• Expand the range of pesticide applications covered by the permit – The draft permit imposes more stringent requirements on discharges that cover more than 20 acres for aquatic pesticides or more than 640 acres (one square mile) for mosquito spraying. [p. 3, 37-38] These thresholds are arbitrary and are too high. If you are concerned about a water body that doesn’t meet these thresholds, EPA needs to hear about it.

• Protect drinking water and sensitive watersheds – The draft permit fails to make special considerations for pesticide applications directly into drinking water sources or into water bodies that feed drinking wells. When drinking water may be impacted by pesticide discharges, there should be more stringent limitations on pesticide use. The same should go for water bodies that serve as habitat for endangered or threatened species.

• Strengthen site monitoring requirements – EPA should require meaningful water quality monitoring after pesticide applications in all cases, just like EPA requires for other sources of permitted water pollution. The draft permit does not require in-stream monitoring after pesticide applications; instead, the applicator need only conduct a visual “spot check,” and need only do that if the opportunity arises. [p. 14, 31]

• Strengthen the public’s right-to-know – The public should have access – on EPA’s website and in state environmental agency offices – to all notices of intent to discharge pesticides, pesticide treatment planning documents, and monitoring data generated as part of the general permit process. The draft permit allows applicators to keep much of this information to themselves, or requires it to be disclosed only in the form of unhelpful summaries. [p. 19-25]