1. EPA NPDES Pesticides General Permit (PGP) – Georgia Update Rosmarie Kelly Public Health Entomologist Georgia Division of Public Health

2. October 31, 2011 NPDES permits under the Clean Water Act will be required to make pesticide applications legally allowed under FIFRA for pesticide applications made to waters of the U.S.

4. What Does It Mean To Work Under the Clean Water Act FIFRA vs CWA Cost/Benefit No Cost/Benefit Risk-Based Hazard-Based $7,000/Incident $37,500/Day No Citizen Suits Citizen Suits Citizens can challenge NPDES permits.

5. What Does It Mean To Work Under the Clean Water Act Georgia EPD Working Draft, Permit No. GAG820000 5. CIVIL AND CRIMINAL LIABILITY The operator is liable for civil or criminal penalties for noncompliance with this permit and must comply with applicable State and Federal laws including promulgated water quality standards. The permit cannot be interpreted to relieve the operator of this liability even if it has not been modified to incorporate new requirements.

6. Yes, it is STILL only a draft!

8. PGP Flowchart

10. We have asked for an increase in acreage for the annual threshold.

11. EPA’s Current Requirements For Filing an NOI

19. Conclusions http://www.GAmosquito.org GA EPD has shown a willingness to work with mosquito control in Georgia and with the GMCA GA EPD is very ignorant about mosquito control practices and they are quite comfortable with their ignorance A whole lot of programs in Georgia are totally clueless that there is an upcoming permit requirement There is an extension until October, so no permit is needed this year…

20. Legislative Fix On March 31, 2011, HR 872 was passed in the house. The Reducing Regulatory Burdens Act of 2011 would eliminate the need to file an NOI and work under an NPDES permit. The AMCA, as well as other organizations, are working on a companion bill to be passed in the Senate, to bring about a “regulatory fix” so that the requirement to work under an NPDES permit would be eliminated.

22. ANY QUESTIONS? NPDES Update E-List Dr Rosmarie Kelly Georgia Division of Public Health 404-657-2912 [email_address] EPD Jill Bingham [email_address] EPD Gigi Steele [email_address]