Exhibit_B_-_IPM_Program_FINAL_MAY_2022.pdf

INTEGRATED PEST MANAGEMENT PROGRAM

WATER DEPARTMENT

MAY 2022

Table of Contents

1. Introduction

2. Purpose

3. Goals

4. Roles and Responsibilities

5. IPM Process

6. Pesticide Use

7. Reduced Risk Pesticide List (RRPL)

8. Exemption Requests

9. Emergency Use of Pesticides

10. Notification of Pesticide Use

11. Reporting

12. Contract Language

13. Training

14. Meetings

15. IPM Program Review and Updates

Exhibits

A. Reduced-Risk Pesticide List B. Exemption Request Form C. Pesticide Use Posting Template D. Pesticidal Bait Area Posting Template E. Pesticide Use Form F. Definitions

1. Introduction On October 28, 2003, the City Council adopted Resolution No. NS-26,405 adopting the Pesticide Use Policy, and approved the City of Santa Cruz Integrated Pest Management Guidance Manual and Reduced-Risk Pesticide Lists (RRPL). The Policy called to eliminate or reduce pesticide applications on City property to the maximum extent feasible. It also set the assumption that pesticides are potentially hazardous to human and environmental health and that priority shall be given to non-pesticide alternatives when considering the use of pesticides on City property. The Guidance Manual describes policies and procedures that constitute the IPM approach adopted by the City Council. It is a living document, which is intended to reflect IPM as a dynamic process that continues to evolve as new insights, methods and products become available. It should be reviewed and revised regularly.

The Policy and Guidance Manual do not apply to the use of any pesticide for the purpose of improving or maintaining water quality at water treatment plants, wastewater treatment plants, reservoirs and related collection, distribution and treatment facilities or the treatment of sewage or to the use of anti-microbial agents for the purpose of protecting public health and safety in the provisions of healthcare and treatment of water in public swimming pools.

2. Purpose The purpose of this IPM Program is to carry out the requirements of the City’s Policy and to provide City employees and pest control contractors with an overview of the City IPM principles. This IPM Program will ensure City operations, including contracted services that manage pests or vegetation on City property, do so in an environmentally sensitive manner while addressing the health and safety of City employees and the general public, and economic and aesthetic requirements.

3. Goals Type Goal

Health & Safety and Habitat Management

Reduce impacts of harmful algae blooms in Loch Lomond Reservoir

Habitat Management

Facilitate restoration work and overall protection of biodiversity

Health & Safety Reduce pests at worksites

Health & Safety Reduce impacts of rodents on critical infrastructure

Health & Safety Ensure worksite employee safety

Health & Safety Implement IPM training

Health & Safety Reduce ladder fuels and maintain defensible space around critical infrastructure

4. Roles and Responsibilities

City IPM Coordinator

• Manage the City’s IPM Program and administer the Pesticide Use Policy

• Review and approve department IPM Programs on an annual basis

• Stay up to date on low-risk IPM principals, safe application of pesticides and alternatives to pesticide use

• Collect departmental IPM reports and prepare annual City IPM report

• Maintain the Reduced-Risk Pesticide List (RRPL)

• Review and provide determination on Exemption Requests

Department Head

• Designate a Department IPM Coordinator

• Ensure Department IPM Coordinator has the necessary resources (e.g.

funds, staff, material, equipment, etc.) to implement the IPM Program

• Review and approve department IPM budget

Department IPM Coordinator

• Act as the department liaison for departmental IPM activities and communication

• Stay up to date on low-risk IPM principals, safe application of pesticides and alternatives to pesticide use

• Maintain and implement the department IPM Program

• Review and submit RRPL revisions to the City IPM Coordinator

• Prepare and submit Exemption Requests to the City IPM Coordinator

• Prepare, collect and submit IPM reports

• Coordinate department IPM budget

• Coordinate biannual Department IPM meetings with the IPM team

• Implement IPM training

• Evaluate the effectiveness of the IPM Program on an annual basis

The Watershed Compliance Manager is designated the Department IPM Coordinator.

Department IPM Team

• Stay up to date on low-risk IPM principals, safe application of pesticides and alternatives to pesticide use

• Attend biannual Department IPM meetings

The Department IPM Team shall consist of, at a minimum, the Watershed Compliance Manager, Water Facilities Field Supervisor, Water Resources Associate Planner II and Engineering Associate Planner II.

Employee

• Adhere to the IPM Program

• Implement IPM activities

• Attend IPM and safety trainings

5. IPM Process IPM is a coordinated application of a variety of suitable management techniques, providing pest managers with options and the necessary tools to manage pests in a given system. This IPM Program consists of:

• Identify pest

• Monitor for pest presence

• Set action threshold

• Determine management techniques

• Evaluate treatment effectiveness

• Conduct recordkeeping

• Identify Pest

Identify pests, potential pests and problem area. Proper identification of pests is critical to understanding how to control them while minimizing impacts to non-target organisms. Once the pest has been identified, knowledge of its life cycle, method(s) of reproduction, habitat requirements, phenology, and other characteristics can help determine optimal control strategies and timing. Plants can be identified through observation of the appearance of features such as stems, leaves, and flowers. Mobile apps such as iNaturalist and PlantNet are also available free of charge and can be helpful in identifying plants in the field.

Although pests such as rodents may not be directly observed, signs of pest presence, activity, or damage can be helpful in identification efforts. For example, the size and appearance of rodent droppings can help distinguish between rats and mice, and the appearance of burrow entrance mounds can help distinguish between gophers, ground squirrels, and moles.

• Monitor for Pest Presence Monitor pests to determine pest population size, occurrence, and natural enemy population, if present. Identify decisions and practices that could affect pest populations. Observe the pest life stages combined with an understanding of the pest life cycle to achieve better-timed control efforts and provide the foundation for long-term solutions to pest problems. If pest control is necessary, use such information to guide effective pest control decisions such as which management strategies to employ and when to employ them.

If resources do not allow for systematic monitoring of all management sites, monitor limited number of sites at a time.

• Set Action Threshold Assess and set action threshold levels for each pest at each site based on the following:

• the tolerable level of environmental, aesthetic, economic damage or risk to human health as a result of the pest population

• the size or density of the pest population that must be present to cause unacceptable environmental, aesthetic, economic damage and/or risk to human health

Conduct pest control if the threat of non-action is significant and action thresholds are exceeded or are anticipated to be exceeded.

• Determine Management Techniques

Determine the most effective treatment time, based on pest biology and other variables, such as weather, seasonal changes in wildlife use and local conditions. Be familiar with control tools available (see below) and what impacts they may have to non-target organisms, humans, and the environment. Utilize information known about the pest to identify and implement a combination of cultural, mechanical/physical, biological, and chemical control tools that are environmentally sound and most likely to be successful. Relying on a single control method can cause pest populations to adapt and overcome the control method or result in the increased presence of other pest species less susceptible to the control method. Shy away from overly restricting the use of management tools that may be important for addressing pest problems.

When indoors, staff should use baits or least toxic methods of pest control rather than sprays.

• Physical/Mechanical Control: mowing, hand pulling, trimming, insect/rodent trapping

• Cultural Control: irrigation management, fertilization, overseeding, aeration

• Biological Control: grazing, encouragement of predation, habitat modification

• Chemical Control: herbicides, insecticides, fungicides, rodenticides, rodent fumigation

• Evaluate Treatment Effectiveness

Conduct follow-up monitoring to evaluate the effectiveness of treatments and to help guide future actions. Note species that were not controlled or only partially controlled. If after management actions have been implemented, pest populations still exceed threshold levels, evaluate a different management approach. Monitor and evaluate potential adverse impacts, such as damage to non-target plants or pest resurgence, resulting from treatment and allows for prompt corrective action to be taken. Compare post-treatment conditions to pre-treatment conditions, which may need to be done several weeks or months.

• Conduct Recordkeeping

Maintain records of pest management activities (e.g. techniques, effectiveness, costs, etc.). Note the acreage/mileage treated (round to the nearest acre/mile), hours spent (round to the nearest hour), location and outside costs such as contractor fees, and volunteer hours associated with each type of activity.

For invasive pest management projects, collect and record data on the population size and distribution to track annual progress on control efforts and plan future activities. Request similar information from contractors. For pesticide applications by pest control contractors, record all information required for monthly County Agricultural Commissioner (CAC) monthly pesticide use reporting. Whenever possible, enter data into an electronic database system, to later use for evaluation.

Retain pre- and post-monitoring records to increase knowledge of the pests and allow pest managers to more accurately assess the impacts of environmental factors such as weather on pest populations, which in turn allows for more efficient and effective selection of pest control methods and timing. Save pictures, noting the date, time and location, whenever possible.

6. Pesticide Use Application of any pesticide, insecticide, herbicide, rodenticide, or algaecide, by a City employee triggers the requirement for an Operator Identification (OpID) number and training pursuant to Title 3 California Code of Regulation, Section 6724 Handler Training.

Application of any pesticide, insecticide, herbicide, rodenticide, or algaecide by a City employee that is on the California Restricted Materials list, triggers the requirement for a California Restricted Materials Permit and a staff member with a Qualified Applicator

Certificate (QAC) or Qualified Application License (QAL). If a City Department Coordinator permits the application of any pesticide, insecticide, herbicide, rodenticide, or algaecide by a City employee, the Department IPM Coordinator shall ensure the regulatory requirements noted above are met.

Note: Pursuant to Food and Agricultural Code, section 11408, and California Code of Regulations, section 6622(c), an OpID or California Restricted Material Permit is not required for industrial use. Water treatment plants and sewage treatment plants are identified as industrial use by the California Department of Pesticide Regulation.

7. Reduced Risk Pesticide List (RRPL)

The City IPM Coordinator shall develop and maintain the RRPL in coordination with Department Coordinators (Exhibit A). The RRPL identifies pesticide products that are:

• “Allowed” – Acceptable for use

• “Limited Use” – Sub-group pesticides that have a hazard ranking indicating moderate toxicity and may be used only in limited predetermined situations and conditions

• “Exemption Required” – Sub-group pesticides can only be used under limited predetermined situations and conditions. These pesticides are used to manage a pest that current lacks an effective non-chemical alternative. The pesticide will be removed from the list as soon as a suitable IPM method or less hazardous pesticide is identified for replacement.

The RRPL shall be reviewed and updated annually, or as needed, to remove products that are no longer used or available, and to add to the list. When evaluating new products, the City IPM Coordinator shall consider the City’s IPM approach, environmental and human health hazard, and costs. The City IPM Coordinator may also reference resources such as the United State Environmental Protection Agency (USEPA), University of California Cooperative Extension (UCCE) or a Pest Control Adviser (PCA) when evaluating products. Record decisions made to accept or deny products to the RRPL. Any revisions to the RRPL shall be communicated to all Department IPM Coordinators.

8. Exemption Requests In some cases, City staff or pest control contractors may not be able to adequately manage a pest by using non-chemical methods and products approved on the RRPL.

Employees or pest control contractors The Department IPM Coordinator may submit an Exemption Request (Exhibit B) to the City IPM Coordinator for use of a product not on the RRPL as follows:

a. The City IPM Coordinator may grant a specific exemption, with limited conditions for use, for up to an one-year period upon a written request showing that a department has:

i. Identified the need for pesticide use;

ii. Researched pesticide alternatives; and

iii. Identified prevention strategies to reduce the likelihood of needing additional exemptions.

b. An exemption may be continued beyond the one-year period by filing a new

Exemption Request.

c. The City IPM Coordinator shall have the discretion to revoke any exemption.

9. Emergency Use of Pesticides

a. A Department IPM Coordinator may apply to the City IPM Coordinator for an emergency pesticide use exemption in the event that a pest outbreak poses an immediate threat to the health and safety of City employees and the general public or may cause significant economic damage.

b. If the City IPM Coordinator cannot respond to the application in a timely manner, the Department IPM Coordinator submitting the application may authorize the one-time emergency use of the required pesticide and provide notice of the emergency application to the City IPM Coordinator in writing within

48 hours.

c. Posting of emergency use of pesticides shall be at the time of pesticide application and comply with all other posting requirements.

d. Reporting of the exemption and pesticide use will comply with all other notification requirements.

10. Notification of Pesticide Use Except as provided for in emergency use, any City department or contractor that uses or authorizes the use of a pesticide shall comply with the following notification procedures:

a. Signs shall be posted at least two working days before the application of the pesticide and remain posted at least four days after application of the pesticide, except for emergency use of pesticides, which are posted at the time of treatment, and baits in accordance with Section [10](f)(3) below.

b. Posting shall be required only in areas where people can reasonably be expected to frequent and as near as practical to the site of applicant.

c. Signs shall be posted at every point where the pesticide is applied if the pesticide is applied in an enclosed area, and (II) in highly visible locations around the perimeter of the area where the pesticide is applied if the pesticide is applied in an open area.

d. Signs shall be of a standardized design that are easily recognizable to City employees and the general public;

e. Signs shall contain the:

i. Product name,

ii. Manufacturer name,

iii. Active ingredient,

iv. EPA Registration number,

v. Target pest,

vi. Date of application,

vii. Date for re-entry, if any is required, to the area treated,

viii. Date sign may be removed,

ix. Signal word, and

x. the name and contact number of the City department responsible for the application.

f. Exemptions to Posting

i. Posting requirements shall not apply in right-of-way locations. If pesticides are used in such locations, the department or contractor that uses or authorizes the use of a pesticide shall provide a public access telephone number for information about pesticide applications. The public access telephone number shall be posted at Water Administration, 212 Locust Street, Santa Cruz, CA 95060. Information provided shall include all the items in Section [10](e).

ii. Any pesticide granted an emergency exemption shall not be required to be posted prior to treatment. However, all other requirements for posting as set forth in Section 10 shall be followed.

iii. The use of baits does not require notification signs. However, if using pesticidal baits, the department employee or contractor that uses or authorizes the use of a pesticide shall post a permanent sign at the facility where the baits are used. The sign shall contain:

1. Product name

2. Manufacturer name

3. Active ingredient

4. EPA Registration number,

5. Target pest,

6. Area(s) where the baits are commonly placed,

7. Signal word, and

8. the name and contact number of the City department responsible for the bait application.

11. Reporting Pest management records and reports are public records and shall be retained for two years. Reports shall be used to identify and track trends and adapt Program goals.

• Pest Control Contractors Reports Pest control contractors hired by the City to apply pesticides must complete and attach a "Contractor Summary Pesticide Use Report" with each invoice submitted to the City.

Typically, pest control contractors do not report pesticide use data to individual clients. They are only required to aggregate the total amount of pesticide applied for all clients on a monthly basis and report this data to the County Agricultural Commissioner. In order for the City to obtain data on pesticide applications applied by contractors on City property, the reporting requirement must be included in the contract or other contract document between the City and the contractor (see Section 12 Contract Language).

• Department Annual Reports

Each Department IPM Coordinator shall submit a summary of pest management records, to the City IPM Coordinator by the 15th of January of the following calendar year. The report shall include:

i. Pest management records, including at least the following information

1. Target pest and extent of problem;

2. Product name, active ingredients, EPA registration number, and quantity of pesticide used;

3. Site of the pesticide application;

4. Date of pesticide application;

5. Name of person conducting pest management activity;

6. Application equipment number, if applicable;

7. Prevention and other non-chemical methods of control recommended or used, and;

8. Evaluation of effectiveness.

ii. A list of all non-chemical pest management methods used to prevent or suppress pests during the calendar year. Such methods include:

biological, cultural, physical, manual, mechanical, and educational (behavioral change) techniques;

iii. Summary of Exemption Requests and emergency use of pesticides

• City Annual Report The City IPM Coordinator shall use Department IPM Coordinator annual reports to prepare and submit an annual Citywide pesticide use report to the City Manager by January 31 of the following year. Any exemptions requests and their disposition shall be included in an annual report, as well as any emergency use of pesticides.

12. Contract Language

a. When the City enters into a new contract or amends an existing contract to extend the term of the contract for more than six months beyond the current term and any optional extension periods, and the contract pertains to pest management related activities, the contract shall require compliance with the provisions of the City’s IPM Policy including those relating to pesticide restrictions, record keeping, and reporting. The contract may include the sample language below.

Contractor is responsible for pest management on the Premises. Contractor must comply with the City’s Integrated Pest Management (IPM) Policy. The Reduced Risk Pesticide List that identifies pesticides authorized for use is available upon request.

b. When the City enters into a new lease in which the City is occupying or using property not owned by the City, the City shall use reasonable efforts to negotiate the use of IPM practices as part of that lease. In current leases in which the City is occupying or using property not owned by the City, the City shall encourage the use of IPM practices whenever practical.

c. When the City is granted an easement, the maintenance of the easement shall be in compliance with the City IPM Policy if consistent with the terms of the easement.

13. Training The Department IPM Coordinator shall implement initial and annual refresher training to staff who are responsible for pest management. Such training shall include:

• IPM goals

• introduction to identification of common pests and plant diseases

• introduction to the evaluation of alternative strategic control options

• IPM process

• RRPL and Exemption Requests

• toxicology of commonly used pesticides

• notification requirements

• reporting requirements

Training records shall be retained in the employee’s training folder for the duration of the person’s employment and 4 years after the employee’s separation from the City, or as consistent with the City’s retention schedule.

14. Meetings The Department IPM Coordinator shall coordinate biannual Department IPM Team meetings. One meeting shall be held in the spring in which the Department IPM Team shall discuss IPM planning efforts. The second meeting shall be held in the fall in which the Department IPM Team shall evaluate IPM efforts. Other topics may be discussed and additional meetings may be called, as necessary.

15. IPM Program Review and Updates The Department IPM Coordinator shall review and update the IPM Program on an annual basis to evaluate the effectiveness of the IPM Program, goals, and obstacles faced. Examples of program effectiveness metrics include a comparison of acres managed and resources spent to the density and distribution of existing pest populations. Examples of factors that may result in the need to modify IPM activities and strategies include new technology, expanded range of a pest, newly introduced pests, changes in the availability of control tools, development of pest resistance, and environmental regulations. The Department IPM Coordinators shall also consider information that is obtained from control activity results as well as information learned from UCCE, UC IPM, the California Weed Science Society (CWSS), the California Invasive Plant Council (Cal-IPC), and others who have studied or managed similar pests. The Department IPM Coordinator shall submit the IPM Program to the City IPM Coordinator by January 31st of any given year.

REDUCED-RISK PESTICIDE LIST (RRPL)

IPM Program – Exhibit A

[insert as Excel file]

EXEMPTION REQUEST FORM

IPM Program – Exhibit B

[insert fillable PDF]

PESTICIDE USE POSTING TEMPLATE

IPM Program – Exhibit C

Pesticide Treated Area An application of a pesticide was made in this area

Signal Word: ☐ Danger ☐ Warning ☐ Caution

Location Name: Location Address:

Product Name: Manufacturer Name:

Active Ingredient:

EPA Registration #:

Target Pest:

Date of Application: Date for Re-entry:

Date Sign May Be Removed:

(no less than 4 days after application)

If you have any questions regarding this notification or require additional information, you may contact the City of Santa Cruz Water Department IPM Coordinator at (831) 420-5483.

PESTICIDAL BAIT AREA POSTING TEMPLATE

IPM Program – Exhibit D

Pesticidal Bait Area Pesticidal baits are used in this area

Signal Word: ☐ Danger ☐ Warning ☐ Caution

Product Name: Manufacturer Name:

Active Ingredient:

EPA Registration #:

Target Pest:

Area(s) where baits are commonly placed:

If you have any questions regarding this notification or require additional information, you may contact the City of Santa Cruz Water Department IPM Coordinator at (831) 420-5483.

PESTICIDE USE FORM

1Round to the nearest acre/mile or hour

IPM Program – Exhibit E-1

Submit the Pesticide Use Form to the Department IPM Coordinator after each pesticide use or after continued use (e.g. three week use of bait).

1. Identify Pest Pest Identifier: Date

Location: Pest:

Occurrence/ Population:

Other Potential Pest:

Life cycle: Habitat requirements:

2. Was this an urgent situation that created an immediate hazard? ☐ Yes ☐ No If yes, please explain.

3. Damage or Nuisance Activity (check all that apply)

☐ Risk to health & safety ☐ Risk to water supply

☐ Risk to restoration biodiversity ☐ Risk to defensible space around critical infrastructure

☐ Other, describe below

4. Objectives (check all that apply)

☐ Reduce risk to health & safety ☐ Reduce risk to water supply

☐ Facilitate restoration work/protect biodiversity

☐ Maintain defensible space around critical infrastructure

☐ Other, describe below

5. Threshold

6. Management Technique

☐ Biological ☐ Cultural

☐ Chemical ☐ Physical/Mechanical

7. Resources (labor and equipment)

Acreage/mileage treated1 Hours spent1

Product(s) Used Product(s) Cost

Equipment Used Contractor costs

Volunteer hours spent1

8. Results/Effectiveness

☐ Pest removed ☐ Unable to remove pest ☐ Other, describe below

DEFINITIONS

IPM Program – Exhibit F-1

Anti-microbial Agent

Any substance or mixture of substances intended for inhibiting the growth of, or destroying any bacteria, fungi pathogenic to man and other animals, or viruses declared to be pests under

Food and Agricultural Code Section 12754.5, except slime control agents, substances intended for use in or on humans or other animals, and use in or on processed food, beverages or pharmaceuticals. Anti-microbial agents include, but are not limited to, disinfectants, sanitizers, bacteriostats, sterilizers, fungicides and fungistats applied to inanimate surfaces, and commodity preservatives and protectants applied to raw materials or manufactured products.

City department

Any department of the City of Santa Cruz and includes any pesticide applicator hired by a City department to apply pesticides on City property. City department does not include any other local agency or any federal or state agency, including but not limited to school districts.

Contract

A binding written agreement, including but not limited to a contract, lease, permit, license or easement between a person, firm, corporation or other entity, including a governmental entity, and the City, which grants a right to use or occupy property of the City for a specified purpose or purposes.

Contractor

A person, firm, corporation or other entity, including a governmental entity, that enters into a contract with the City.

Integrated Pest Management

A decision-making process for managing pests that uses monitoring to determine pest injury levels and combines biological, cultural, physical, and chemical tools to minimize health, environmental and financial risks. The method uses extensive knowledge about pests, such as infestation thresholds, life histories, environmental requirements and natural enemies to complement and facilitate biological and other natural control of pests. The method uses the least toxic and least hazardous pesticides as defined herein only as a last resort to controlling pests.

Pest

Any insect, rodent, nematode, fungus, weed, or any other form of terrestrial or aquatic plant or animal life or virus, bacteria, or other microorganism (except certain insects, viruses, bacteria, or other microorganism on or in living man or living animals.

Pesticide

As defined in Section 12753 of the California Food and Agricultural Code. This definition includes herbicides and fungicides.

Toxicity Category I Pesticide Product

Any pesticide product that meets United States Environmental Protection Agency criteria for

Toxicity Category I under Section 156.10 of Part 156 of Title 40 of the Code of Federal

Regulations.

DEFINITIONS

IPM Program – Exhibit F-2

Toxicity Category II Pesticide Product

Toxicity Category II under Section 156.10 of Part 156 of Title 40 of the Code of Federal

Toxicity Category III Pesticide Product

Toxicity Category III under Section 156. 10 of Part 156 of Title 40 of the Code of Federal

IPM Coordinator

A qualified staff position with expertise in Integrated Pest Management responsible for managing the City's IPM Program and administering the IPM Policy.

Reduced-Risk Pesticide List

A maintained list of pesticide products acceptable for use, limited use or exemption required, within the City's IPM Program. Pesticides on the Reduced-Risk Pesticide List are screened using the three tiered risk listed below.

• "Allowed" pesticides have a ranking indicating low toxicity and can be used as part of a comprehensive IPM program at the discretion of trained city pest management personnel.

• "Limited Use" pesticides have a ranking indicating moderate toxicity and may be used only in limited predetermined situations and conditions.

• "Exemption Required" pesticides may be used only on a one-time basis during an emergency when an exemption has been granted or when there is a failure to adequately manage a pest after using all non-chemical methods and "Allowed" pesticides.

Signal Word

The word used on a pesticide label – Danger, Warning, Caution – to indicate toxicity level.