category II pesticides are moderately toxic and cany the word "warning" on the label. The least hazardous pesticides are Category Ill and IV pesticides. These are slightly toxic or relatively nontoxic but basic safety precautions should still be taken. These carry the word flcaution" on the label. Citv of Carlsoad Storm water Pro cram 37 12/16/2003 December 5, 2017 Item #11 Page 45 of 53 Section I -Purpose The purpose of this Integrated Pest Management (1PM) plan is to direct health conscious and environmentally sensitive pest management strategies on city owned or controlled properties and public rights of way, in accordance with applicable federal, state and local regulations. Section II -Policy The city will focus on the prevention and suppression of pest issues with the least impact on human health, the environment, and non-target organisms. In particular, the use of chemical pesticides on city owned or operated properties and public rights of way will be significantly reduced, according to these guiding principles: A. Emphasize the initial use of organic pesticides. B. Limit the use of chemical pesticides where the general public congregates. C. Use EPA level pesticides in a targeted manner, and only if deemed necessary by supervisory staff -to protect public safety; to prevent a threat to sensitive species or native habitats; to assist in meeting regulatory compliance requirements; or to prevent economic loss -when pests cannot be managed by other tactics. Section Ill -Goals The goals of the 1PM plan are: A. Protect human health and the surrounding environment by implementing a range of preventative strategies, and using the least-toxic pesticides available for pest control and eradication. B. Monitor presence of pests on a routine basis to ensure the most effective (combination of) pest control tactics are being used. Reference Section VI. E. 6. C. Minimize the quantity of products used for pest management. D. Use species-specific products for pest management and carefully target application areas. E. Chemical pesticides shall only applied to: protect public safety; to prevent a threat to sensitive species or native habitats; to assist in meeting regulatory compliance requirements; or to prevent economic loss -when pests cannot be managed by other tactics. F. Provide public notification signs at perimeter of outdoor areas or at entrances of buildings, where chemical pesticides are to be applied. 2 December 5, 2017 Item #11 Page 47 of 53 Section VI -Pest Control Tactics Integrated Pest Management uses a variety of pest control tactics in a compatible manner that minimize adverse effects to human health and the environment. A combination of several control tactics is usually more effective in minimizing pest damage than any single control method. The type of control(s) selected will likely vary on a case-by-case basis due to differing site conditions. The primary pest control tactics to choose from include: • Cultural • Mechanical • Environmental/Physical • Biological • Pesticide A. Cultural Controls Cultural controls are modifications of normal plant care activities that reduce or prevent pests. Cultural control methods include adjusting the frequency and amount of irrigation, fertilization, and mowing height. For example, spider mite infestations are worse on water-stressed plants; over-fertilization may cause succulent growth which then encourages aphids; too low of a mowing height may thin turf and allow weeds to become established. B. Mechanical Controls Mechanical control tactics involve the use of manual labor and machinery to reduce or eliminate pest problems, such as handpicking, physical barriers, or machinery. Other examples include hoeing and applying mulch to control weeds, using trap boards for snails and slugs, and use of traps for gophers. C. Environmental/Physical Controls The use of environmental/physical controls such as altering temperature, light, and humidity, can be effective in controlling pests. Although in outdoor situations these tactics are difficult to use for most pests, they can be effective in controlling birds and mammals if their habitat can be modified such that they do not choose to live or roost in the area. Other examples include removing garbage in a timely manner, and using netting or wire to prevent birds from roosting. D. Biological Controls Biological control practices use living organisms to reduce pest populations. These organisms are often also referred to as beneficials, natural enemies or biocontrols. They act to keep pest populations low enough to prevent significant economic damage. Biocontrols include pathogens, parasites, predators, competitive species, and antagonistic organisms. Biocontrols can occur naturally or they can be purchased and released. 4 December 5, 2017 Item #11 Page 49 of 53 The most common organisms used for biological control in landscapes are predators, parasites, pathogens and herbivores. • Predators are organisms that eat their prey (e.g. Ladybugs) • Parasites spend part or all of their life cycle associated with their host. Common parasites lay their eggs in or on their host and then the eggs hatch, the larvae feed on the host, killing it (e.g. tiny stingless wasps for aphids and whiteflies) • Pathogens are microscopic organisms, such as bacteria, viruses, and fungi that cause diseases in pest insects, mites, nematodes, or weeds (e.g. Bacillus thuringiensis or BT) • Herbivores are insects or animals that feed on plants. These are effective for weed control. Biocontrols for weeds eat seeds, leaves, or tunnel into plant stems (e.g., goats and some seed and stem borers) In order to conserve naturally occurring biocontrols, broad-spectrum pesticides should not be used since the use of these types of pesticides may result in secondary pest outbreaks due to the mortality of natural enemies that may be keeping other pests under control E. Pesticide Controls As defined in California Food and Agriculture Code Section 12753, "Pesticide" includes any of the following: (a) any spray adjuvant; (b) any substance, or mixture of substances which is intended to be used for defoliating plants, regulating plant growth or for preventing, destroying, repelling or mitigating any pest ... which may infest or be detrimental to vegetation, man, animals, or households, or be present in any agricultural or nonagricultural environment whatsoever. The term pesticides includes organic products and chemica l products. Insecticides, herbicides, fungicides and rodenticides are all pesticides. Pesticides may be used when other methods fail to provide adequate control of pests and before pest populations cause unacceptable damage. When pesticides are to be used, considerations will be made for how to apply them most effectively. Pesticides that are broad-spectrum and persistent shall be avoided, since they can cause more environmental damage and increase the likelihood of pesticide resistance. The overuse of pesticides can cause beneficial organisms to be killed and pest resistance to develop. In addition, considerations should be given to the proximity to water bodies, irrigation schedules, weather, etc., that may result in the pesticide being moved off-site, into the environment. 1. Criteria for Selecting Treatment Strategies Once the 1PM decision making process is in place and monitoring indicates that pest treatment is needed, the choice of specific strategies can be made. Strategies will be chosen that are: a) Least hazardous to human health b) Least disruptive of natural controls in landscape situations c) Least toxic to non-target organisms other than natural controls d) Most likely to be permanent and prevent recurrence of the pest problem e) Easiest to carry out safely and effectively f) Most cost effective in the long term g) Appropriate to the site and maintenance system 5 December 5, 2017 Item #11 Page 50 of 53 2. Selection of Appropriate Pesticides The following criteria will be used when selecting a pesticide: a) Safety b) Species specificity c) Effectiveness d) Endurance e) Speed f) Repellency g) Cost When selecting pesticides, supervisory staff will rely on advisement from State of California certified pest control applicators, to ensure that the most appropriate pesticide is selected. 3. Prioritized Use of Pesticides Pesticides are to be utilized in a prioritized approach on city properties as follows: a) Organic pesticides to be used first, when pesticides are deemed necessary. b) Pesticides registered with the California Department of Pesticide Regulations Registrations Branch to be used as a protocol. c) U.S. Environmental Protection Agency {EPA) Toxicity Category Ill "Caution" label pesticides to be used in a targeted manner by a certified pest control applicator, and only if deemed necessary by supervisory staff-to protect public safety; to prevent threats to sensitive species or native habitats; to assist in meeting regulatory compliance requirements; or to prevent economic loss - when pests cannot be managed by other tactics. d) U.S. EPA Toxicity Category II "Warning" label pesticides to be used in a targeted manner by a certified pest control applicator, and only if deemed necessary by supervisory staff-to protect public safety; to prevent threats to sensitive species or native habitats; to assist in meeting regulatory compliance requirements; or to prevent economic loss -when pests cannot be managed by other tactics. e) U.S. EPA Toxicity Category I "Danger" label pesticides, to be used in a targeted manner by a certified pest control applicator, and only if deemed necessary by supervisory staff -to protect public safety; to prevent threats to sensitive species or native habitats; to assist in meeting regulatory compliance requirements; or to prevent economic loss -when pests cannot be managed by other tactics. 4. Certification and Permitting Restricted use pesticides shall only be applied by, or under the direct supervision of, an individual with a State of California, Department of Pesticide Regulations, Qualified Applicators Certificate. Pesticides listed as "restricted" in the State of California shall be applied on ly under a restricted materials permit, issued by the San Diego County Department of Agriculture, Weights and Measures. The permit must be renewed annually for continued application. 6 December 5, 2017 Item #11 Page 51 of 53 5. Employee Training Staff and contractors must know the information on the chemical label and the MSDS before using or handling the chemical. In addition, they will be trained annually and when a new pesticide is to be used. The certified pest control applicators must know: • The immediate and long-term health hazards posed by chemicals to be used, the common symptoms of chemical poisoning, and the ways poisoning could occur; and • The safe work practices to be followed, including the appropriate protective clothing, equipment, mixing, transportation, storage, disposal and spill cleanup procedures applicable to the chemical used • In addition to the training and annual continuing education required for certification, staff will be encouraged to participate in pesticide application programs that are above and beyond minimum compliance requirements. 6. Record Keeping Monitoring the effectiveness of the 1PM plan over time requires diligent tracking of several items: pest populations and locations; management strategies employed; quantities and types of chemicals or other products used; and the outcome of pest management activities. The certified pest control applicator is responsible for maintaining, and submitting to the city as requested, records that include the following: a) Target pest b) Prevention and other non-chemical methods of control used c) Type and quantity of pesticide used d) Location of the pesticide application e) Date of pesticide application f) Name of the pesticide applicator g) Application equipment used h) Summary of results 7. Materials for Use -Least Toxic Pesticides Pesticides are considered a secondary resort under the tenets of 1PM. This control strategy is to be used on city owned or controlled properties and rights of way after general preventative practices and non- chemical options -including organic pesticides -have been fully explored. Least-toxic pesticides meet the following criteria: a) Products contain no known, likely, or probable carcinogens -as listed by the CA Office of Environmental Health Hazard Assessment. b) Products contain no reproductive toxicants (CA Prop 65). c) Products contain no items listed by the CA Department of Toxic Substance Control as known, probable, or suspected endocrine disrupters d) Active ingredients have soil half-life of thirty days or less. e) Products are labeled as not toxic to fish, birds, bees, wildlife, or domestic animals. 7 December 5, 2017 Item #11 Page 52 of 53 The term "least toxic" refers to pesticides that have low or no acute or chronic toxicity to humans, affect a narrow range of species and are formulated to be applied in a manner that limits or eliminates exposure of humans and other non-target organisms. Examples of least toxic pesticides include products formulated as baits, pastes or gels that do not volatilize in the air and that utilize very small amounts of the active ingredient pesticide, and microbial pesticides formulated from fungi, bacteria or viruses that are toxic only to specific pest species but harmless to humans. Least toxic pesticides include: • Boric acid and disodium octobrate tetrahydrate • Silica gels • Diatomaceous earth • Nonvolatile insect and rodent ba its in tamper resistant containers • Microbe based pesticides • Pesticides made with essential oils (not including synthetic pyrethroids) without toxic synergists • Materials for which the inert ingredients are nontoxic and disclosed. The term least toxic pesticides does not include a pesticide that is: a) Determined by the U.S. EPA to be a possible, probable or known carcinogen, mutagen, teratogen, reproductive toxin, developmental neurotoxin, endocrine disrupter or immune system toxin. b) A pesticide in the U.S. EPA's Toxicity Category I or II. c) Any application of the pesticide using a broadcast spray, dust, tenting, or fogging application. 8. Notification Signs Chemical pesticide application notification signs shall meet the following criteria: a) Posted at perimeter of outdoor areas or at building entrances, where chemical pesticides are to be applied. b) Posted at least 24 hours prior to application of chem ical pesticides and shall remain for at least 72 hours after the application. c) Include "Notice -Pesticide Treated Area," and product's/manufacturer's name, scheduled date of application, and pest to be controlled -e.g., weeds, insects, rodents. 9. Revisions Staff will review this 1PM plan annually at minimum, and update it as needed. 8 December 5, 2017 Item #11 Page 53 of 53 From: Kim Konte (mailto:] Sent: Tuesday, December 05, 2017 1:11 PM To: Matthew Hall <Matt.Hall@carlsbadca.gov>; Keith Blackburn <Keith.Blackburn@carlsbadca.gov>; Michael Schumacher <michael.schumacher@carlsbadca.gov>; Cori Schumacher <Cori.Schumacher@CarlsbadCA.gov> Cc: Council Internet Email <CityCouncil@carlsbadca.gov>; City Clerk <Clerk@carlsbadca.gov>; Manager Internet Email <Manager@CarlsbadCA.gov>; Attorney <attorney@CarlsbadCA.gov>; Bruce Blumberg_; Defln Baker db k h .Hn ern # 1L < a Robert Jo nson < F h I f . f h S b. t M · f 1-b·i·t· t d f 1 . or t e n ormat1on o t e: u Jee : ovmg away rom 1a 1 1 1es o proven an sa e so ut1ons CITY COUNCIL - ACM VvCA VCC v Dear Mayor Hall Carlsbad's City Council members, Datel~City Manager 7 My name's Kim Konte and I'm one of the founding members ofNon Toxic Irvine and we have been working closely with your Non Toxic Carlsbad team. We have also met with some of your City staff last summer. Bob Johnson(NTI co-founder) who was in the same meetings will present tonight at the City Council meeting in support the City Council voting in 11, 3b. We are asking that you please make the health of your resident's health your priority over weed abatement by voting for agenda item 11 -3b Adopt Update to the IPM Plan-All sites with Immediate Implementation. Setting aside public health considerations, is the City of Carlsbad prepared for the potential financial and legal liabilities related to allowing a known carcinogen to be applied in the city's playgrounds and parks exposing the most at risk population -particularly when this is to be done for purely cosmetic reasons? Today there are so many proven and cost effective options that we would be happy to share with you. Thanks to the City of Irvine's organically driven IPM that was unanimously voted into City policy on 2/23/16, the City of Carlsbad can implement Irvine's best practices. The City leaders and school districts from of San Juan Capistrano, Burbank, and now Tustin have all banned glyphosate in all of their parks, playgrounds, and athletic fields. We have worked with their City staff and school district staff to share not only proven, but cost effective options. Thanks to Irvine's purchasing power and the other cities coming online, we now have local distributors that are providing these products at a lower cost than going directly through the manufacturer. Our school district and Pepperdine have been able to switch to organic landscaping practices at the same cost from the previous year when they were chemically maintained. With all do respect how can your City staff get accurate costs to switch to safe landscaping practices from a landscaping company that has yet to implement these practices and has lost multiple HOA contracts for their current and toxic landscaping practices? We met with Park West Landscaping's president(Dustin) and staff have at their request. They shared that they want to become the gold standard in organic landscaping practices, but unfortunately they are in the beginning stages and are not in a place to provide accurate information in safe landscaping practices, methods, products and costs at this time. We would share our contacts at the distributers that are transitioning away from toxic pesticides and moving to safer products as a result to the growing demand. Both Siteone and Simplot have the knowledge and product portfolio to keep your costs down and weed pressure controlled. The chemical distributer, Target does not and will only provide misinformation as they do not have the product line to support safe landscaping practices and they do not want to loose more business. They lost the City of SJC, and now Burbank as a result. Not only will your parks aesthetics improve, it will also increase your resident's property value when you can share that your parks, playgrounds and athletic fields are "Organically Maintained Landscape". Below are two of our City Council members, Councilwoman Shea and Councilwoman Fox next to Irvine's new park signs. Photo of your current landscape contractor who was caught broadcast spraying 2,4-D(agent orange) in a drive by application. The same pesticide our City and school district banned over 2 years ago due to its related health risks in an HOA they are under contract to maintain. As a result the developer has agreed to implement the City oflrvine's organically driven IPM in all of their HO As in the City oflrvine to protect their residents from Park West's current landscaping practices. 2,4-D: https://www.nrdc.org/stories/24-d-most-dangerous-pesticide-youve-nevcr-heard Again, Carlsbad does not need to reinvent the wheel, you can emulate the City of Irvine's approach and practices. Irvine has already done the work providing us with best practices, proven products, distributer channels, and you also have the opportunity to avoid products from their "lessons learned" items. Please find attached the City of Irvine's 1PM: The staff report from Carlsbad's City staff is full misinformation: City oflrvine's parks are not only beautiful, they are also safe. Take a look for yourself in this 3 min, video we made to thank our City leaders for making our children's health their priority over weed abatement: ht1ps://youtu.be/rA8rAz91 YN4 Irvine Unified School District not only has the appearance, soil and turf conditions improved, at IUSD's first organic pilot sites, they have now been able to conserve water as the soil at these sites have had time to heal from the previous synthetic inputs. At these 2 pilot sites they have been able to cut their in-igation days from 6 days a week down to 2 days a week! We would be happy to share the soil reports, approach and costs with you. Below is an example of the same Systems Approach excited in Boston, MA: ** #3. "To protect public safety" is to stop using toxic pesticides for weed control, especially since this is currently allowed in our parks, playgrounds and athletic fields directly exposing our most at risk population, especially for cosmetic purposed. A dandelion does not pose a risk to the health of a child or our environment, but the herbicides you allow do. For the past 22 months since the City oflrvine adopted an organically driven IPM they have been able to successfully maintain all pest pressure from weeds to rodents organically for more than 570 acres of community and neighbourhood parks and athletic fields; over 800 acres of public right- of-way, including street medians and parkways, 70,000 plus trees; and nearly 1.5 million square feet of facilities. There was one instance last summer when they almost had to use an EPA registered rodenticide to combat a ground squin-el issue they had as it was becoming a potential hazard as they were damaging the root base for a tree close to a home. They shared this issue and NTI was able to find other options that proved successful to combat the pest pressure. They used a burrow blocker to flush them out and backfill the soil. The staff report just reflects their lack of knowledge in implementing safe landscaping practices. Once you stop using synthetic inputs the soil has time to heal and once this happens the soil retains water, and will also naturally choke out weed pressure. If done correctly like Irvine Unified School district has been able to do, the field conditions not only improve from an aesthetic standpoint, but the fields are less compact and safer for the students and athletes playing on them. Non only had Irvine's school district implemented this approach so has Pepperdine University who's devision 1 soccer coach will happily share with you, that he has never seen the field look and preform better. The use of chemical pesticides on city owned or operated properties and public rights of way \VOu!d be significantly reduced, based on the guiding principles of the update to the 1PM Plan: L Emphasize the initial use of organic pesticides. 2, limit the use of chemical pesticides where the general public congregates. 3. Use EPA Toxicity Category pesticides in a targeted manner by a certified pest control applicator. and onl•; if deemed necessary by supervisory staff. to protect public safety; to prevent threats to sensitive species or native habitats; to assist in meeting regulatory compliance requirements; or to prevent economic loss. when pests c.H1not be mar1t1ged by other tactics. The majority of the recent concerns expressed by citizens regarding the application of certain chemiul pesticides have pertained to school sites, parks and similar recreation.ti areas. The PMks & Recre,Hion Oepartment maintains and oper,ltes portions of 10 school sites in th€' city, under Joint Use Agreements with three school districts. As an informal pilot progr.im, over the last 15 month,;, .. taff directed the contractor ma,ntaining the sites to forego the use of chemical pesticides. Only no,Hhemical pest control tactics were used on these sites during this period. The effect.veness of these tactics has been modest In particular, a greater number of weeds a:1d burrowing rodents has been evident on the school sites. These conditions had a moderately negative effect on the ae'>thetics of the school sites· landsupes, and in particular, on the playability of the athletic fields. To date, however, the number of complaints received by staff on the landscape and field conditions at these school sites has been relatively low. The increased maintenance costs for this lS month program have been approximately $10,000. • Since Carlsbad already has an 1PM why is this section even in the staff report? Tabk 1.14 Advaotageta,ad D~'tlntagcs ofa Pt:Stiridc-Basld Progr:am Versus. an IPM-8asat Pdt Control Pn,imm. I_ ___ P~ici!)e B~tl Pc t Control · ! ,\,h. nl:tgtt ·-·-___ i-.:.:;O:.::l~~:,::.<h;,;":2:.:,n:.:;f::,,;:..,•~a:_ __ ;..:,:.::.:.:=::.;,,:..;:._ ___ i-:,:D.:.;i,:.:::i~d>'.:.::,:n:Jt·;:.:l';;,:• ~- I l)nid; si,prn-:.ssioo l'lf Lt.: " of ll,l(i1n I T l':lirun.; is requir~r,_;-I !I r,.: K control~. i.l.:111ily ~ ond . , 1\1tui':ll ~mi..-" I: jl-"I ~ i~ nl~· frr , ,,1 1,,ng-i.-m, ,\fu.g h:nc: kn<, -i.~..: ! nfJ)m~. ofp::-i.i.:· •· illJJ their ·ff('CH other ftt•.,,;1n,'\n1~. -=-..,.....-,----i NI>\ nm,:h pn.1',1t:11i<)n folfolW·!IJl 1,:..-J..'\l. Morr. p.,lkid..-in rn,·irur.mcnt c:~;i;,;;1i;·1J,i.,,n ,, \\.~!~t (.>CJiN lf'1..-t> r 1111. ______ _ l<c-JucN ,f,mptic,n of 0.11 •ul :tl<C!Ok."l'. ~ ____ i-c;.ruoolf. , --· . -. P :i..-uJ.: ~i';t~ f1•r. R,·Juc,. :1i1plit;1ll'~. I 1t>lic nml:>llllll.\l,on !rcr.1 .1111m.'I -. n:.iuff Mu I nra::11.1w II l r,,-.m.1-l..,-... 1ii11,: 1 1 ,-..-sltnl. Mnst <c,-.;11 r~ubrly. I Lal-ur i, r,~vir J fi1r ; tnou1h\f ln:; Often \:Ct c«Jt>n.-;,l •ot' · L,·,{, p,,·ur.: 1 · • --·-·-· · ---·---- r . -_J ·~~~~. • _Lf"::·,IJ\'.<. ~---.. ·--·---. : t'J'\ N' l"l'n:,~11, · m -·i I ~ ,~:''"1 «. ... Cilrvf .1ll! •,.)~ .J. I ----·---J Beyond Pesticides and Pepperdine University Center for Sustainability, Governmental & Regulatory Affairs will be awarding the City of Irvine and Irvine Unified School District for the health protective actions they made to protect our children and the environment. The City oflrvine adopted an historic organics-first landscaping policy in February 2016. Since then the City of Irvine has been able to successfully maintaining all pest pressure from weeds to rodents organically for more than 570 acres of community and neighbourhood parks and athletic fields; over 800 acres of public right-of- way, including street medians and parkways, 70,000 plus trees; and nearly 1.5 million square feet of facilities. Irvine Unified School District, they have banned the use of glyphosate in May 2015. Since then, IUSD created a new Progressive Pest Management (PPM) Playbook, Policy, and Organically Focused 2017-18 Pesticide List. They are now organically maintaining all 42 IUSD sites and are in the process of switching all IUSD emission equipment to silent, non-emissions equipment. This will include battery operated blowers, edger's, chainsaws, and eventually mowers. We know how lucky we are to live in a City that makes the health of our children and the environment their priority, and we are encouraged to see other cities and school districts taking the actions needed to do the same for their residents. The City of Irvine and our school district are now receiving awards for the health protective actions they made to protect our children and the environment. This's something we want to see the City of Carlsbad get in front of. .-., ·, .. Non Toxic IRVINE • "The major challenge with showing that a chemical causes cancer in humans fas opposed to animals] is that the cancer typically develops many years after exposure." -Non Toxic Irvine advisor, Dr. Bruce Blumberg, PhD. UCI Professor of Developmental and Cell Biology, and Professor of Pharmaceutical Sciences "By allowing children to be exposed to toxins or chemicals of unknown toxicity, we are unwittingly using our children in a massive experiment," -Non Toxic Irvine advisor, Bruce Lanphear, professor of health sciences, Simon Fraser University, Canada "Impacts from multiple chemicals may simply add up, amplify one another's effects," -David Bellinger, professor of neurology at Harvard Medical School Best, Kim Non Toxic Ii-vine Jane Goodall's Roots & Shoots \v,vw.nontoxicirvine.org 0 Soil Biology & Biochemistry ELSffil.IER Soil Biology & Biochemistry 37 (2005) 1303-1307 www.elsevier.com/locate/soilbio Glyphosate degradation as a soil health indicator for heavy metal polluted soils S.A.E. Kools*, M. van Roovert, C.A.M. van Gestel, N.M. van Straalen Department of Animal Ecology, Institute of Ecological Science, Vrije Universiteit, De Boelelaan 1087, 1081 HV Amsterdam, The Netherlands Received 17 August 2004; received in revised form 26 November 2004; accepted 30 November 2004 Abstract Glyphosate is a commonly used herbicide in grassland soils and microorganisms control its degradation. We introduce the concept of using the degradation rate as an indicator for ecosystem health. Testing this concept, we used soils with a long history of heavy metal pollution (Cu, Pb, and Zn). We hypothesized lower degradation rates in metal-polluted compared to less polluted soils. The degradation rates were measured by repeated measurements of the parent compound in spiked soil-water slurries incubated at 20 °Cover 21 days. Average rates showed no differences comparing among soils. We observed a positive correlation between glyphosate degradation rates and soil metal pollution. Therefore, we concluded that the expected impact of the metals on the bacteria responsible for the herbicide degradation was not established. We discuss the potential influence on biological degradation rates of soil pH and adsorption and implications using the concept of the soil health indicator. © 2005 Elsevier Ltd. All rights reserved. Keywords: Bacteria; Ecosystem health indicator; Glyphosate degradation; Heavy metal; Copper; Lead; Zinc 1. Introduction In the Netherlands, some peaty grassland areas received city waste for soil emichment and reinforcement. As a result, these soils contain elevated metal concentrations, of which lead and zinc are locally exceeding legal intervention values (Bosveld et al., 2000). Risk assessments indicated a serious threat for this soil and legislation demands intervention to clean the soil (Vegter, 1995). Toxicity data of species and processes, obtained in the laboratory, are the basis for estimations of these intervention values. Besides determining the impact on single organisms, current eco- toxicological research seeks indicators for effects at the ecosystem level (Van Straalen, 2002). Degradation of xenobiotic compounds is an important indicator for healthy ecosystems. We hypothesized that the capacity to degrade xenobiotic compounds is reduced because of long-term exposure of bacterial communities to heavy metal pollution. Studies have shown reduced degradation of diesel fuel * Corresponding author. Tel.: +31205987217; fax: +31205987123. E-mail address: stefan.kools@ecology.falw.vu.nl (S.A.E. Kools). 0038-0717/$ -see front matter© 2005 Elsevier Ltd. All rights reserved. doi: 10.1016/j.soilbio.2004.11.026 (Riis et al., 2002) and other organic compounds (Doelman et al., 1994) in soils impacted by heavy metals. In this study, we studied the degradation of the herbicide glyphosate (N-phosphonomethyl-glycine). This is often used to control 'weeds in grasslands but detailed information on degradation rates is lacking. Glyphosate is the active ingredient of the commonly used herbicide Roundup®. Plants take the herbicides up very easily and then, it exhibits specific growth reduction by interfering upon the metabolism of essential aromatic compounds in the shikimic acid pathway (Cole, 1985). This herbicide is an organophosphonate, characterized by the presence of a stable, covalent carbon to phosphorous (C-P) bond. Very specific bacteria seem to be responsible for degradation (Dick and Quinn, 1995; Forlani et al., 1999). Since few bacteria isolates grow solely on glyphosate, degradation in non-limiting environments is thought to result from co-metabolism (Teman et al., 1998). Glyphosate can act as a carbon source, but growth stimulation is more apparent when applied in high concentrations (Busse et al., 2001). We studied the initial degradation rate of glyphosate during an incubation period of 20 days. Previous research 1304 S.A.E. Kools et al. I Soil Biology & Biochemistry 37 (2005) 1303-1307 showed that this is predominantly the rapid initial degra- dation of the labile fraction of glyphosate (Eberbach, 1998). Soil pH, clay, or organic matter content (Torstensson, 1985) not largely influence this rate, enabling a comparison among different soils in this study. 2. Materials and methods 2.1. Soil sampling We selected research areas, based on the presence of elevated heavy metal concentrations. Three sample areas were close to each other in an area called Demmerikse polder, Ronde Venen, located southeast from Amsterdam, The Netherlands (52°131 North 4°56' East). This region received city waste as fertilizer and soil reinforcement since the 1600s and later, extensive cattle farming was the main form of land use. The area shows a very heterogeneous pollution pattern, thus 150 soil samples were taken earlier to identify spots differing the most in total heavy metal concentrations. We sampled using a soil drill of 3 cm wide and 10 cm deep and discarded the root zone (0-2 cm). Samples were first dried over night at 50 °C, then crushed using a mortar and subsequently analyzed for metal concentrations using a XRF spectrum analyzer (XTAC Analytical, Leiden, The Netherlands). We sampled seven spots in the location containing the lowest concentrations of zinc, lead, and copper (part A) and another seven at the location with the highest concentrations (part B). In adjacent grasslands with more intensive land management, e.g. manure application (part C), six samples were taken. Outside this area, we selected Folder Blokland and Folder Zeevang based on expected lower metal concentrations and comparable land management practices to serve as refer- ence locations. Folder Blokland lies 20 km west of Folder Demmerik while Folder Zeevang is located 38 km north. At all locations, we sampled the top 10 cm soil layer in duplicate, by means of the same soil drill; again first 2 cm discarded. Directly after, samples were stored in the dark at 5 °C. Analyzing duplicate soil samples, we used one for characteristics and metal contents and the other for the degradation experiments. 2.2. Metal analysis Soil samples were first dried over night at 100 °C and then pulverized using a ball mill. Subsequently, 2 ml demineralized water; 6 ml hydrogen chloride (HCl: 37%, ultrex grade: Baker, Philipsburg, NJ, USA) and 2 ml HN03 (65%, ultrex grade, Riedel-de Haen, Seelze, Germany) were added to 1 ± 0.1 g soil. In a microwave oven (CEM Mars 5), we digested this mixture for 60 min at a pressure of 100 psi and a temperature of 150 °C. After cooling, we added 15 ml demineralized water. Metal concentration in the solutions was determined by flame Atomic Absorption Spectrometry (AAS) using a Perkin Elmer 1100B. San Ioaqin soil (NIST, Gaitersburg, MS, USA) served as certified standard reference material to maintain quality control. To get an estimate of metal exposure to organisms, 0.01 M CaC12 exchangeable zinc concentrations were determined (Houba et al., 1996). Using fresh soil, we added 20 g to 50 ml 0.01 M CaC12 in water and rotated this for two hours at 200 rpm. The pH of these samples was determined using a Consort P907. After precipitation of soil particles, we analyzed zinc concentrations using flame AAS. 2.3. Organic matter and clay content We calculated organic matter contents by determining loss on ignition. For this, porcelain crucibles were previously weighed. We filled these with soil samples, previously dried at 100 °C over night, then weighed them and finally placed them at 450 °C for 6 h and weighed again. For determining the percentage clay, a 'laser particle sizer' A22 was used (Fritsch GmbH, Idar Oberstein, Germany). This method is based on the forward scattering of monochromatic coherent light. We prepared the samples and did the analysis as described in (Konert and Vandenberghe, 1997). 2.4. Glyphosate degradation Five grams of fresh soil were transferred to a 100 ml Erlenmeyer flask and 20 ml demineralized H20 was added. We put the flasks in a rotary shaker at 150 rpm and incubated them at 20 °C. The starting concentration was 10 mM glyphosate (N-phosphonomethyl-glycine, > 96%, purchased from Fluka, Buchs, Germany). Immediately after, we centrifuged 500 µl aliquots at 8000 g. Sub- sequently; we performed a pre-column derivatization, thus enabling high performance liquid chromatography (HPLC). We added 130 mM p-toluene-sulphonyl chloride ( > 99%, Fluka, Buchs, Germany) in acetonitrile (1:1 v/v, pH 11.3) (Tomita et al., 1991) and injected the extracts on a 4.6X 250 mm Supelcosil ODS column equilibrated with 50 mM di-sodium-hydrogen-phosphate-2-hydrate buffer (99.5%, Riedel-deHaen, Seelze, Germany). While the isocratic elution proceeded at a flow rate of 1 ml/min, we monitored at 240 nm (UV-ABS) using a diode array detector (Gynotek, Munich, Germany). We made a glyphosate standard dilution series and calculated the concentrations using the area under the curve (the lower limit of detection was 0.2 mmol/1). This procedure was repeated 1, 3, 6, 8, 10, 13, 15, 17 and 20 days after the start of the experiment. 2.5. Data handling We natural log transformed the data, and preformed a linear regression on each individual sample. Assuming first order kinetics, we modeled the starting concentrations (CO) and degradation rate constants (k) from plots of logarithmic concentrations against time using SYST AT 10 software S.A.E. Kools et al. I Soil Biology & Biochemistry 37 (2005) 1303-1307 1305 Table 1 Average soil characteristics ± SD from the sampled areas in the Netherlands over N replicates, total metal concentrations (in bold exceeds Dutch legal intervention values) and 0.01 M CaC12 exchangeable zinc concentrations (in mg/kg dry soil) Area Cu Pb Zn pH" Clay(%) O.M.b(%) Zeevang (N=6) Total 35±3 90±29 162±31 6.0±0.1 30±4.5 40±3.4 Exchangeable 2.3± 1.1 Blokland (N = 6) Total 67± 11 265±59 228±22 5.9±0.4 25±2.2 25±4.2 Exchangeable 4.6±0.96 Demmerik A (N = 6) Total 115±36 540±205 271 ±62 6.5±0.5 10±2.3 60±4.6 Exchangeable 4.6±3.4 Demmerik B (N = 7) Total 134±23 726±103 298±35 5.8±0.5 13±0.8 41 ±0.7 Exchangeable Demmerik C (N = 6) Total 178±23 802±89 Exchangeable a Measured in 0.01 M CaCli. b Organic matter(% loss on ignition). package. From (k), half-lives were expressed as DT50 (days at which 50% of the herbicide is degraded). We used SPSS version 10.0 for calculating means for the different polders, based on individual degradation rates and Pearson corre- lations with soil characteristics, with a significance level of P<0.05. At last, we calculated a partial correlation, controlling for soil pH. 3. Results 3.1. Soil analysis First, we compared the soil characteristics (Table 1). All soils had a high organic matter content, some up to 60% and the clay fraction varied from 10 to 30%. The total lead concentration had the greatest range from 69 to 911 mg/kg DW, while zinc and copper had similar patterns among the different soils, but showed smaller ranges (Cu: 31- 207 mg/kg DW, Zn: 134--480). Locally, lead exceeded the intervention value of 750 mg/kg DW, also after correction for the high clay and organic matter contents (\/ egter, 1995). Heavy metal concentrations correlated not significantly with organic matter, but in contrast, negatively correlated with the content of clay (Pearson, Cu: -0.65, Pb: -0.62, Zn: -0.50). We found the same for soil pH (Pearson, Cu: 0.8 0.6 * ~ 0.4 [!? E .c ~ 0.2 Cl. C >, 0 ~e .E c: t§ f 8 -0.6 -0.8 0 -0.2 -0.4 -1 I - ---............ 0 ~ -~ ~--............_ --....__ 5 10 15 20 25 Time (days) Fig. 1. Representative example of the logarithmic transformed glyphosate concentrations, measured during incubation at 20 °C of a glyphosate-soil suspension, showing the fitted curve. 7.3±2.7 397±61 5.5 ±0.4 13± 1.3 42±2.4 8.8±2.5 -0.38, Pb: -0.47, Zn -0.51). Exchangeable zinc concentrations in 0.01 M CaC12 solution were around 50 times lower than total metal concentrations and were positively correlated (Pearson coefficients, 0.68, P<0.01), making it an estimator of exposure. Exchangeable copper and lead concentrations were below detection limits. 3.2. Glyphosate degradation Fig. 1 shows a representative example of the glyphosate concentration measured over time. In total, we selected 31 samples with a significant individual fit using the log-linear regression model (one-way ANOVA, P<0.01). We dis- carded one curve due to technical errors during incubation. The coefficient of determination (r2) ranged from 0.65 to 0.99. Rapid degradation of glyphosate was comparable in all soils (Table 2) and the derived glyphosate half-lives (DT 50) varied from 5 to 23 days. We observed no significant correlations between degradation rates and the soil organic matter or the clay content. On the contrary, we found low, but significant positive correlations with the total metal concentrations (Pearson, P<0.05) by performing analyses on all individual observations (Fig. 2, Cu: 0.40, Pb: 0.43, Zn: 0.37). Plotting the exchangeable concentrations showed a higher correlation (0.61) between degradation rates and exchangeable zinc concentrations (Fig. 3). Furthermore, degradation rates positively correlated with soil pH (Pearson, 0.53, P<0.01) (Fig. 4). We therefore included a partial correlation (Table 3), which decreased correlation coefficients. Table 2 Average degradation rates (k) and expressed half-lives (DT50) in days of glyphosate in different soils and their range (min-max) over N replicates SOIL N k (day-1)±SD DTso min-max Zeevang 6 0.0500±0.009 14.3 12-20 Blokland 6 0.0478±0.Q18 16.1 9.3-23 Demmerik part A 6 0.0524 ± 0.019 14.3 8.6-23 Demmerik part B 7 0.0557±0.014 13.2 8.7-18 Demmerik part C 6 0.0654±0.010 10.8 8.9-14 1306 S.A.E. Kools et al. I Soil Biology & Biochemistry 37 (2005) 1303-1307 2 90 e 80 Ji">: 70 -Cll co 'C 60 ~~ 50 X OJO ~~ 40 ma 30 1iiE "' E 20 _g~ a. 10 >, 0 0 0 200 400 600 800 1000 Total metal concentration (mg/kg/DW) Fig. 2. Glyphosate degradation rates (µmol/g DW/day) plotted against total metal concentrations (X =Cu, + =Zn and O =Pb, mg/kg dry soil), all significant correlations: (Pearson, P<0.05, 31 samples). 4. Discussion 4.1. Glyphosate degradation rates This is the first time degradation rates of glyphosate were determined in relation to existing heavy metal pollution in soils and the use as a soil health indicator. Contrary to our hypothesis, we did not observe reduced rates of degradation in polluted soils. We therefore concluded that these polluted soils degrade glyphosate to at least the same extent as non- polluted soils. This finding is in contrast with earlier studies (Doelman et al., 1994; Riis et al., 2002). From parallel studies on soil from Polder Demmerik (Boivin et al., unpublished), we learned that the presence of heavy metals negatively correlated with bacterial biomass, BIOLOG substrate utilization, and growth rates. Fungi, which might be favored in slightly acidic soils, can contribute to microbial degradation of glyphosate (Krzysko-lupicka and Orlik, 1997), but we have no specific fungal data available. Our degradation rates seems to be consistent with literature (Cheah et al., 1998; Eberbach, 1998), though comparing these degradation rates of glyphosate is not fully justified because of the higher temperatures (30 and 25 °C 90 2 80 ~ c_ 70 .Q >--"' 60 "''O e~ 50 c»O • i.e, 40 Cl) 0 iiiE 30 "'E _g~ 20 0. >, c3 10 0 0 2 4 6 8 10 12 14 Exchangeable Zn (mg/kg OW) Fig. 3. Glyphosate degradation rate (µmol/g DW/day) plotted against 0.01 M exchangeable zinc (mg/kg DW) in the soil concentration- significant correlation (Pearson, 0.61, P<0.01), 31 samples. 90 80 §-70 ., iii' "'-o 60 ~~ O>O 50 ~Ql 40 {';l ~ 30 g.s 20 5:; 10 cl 0 4.50 ... • ~ ---... .,, ~ • .... -----• ·-· .... -:-- 5.00 5.50 6.00 6.50 7.00 7.50 pH (0.01M CaCl2) Fig. 4. Glyphosate degradation rates (µmol/g DW/day) plotted against soil pH (as measured in 0.01 M CaCJ2 solution)-significant correlation (Pearson, 0.53, P<0.01), 31 samples. respectively) in these studies, possibly influencing bacterial activity (Heinonen-Tanski, 1989). 4.2. Possible factors determining glyphosate degradation Although being correlative, the apparent positive effect of the heavy metal pollution on the degradation of this compound is intriguing. Exchangeable metal concentrations in these soils were indicative for lead and copper pollution and these concentrations are one thousand times lower than the total concentrations in these soils. Based on the observed lower bacterial biomass and activity in the parallel study, one would indeed expect a reduced degradation rate, as co- metabolism is the primary mechanism for glyphosate degradation (Teman et al., 1998). We noted that these methods are based on the biological degradation of aromatic carbon containing compounds, lacking carbon-phosphate bonds, making direct comparisons not fully justified. The degradation of these bonds appear to involve specific bacterial communities as described by (Forlani et al., 1999). We concluded that the apparent positive effect of heavy metals on glyphosate degradation confounded by pH, as indicated by partial correlation (Table 3). The effect of soil pH on rapid initial degradation rates was thought to be negligible (Torstensson, 1985), which is not the case in this in this study and we paid more attention to this observation. The influence of the soil pH on the bacterial community responsible for this degradation can be of importance. Soil pH can also affect the adsorption of the labile fraction, which seems to be stronger in acidic soils Table 3 Correlation coefficients between degradation constants (k) and heavy metal concentrations (total and 0.01 M CaCJ2 exchangeable) of 31 samples with and without controlling for soil pH (partial correlation) Correlation k with: Total Zn Total Pb Correlation coefficient 0.37* 0.43* Total Cu 0.40* Exchangeable Zn 0.61 * *Significant (P < 0.05), NS: not significant. Controlling for pH 0.27 NS 0.34 NS 0.29 NS 0.41* S.A.E. Kools et al. I Soil Biology & Biochemistry 37 (2005) 1303-1307 1307 (e.g. Eberbach, 1998). Next to this, glyphosate is a metal chelating herbicide (Subramaniam and Hoggard, 1988). Copper-glyphosate complexes showed a higher affinity for soil (Morillo et al., 2000). We did indeed observe that soils with higher exchangeable concentrations showed a higher initial decrease of the nominal glyphosate concentrations. The formation of complexes proceeds rapidly and is not likely to have played a role over the extended time window of our experiments (20 days). Therefore we believe that metal complexation by glyphosate cannot explain the higher apparent degradation rates in metal-polluted soils. Metal-glyphosate complexes might however be trans- ported more efficiently across microbial cell walls than the sole compound, but such a mechanism is not documented. Together, these phenomena are not to be ruled out in assessing degradation rates, while the question remains unclear which is more to occur. 4.3. Conclusion We concluded that glyphosate degradation is not a sensitive soil health indicator, since this process is compli- cated due to the chelating behavior of glyphosate. Subsequent soil bound glyphosate exhibits a half-life of up to 22 years (Eberbach, 1998) and investigating these soil-glyphosate complexes is of high interest, since the bulk of the pesticide will remain in this fraction. Next to that, degradation and/or toxicity are not fully understood, especially not for metal polluted soils. Studies on fate and biological degradation in time, using controlled pH and soils polluted artificially with heavy metals give results that are more conclusive. In general, assessments of the purifying function of polluted soils in the light of ecosystem health indicators should consider both short-term and long-term effects. Acknowledgements The authors thank Gerdit Greve (RIVM, Bilthoven, The Netherlands) for clay and organic matter analysis, Rudq Verweij and Henk Lingeman (VU) for help with the HPLC- analysis and Tjalling Jager and Rik Zoomer for statistical assistance. We thank Thea Edwards (UFL, Gainesville FL, USA) and two anonymous reviewers for improvements on the manuscript and the Netherlands Organization for Scientific Research (NWO) for financial support within stimulation programme system-oriented ecotoxicological research (SSEO). 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Effects of heavy metals in soil on microbial diversity and activity as shown by the sensitivity-resistance index, an ecologically relevant parameter. Biology and Fertility of Soils 17, 177-184. Eberbach, P., 1998. Applying non-steady-state compartmental analysis to investigate the simultaneous degradation of soluble and sorbed glyphosate (N-(phosphonomethyl)glycine) in four soils. Pesticide Science 52, 229-240. Forlani, G., Mangiagalli, A., Nielsen, E., Suardi, C.M., 1999. Degradation of the phosphonate herbicide glyphosate in soil: evidence for a possible involvement of unculturable microorganisms. Soil Biology & Bio- chemistry 31, 991-997. Heinonen-Tanski, H., 1989. The effect of temperature and liming on the degradation of glyphosate in two arctic forest soils. Soil Biology & Biochemistry 21, 313-317. Houba, V.G.J., Lexmond, T.M., Novozamsky, I., Van der Lee, J.J., 1996. State of the art and future developments in soil analysis for bioavailability assessment. The Science of The Total Environment 178, 21-28. Konert, M., Vandenberghe, J., 1997. Comparison of laser grain size analysis with pipette and sieve analysis: a solution for the under- estimation of the clay fraction. Sedimentology 44, 253-535. Krzysko-tupicka, T., Orlik, A., I 997. The use of glyphosate as the sole source of phosphorous or carbon for the selection of soil-borne fungal strains capable to degrade this herbicide. Chemosphere 34, 2601-2605. Morillo, E., Undabeytia, C., Maqueda, C., Ramos, A., 2000. Glyphosate adsorption on soils of different characteristics. Influence of copper addition. Chemosphere 40, 103-107. Riis, V., Babel, W., Pucci, O.H., 2002. Influence of heavy metals on the microbial degradation of diesel fuel. Chemosphere 49, 559-568. Subramaniam, V., Hoggard, P.E., 1988. Metal complexes of glyphosate. Journal of Agricultural and Food Chemistry 36, 1326-1329. Teman, N.G., McGrath, J.W., Mc Mullan, G., Quinn, J.P., 1998. Review: Organophosphonates: occurrence, synthesis and biodegradation by microorganisms. World Journal of Microbiology and Biotechnology 14, 635-647. Tomita, M., Okuyama, T., Wanatebe, S., Uno, B., Kawai, S., 1991. High- performance liquid chromatographic determination of glyphosate and (aminomethyl)phosphonic acid in hnman serum after conversion into p-toluenesulphonyl derivatives. Journal of Chromatography 566, 239-243. Torstensson, L., 1985. Behaviour of glyphosate in soils and its degradation, in: Grossbard, E., Atkinson, D. (Eds.), The Herbicide Glyphosate. Butterworths, London, pp. 137-150. Van Straalen, N.M., 2002. Assessment of soil contamination-a functional perspective. Biodegradation 13, 41-52. Vegter, J.J., 1995. Soil protection in the Netherlands, in: Salomons, W., Forstner, U., Mader, P. (Eds.), Heavy metals-problems and solutions. Springer-verlag, Berlin-Heidelberg. Public Works Department Maintenance Operations Policies and Procedures INTEGRATED PEST MANAGEMENT PROGRAM PURPOSE: To establish criteria for an Integrated Pest Management (1PM) Program. POLICY: The City of Irvine will focus on long-term prevention or suppression of pest problems with minimum impact on human health, the environment, and nontarget organisms with the limited use of pesticides in accordance with direction provided by the City Council (2/23/16) for Parks, Fields and Playgrounds; City-wide Pest Management Guiding Principles, and an annual update: Parks, Fields and Playgrounds When pesticides are needed, use the following prioritized approach: (1) organic pesticides; (2) Water Quality Act Allowed Pesticides; and (3) EPA Level Ill "caution" labeled pesticides only when deemed necessary to protect public health and economic impact by a licensed pest control adviser. City-wide Pest Management Guiding Principles a. Use of organic pesticides in all City properties. b. Limit exposure to any pesticides where children and the general public congregate. c. Incorporate additional guidance on use of pesticides for city rights of way, facilities, and other properties as reflected in the staff report. d. Use EPA Level pesticides in a targeted manner, and only if deemed necessary to protect public health and economic loss by a licensed pest control advisor and City staff, when pests cannot be managed by other methods that we would have. Annual Update Staff will return to the City Council annually with an update. PROCEDURES: Prevention 1 . Public Works Staff shall review all new development and rehabilitation projects plans to verify compatibility with the site's environment. Monitoring 1. The Maintenance Divisions shall hire a consultant or contractor to provide regular monitoring services for all of the City's properties. 2. The consultant or contractor shall determine if pest populations are increasing, decreasing, or staying the same and to determine when to use a control tactic. 3. The consultant or contractor shall provide monthly monitoring records which include information such as date of examination, pests found, size and extent of the infestation, location of the infestation, control options utilized, effectiveness of the control options, labor and material costs. Non Chemical Control Measures 1. The Landscape Division shall utilize cultural controls which are modifications of normal plant care activities that reduce or prevent pests. In addition to those methods used in the pest preventions, other cultural control methods include adjusting the frequency and amount of irrigation, fertilization, and mowing height. 2. The Maintenance Divisions shall utilize mechanical control tactics involve the use of manual labor and machinery to reduce or eliminate pest problems using methods such as handpicking, physical barriers, or machinery to reduce pest abundance indirectly. 3. The Maintenance Divisions shall utilize the use of environmental manipulations that indirectly control or prevent pests by altering temperature, light, and humidity can be effective in controlling pests. Although in outdoor situations these tactics are difficult to use for most pests, they can be effective in controlling birds and mammals if their habitat can be modified such that they do not choose to live or roost in the area. Integrated Pest Management Program Page 2 of 5 4. The Maintenance Divisions shall utilize a biological control practice which uses living organisms to reduce pest populations. These organisms are often also referred to as beneficials, natural enemies or biocontrols. They act to keep pest populations low enough to prevent significant economic damage. Biocontrols include pathogens, parasites, predators, competitive species, and antagonistic organisms. Beneficial organisms can occur naturally or can be purchased and released. The most common organisms used for biological control in landscapes are predators, parasites, pathogens and herbivores. Pesticide Controls Pesticides are to be utilized in a prioritized approach on City properties as follows: Parks. Fields and Playgrounds When pesticides are needed, use the following prioritized approach: (1) organic pesticides; (2) Water Quality Act Allowed Pesticides; and (3) EPA Level Ill "caution" labeled pesticides only when deemed necessary to protect public health and economic impact by a licensed pest control adviser. Rights of Way (Street medians/parkways) -Prioritized Use of Pesticides: a. Use organic pesticides first, when pesticides are needed. b. Use Clean Water Act allowed pesticides. c. EPA Level Ill "caution" label pesticide only if deemed necessary to protect public health and economic impact by a licensed pest control advisor and City staff. d. EPA Level II "warning" label pesticides, only if deemed necessary to protect public health and economic loss by a licensed pest control advisor and City staff, when other methods do not adequately control the pest. e. EPA Level I "danger" label pesticides, only if deemed necessary to protect public health and economic loss by a licensed pest control advisor and City staff, when other methods do not adequately control the pest. Facilities/Buildings -Prioritized Use of Pesticides: a. Use organic pesticides first, when pesticides are needed. b. Use Clean Water Act allowed pesticides. Integrated Pest Management Program Page 3 of 5 c. Bait formulations of insecticides will be used where appropriate. d. EPA Level Ill "caution" label pesticide only if deemed necessary to protect public health and economic impact by a licensed pest control advisor and City staff. e. EPA Level II "warning" label pesticides, only if deemed necessary to protect public health and economic loss by a licensed pest control advisor and City staff, when other methods do not adequately control the pest. f. EPA Level I "danger" label pesticides, only if deemed necessary to protect public health and economic loss by a licensed pest control advisor and City staff, when other methods do not adequately control the pest. Other City Properties -Prioritized Use of Pesticides: a. Use organic pesticides first, when pesticides are needed. b. Use Clean Water Act allowed pesticides c. EPA Level Ill "caution" label pesticide only if deemed necessary to protect public health and economic impact by a licensed pest control advisor and City staff. d. EPA Level II "warning" label pesticides, only if deemed necessary to protect public health and economic loss by a licensed pest control advisor and City staff, when other methods do not adequately control the pest. e. EPA Level I "danger" label pesticides, only if deemed necessary to protect public health and economic loss by a licensed pest control advisor and City staff, when other methods do not adequately control the pest Pesticides should only be used when other methods fail to provide adequate control of pests and just before pest populations cause an unacceptable damage, since the overuse of pesticides can cause beneficial organisms to be killed and pest resistance to develop. I Approvals and Application of Chemical Pesticides 1. Pesticides shall be approved by the Maintenance Division Superintendents for their area of oversight prior to use. A written recommendation of proposed pesticide, including commercial name, concentrations, allocation rates, usage and reentry time shall be prepared by a licensed California Pest Control Advisor and site specific schedule submitted for approval. No work shall begin until written approval of use is obtained and a notice of intent has been Integrated Pest Management Program Page 4 of 5 filed with the County Agricultural Commissioner's office, as required. Copies of Safety Data Sheets and specimen labels shall be given to the City prior to pesticide use on City property. 2. Chemicals shall only be applied by those persons possessing a valid California Qualified Applicator license/certificate. Application shall be in strict accordance with all governing regulations. Records of all operations shall be kept per California Department of Pesticide Regulations. 3. Pesticides shall be applied in a manner to avoid contamination of non-target areas. Precautionary measures shall be employed to keep the public from entering the spray zone until it is safe. 4. Posting of signs shall be required at all park facilities when any application of pesticides is performed. Specific requirements for posting are as follows: • Post signs at all park entrances at least 48 hours prior to spraying applications. The vendor's contact information, chemical name and application date must be listed. • Place spray notices inside plastic page protectors. Attach them to a four-foot (4') high wooden stake. Signs must be readable 25' away from posted area. • Leave the same signs up for 72 hours after the spraying applications are completed, then remove promptly. • A temporary mesh fence such as orange plastic construction fencing can be erected on the perimeter of any area that is to be treated with a broadcast type application with the intent to keep people and pets off the treated area for a period of 24 hours. Records and Reporting Records of all pesticides used by the Contractor on City property shall be retained in accordance with Department of Pesticide Regulations. Maintenance Superintendents will keep records of all pesticide usage and provide an annual report to the Director of Public Works reflecting the pesticide usage each year. The Public Works Department will provide an annual report to the City Council. Manuel Gomez, Director of Public Works Approved: March 1, 2016 Integrated Pest Management Program Page 5 of 5 Morgen Fry From: Sent: To: Cc: Council Internet Email Tuesday, December 05, 2017 1:36 PM Morgen Fry Chris Hazeltine; Kyle Lancaster Subject: FW: in support of Agenda item #11 3b: Adopt Update to the IPM Plan -All Sites with Immediate Implementation Attachments: Portland ME testimony c.docx; South Portland c.docx; NH testimony copy.pdf; Testimony NHvl.docx I All Receive -Agenda item # _l _ Morgen, Please distribute the attached items to council. Andi From: Kim Konte [] Sent: Tuesday, December 05, 2017 12:01 PM To: Council Internet Email <CityCouncil@carlsbadca.gov> For the Information of the: CITY COUNCIL ACM v\,/ CA V CC~ Date~ City Manager V Subject: in support of Agenda item #11 3b: Adopt Update to the 1PM Plan -All Sites with Immediate Implementation > 1 June 19, 2017 Spencer Thibodeau, Belinda Ray, Jill Duson City Councilors Sustainability Sub Committee City of Portland Portland, ME Dear Councilors, A personal issue is going to prohibit me from testifying in person on June 21, 2017. I respectfully submit these written comments. I have been a professional horticulturist for forty-five years. I have been involved in the organic industry for the past twenty years. I am conventionally trained and spent twenty-five years as a chemical applicator in nursery, greenhouse, and horticultural production. Twenty years ago, I shifted my focus from chemical intensive management to natural, organic strategies. At that time I expanded my area of expertise to include turf and landscape management. In addition to my industry experience, I am a fifteen-year elected member and Chairman of the Town of Marblehead, MA Recreation and Park Commission. I believe that there is enough science that exists to show that there are issues with many of the products that we routinely use where children play. It is true that we will never be able to say that a specific product caused a specific disease, but we do know that science has shown that repeated exposures to low dose applications is problematic with developing children and adults with immune issues. I believe that the use of synthetic fertilizers and pesticides puts one on a treadmill when managing the landscape. Generally speaking, the weeds that we are targeting with herbicides are not the problems in the turf system, but rather they are the symptoms of underlying problems. We have been taught by an industry to repeatedly treat those symptoms as opposed to focusing on solving the problem. If we just use chemicals and do not employ other inputs or strategies to grow healthy grass, the weeds will return and we will fall back on chemicals once again. A chemical-free approach does not focus on a product swap. It is following this concept where many fail. There is a general lack of understanding that organic management is not just switching to organic products, but in reality it is learning how to manage the lawn, the garden, or any other area as a system. That system involves what we can see above ground and most 11 Laurel Street Marblehead, MA 01945 781-631-2468 Osborne ~Organics Organic 1PM Organic 1PM is problem-solving strategy that prioritizes a natural, organic approach to turf and landscape management without the use of toxic pesticides. It mandates the use of natural, organic cultural practices that promote healthy soil and plant life as a preventative measure against the onset of turf and landscape pest problems. The US EPA and CDC recommend the use of an Integrated Pest Management {1PM) program by local governments. 1PM promotes the use of nonchemical methods for pest prevention and management, such as physical, mechanical, cultural, and biological controls. Least toxic pesticides maybe selected for pest control only after all other reasonable nonchemical methods have been exhausted. The use of even allowed pest control products should be used on a rescue basis as opposed to incorporation into routine management programs. This approach will eliminate or significantly reduce the use of, and exposure to, pesticides in the management of lawn areas, playing fields, and landscapes. Furthermore, it will mitigate the potentially negative impact of landscape management on local waterways, air quality, and ecosystems. This protocol will rely on a systems approach that integrates soil health and plant vigor with proper cultural practices. The goal is to put a series of preventative steps in place that can naturally attenuate pest issues before they become a significant concern. Careful monitoring for pests and the development of the threshold levels within this system will allow for easier control of pest problems, if they do arise. This protocol is knowledge-based utilizing an intimate understanding of soil dynamics, grass biology, and pest/disease morphology to establish the proper procedures for maximizing the health of the landscape. This protocol should mitigate most serious pest pressures. When a pest has not been satisfactorily controlled by the above strategies, the rescue approach follows the path to the use of the least toxic pesticides. Recommendations are for the use of Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) section 25b minimum risk, pesticides listed by the US Environmental Protection Agency. Materials that are bio-rational in nature can also be used. Bio-rational pesticides are EPA registered. They have been approved by the Organic Materials Review Institute (OMRI) or an equivalent certifying body. Essential Organic Integrated Pest Management practices include, but are not limited to: • Regular soil testing 11 Laurel Street Marblehead, MA 01945 781-631-2468 • The addition of approved materials for soil fertility and amendment as necessitated by soil test results • Selection of plantings using criteria of hardiness; suitability to native conditions; disease and pest resistance; and ease of maintenance • Modification of outdoor management practices to comply with organic horticultural science, including scouting, monitoring, watering, mowing, pruning, proper spacing, and mulching • The use of physical controls, including hand weeding and over seeding • The use of biological controls, including the introduction of natural predators, and the enhancement of the environment of a pest's natural enemy • Through observation, determining the most effective treatment time, based on past biology and other variables, such as weather and local conditions • Eliminating pest habitats and conditions supportive of pest population increases 11 Laurel Street Marblehead, MA 01945 781-631-2468 Os bornc;_AC'.v -~-· rga11ic~ ,7\:,.-. February 7, 2017 Environment & Agriculture Committee House of Representatives New Hampshire General Court Concord, New Hampshire Dear Committee Members: I would like to present this to you as written testimony which will be outlined in my oral testimony. I am a professional horticulturist with over forty years of experience in the green industry. For thirty-seven years I owned and operated commercial greenhouses, a retail florist, and a garden center. My education and training in the early 1970s was entirely chemically oriented. I was taught that it was not feasible to successfully grow plant material, either in a greenhouse or in the landscape, without the use of synthetic chemicals to provide plant nutrition and pesticidal control of insects, weeds, and disease. I was a licensed pesticide applicator for twenty plus years. I followed that approach for over twenty years until I realized that I was on a treadmill of pesticide and synthetic fertilizer use and plants were not getting any better. I was continually addressing the same symptoms, but never solving any problems. My personal experience led me to explore alternative practices and strategies in the mid 1990s. At that time, I could not avail myself any education regarding alternative practices. I began a process of experimentation and self-teaching that led me to develop protocols for successful management without chemicals. I eliminated synthetic pesticides from my growing environment and moved my mechanisms of fertility to natural materials. Twenty years ago I switched my horticultural specialty from ornamental horticulture to turf and landscape management with the idea that a broader approach to chemical reduction could embrace the public and private sectors. For the past twenty years I have been specializing in turf and landscape management without the use of chemicals. Many of you have probably heard that organic or natural management has serious limitations and without the use of chemicals a turf area will very quickly deteriorate into a broad diversity of undesirable plant material. While diversity in nature is preferable to monocultures, the reality is that we are dealing with a mental picture of a lawn or grass system that was created for us by an industry. 11 Laurel Street Marblehead, MA 01945 781-631-2468 You may have heard that alternative turf management is prohibitively expensive for a do-it- yourself homeowner, landscape contractor, or a school district or municipality. First, let me tell you what organic or natural management is not. It is not a protocol based on a swap out with conventional products. In the early days of alternative management that is exactly what happened. Conventional fertilizers were switched for organic fertilizers. If a pesticide was being used for either pre-emergence or post-emergence weed control, an alternative material was sought out. In the early days those programs were focused heavily on the grass with product chosen to deliver nitrogen, phosphorus, and potassium as well as take out undesired pests. Most often these attempts produced little in the way of a satisfactory alternative to chemicals. Natural, organic management is a System's Based Approach. A conventional program (ie: the four-step program or something similar), is a product centered approach whereby we have been taught that based on the calendar date there is a certain combination of products that we should apply to meet our expectations. Organic programs are systems based. The most critical concept to understand in the beginning is that we are not just applying products to meet the needs of the grass, but rather we are using product inputs, science-based information, and good cultural practices in a way that allows us to enhance and manage the system. The system is the soil, the microbes that exist in that soil, the environment, the ecosystem of which that grass is a part, and the grass plant itself. When we broaden our understanding to begin to manage in this way, we can then begin to move away from chemicals. The Systems Based Approach to Natural Turf Management involves three distinct concepts. 1. It is a strong focus and basic understanding that the soil is very much alive and has resources that are critical to and support healthy plant growth. 2. It should involve the exclusive use of natural, organic products for fertility and pest control. Synthetic fertilizers are salt-based and not conducice to building a healthy biomass 3. Revised horticultural practices such as proper mowing, watering, and relief of compaction. It is the Systems Based Approach that guides us in building a healthy soil which in turn facilitates the growth of grass. We use inputs as fertilizers for the grass, foods for microbes, and amendments to create the correct soil environment to enable us to meet communicated expectations. It is important to understand that when we manage a chemical free program, we are not necessarily assuming there will automatically be substantial weed pressure. When we manage organically, we manage to communicated expectations. One fact is a given in either conventional or natural management. A higher level of expectations generally means a 11 laurel Street Marblehead, MA 01945 781-631-2468 os·borr1e · rganics _.---~ .• ,,,~.,,--=~,=--,s··-=-oc-~1-~:=77<,·,~--=-.,...,....----~-~- ~( \ •. higher cost and more product applied. Lower expectations can be satisfactorily met with lower product input and a lower cost. High expectations are not always good or necessary and low expectations are not always bad. It is the appropriate expectation for an individual site. We then set our management strategy to meet those expectations from either an aesthetic or functional point of view. Aesthetic expectations are what the grass looks like and functional expectations are how it performs as a playing surface, athletic field, or public park. High expectation generally means thick grass and low weed pressure. Lower expectations are generally more inclusive of non- grass species. With the systems based approach, experience has taught us that we can manage successfully to less than 5% weed pressure per acre. That is the same general guideline put forward in conventional management. We are combining the Systems Based Approach with a redefined Integrated Pest Management concept known as Organic Integrated Pest Management. It is through Organic 1PM strategies and protocols that we achieve our goals and manage successfully without the use of toxic materials. Within this decision-making process there are allowed materials that can be used to intervene if necessary. Very often overtime the need for intervention is very small. A definition of Organic 1PM is included. Natural management is no longer prohibitively expensive. There is not just one organic program as the counterpoint to the more traditional four-step program. Because we are now managing to communicated expectations, product input can vary depending upon what we are trying to do. For the highest level of expectations, if we embrace new science and the development of liquid fertility and soil building materials, we can begin to manage in the same general cost range as conventional management. If we stay with the more traditional granular, organic materials, the cost might be slightly more expensive in the beginning, but as we move through the transition process we experience a reduction in product input and therefore a reduction in budget while at the same time maintaining expectations. My work over the past fifteen years has been focused on large public and private properties with a goal to reduce chemical use. I am currently working with twenty-five school districts, municipalities, corporations, and colleges and universities to develop programs to transition these properties to natural management. In addition to these projects I work with both federal agencies and state governments to develop pilot projects that showcase successful alternative land management programs. Over the past five years I have worked with the National Park Service as a volunteer to develop natural protocols on pilot sites around the country. We have worked in situations where there was adequate budget money and then others where there was not. In all cases, we made improvements and met expectations for the individual sites. 11 Laurel Street Marblehead, MA 01945 781-631-2468 1'i \' Osborn~'},Q~ganics ! / \ \ It is this new, science-based approach that we are taking to alternative land management that is primarily responsible for the successes that we are seeing. This approach is largely unaddressed at teaching institutions for a variety of reasons. As you can see, our approach is as scientific as conventional management. It is simply embracing a different science. Experience has taught us that if we manage a transition from chemical to natural products and protocols in the right way, with a strong focus on the soil in the beginning, we can be successful. It is a paradigm shift and it will involve a shift in education over time. There is a learning curve, but the good news is that the heart of education in this field is here in New England. After passage of HB 399, a broad outreach to school districts and those charged with the responsibility to manage grass where children play, with an offer of comprehensive education, will go a long way to ensuring a successful transition. Thank you for your time. R"§l:_r Chip Osborne, ..President Osborne Organics, Inc. Organic 1PM A problem-solving strategy that prioritizes a natural, organic approach to turfgrass and landscape management without the use of toxic pesticides. It mandates the use of natural, organic cultural practices that promote healthy soil and plant life as a preventative measure against the onset of turf and landscape pest problems. The US EPA and CDC recommend the use of Integrated Pest Management (1PM) program by local governments. Organic 1PM promotes the use of nonchernical methods for pest prevention and management, such as physical, mechanical, cultural, and biological controls. Least toxic pesticides maybe selected for pest control only after all other reasonable nonchemical methods have been exhausted. The use of even allowed pest control products should be used on a rescue basis as opposed to incorporation into routine management programs. This approach will eliminate or significantly reduce the use of, and exposure to, pesticides in the management of lawn areas, playing fields, and landscapes. 11 Laurel Street Marblehead, MA 01945 781-631-2468 Furthermore, it will mitigate the potentially negative impact of landscape management on local waterways, air quality, and ecosystems. This protocol will rely on a systems approach that integrates soil health and plant vigor with proper cultural practices. The goal is to put a series of preventative steps in place that can naturally attenuate pest issues before they become a significant concern. Careful monitoring for pests and the development of threshold levels within this system will allow for easier control of pest problems, if they do arise. This protocol is knowledge-based utilizing an intimate understanding of soil dynamics, grass biology, and pest/ disease morphology to establish the proper procedures for maximizing the health of the landscape. This protocol should mitigate most serious pest pressures. When a pest has not been satisfactorily controlled by the above strategies, the rescue approach follows the path to the use of the least toxic pesticides. Recommendations are for the use of Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Section 25 b Minimum Risk Pesticides listed by the US Environmental Protection Agency. We can also use materials that are bio-rational in nature. These bio-rational pesticides are EPA registered, but they are approved for organic production by the Organic Materials Review Institute (OMRI) or an equivalent certifying body. • Essential Organic Integrated Pest Management practices include, but are not limited to: • Regular soil testing • The addition of approved materials for soil fertility and amendment as necessitated by soil test results • Selection of plantings using criteria of hardiness; suitability to native conditions; disease and pest resistance; and ease of maintenance • Modification of outdoor management practices to comply with organic horticultural science, including scouting, monitoring, watering, mowing, pruning, proper spacing, and mulching • The use of physical controls, including hand weeding and overseeding; • The use of biological controls, including the introduction of natural predators, and the enhancement of the environment of a pest natural enemy • Through observation, determining the most effective treatment time, based on past biology and other variables, such as weather and local conditions • Eliminating pest habitats and conditions supportive of pest population increases 11 Laurel Street Marblehead, MA 01945 781-631-2468 Osborne ~ganics February 29, 2016 Mayor Thomas E. Blake Councilman Claude V. Z. Morgan Councilwoman Patricia Smith Councilman Eben Rose Councilwoman Linda C. Cohen Councilman Brad Fox Councilwoman Maxine Beecher South Portland City Council South Portland, Maine Dear Councilors, Thank you for the opportunity to submit these comments. I will be in Portland all day Monday and have to return to Marblehead, MA in the late afternoon to make a presentation to my Finance Committee in public session. I am an elected official, Chairman of the Town of Marblehead Recreation and Park Commission. I will be in Portland Monday for the purpose of presenting a one-day professional training to the landscape industry and municipal officials. The title of the training is A Systems Based Approach to Natural Turf Management. Forty-six people are registered for the event and represent a diverse cross-section of the land management industry. Attendees range from twenty-two landscape contractors from the region to representatives from the cities of Portland, South Portland, Scarborough, Camden/Rockport, and York. In addition, we have representatives from two turf farms, Central Maine Power Co., Poland Springs Resort, Colby College, and two golf courses. The interest in learning alternative strategies to land management is extremely high. I just trained twenty professionals in New York last month and I will be training thirty in Massachusetts in two weeks. After that I will be traveling to Ohio, California, Wisconsin, Colorado, and North Carolina to present the same type of information over the next eight weeks. When discussing the issue of synthetic chemicals and their adverse effect on human health and the environment there are some very real concerns. The reality is that we 11 Laurel Street, Marblehead, MA 01945 781-631-2468 co@osborneorganics.com simply do not need these products because we have developed a truly science-based approach to land management that relies on natural product inputs for both fertility and control. I will not debate the conventional industry and say we have a swap for every single product, but I can say with confidence that the products that we have available when combined with a thoughtful systems-based approach to management can produce results that meet communicated expectations. To give you an idea on the magnitude of the interest in switching to natural methods, I will soon be working with the city of Irvine, CA who last week voted to prohibit pesticides on all public land and mandated an organic approach. In addition, I am working with six colleges and prep schools, two major national hospitals, four state capitol grounds, three county governments, fifteen school districts and municipal departments around the country, and the National Park Service. There should be no fear in having any deterioration of either public or private lawns, turf, or landscapes if the ability becomes restricted to use synthetic fertilizers and control products. We have shown time and time again that alternative strategies work and we believe provide a safer alternative to synthetic products. Respectfully, Chip Osborne, President Osborne Organics, Inc. 11 Laurel Street, Marblehead, MA 01945 781-631-2468 co@osborneorganics.com Morgen Fry From: Sent: To: Cc: Subject: Attachments: maryanneviney Tuesday, December 05, 2017 2:17 PM Council Internet Email Manager Internet Email All Receive -Agenda Item # J.f_ For the Information of the· CITY COUNCIL . Dr. Blumberg's Presentation for this Evening's (Dec 5) City Council Meeting: Agenda Item Number 11, Integrated Pest Management Plan Blumberg-SJC_city_council..pptx Honorable Mayor and Council Members, Unfortunately, Dr. Blumberg, UCI Professor of Developmental & Cell Biology at the School of Biological Sciences, and one of Non Toxic Irvine's scientific advisors, will be unable to carry out his presentation tonight for Agenda Item Number 11, Integrated Pest Management Plan. He is attending a conference in Europe. However, Dr. Blumberg requested to have his presentation (below) emailed to you, for your information. It is only eight slides long and is quite self-explanatory. Thank you very much for your consideration. With kind regards, Mary Anne Viney 1 The Science of Endocrine Disiu()tion Bruce Blumberg, Ph.D. Department of Developmental and Cell Biology Department of Pharmaceutical Sciences Department of Biomedical Engineering University of California, Irvine Non-communicable Diseases On the Rise • Leukemia, brain cancer: over 20% increase since 1975 • Asthma: doubled between 1980 and 1995, stays elevated • Difficulty in conceiving and maintaining pregnancy: 40% more women in 2002 than in 1982 ( doubled in women aged 18-25) • Autism diagnosis: increased 1000% over the past 3 decades • Obesity: Increased 3 fold in US over past 40 years doubled worldwide last 20 years • NCDs account for 35 million deaths each year WHY? 12/5/2017 Endocrine Disrupting Chemicals (EDCs) affect many organ systems • "Endocrine Disruptor -an exogenous chemical, or mixture of chemicals, that interferes with any aspect of hormone action." -The Endocrine Society, 2012 -Wrong signal, loss of signal, wrong place or wrong time -Act on specific hormone receptors -Hormones work at low concentrations and so do EDCs EDCs are often persistent pollutants or dietary components Disturb development, reproduction, and physiology -Increase risk of many cancers • Breast, ovarian, prostate Leukemia, non-Hodgkins lymphomas • Brain cancers Endocrine Disrupting Chemicals (EDCs} HERBICIDES .... 2,4,-D 2,4,5,-T Alachlor Amitro .... Atrazine .... Glyphosate Linuron Metribuzin Nitrofen Trifluralin FUNGICIDES Benomyl Ethylene thiourea Fenarimol Hexachlorobenzene Mancozeb Maneb Metiram -complex Triorganotins Vinclozolin Zineb INSECTICIDES Aldicarb beta-HCH Carbary! Chlordane Chlordecone DBCP Dicofol Dieldrin DDT and metabolites Endosulfan Heptachlor / H-epoxide Lindane (gamma-HCH) Malathion Methomyl Methoxychlor Oxychlordane Parathion .... Pyrethroids Transnonachlor Toxaphene Thyroid hormone disruptor INDUSTRIAL CHEMICALS Bisphenol - A Polycarbonates Butylhydroxyanisole Cadmium Chloro-!i: Bromo-diphenyl Dioxins Furans Lead Manganese Methyl mercury Nonylphenol Octylphenol Organotins PBDEs PCBs Pentachlorophenol Penta-to Nonylphenols Perchlorate PFOA p-tert-Pentylphenol Styrene Estrogen receptor agonist Androgen receptor antagonist 12/5/2017 2 We all Carry a Chemical Body Burden • 287 chemicals (of 417 examined) found in umbilical cord blood (range of 154 -231 for each child) -180 of these cause cancer in humans or animals -217 are neurotoxic in animals -208 are developmental toxins • Did any of these moms or children give informed consent for, or benefit from their chemical exposures? • Is this really a good idea? Myth Myths and Realities in EDC Science Reality • EPA under the aegis of FIFRA, TSCA and other laws tests the effects of chemicals on human, animal and environmental health • EPA practices the "precautionary principle" (better safe than sorry) in regulating chemicals • EPA, USDA, CDC and/or FDA measure real life levels of chemicals and protect us from exposures to dangerous chemicals • EPA and other agencies use "state of the art" science to evaluate chemical safety for risk assessment • EPA tests NOTHING and requires only that manufacturers perform rudimentary testing for toxicity and carcinogenesis • Opposite -substantial certainty of harm to humans is required before a chemical is unlicensed • Exposure assessments are based on modeling and rarely, if ever, measure actual exposures. -Relevant for low dose effects • "Science" used by EPA, et al. is archaic and heavily influenced by registrants -EDC screening battery 12/5/2017 3 rse health effects of herbicides and "tng; Even if one accepts that 1nty" i ·'udyresults, which way · m /fpublic safety or ' ~'t our aren, grahc;lchildren and f gen~iations the most important consider Testing for Effects of Chemical Exposure ,1 ,1 '4 Ufl\,.. WE DO TEST !=DR. Tl.IE. SAFHY 6F P€.WC!OfS IN ~OuR Foo[), AND ENVIRONMENT 12/5/2017 4 Morgen Fry From: Sent: To: Cc: Subject: Morgen, Please distribute to council. Andi -----Original Message----- Council Internet Email Tuesday, December 05, 2017 8:14 AM Morgen Fry Chris Hazeltine; Kyle Lancaster FW: Non-Toxic Carlsbad From: Kelly K [] Sent: Monday, December 04, 2017 9:15 PM To: Council Internet Email <CityCouncil@carlsbadca.gov> Subject: Non-Toxic Carlsbad Hello, All Receive -Agenda Item # 11 For the Information of the:- CITY COUNCIL ACM v v CA v CC _L Date 1.:Ii]aCity Manager v I would like to show my support for an organically driven pest management system for Carlsbad. I have heard that the schools are no longer being sprayed with round up, but that parks are still using it. I am in full support of using an organic Pest management system on all parks and schools in Carlsbad. Thank you for your help in this matter! Kelly Kootman 1 Morgen Fry From: Sent: To: Cc: Subject: Morgen, Please distribute to council. Andi Council Internet Email Tuesday, December 05, 2017 8:20 AM Morgen Fry Chris Hazeltine; Kyle Lancaster FW: Non-Toxic Carlsbad From: Caroline Barr [mailto:b Sent: Monday, December 04, 2017 6:16 PM To: Council Internet Email <CityCouncil@carlsbadca.gov> Subject: Non-Toxic Carlsbad Dear Carlsbad City Council, I have been a resident of the city of Carlsbad for the past nine years, and am a native of North County, growing up in Encinitas. I love our beautiful city and love raising my family here. I am writing today for the future of our city and for the safety of my eight-year-old daughter. I wholeheartedly support the City of Carlsbad becoming an organic driven community and eliminating the use non-organic substances in our city schools, parks, and shared communal areas. I have had experience first hand with 'round-up' used in our neighborhood and watched it make my dog sick. My daughter plays competitive soccer in Carlsbad and plans to for many years to come, spending countless hours on Carlsbad fields and park grass. I hope you will take her health and the health of all Carlsbad youth into consideration when making this important decision. Sincerely, Caroline Barr 1 Morgen Fry From: Sent: To: Cc: Subject: Morgen, Please distribute to council. Andi Council Internet Email Tuesday, December 05, 2017 1:35 PM Morgen Fry Chris Hazeltine; Kyle Lancaster FW: Integrated Pest Management From: Sue I. [mailto:n Sent: Tuesday, December 05, 2017 11:53 AM To: Council Internet Email <CityCouncil@carlsbadca.gov> Subject: Integrated Pest Management December 5, 2017 Dear honorable Mayor and council members, , Ji Receive -Agenda Item # l I For the Information of the: CITY COUNCIL ACM vv CA v'CC V nate1~ City Manager v' I would just like to express my opinion regarding Integrated Pest Management that is on the agenda for this evenings council meeting. I support option 3A! I believe we all want to live in a non toxic city and reducing the use of pesticides when non toxic alternatives are available. We should choose the latter to use in our gathering places and also areas where the pesticides could be airborne such as in our parks where children play. · I hope Council finds this as important as I do and as such you choose your vote to the alternative non toxic pest management. Thank you, Sincerely, Sue Igoe Carlsbad, Ca 92008 1 Morgen Fry From: Sent: To: Cc: Subject: Morgen, Please distribute this to council. Thanks, Andi -----Original Message----- Council Internet Email Monday, December 04, 2017 3:05 PM Morgen Fry Chris Hazeltine; Kyle Lancaster FW: Agenda item 11-Non Toxic Carlsbad 12-5-17 From: Meg Beauchamp [mailto:m Sent: Monday, December 04, 2017 2:09 PM To: Council Internet Email <CityCouncil@carlsbadca.gov> Subject: Agenda item 11-Non Toxic Carlsbad 12-5-17 All Receive -Agenda Item # J..L For the Information of the: CITY COUNCIL ACMJ/JI._CA ./'cc V Date'~ City Manager V I would like this email to be on the public record concerning agenda item 11 for the city council meeting on 12-5-2017. I would like to thank Chris and Kyle of the Parks and Rec department, for working so diligently to assess the alternatives available to Carlsbad, in regards to Integrated Pest Management (1PM). Now that CUSD has officially committed to moving toward organic alternatives, this would be an excellent time for our city to join forces and create a healthier environment for all of our children and residents. We have seen how a viable and sustainable program can work ( Non Toxic Irvine) and we have the responsibility to make our community as safe as possible for our families, (including our pets),and visitors that make their way to Carlsbad. The council has an opportunity to make Carlsbad safer by adopting option 3A of the staff report. Respectfully, Meg Beauchamp 1 Sheila Cobian Subject: FW: In support of agenda item 11 -3b Adopt Update to the IPM Plan-All sites with Immediate Implementation Attachments: Blumberg-SJC_city_council..pptx .. ii Receive_ Agenda Item # .1l_ From: Council Internet Email Sent: Monday, December 04, 2017 1:02 PM To: Morgen Fry <Morgen.Fry@carlsbadca.gov> For the Information of the: CITY COUNCIL ACM~CA~CC V Oate ~City Manager Subject: FW: In support of agenda item 11-3b Adopt Update to the 1PM Plan-All sites with Immediate Implementation Morgen, Please distribute the attached item to council regarding the 1PM Plan agenda item. Thanks, Andi From: Kim Konte f mailto: Sent: Monday, December 04, 2017 11:49 AM To: Council Internet Email <CityCouncil@carlsbadca.gov> Subject: In support of agenda item 11 -3b Adopt Update to the 1PM Plan-All sites with Immediate Implementation Best, Kim .:c~i··1e • Agenda ltern # JL · :1e lnformaticn of the: -~!TY COUNCL VVCA v cc.,/' · · 1~iila City Manage: ~ The Science of Endocrine Disi;Uption Bruce Blumberg, Ph.D. Department of Developmental and Cell Biology Department of Pharmaceutical Sciences Department of Biomedical Engineering University of California, Irvine Non-communicable Diseases On the Rise • Leukemia, brain cancer: over 20% 1· increase since 1975 • Asthma: doubled between 1980 and 1995, stays elevated • Difficulty in conceiving and maintaining pregnancy: 40% more women in 2002 than in 1982 (doubled in women aged 18-25) • Autism diagnosis: increased 1000% over the past 3 decades • Obesity: Increased 3 fold in US over past 40 years doubled worldwide last 20 years • NCDs account for 35 million deaths each year WHY? 12/4/2017 Endocrine Disrupting Chemicals (EDCs) affect many organ systems ,\-\..1mmill'}' gl.md, (fl'f'llal(!i Brain Piluitdry • "Endocdne D;sruptor -an exogenous chemical, or mixture of chemicals, that interferes with any aspect of hormone action." -The Endocrine Society, 2012 -Wrong signal, loss of signal, wrong place or wrong time -Act on specific hormone receptors -Hormones work at low concentrations and so do EDCs • EDCs are often persistent pollutants or dietary components Adipo.<,e Tlssue-~----+-O.<aries -Disturb development, reproduction, and physiology 1il.'1lli:lle) -Increase risk of many cancers "'""'~ --+-----+ (male) • Breast, ovarian, prostate Trstcs -f-------t\J lm.:dt'J • Leukemia, non-Hodgkins lymphomas • Brain cancers Endocrine Disrupting Chemicals (EDCs) HERBICIDES -+ 2,4,-D 2,4,5,-T Alachlor Amitro -+ Atrazine -+ Glyphosate Linuron Metribuzin Nitrofen Trifluralin FUNGICIDES Benomyl Ethylene thiourea Fenarimol Hexachlorobenzene Mancozeb Maneb Metiram -complex Triorganotins Vinclozolin Zineb INSECTICIDES Aldicarb beta-HCH Carbary! Chlordane Chlordecone DBCP Dicofol Dieldrin DDT and metabolites Endosulfan Heptachlor / H-epoxide Lindane (gamma-HCH) Malathion Methomyl Methoxychlor Oxychlordane Parathion -+ Pyrethroids Transnonachlor Toxaphene Thyroid hormone disruptor INDUSTRIAL CHEMICALS Bisphenol - A Polycarbonates Butylhydroxyanisole Cadmium Chloro-a Bromo-diphenyl Dioxins Furans Lead Manganese Methyl mercury Nonylphenol Octylphenol Organotins PBDEs PCBs Pentachlorophenol Penta-to Nonylphenols Perchlorate PFOA p-tert-Pentylphenol Styrene Estrogen receptor agonist Androgen receptor antagonist 12/4/2017 2 We all Carry a Chemical Body Burden • 287 chemicals (of 417 examined) found in umbilical cord blood (range of 154 -231 for each child) -180 of these cause cancer in humans or animals -217 are neurotoxic in animals -208 are developmental toxins • Did any of these moms or children give informed consent for, or benefit from their chemical exposures? • Is this really a good idea? Myth Myths and Realities in EDC Science Reality • EPA under the aegis of FIFRA, TSCA and other laws tests the effects of chemicals on human, animal and environmental health • EPA tests NOTHING and requires only that manufacturers perform rudimentary testing for toxicity and carcinogenesis • EPA practices the "precautionary • Opposite -substantial certainty principle" (better safe than sorry) of harm to humans is required in regulating chemicals before a chemical is unlicensed • EPA, USDA, CDC and/or FDA measure real life levels of chemicals and protect us from exposures to dangerous chemicals • EPA and other agencies use "state of the art" science to evaluate chemical safety for risk assessment • Exposure assessments are based on modeling and rarely, if ever, measure actual exposures. -Relevant for low dose effects • "Science" used by EPA, et al. is archaic and heavily influenced by registrants -EDC screening battery 12/4/2017 3 Testing for Effects of Chemical Exposure UM ... WE DO mr FDR 11-\E. SAFITY ot= PSWC!OfS IN r'OUR Foot), AND ENVIRONMENT 12/4/2017 4 Pharm Solutions Inc. P.O.BOX 1500, Cambria, CA. 93428 805.927.7500 tel. 888.422.8875 fax www.pharmsolutions.com Dear City Manager, All Receive -Agenda Item # 1.L For the Information of the: Cl1Y COUNCIL / ACM //cA./ CCy__/ Datel~ City Manager ...JL This letter is in support of item 3b Adopt Update to the IPM plan-All sites with Immediate Implementation Our company Pharm Solutions has manufactured organic pesticides since 2004. All our products are made with food grade ingredients only. In particular our Organic Herbicide "Weed Pharm" is a food grade organic acid (high strength table vinegar) that desiccates the leaves of weeds and unwanted grasses leaving them unable to take in moisture or sunlight. The weed promptly dies. There is no residue from the product, it does not subsist in the soil, nor does it translocate. It simply evaporates into the air. Weed Pharm is approved by the EPA, the USDA National Organic Program and Washington State University and California Certified Organic Farmers for "Use in Organic Agriculture". Weed Pharm is used by the Minnesota State Zoo in the animal pastures. Weed Pharm is used around the country by multiple municipalities to protect children from toxic synthetic chemicals in Parks and Recreations programs. Locally, Weed Pharm has been chosen by The City of Irvine as their organic herbicide going forward as has the school district of Tustin. For your information, I have attached three recent articles on the danger and likelihood of cancer causing agents left in pesticide residue. I implore you and the City Council of Carlsbad; the time is now to make the change to organic pesticides. We can and will, help you accomplish your goal. Respectfully submitted, Susan E. Lewis Susan E. Lewis Pharm Solutions Inc. C.E.O 12/4/2017 Print Subject: Monsanto responds to glyphosate/birth defects report/ Earth Open Source replies From: Thomas Wittman (info@eco-farm.org) To: info@certifiedorganicpesticides.com; Date: Wednesday, June 22, 2011 9:40 AM Having trouble viewing this email? Click Here (-':.. ·ll'..i EcoFarm Logo Genetic Engineering News List From GMWatch <gmwatch-daily@gmwatch.eu> 1. Earth Open Source response to Monsanto 2. June 2011 Earth Open Source Report on Roundup -Monsanto response NOTE: Below (item 2) is Monsanto's initial response to the Earth Open Source report, "Roundup and birth defects: Is the public being kept in the dark?". The EOS report showed industry has known that glyphosate causes birth defects since the 1980s and EU regulators have known since the 1990s. But instead of informing the public, industry and regulators have repeatedly claimed that glyphosate and Roundup do not cause birth defects: http://www.scribd.com/doc/57277946/RoundupandBirthDefectsv5 Earth Open Source's response to Monsanto is also below (item 1 ). 1. Earth Open Source response to Monsanto June 14, 2011 http://on.fb.me/machCY Monsanto responded to our report, "Roundup and birth defects: Is the public being kept in the dark?" in a statement on its website. Monsanto said, "Regulatory authorities and independent experts around the world agree that glyphosate does not cause adverse reproductive effects in adult animals or birth defects in offspring of these adults exposed to glyphosate, even at doses far higher than relevant environmental or occupational exposures." However, one of the main points of our report is that regulatory authorities have indeed agreed that glyphosate does not cause birth defects -but that conclusion is directly contradicted by the evidence in industry's own studies. These industry studies, submitted by companies including Monsanto in support of glyphosate's approval in the EU, showed that glyphosate causes birth defects in experimental animals. These effects were found not only at high doses, but also at mid and lower doses. In addition, studies from the independent scientific literature, also detailed in our report and hitherto ignored or dismissed by the EU Commission and the file:///C:/Users/mfry/AppData/Local/Microsoft/Windows/Temporary%20lntemet%20Files/Content.Outlook/LL7FYXIO/Monsanto%20and%20Birth%20De... 1/3 12/4/2017 Print EFSA, show that glyphosate and Roundup cause birth defects in experimental animals, as well as cancer, genetic damage, endocrine disruption and other serious health effects. Many of these effects are found at very low, physiologically relevant doses. Monsanto said that Earth Open Source created "an account of glyphosate toxicity from a selected set of scientific studies, while they ignored much of the comprehensive data establishing the safety of the product". This is false, since our data analysis included industry-funded research studies, some commissioned by Monsanto, which were submitted to the European Commission in support of glyphosate's approval. We found that both these studies and studies by independent scientists contained clear evidence indicating that glyphosate and Roundup cause birth defects. Monsanto said, "glyphosate inhibits an enzyme that is essential to plant growth; this enzyme is not found in humans or other animals, contributing to the low risk to human health from the use of glyphosate according to label directions." However, numerous studies by industry and independent scientists detailed in our report show that glyphosate and Roundup are toxic to mammals and to human cells tested in vitro. Thus, Roundup must have other modes of action in addition to the enzyme inhibitory effect described by Monsanto. This is not surprising, as it can take decades to establish the precise mode of action of a toxin. Often, it remains unclear. Monsanto called the studies that show problems with glyphosate "flawed". But we repeat -among the studies that we review in our report are industry studies, including some commissioned by Monsanto, which show that glyphosate causes birth defects in experimental animals. It follows that Monsanto is condemning the industry studies -including its own studies -as flawed. Since the current EU approval of glyphosate is based on these industry studies, Monsanto's apparent judgment that they are flawed gives us all the more reason to question the current approval of glyphosate. Monsanto's less than convincing attempt to rebut the conclusions presented in our paper raises additional questions regarding the logic supporting the approval of glyphosate as safe for use in the EU. It provides additional justification for our appeal that the European Commission appoint independent scientists to carry out an immediate, objective review of glyphosate and Roundup, considering the full range of industry and independent studies. 2. June 2011 Earth Open Source Report on Roundup Monsantoblog June 09, 2011 http://bit.ly/1uPi1 M We are aware of the report released by Earth Open Source regarding Roundup herbicides and glyphosate, the active ingredient in Roundup herbicides. Monsanto health and environmental experts are reviewing the report in detail. Based on our initial review, the Earth Open Source report does not appear to file:I//C:/Users/mfry/AppData/Local/Microsoft/Windows/Temporary%20Intemet%20Files/Content.Outlook/LL7FYXIO/Monsanto%20and%20Birth%20De... 2/3 12/4/2017 Print contain any new health or toxicological evidence regarding glyphosate. Regulatory authorities and independent experts around the world agree that glyphosate does not cause adverse reproductive effects in adult animals or birth defects in offspring of these adults exposed to glyphosate, even at doses far higher than relevant environmental or occupational exposures. The authors of the report create an account of glyphosate toxicity from a selected set of scientific studies, while they ignored much of the comprehensive data establishing the safety of the product. Regulatory agencies around the world have concluded that glyphosate is not a reproductive toxin or teratogen (cause of birth defects) based on in-depth review of the comprehensive data sets available. Additionally, we have anecdotal results from first-hand experience of millions of farmers and home gardeners who have used this product for decades. Roundup agricultural herbicide provides environmental and economic benefits of conservation tillage which are sustainable and provide effective weed management. To understand the herbicide's active ingredient, it helps to know that glyphosate inhibits an enzyme that is essential to plant growth; this enzyme is not found in humans or other animals, contributing to the low risk to human health from the use of glyphosate according to label directions. Earth Open Source authors take issue with the decision by the European Commission to place higher priority on reviewing other pesticide ingredients first under the new EU pesticide regulations, citing again the flawed studies as the rationale. While glyphosate and all other pesticide ingredients will be reviewed, the Commission has decided that glyphosate appropriately falls in a category that doesn't warrant immediate attention. A few outlets covering the story have also mentioned other reports that we have addressed previously. For more information on them, please look at the following: · Sudden Interest in Dated Argentine Research by Carrasco on Glyphosate · Alleged Plant Pathogen Potentially Associated with Roundup Ready Crops (Huber) The Genetic Engineering Blog is produced by Thomas Wittman and EcoFarm. and supported by a generous donation from the Newman's Own Foundation. Forward email Follow us on Twitter Find us on Facebook This email was sent to info@certifiedorganicpesticides.com by info@eco-farm.org I Update Profile/Email Address I Instant removal with SafeUnsubscribe™ I Privacy Policy. Ecological Farming Association I 406 Main Street, Suite 313 I Watsonvillle l CA I 95076 file:IIIC:/Users/mfry/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/LL7FYXIO/Monsanto%20and%20Birth%20De... 3/3 12/4/2017 Autism and Toxic Chemicals User ID: Password: i Log In Ii Sign Up i --' •t---~---· ' Autism and Toxic Chemicals Posted by KatHoughton 05/10/2012Go Back\ Comments (0) The Ultimate Green Store The scientific evidence for a link between the toxic chemicals now pervasive in our environment and incidence of autism, ADHD, learning difficulties and developmental delays is rapidly mounting from many countries. Toxic chemicals widely used in agriculture and industry have been linked to developmental delays. mex Children are most vulnerable to toxic chemicals in our air water and food because pound of pound they eat 3-4 times as much food and breathe twice as much air as adults. Many of these chemicals do their worst damage at the time of conception and early pregnancy. The CDC (Center for Disease Control) released data in 2011 from a study in 2003 that included a sample of pregnant women. Known toxins were found in 100% of the women, including DDT which has been banned in the US since the 1970s. These chemicals are saturating our environment and our bodies and appear to be impacting the most vulnerable, our children. We are providing this information to help you make choices about which chemicals you are willing to expose your family to. At the end of the article we provide resources for more information on how to make choices to limit your own exposure and ways you can take action to help reduce the global toxic load we are all bearing. pesticides, autism and developmental delays Pesticides are used to kill insects and plants in agriculture. Pesticides include a variety of harmful chemicals including organophosphates which were originally developed for war fare. They work by disrupting brain and nervous system development in insects and appear to be having similar effects on humans. According to Pesticide Action Network North America each year in the US about 1 billion pounds of pesticides are applied to fields, lawns, forests and golf courses. The map to the right clearly shows that where you live greatly impacts your exposure level. In 2002 a study of children of men working with glyphosphate (Roundup®) had a increased risk of birth defects, ADD and hyperactivity. A 2007 study of families in the California Central Valley found that women living close to fields where organophosphates (specifically endosulfan and dicofol) where used during their first trimester of pregnancy were 6 times more likely to have a child later diagnosed with ASD that women who lived elsewhere. The risk factor decreases with distance of residence from the agricultural fields. A 2010 Harvard study published in Pediatrics found that children with above average levels of organophosphate metabolites in their urine with twice a likely to be diagnosed with ADHD. A 2010 study looked specifically at Mexican-American women living in the agricultural regions of California and found an association between maternal levels of pesticide load ( measured in their urine) during pregnancy and attention problems in their sons at 5 year of age. Other US studies have file:///C:/Users/mfry/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/LL7FYXIO/Neurodevelopmental%20Disorders... 1/5 12/4/2017 Autism and Toxic Chemicals linked maternal exposure to pesticides during pregnancy to seriously delayed motor and cognitive development, spatial performance and visual memory, learning rates and increased behavioral problems. This link between pesticides and neurodevelopmental disorders and delays is not restricted to the US, this is just where most of the research has been done. As early as 1998 researchers from Arizona found startling evidence of serious developmental delay in children in northwestern Mexico. The looked at two villages of Yaqui indians, one in a valley that employed heavy pesticide use in agricultural practices and one from the higher foothills where they did not use pesticides. These children share similar genetic backgrounds, diets, water mineral contents, cultural patterns, and social behaviors. The major difference was their exposure to pesticides. The children in the valley showed decrease stamina, gross and fine hand-eye coordination, 30-minute memory and the ability to draw a person. The results from this last test (shown right) clearly illustrate the degree to which the exposed children were delayed. Similar results were found in India in a Greenpeace funded study in 2003 investigating the development of children of cotton farmers. India is the third largest producer of cotton in the world with the largest amount of land dedicated to cotton (19% of the world's total). Even so this huge land mass still only accounts for 5% of the total land mass under agriculture in India. The cotton fields however consume 50% oflndia's pesticides. 70% of Indian cotton farms are run by individual families. They often have to spend 5 times as much money on pesticides as they do on seeds as weeds and insects are becoming more and more resistent to the chemicals - most of which are designated as hazardous by the World Health Organization. The study reveals serious mental development disorders that range from severely impaired analytical abilities, motor skills, concentration and memory among the children in the chemical-intensive cotton belts oflndia. other toxic chemicals, autism and developmental delays Five known mutagens have been linked to increased risk for autism specifically, mercury (from incineration and coal burning), cadmium, nickel, trichloroethylene, and vinyl chloride. A 2009 study in Texas. This study found that autism prevalence increased 2.6% for every 1,000 pounds of mercury released in the vicinity of the geographical center of a given district, and 3. 7% with nearby power plant emissions. The closer a child lived to a coal burning power plant the more likely they were to be diagnosed with autism. A 2006 study in San Fransisco took 284 children with autism and found out what the hazardous air file:///C:/Users/mfry/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/LL7FYXIO/Neurodevelopmental%20Disorders... 2/5 12/4/2017 Autism and Toxic Chemicals pollutant (HAP) concentrations compiled by the U.S. Environmental Protection Agency were for the place each of these children was born. They found a strong link between exposure to air born mercury, cadmium, nickel, trichloroethylene, and vinyl chloride and autism. Bisphenol A (BPA) is a chemical used to make epoxy resin to line food cans and other containers, it is the building block for polycarbonate plastic and is present in paper products. It has been linked to externalizing behavior ("acting out") in children. Lead is a heavy metal used in industry it is present in many products including electronics, PVC plastics and cosmetic. It has been shown to damage brain tissue and has been linked to antisocial behavior and ADHD. PBDEs are Polybrominated diphenyl ethers, a class of flame retardant chemicals used in construction, electronics and furniture upholstery. They have been linked to impaired fme motor skills and attention. The authors of this 2009 study conclude "Our results demonstrate for the first time that transplacental transfer of polybrominated flame retardants is associated with the development of children at school age. Because of the widespread use of these compounds, especially in the United States, where concentrations in the environment are four times higher than in Europe, these results cause serious concern." learn more For more information on the chemical we and are children are currently exposed to we recommend the following resources Mind, Disrupted. Click on the image to the right to download their full report detailing the toxic chemicals they found in American people and how these are impacting our children's development Find out what pesticides are lurking on each type of food you eat at www.whatsinmyfood.org EveryDayExposures.com shows you where in yoll! home you will fmd these types of toxic chemicals and how to reduce your exposure to them. Get involved with current campaigns at PANNA (Pesticide Action Network North America] detoxify your home You can have an immediate impact on the amount of chemicals you and your family are exposed to on a daily basis by choosing products that do not use these types of toxic chemicals. Here are some we recommend, there are more in the Resource Center under General Health and Products. Green to Grow SPA-free Regular Neck file:I//C:/Users/mfry/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/LL7FYXIO/Neurodevelopmental%20Disorders... 3/5 12/4/2017 Baby Bottle Welcome Home Set -$ 54.99 Autism and Toxic Chemicals Nourish your baby with confidence with this Welcome Home Bottle Set. These eco- friendly regular-neck baby bottles are free of bisphenol-A (BPA) nitrosamine lead&PVC toxins present in conventional polycarbonate plastics. Organic Cotton 300 TC Percale Lace Sheets & Bedding ($28 -$280) Organic Cotton 300 TC Percale Lace Sheets&Bedding ($28 -$280) -$ 231.00 Made with certified fair trade organic cotton these classic white percale&lace sheets feature a luxuriously crisp 300 thread count weave that is cool&soft to the touch. Full Queen King or Cal King. Sold individually or as sets. Plan Toys 50 Organic Building Blocks - $ 20.00 Stimulate your child's imagination with these eco-friendly building blocks made from recycled organic rubberwood trees. Set contains 36 natural and 14 colored blocks. PlanToys has won numerous awards from Europe U.S.A. Japan and Thailand. Seventh Generation Chlorine-Free Stage 6 Diapers (35+ lbs) -$ 19.95 These soft&eco-friendly diapers are hypo- allergenic and free of chlorine latex &fragrances. They have a cloth-like feel and feature stretchy leg gathers&re-sealable closure tabs for a premium fit&absorbancy. Size: 35+ lbs. 26 count pack. file:///C:/Users/mfry/AppData/Local/Microsoft/Windows/Temporary%20lnternet%20Files/Content.Outlook/LL7FYXIO/Neurodeveloomental%20Disorders... 4/S 12/4/2017 Autism and Toxic Chemicals Seventh Generation Free and Clear HE Powdered Laundry Detergent -$ 17.25 This phosphate free natural powdered laundry detergent is hypo-allergenic and effective in both high-efficiency and standard machines. Plant-based surfactants and enzymes power out even the toughest stains. Gentle on fabric and the earth. 112 oz Dixon Ticonderoga Soyblend Biodegradable Crayons (24pk} -$ 2.45 Made from a natural soybean blend these eco-friendly crayons are completely biodegradable&contain no petroleum-based paraffin wax like conventional crayons. This 24 count certified non-toxic crayons come in an easy-open tuck box. The Ultimate Green Store Share on google Share on facebook Share on twitter Share on email More Sharing Services Receive Email Updates My Program Log In ©2009-2011 Rclafillffl WRtisQl, :J;nc. All Rights Reserved. • Designed and Developed by ilumivu, Inc • Contact Support • Terms~~dRY&N\9PUse • Privacy Policy About Us Initiatives Contact Us Resource Center Home A Place for You file:I//C:/Users/mfry/AppData/Local/Microsoft/Windows/Temporary%20Internet%20Files/Content.Outlook/LL7FYXIO/Neurodevelopmental%20Disorders... 5/5 Tammy McMinn From: Council Internet Email Sent: To: Wednesday, December 06, 2017 8:42 AM City Clerk Cc: Subject: Chris Hazeltine; Kyle Lancaster; Celia Brewer FW: IPM vote tonight City Council Members, This email was sent yesterday after our deadline. Andi From: Paige DeCino [mailto:p Sent: Tuesday, December 05, 2017 3:02 PM To: Council Internet Email <CityCouncil@carlsbadca.gov> Subject: 1PM vote tonight Dear Council Members and Mayor: This is what I plan on sharing with you at tonight's city council meeting: "You have the opportunity tonight to take the necessary first step to do something about the thousands of synthetic compounds, including pesticides, with which we come into daily contact. Since World War II, better living through chemistry has had a profound impact on our lives; in many cases for the better, but in too many cases leading to human and environmental harm. I cite DDT and dioxins as examples of those chemicals in the latter category. The problem exists that of the tens of thousands chemicals synthesized in the last 60 years, only a few hundred have been adequately tested by the FDA, USDA or EPA for toxicity. And of those tested, virtually none have been tested in combination with other chemicals, often considered inactive or inert ingredients in a formulation, so that it is impossible to know the true impact of a pesticide on human health. How compounds act synergistically with others is scary to say the least. The formulation in Roundup, for example, includes a surfactant that facilitates the herbicide's entry into the plant cells. And yet, there's been little research evaluating the impact of that combination, glyphosate and surfactant in Roundup, on our health. Other manufacturers that use glyphosate have different formulations, also untested. And that's just one herbicide. We are exposed to more chemicals each day than you can name or imagine. Sorting out the cross- reactions is daunting. 1 Therefore, the most straightforward approach is avoidance. Afinimize contact. The Integrated Pest Management plan takes that approach. Do what you can to avoid using harmful or potentially harmful chemicals. I trust you follow staff's recommendation to incorporate the good practices outlined in the IP M " Respectfully, Paige DeCino Preserve Ca avera I Coast:ll 1''<ll1b San C.:,;a C-..unt1 2 Tammy McMinn From: Sent: To: Cc: Subject: City Council Members, Council Internet Email Wednesday, December 06, 2017 8:43 AM City Clerk Chris Hazeltine; Kyle Lancaster; Celia Brewer FW: Toxic herbicide glyphosate This email was sent yesterday after our deadline. Andi -----Original Message----- From: Lynda Daniels [mai1to:l Sent: Tuesday, December 05, 2017 5:33 PM To: Council Internet Email <CityCouncil@carlsbadca.gov> Subject: Toxic herbicide glyphosate I am very concerned about the pest control spraying being done. I have watched in horror as squirrels have seizures and are paralyzed trying to drag themselves across the street after ingesting poisons. This must stop. We he hawks that way the diseased animals then die. Please stop the toxic spraying! Sent from my iPhone 1 Tammy McMinn From: Sent: To: Cc: Subject: City Council Members, Council Internet Email Wednesday, December 06, 2017 8:43 AM City Clerk Chris Hazeltine; Kyle Lancaster; Celia Brewer FW: Non Toxic Carlsbad This email was sent yesterday after our deadline. Andi From: Kim Goodsell [mailto:k Sent: Tuesday, December 05, 2017 7:55 PM To: Council Internet Email <CityCouncil@carlsbadca.gov> Subject: Non Toxic Carlsbad Dear Carlsbad City Council I'd like to tell you a story. This is a children's story. It's a tragic story never before told, because it has never happen before. The CDC predicts that today's children to be the first generation in American history whose lifespan will be cut 10 years short of their parent's because of the toxic landscape we've built around them. The majority of our children (54%) suffer with preventable chronic disease conditions which have never been known to affect children. Our children are not aging well. We are losing a generation of children. This is the story ... this is what's at stake here. Documenting Hope 7 minute trailer - Y ouTube We do not accept the "new normal" of sick children, any more than we accept the demise of fish in our oceans or the mass bee hive die off. Our greatest hope to reverse this devastating trend is to revolutionize how we think about our health and the human relationship with the planet. Stop exposing our children to toxins known to cause cancer, life threatening allergic reactions, asthma ... etc. NOW! Every generation has a responsibility to help our children find their force and fight for their future of health. There's only one time ... NOW! There's only one design ... a future of #HealthMadeByUs. There's only one sound ... all our voices together with a mighty roar that tells the world #WeAreNotWaiting! ! ... we are coming in force to take back our health! 3A Adopt Update to the 1PM Plan-All sites with Phased Implementation 3B Adopt Update to the IPM plan-All Sites Immediate Implementation. Our kids future of health depends on it! Kim Goodsell Kim Goodsell, Principal: Perfecting the Art of Aging 1 • Certified Integrated Nutrition Health Coach • Advanced Training in "children hood epidemics" from Epidemic Answers -Bringing awareness to the next generation of parents about the relationship between their environments and their future children's health. • MPI Cognition Certified practitioner of The Bredesen 3.0 Protocol™ • Advanced Clinical Training: Reversing Cognitive Decline -Institute of Functional Medicine • Certified MoCA Montreal -Cognitive Assessment Administrator • Kim Goodsell:Force For Health -YouTube 2 Chris Hazeltine, Parks & Recreation Director Elaine Lukey, Public Works Director Kyle Lancaster, Parks Services Manager December 5, 2017 Integrated Pest Management Recommended Action •Receive a staff report on Integrated Pest Management, consider available options on city owned or operated properties and rights of way, and adopt a Resolution providing direction to staff as appropriate Responsibilities •Parks & Recreation Department -183 ac. of Community Parks & School Athletic Fields -139 ac. of Passive Parks & Facilities Landscapes -90 ac. of Streetscapes, Medians & Parkways -137 ac. of Undeveloped Parks, Forests & Trailheads Responsibilities •Parks & Recreation Department -594 ac. of Open Space Preserves -19,000 Trees -18-hole Golf Course -47 mi. of Trails Responsibilities •Public Works Department -11 ac. of Habitat Mitigation Sites -15 ac. of Vegetation Control -3 ac. of Vegetation Monitoring -58 Buildings Historical Application •Creation, establishment, and maintenance of city owned properties and rights of way has historically included application of selective pesticides -Application is in accordance with the relevant local, state and federal regulations and applicable permits Definition •“Pesticide” (per CA Food & Ag. Code Section 12753): -(a) any spray adjuvant Definition •“Pesticide” (per CA Food & Ag. Code Section 12753): -(b) any substance, or mixture of substances which is intended to be used for defoliating plants, regulating plant growth or for preventing, destroying, repelling or mitigating any pest… Definition •“Pesticide” (per CA Food & Ag. Code Section 12753): -…which may infest or be detrimental to vegetation, man, animals, or households, or be present in any agricultural or nonagricultural environment whatsoever Definition •“Pesticide” by reference, includes: -Organic products and chemical products -Insecticides, herbicides, fungicides and rodenticides Standard Practice •Selection and application of these pesticides are to be performed according to the city’s IPM Plan -An IPM Plan directs health conscious and environmentally sensitive pest management strategies Core Values •IPM strategies are consistent with the Carlsbad Community Vision core values of: -Sustainability -Open Space and the Natural Environment Operations •Dec. 16, 2003 –Last Update to the IPM Plan •Nov. 30, 2017 -Draft Update to the IPM Plan -Monitoring of industry changes/best management -Receipt of concerns from citizens over pesticide use Focus of Update •Prevention and suppression of pest issues with the least impact on human health, the environment, and non-target organisms Pest Controls •Primary Control Tactics: –Cultural –Mechanical –Environmental/Physical –Biological –Pesticide Pesticide Controls •They may be used when other methods fail to provide adequate control of pests and before pest populations cause unacceptable damage –Considerations should be given for how/when to apply them the most effectively and sparingly Pesticide Controls •Pesticides that are broad-spectrum and persistent are to be avoided –They can cause more environmental damage and increase the likelihood of pesticide resistance Pesticide Controls •Considerations should be given to the proximity to water bodies, irrigation schedules, weather, etc., that may result in the pesticide being moved offsite, into the environment Pesticide Controls •Topics further addressed in Update to the IPM Plan: –Criteria for Selecting Treatment Strategies –Selection of Appropriate Pesticides –Prioritized Use of Pesticides –Certification and Permitting Guiding Principles •Emphasize the initial use of organic pesticides •Limit the use of chemical pesticides where the general public congregates Guiding Principles •Use EPA Toxicity Category pesticides in a targeted manner by a certified pest control applicator, and only if deemed necessary by supervisory staff –to protect public safety –to prevent threats to sensitive species/native habitat Guiding Principles •Use EPA Toxicity Category pesticides in a targeted manner by a certified pest control applicator, and only if deemed necessary by supervisory staff –to assist in meeting regulatory compliance –to prevent economic loss Pilot Program •Majority of concerns received on chemical pesticides have pertained to school sites, parks and similar areas •Over the last 15 months, no chemical pesticides have been used on the 10 school sites maintained by the city –Only non-chemical pest control tactics were used Pilot Program •Greater number of weeds and burrowing rodents evident –Moderately negative effect on aesthetics of landscapes, and playability of athletic fields –Relatively low number of citizen complaints received Option 1 •Expand IPM Pilot Program – Specific Sites/Immediate –Under provisions of update to IPM Plan, include parks, community centers and libraries -for 1 year –Continue current IPM practices on balance of sites Option 1 •Expand IPM Pilot Program – Specific Sites/Immediate –Initial expenses absorbed within existing FY 2017-18 and pending FY2018-19 operating budgets –Return to City Council at the end of 1 year with report analyzing the results, impacts and costs Option 1 •Expand IPM Pilot Program – Specific Sites/Immediate –Pros: Allows review of benefits, impacts and costs of program on greater number sites, before considering adoption of the update to the IPM Plan; Limits costs –Cons: Impacts aesthetics/playability of high touch sites Option 1 •Expand IPM Pilot Program – Specific Sites/Immediate –Estimated Costs: •Second half of FY 2017-18 $250,000 -Parks & Rec; $75,000 - Public Works •First half of FY 2018-19 $250,000 -Parks & Rec; $75,000 - Public Works Option 2a •Adopt Update to IPM Plan – Specific Sites/Phased –Adopt update to the IPM Plan, with a phased implementation over the balance of FY 2017-18, on school sites, parks, community centers and libraries –Continue current IPM practices on balance of sites Option 2a •Adopt Update to IPM Plan – Specific Sites/Phased –City absorbs initial expenses related to the phased implementation in the FY 2017-18 operating budgets –Enhancement requests for the FY 2018-19 operating budgets to be included with Citywide submittal Option 2a •Adopt Update to IPM Plan – Specific Sites/Phased –Pros: Reduces use of chemical pesticides on high- touch sites in a phased manner –Cons: Impacts aesthetics/playability of high touch sites; Increases costs Option 2a •Adopt Update to IPM Plan – Specific Sites/Phased –Estimated Costs: •Second half of FY 2017-18 $200,000 -Parks & Rec; $50,000 - Public Works •Annually as of FY 2018-19 $500,000 -Parks & Rec; $150,000 - Public Works Option 2b •Adopt Update to IPM Plan – Specific Sites/Immediate –Pros: Reduces use of chemical pesticides on high- touch sites immediately –Cons: Impacts aesthetics/playability of high touch sites; Increases costs Option 2b •Adopt Update to IPM Plan – Specific Sites/Immediate –Estimated Costs: •Second half of FY 2017-18 $250,000 -Parks & Rec; $75,000 - Public Works •Annually as of FY 2018-19 $500,000 -Parks & Rec; $150,000 - Public Works Option 3a •Adopt Update to IPM Plan –All Sites/Phased –Adopt update to the IPM Plan, with a phased implementation over the balance of FY 2017-18, on all city owned/operated properties and rights of way Option 3a •Adopt Update to IPM Plan –All Sites/Phased –City absorbs initial expenses related to the phased implementation in the FY 2017-18 operating budgets –Enhancement requests for the FY 2018-19 operating budgets to be included with Citywide submittal Option 3a •Adopt Update to IPM Plan –All Sites/Phased –Pros: Reduces use of chemical pesticides on all sites in a phased manner –Cons: Impacts aesthetics/playability of all sites; Increases costs Option 3a •Adopt Update to IPM Plan –All Sites/Phased –Estimated Costs: •Second half of FY 2017-18 $300,000 -Parks & Rec; $90,000 - Public Works •Annually as of FY 2018-19 $750,000 -Parks & Rec; $225,000 - Public Works Option 3b •Adopt Update to IPM Plan –All Sites/Immediate –Pros: Reduces use of chemical pesticides on all sites immediately –Cons: Impacts aesthetics/playability of all sites; Increases costs Option 3b •Adopt Update to IPM Plan –All Sites/Immediate –Estimated Costs: •Second half of FY 2017-18 $375,000 -Parks & Rec; $112,500 - Public Works •Annually as of FY 2018-19 $750,000 -Parks & Rec; $225,000 - Public Works Option 4 •Suspend IPM Pilot Program –All Sites/Immediate –Suspend program on school sites, and halt further efforts to update the IPM Plan –Resume/continue current IPM practices on all sites Option 4 •Suspend IPM Pilot Program –All Sites/Immediate –City absorbs expenses related to the pilot program, and the refurbishment of the school sites, within the existing FY 2017-18 operating budget Option 4 •Suspend IPM Pilot Program –All Sites/Immediate –Pros: Returns or retains present aesthetics/playability of all sites; Limits costs –Cons: Resumes or continues historical use of chemical pesticides on all sites Option 4 •Suspend IPM Pilot Program –All Sites/Immediate –Estimated Costs: •FY 2017-18 $50,000 -Parks & Rec; $0 –Public Works Recommended Action •Receive a staff report on Integrated Pest Management, consider available options on city owned or operated properties and rights of way, and adopt a Resolution providing direction to staff as appropriate Options for Consideration 1.Expand IPM Pilot Program –Specific Sites/Immediate 2a.Adopt Update to IPM Plan –Specific Sites/Phased 2b. Adopt Update to IPM Plan –Specific Sites/Immediate 3a.Adopt Update to IPM Plan –All Sites/Phased 3b. Adopt Update to IPM Plan –All Sites/Immediate 4.Suspend IPM Pilot Program –All Sites/Immediate