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Programmatic Environmental Impact Report for Integrated Vector Management Practices of the Sutter-Yuba Mosquito & Vector Control District

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Programmatic Environmental Impact Report for Integrated Vector Management Practices of the Sutter-Yuba Mosquito & Vector Control District Administrative Draft Final Programmatic Environmental Impact Report for Integrated Vector Management Practices of the Sutter-Yuba Mosquito & Vector Control District Prepared for: Sutter-Yuba Mosquito & Vector Control District 701 Bogue Road Yuba City, CA Prepared By: Eco-Analysts 1469 Humboldt Road, Suite 100 Chico, Ca 95928 EXECUTIVE SUMMARY This Program Environmental Impact Report (PEIR) has been prepared to cover ongoing activities of the Sutter‐Yuba Mosquito and Vector Control District (SYMVCD or “District”), an independent special district charged with protecting citizens of Sutter and Yuba Counties from vectors (i.e., insects or other organisms capable of harboring and transmitting agents of human diseases) and vector‐borne diseases. Originally established in 1946 as the Sutter and Yuba Mosquito Abatement District, the District’s name was changed to the Sutter‐Yuba Mosquito and Vector Control District in 1993. The District currently provides services primarily to residents of Sutter County and the valley floor of Yuba County. The District is funded ad valorem from property taxes, at two cents per dollar. The District has developed and adopted integrated vector management practices to guide control programs for targeted species. Species targeted by the District include many species within several genera of mosquitoes that are vectors of serious diseases, such as West Nile virus and Western equine encephalitis. The District also provides identification of and information to the public on other vector and nuisance species such as flies, cockroaches, ants, bedbugs, rats and bats. Integrated vector management practices include surveillance for vectors and disease, source reduction to limit breeding by vectors, education of the public in ways to aid source reduction and protect against disease‐carrying vectors, and control of vector species using both chemical and biological agents. SYMVCD uses a combination of physical inspections, trapping of mosquito species, and laboratory tests to establish the extent of vector populations and potential disease organisms. Information from field inspections is supplemented by contacts from the public about the presence and numbers of vectors and hosts. When vector populations surpass established thresholds and cannot be controlled with source reduction alone, the District applies chemical and/or biological control agents to reduce vector populations. Chemicals are rotated to reduce development of resistance in vectors and applied strictly according to label and safety requirements established by the US Environmental Protection Agency (USEPA) and the California Department of Pesticide Regulation. The District has applied for a general permit (Order No. 2011‐002‐DWQ; General Permit No CAG 990004) from the State Water Resources Control Board (SWRCB) for the application of mosquito insecticides to waterways and is a member of the Mosquito and Vector Control Districts’ Monitoring Coalition, which has recently been instituted to monitor effects of chemical mosquito control on water quality. The District’s program is overseen and monitored by the California Department of Public Health and the County Agricultural Commissioners. CEQA/NEPA Process Mosquito and vector control districts in California were established prior to the enactments of the National Environmental Policy Act (NEPA, 42 USC § 4321 et seq.) in 1969 and the California Environmental Quality Act (CEQA, Cal PRC §21000 et seq.) in 1970 and historically have been considered exempt from CEQA and NEPA analysis. However, recent federal court cases have raised questions about the potential effects upon rare and endangered species and water quality from habitat management activities and from pesticides. In 2001, the 9th Circuit Federal Court issued the first of three decisions (Headwaters Inc. v. Talent Irrigation District) that pesticides applied to waters of the United States Sutter‐Yuba Mosquito & Vector Control District i Programmatic EIR Integrated Vector Management Practices November 20, 2011 constitute chemical wastes or biological materials under the Clean Water Act. This case resulted in the adoption of an order requiring National Pollution Discharge Elimination System (NPDES) permits for the public health use of larvicides (pesticides to kill larval mosquitoes) by the California State Water Resources Control Board. A 2009 6th District Federal Appeals Court decision (National Cotton Council v. United States Environmental Protection Agency) required NPDES permits for the use of pesticides to kill adult mosquitoes (adulticides) for public health. The District is preparing this Program Environmental Impact Report (PEIR)/Environmental Impact Study (EIS) to serve as a basis for any future state or federal permits required for its operations and to disclose to the public the nature of the District’s activities and their potential effects on the environment. The CEQA/NEPA process was initiated by preparation of an Initial Study to determine if there were gaps in information on environmental issues and to assess the extent of potentially adverse environmental impacts. The Initial Study revealed that there are potential adverse impacts from the District’s programs in the areas of air quality, biology, water quality, greenhouse gases, and hazardous materials; these areas are the focus of the program EIR/EIS. Potential Areas of Controversy Potential areas of controversy include concerns of the public about exposure to toxic chemicals, the effect of these chemicals on human health and health of rare and endangered wildlife and other organisms, and the potential effect of source reduction practices such as vegetation clearing on protected habitats and organisms. Alternatives Several alternatives to the current program are evaluated in this PEIR. Alternative 1, the “No Project” Alternative, is a continuation of the current programs of the District and is the preferred alternative. The current District programs include the following main activities that are analyzed within this PEIR: Monitoring and estimating mosquito populations; Surveillance of West Nile virus and other arboviruses (viruses transmitted by arthropod vectors) in mosquitoes and sentinel chicken flocks; Biological control, including distribution of mosquitofish (Gambusia affinis) to the public for control of mosquitoes; Chemical treatment of mosquito populations with various larvicides (predominantly methoprene, water surface films, and bacterial larvicides) applied at ground level with truck‐ mounted or hand‐held sprayers or aerially from small agricultural aircraft; Application of adulticides (insecticides to kill adult mosquitoes; predominantly synthetic pyrethroids, pyrethrins, and the organophosphates, malathion and naled) to rice fields, duck clubs, and other vector sources using ultra‐low volume (ULV) sprayers mounted on trucks or from aircraft; Sutter‐Yuba Mosquito & Vector Control District ii Programmatic EIR Integrated Vector Management Practices November 20, 2011 Source reduction activities, including recommendations of best management practices (BMPs) for source reduction to landowners. Public education about disease risks and source reduction methods and responding to service requests made by the public. The second alternative assessed a number of variations on eliminating or significantly reducing the application of chemical pesticides. Scenarios examined under this alternative included elimination of ULV application of adulticides only, discontinuation of aerial larvicide applications only, elimination of all ULV insecticide application by the District, and increased use of abatement proceedings to compel landowners to control mosquito sources using their own methods. None of the scenarios considered presented clear significant environmental benefits over the current program when weighed against the potential risks to human health by eliminating some or all of the chemical control of vectors. In addition, the amount of insecticides currently applied by the District for public health is a small fraction of the overall use of the same active ingredients in the District; therefore, eliminating chemical control by the District would not significantly decrease the amount of these insecticides in the environment. Finally, increased reliance upon private landowners to control mosquitoes could result in a net increase in insecticide usage due to differences in efficiency between trained professionals and private landowners. Findings of Significance The assessment for the Initial Study eliminated a number of areas of potential environmental effects because the project does not include new construction, significant changes in land form or land use, or significant changes in activities. The project, as proposed, is a continuation of ongoing policies and activities. None of the District’s operations or policies induces, facilitates or stimulates growth. No major changes in activities or practices are currently being considered that would create additional impacts under the preferred alternative. The current insecticides used by the District are non‐persistent compounds that degrade within a few hours to a few weeks when exposed to sunlight, moisture and soil. None of the active ingredients used by SYMVCD are expected to have significant adverse effects on human health when used as specified on the product labels as in the current vector control program. Based on studies by USEPA and several universities, there will be no cumulative impacts to human health with continued
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