TO: SEE Committee Members
FROM: Bill Letteri, Public Works Director
SUBJECT: Response to Letter from Ms. Fawn Pattison Regarding Integrated Pest Management
DATE: March 16, 2006
The purpose of this report is to provide follow-up information about the Town’s Least Toxic Pest Management Policy in response to concerns raised by Ms. Fawn Pattison in a letter to the Council dated January 30, 2006.
On October 3, 2005 the Council was sent a petition from Ms. Julie Vann requesting that the Town adopt an Integrated Pest Management Plan. On November 21, 2005 the Council received a report from the Town Manager in response to Ms. Vann’s petition. At that meeting a Council Member raised concerns about the Town’s use of contracted landscape maintenance companies to apply pesticides at Town maintained Bermuda grass ball fields and at the Strowd Rose Garden. At that time the Council also requested that the staff contact Mr. Allen Spalt, former director of the Pesticide Education Project, and seek his advice for possible improvements to the Town’s landscape maintenance practices.
On January 30, 2006 the Council was sent a letter from Ms. Fawn Pattison, Executive Director of the Pesticide Education Project, identifying concerns she has with the Town’s Integrated Pest Management Program (Attachment 1). On February 13, 2006 the Council directed that the staff meet with the Council’s Sustainability, Energy and Environment Committee to review Ms. Pattison’s concerns.
In response to the questions raised by the Council at its November 21, 2005 meeting, Town staff has been preparing a follow-up report on its Integrated Pest Management Policy. Attachment 2 is a draft of this report prepared by Curtis Brooks, the Town’s Landscape Architect/Urban Forester.
The draft report provides a comprehensive review of the implementation practices the staff has used in support of the Town’s Least Toxic Integrated Pest Management Policy and includes a number of recommended updates to these practices to further meet the objective of the Policy to minimize the use of pesticides on Town owned properties. It was prepared after conferring with Mr. Allen Spalt, Ms. Pattison’s predecessor as Director of the Pesticide Education Project, and discussing possible changes in the Town’s landscape maintenance practices with ball field and rose garden maintenance experts at North Carolina State University, the JC Raulston Arboretum and elsewhere. We believe this report answers the essential questions posed by Ms. Pattison in her letter but believe some supplemental discussion is warranted in response to the following highlighted general concerns she included in her review of the Town’s program:
· Contractors not in compliance with policy
Staff Response: As recommended in the draft Integrated Pest Management report to the Council the staff intends to distribute the Town’s Least Toxic Integrated Pest Management Policy to all future contractors providing pest control services to the Town in an effort to negotiate contracts that further reduce the use of pesticides on Town owned properties. We believe that this could result in a decrease in the frequency and quantity of pesticide applications but, as recommended in the draft report, would not eliminate the use of all pesticides by contractors, notably those funded by the Strowd family estate to maintain the rose garden. As discussed in the draft report, information we have received from a number of sources suggests that more significant reductions in pesticide use at the Strowd Rose Garden, specifically discontinuing all preventative fungicide applications, cannot be recommended at this time unless a plan is put in place to significantly redesign the garden with plantings that are more disease resistant than the hybrid roses that were donated to the Town when the garden was created.
· Spotty compliance across departments
Staff Response: We believe that the recommended newly negotiated pest control contracts could make pest management practices more consistent across Town departments. We acknowledge Ms. Pattison’s commendation to the Town on its pest management practices in public housing and at Town fire stations but note that in buildings fully open to the public, such as Town Hall and the Community Center, maintaining sanitary conditions at a level that effectively suppresses pest populations and eliminates the need for all pesticide applications can be challenging.
In her comments, Ms. Pattison also indicated that proper staff training of pesticide hazards and alternative pest management practices is an important component of a cost-effective Integrated Pest Management program. We believe the staff is well trained and note that since the Town initiated its Least Toxic Pest Management Policy in 1999, all of the staff involved in pesticide use has undergone extensive training, and although not required by state regulations, these staff members are required by the Town’s Integrated Pest Management Coordinator to obtain Commercial Pesticide Applicators Licenses.
· Potential exposures to high-risk populations
Staff Response: As described in the draft report, the Town’s existing landscape maintenance practices prohibit the use of any pesticides, with the exception of necessary spot applications of wasp killers, in Town owned playgrounds. As recommended in the draft report, future scheduled pesticide applications on Town owned Bermuda grass ball fields would be reduced to a total of two applications per year, with no applications being scheduled at the Scroggs Elementary School field which is under a shared use and maintenance agreement with the Chapel Hill Carrboro City School System.
· Unnecessary use of high-hazard chemicals
Staff Response: The Environmental Protection Agency designates pesticides into four categories based on their potential hazard. When the Integrated Pest Management Coordinator determines that pesticide applications are merited to address a pest problem, effective pesticides with lower hazard designations are utilized. Accordingly, existing Town practices require that no Category I (labels include the word “DANGER”) or Category II (labels include the word “WARNING”) pesticides be applied by Town staff and recommended updates to the Town’s practices will extend this restriction to the contractors working for the Town at the Strowd Rose Garden and the Bermuda grass ball fields. When pesticides are applied by Town staff, they are non-restricted use products of the type available over the counter to the general public. Although all chemicals can pose some level of risk, the Town’s restrictions on the use of Category I and II pesticides is intended specifically to address “high-hazard” chemicals.
Ms. Pattison also suggests, without providing specific information, that there are alternative products and/or management practices that are cost effective alternatives to the pesticides the Town currently does use. We believe that in some cases these alternative approaches may be reasonable and that is the essential issue that the Town’s Integrated Pest Management Coordinator must study and consider as determinations are made on a case by case basis as to how specific pest problems are to be dealt with. We also believe, however, that there are some pest problems the Town addresses where alternative approaches are either ineffective or unreasonably labor intensive. Examples of these problems would include control of fungal diseases on hybrid roses as previously discussed, control of crabgrass infestations in heavily utilized soccer fields, control of naturalized Bermuda grass in mulched areas around trees and other plantings, and the control of some perennial invasive species, notably Japanese honeysuckle and wisteria once established in the Town’s cemeteries, parks and other facilities. We believe that in these types of situations, restrictions on the use of all pesticides would likely result in a notable decrease in the level of landscape maintenance service the Town staff is able to provide.
The Town’s Least Toxic Integrated Pest Management Policy was established in 1999 to integrate alternative pest control measures into the Town’s pest control program in an effort to reduce the amount of pesticides applied to Town owned properties. The attached draft Integrated Pest Management follow-up report provides a comprehensive review of how the policy has been implemented and includes recommendations to improve the Town’s pest management practices to further reduce pesticide use. We believe that the Town’s pest management practices set an example to other communities as well as our own citizens on how to minimize pesticide applications while still providing reasonably maintained and fully functional landscape areas.