PDMP - Pesticide Discharge Management Plan for PRD_2017.doc

Version 2

March 24, 2017

Pesticide Discharge Management Plan for Treatments In, Over, or Near Waters of the State on Parks & Recreation Division-Administered Lands Michigan Department of Natural Resources Parks & Recreation Division Prepared by:

Glenn R. Palmgren, Ecologist Approved by:

Date: _______________

Ron Olson, Chief Parks & Recreation Division

Michigan Department of Natural Resources

525 West Allegan Street

PO Box 30257

Lansing, Michigan 48909-7757

Table of Contents

Pesticide Discharge Management Team Pest Management Area Control Measures Schedules and Procedures Attachments:

· NPDES General Permit for Aquatic Nuisance Plant and Algae Control

· NPDES General Permit for Forest Canopy Pest Control

· Parks & Recreation Division Field Directory Pesticide Discharge Management Team Pest Managers Individuals responsible for managing pests in relation to the pest management area (DNR–Parks & Recreation Division lands), and for developing, revising, and implementing corrective actions and other discharge limitation requirements:

· Ray Fahlsing, Stewardship Unit Manager FahlsingR@michigan.gov, 517-284-6097, PO Box 30257, Lansing, MI 48909

· Robert Clancy, Ecological Restoration Specialist ClancyR@michigan.gov, 517-284-6088, PO Box 30257, Lansing, MI 48909

· Unit Managers and Supervisors for all state parks, recreation areas, scenic sites, boating access sites, harbors, state forest campgrounds, and non-motorized pathways (see attached field directory)

PDMP Developer

Individual responsible for developing and revising the Pesticide Discharge Management Plan (PDMP):

· Glenn Palmgren, Ecologist PalmgrenG@michigan.gov, 517-284-6121, PO Box 30257, Lansing, MI 48909 Pesticide Applicators Individuals responsible for applying pesticide in accordance with this plan:

· Various state employees at state parks, recreation areas, scenic sites, boating access sites, harbors, state forest campgrounds, and non-motorized pathways

· Various contractors, operating under a valid state contract

· Volunteers, operating under a volunteer project agreement

· All state employee and contract pesticide applicators will be Michigan Department of Agriculture (MDA) Certified Commercial Pesticide Applicators, with names and certification numbers documented on each treatment record

· Contract applicators will operate under a state contract, and volunteers will operate under a volunteer project agreement, the terms of which will clearly specify the division of responsibilities between the contractor/volunteer applicator and the DNR project manager. Copies of these written agreements/contracts will be available at the unit conducting the treatment or in the Parks & Recreation Division office in Lansing (contact Glenn Palmgren).

Pest Management Area

Target Pests

Invasive plants, including, but not limited to the following:

· Asian bittersweet

· Autumn olive

· Black alder

· Black jetbead

· Black locust

· Bladder campion

· Chinese bush-clover

· Common and glossy buckthorn

· European frogbit

· False indigo

· Flowering rush

· Garlic mustard

· Goutweed

· Hedge parsley

· Honeysuckle

· Japanese barberry

· Japanese knotweed

· Lily-of-the-valley

· Lyme grass

· Multiflora rose

· Narrow-leaf & hybrid cattail

· Narrow-leaf bittercress

· Norway maple

· Periwinkle

· Phragmites

· Privet

· Purple loosestrife

· Quackgrass

· Reed canary grass

· Russian olive

· Smooth brome

· Spotted knapweed

· Swallow-wort

· Sweet-clover

· Tree-of-heaven

· Translocation of seed and other plant parts from infested areas by humans, wildlife, wind, water, and other means

· Disturbance of natural processes such as hydrology, fire regime, windthrow, and nutrient cycling

· Periodic site surveys conducted by state employees, contractors, or other partners documenting the presence, relative abundance, and distribution of known invasive plant species

Aquatic weeds:

· Vegetation of any species growing within ponds, lakes, or other waterways in the vicinity of harbors, beaches, and boat access sites

· Translocation of seed and other plant parts from infested areas by humans, wildlife, wind, water, and other means

· Periodic site surveys conducted by state employees, contractors, or other partners documenting the presence, relative abundance, and distribution of weeds

Weeds in developed areas:

· Vegetation of any species growing within designated parking lots, walkways, ramps, and around posts

· Translocation of seed and other plant parts from infested areas by humans, wildlife, wind, water, and other means

· Periodic site surveys conducted by state employees, contractors, or other partners documenting the presence, relative abundance, and distribution of weeds

Forest insect pests and diseases, including but not limited to the following:

· Gypsy moth

· Emerald ash borer

· Asian long-horned beetle

· Balsam wooly adelgid

· Hemlock wooly adelgid

· Beech bark disease

· Sudden oak death

· Oak wilt

· Sirex woodwasp

· Movement of firewood and other materials by humans

· Dispersal of forest pests from other nearby populations through flight, wind, and attachment to animals

· Translocation of diseases underground through the soil and root grafting

· Periodic site surveys conducted by state employees, contractors, or other partners documenting the presence, relative abundance, and distribution of known forest pests

Action Thresholds

For invasive plants, the action threshold is one individual within any part of the pest management area. Early detection and rapid response to invasive plants is the most cost effective and environmentally benign response once an invasive plant has become established at a site. Invasive plants spread rapidly once established. Implementing control as early as possible will minimize the amount of management action needed, and minimize the quantity of pesticide needed when chemical control is used.

For aquatic weeds, the action threshold is the point at which a sufficient quantity of vegetation is present to significantly impair the recreational use, physical access, or visual quality of the site for the public or to cause damage to infrastructure and boats. For example, aquatic vegetation that is blocking boat access to ramps or harbor slips can significantly reduce the recreational use of the site. Excessive abundance of aquatic weeds can also detract from the visual beauty of the site and result in reduced visitation and visitor satisfaction. Weed growth must be at a high level such that it has (or is expected to) impair recreational use or generate visitor complaints before treatment with pesticides would be justified.

For weeds in developed areas, the action threshold is the point at which a sufficient quantity of vegetation is present to significantly reduce the visual quality of the site for the public or to cause damage to infrastructure. For example, vegetation that is growing through cracks in pavement can cause the deterioration and splitting of pavement. A significant investment has been made in the infrastructure in developed portions of state parks, recreation areas, scenic sites, access sites, harbors, state forest campgrounds, and non-motorized pathways. Damage to that infrastructure from excessive weed growth requires action to protect the integrity of the infrastructure. Also, significant growth of weeds in manicured lawns, flower beds, and around structures detracts from the visual beauty of the site and can result in reduced visitation and visitor satisfaction. In instances where these areas fall within the scope of the NPDES permit, weed growth must be at a high level such that it has (or is expected to) generate visitor complaints before treatment with pesticides would be justified.

For forest insect pests and diseases, in developed areas the action threshold is a population level that will cause significant nuisance to guests at the facilities, or damage to infrastructure. A significant nuisance is one that is serious enough that it is expected to result in a significant reduction of visitor use and revenue. Death or defoliation of important shade trees in campgrounds or picnic areas is one example. In undeveloped areas the action threshold is a level that is likely to result in a significant reduction in the ecological integrity or health of the natural community and associated rare species. Pest levels that would disturb the natural function and structure of known high-quality, rare, or unique natural features or result in the decline of an endangered, threatened, or special concern species or species of greatest conservation need would meet the action threshold. The specific quantity or density of pest that meets this threshold depends on the site location, the natural community or rare species present, current and predicted weather and site conditions, and other factors. For early-detection species that are new to the state or local area, the action threshold is one individual within any part of the pest management area. See the justification for invasive plants above.

General Location Map

The pest management area is defined as all state-owned or leased land administered by the Michigan Department of Natural Resources, Parks & Recreation Division. Also included are adjacent private and public partner lands where a written agreement is in place for treatments.

Specific maps of state parks, recreation areas, scenic sites, access sites, harbors, state forest campgrounds, and non-motorized pathways are available at: www.michigandnr.com/parksandtrails/parkmap.aspx and at www.michigan.gov/dnr/0,1607,7-153-10366_34947-31021--,00.html.

Control Measures

Pesticide discharge to waters of the state will be minimized by implementing the following procedures:

· All requirements of the applicable National Pollutant Discharge Elimination System Point Source Discharge General Permits for Aquatic Nuisance Plant and Algae Control (MIG031000) and Forest Canopy Pest Control (MIG033000) will be followed.

· Pre-treatment surveillance will be conducted to determine whether the target pest exceeds the action threshold. In most cases the pre-treatment surveillance will be conducted by the Pesticide Applicator, Pest Manager, or another state employee capable of identifying the pest immediately preceding any treatment.

· A “No Action” alternative will be considered first. If the target pest is not likely to reach the action threshold, or if it is likely to have minimal impacts and be reduced below the threshold on its own without management action then no treatment will be conducted.

· “Prevention” measures will be employed wherever cost effective and practical to reduce the potential for the target pests to become established in portions of the pest management area where they do not already occur. Examples of prevention measures may include:

· boot brushes at trailheads to remove invasive plant seeds

· informational signage to educate visitors about not moving firewood, or about washing/decontaminating boats

· preventing the establishment of new corridors such as utilities, roads, or trails in locations where they would facilitate the spread of invasive plants

· “Mechanical or physical” methods will be considered. Mechanical methods such as mowing, cutting, and hand pulling are preferred over pesticides in situations where they will be as effective or more effective at controlling the target pest, are practical to implement, and of similar or lower cost.

· “Cultural” methods will be considered to make site conditions less favorable for the establishment of invasive plants and other pests. In natural settings, this may include ecological restoration practices such as prescribed burning and hydrological restoration to maintain biodiversity and ecological integrity of natural communities and increase their resilience and resistance to invasion.

· “Biological Control Agents” will be considered when available and practical. For example, the use of Bt for gypsy moth control, and Galerucella beetles for purple loosestrife control may be appropriate in lieu of chemical pesticides in many situations. When considering biological controls, potential non-target impacts to native and beneficial species must be considered. The effectiveness of using biological control may also be impacted by population size and density of the target pest and other ongoing management practices.

· Pesticides will be used in cases where the other alternatives have been evaluated and pesticides are determined to be the most effective, cost-effective, and practical control method, with the least negative environmental impact.

· When pesticides are used, each application will use an appropriate chemical, quantity, timing, and application technique that will produce the best results with the least non-target damage and cost.

· Only pesticides registered for use in Michigan by the Michigan Department of Agriculture and Rural Development that are labeled for use in aquatic environments will be used in areas covered by the NPDES permit. The list of pesticides that may be used by DNR, Parks & Recreation Division when operating under this permit is available here: https://www.michigan.gov/documents/deq/wrd-anc-approvedherbicides_445623_7.pdf. This includes all pesticides currently approved by the Michigan Department of Environmental Quality for use in aquatic environments.

· All pesticide storage and application equipment will be maintained and calibrated by trained personnel, according to manufacturer recommendations and standard industry practices, to reduce the likelihood of spills and leakage and to insure the proper dose of pesticide is applied.

· A visual assessment of the treatment area will be performed by the Pesticide Applicator or Pest Manager following each treatment to look for adverse incidents such as unusual or unexpected death of non-target organisms, or turbidity, color, oil films, foams, or other deposits in surface water. Any adverse incidents will be reported as required in the applicable NPDES general permit.

Schedules and Procedures

Pre-application Pest Surveillance Areas will be visually inspected prior to any treatments to determine whether the action threshold is exceeded for any target pests. In many instances the areas will be inspected by a Pest Manager or their designee earlier in the growing season, up to several months before the treatment window. At minimum, every area to be treated will be visually inspected immediately prior to treatment by the Pesticide Applicator or another designated individual capable of identifying the target pest(s). The pre-application surveillance will be documented as part of the treatment record.

Assessment of Environmental Conditions in the Treatment Area A Pest Manager, Pesticide Applicator, or their designee will assess the condition of the treatment area prior to any treatments. This will include a visual assessment of the amount and location of standing water and wet areas and evidence of protected species or other non-target organisms that could be impacted by treatments.

Determination of the Treatment Method, Type of Chemical, and Lowest Effective Dose A Pest Manager or their designee will use the “Control Measures” guidance in this plan (page 6) to determine:

· the necessity of action, based on action thresholds

· the most effective, cost-effective, and practical control method, with the least negative environmental impact

· for pesticide treatments, the appropriate chemical, dose, timing, and application technique that will produce the best results with the least non-target damage and cost Maintenance Activities The Pesticide Applicator or another trained individual will insure all equipment used for storage, handling, transport, and application of pesticides has been properly maintained, calibrated, and cleaned to manufacturer recommendations and industry standards prior to every use. Equipment will be visually inspected by the applicator for leaks or signs of damage immediately prior to use, and will be cleaned and inspected following application. During transport and storage, equipment and pesticides will be double-contained to prevent spills and leaks.

Spill Response Procedure All locations where pesticide is stored, transported, and used will have a standard spill response kit. All Pesticide Applicators (and others as appropriate) will be trained on how to properly and expeditiously stop, contain, and clean up a spill or leak, including proper use of the spill response kit. Individuals who cause or detect a spill or leak must immediately notify an individual trained in spill response, and that individual must immediately take all practical measures to stop, contain, and clean up the spill or leak. All staff, contractors, or volunteers working with pesticides at a given location must be made aware of this procedure and who the trained individual(s) are for that location and time.

Spills must be reported immediately to an individual’s immediate supervisor, and all notification procedures specified in the NPDES general permit (Part II, Section B, Items 2, 3, and 4, as appropriate) must be followed. This includes 24-hour verbal reporting requirements and various levels of written reporting requirements depending on the nature of the spill.

Adverse Incident Response Procedure An adverse incident is defined as an incident in which a person or non-target organism is exposed to a pesticide residue and suffers a toxic or adverse effect. Any unusual or unexpected exposure or non-target damage must be documented and reported by the person who discovered it, in conjunction with the applicable Pesticide Applicator and Pest Manager for that treatment. Adverse incident reporting requirements are described in detail in the NPDES general permit, Part II, Section B, Item 2 (page 19). Some adverse incidents require 24-hour reporting by phone, and all require written reporting within 30 days. The cause of all adverse incidents must be investigated and included in the required reports. Corrective action (described in the NPDES general permit) may be required if any permit conditions were violated.

Monitoring The Pesticide Applicator or their designee will visually inspect the treatment area immediately after the pesticide application is complete. They will record any unusual or unexpected non-target kill or adverse effects as described above. The Pest Manager or designee will conduct spot inspections of pesticide treatment areas one or more days later, during a timeframe when the effects of the pesticide are expected to be visible. These spot inspections will assess the effectiveness of the treatment (amount of target pest kill) and again visually check for evidence of adverse effects to non-target organisms or water quality.

Record Keeping As a requirement of the NPDES permit, no later than 14 days following treatment a complete treatment record must be forwarded to the Stewardship Unit in Lansing. The Stewardship Unit will retain all NPDES-related treatment records, adverse incident reports, copies of permits and certificates of coverage, and any corrective action documentation for a minimum of three years from the date of the activity. Those records, along with the current PDMP, will be available immediately upon request by DEQ.

Reporting Stewardship Unit will prepare and submit an annual report to DEQ by November 30 each year, to include all NPDES-related pesticide treatment records for the Division.