1. Status of California NPDES Permit

2. TIMELINES SEPTEMBER 2010-DRAFT PERMIT AVAILABLE FOR PUBLIC COMMENT OCTOBER 19, 2010-PUBLIC HEARING NOVEMBER 2 ND, 2010-PUBLIC COMMENTS DUE TO SWRCB JANUARY 4 TH, 2011-DRAFT PERMIT UP FOR SWRCB ADOPTION APRIL 2011-PERMIT ENACTED

3. WHAT IS NEEDED FOR NPDES COMPLIANCE? FILE A NOTICE OF INTENT (NOI) FILE A NOTICE OF INTENT (NOI) PESTICIDE APPLICATION PLAN (PAP) PESTICIDE APPLICATION PLAN (PAP) ADMINSTRATIVE FEE -$1500 ANNUALLY ADMINSTRATIVE FEE -$1500 ANNUALLY SWRCB STAFF WILL REVIEW THE APPLICATION PACKET-NO LONGER THROUGH THE REGIONAL BOARDS

4. PROVISION COMPLIANCE STANDARD PROVISIONS STANDARD PROVISIONS FOLLOW FIFRA, BMPS, ETC FOLLOW FIFRA, BMPS, ETC MONITORING MONITORING CHEMISTRY AND TOXICITY SAMPLING CHEMISTRY AND TOXICITY SAMPLING RECORDKEEPING RECORDKEEPING 3 YEAR HISTORY 3 YEAR HISTORY REPORTING REPORTING MONTHLY AND ANNUAL REQUIREMENTS MONTHLY AND ANNUAL REQUIREMENTS

5. WHAT DO WE HAVE TO MONITOR FOR? LARVICIDES LARVICIDES TEMEPHOS TEMEPHOS ADULTICIDES ADULTICIDES PYRETHRIN, PERMETHRIN, RESMETHRIN, SUMITHRIN, PRALLETHRIN, ETOFENPROX, PIPERONYL BUTOXIDE, NALED, MALATHION, MGK 264 PYRETHRIN, PERMETHRIN, RESMETHRIN, SUMITHRIN, PRALLETHRIN, ETOFENPROX, PIPERONYL BUTOXIDE, NALED, MALATHION, MGK 264 SAMPLING WILL BE DONE IN THREE ENVIRONMENTS-URBAN, AGRICULTURAL, WETLAND

6. HOW MANY SAMPLES NEED TO BE TAKEN? EACH PRODUCT 6 EVENTS EACH YEAR IN 6 EVENTS EACH YEAR IN URBAN URBAN AGRICULTURAL AGRICULTURAL WETLAND WETLAND CHEMISTRY ANALYSIS CHEMISTRY ANALYSIS TOXICITY ANALYSIS TOXICITY ANALYSIS OTHER (TEMP, pH, DO, EC, TURBIDITY) OTHER (TEMP, pH, DO, EC, TURBIDITY)

7. CHEMISTRY ANALYSIS BACKGROUND SAMPLE BACKGROUND SAMPLE DONE WITHIN 24 HOURS BEFORE APPLICATION DONE WITHIN 24 HOURS BEFORE APPLICATION EVENT SAMPLE EVENT SAMPLE DONE WITHIN 24 HOURS AFTER APPLICATION DONE WITHIN 24 HOURS AFTER APPLICATION POST EVENT SAMPLE POST EVENT SAMPLE DONE WITHIN 7 DAYS AFTER APPLICATION DONE WITHIN 7 DAYS AFTER APPLICATION

8. TOXICITY SAMPLE BACKGROUND SAMPLE BACKGROUND SAMPLE DONE WITHIN 24 HOURS BEFORE APPLICATION DONE WITHIN 24 HOURS BEFORE APPLICATION EVENT SAMPLE EVENT SAMPLE DONE WITHIN 24 HOURS AFTER APPLICATION DONE WITHIN 24 HOURS AFTER APPLICATION

9. WHAT NEXT? IF CHEMISTRY SAMPLES EXCEED TRIGGERS OR TOXICITY SAMPLE FAILS THEN MORE ANALYSIS COULD BE REQUIRED BY SWRCB (48 HR SAMPLE, 72 HR SAMPLE, ETC)

10. HOW MUCH? WORST CASE-11 CONSTITUENTS CHEMISTRY 18 SAMPLES PER ENVIRONMENT 18 SAMPLES PER ENVIRONMENT 3 ENVIRONMENTS 3 ENVIRONMENTS 11 X 18 X 3 = 594 SAMPLES @ $500 EACH = $297,000 TOXICITY 12 SAMPLES PER ENVIRONMENT 12 SAMPLES PER ENVIRONMENT 3 ENVIRONMENTS 3 ENVIRONMENTS 11 X 12 X 3 = 396 SAMPLES @ $1000 EACH = $396,000 TOTAL COST FOR SAMPLING $693,000

11. OTHER COSTS COST OF PROGRAM MANAGER COST OF PROGRAM MANAGER FUTURE INVESTIGATION COSTS- DEPENDING ON FINDINGS FROM EXCEEDING TRIGGERS OR FAILED TOXICITY FUTURE INVESTIGATION COSTS- DEPENDING ON FINDINGS FROM EXCEEDING TRIGGERS OR FAILED TOXICITY TEMPERATURE, pH, DO, etc TEMPERATURE, pH, DO, etc

12. NEXT STEPS DEVELOP COALITION CONTINUE TO WORK WITH SWRCB STAFF TO MINIMIZE OUR REQUIREMENTS IN THE FUTURE WORK ON A FEDERAL LEGISLATIVE FIX