Dana Perls T0 john.greitzer@dcd.cccounty.US

December 3, 2012 Board of Supervisor Members Mary Piepho Federal Glover Karen Mitchoff Candace Anderson John Gioia Dear Honorable Board of Supervisor Members: My name is Dr. Thomas Robert Jones M. D. I am a psychiatrist working in Antioch. In August 2011 our clinic moved to 3454 Hillcrest Ave in Antioch. I was pleased to see our new clinic building was wrapped on two sides by the Contra Costa Canal. Water is pumped into the canal from the Delta and I understand provides a large part of Contra Costa County with its drinking water. A paved trail for hiking, The Delta de Anza Regional trail, runs along the top of the bank on the downhill side of the canal. People often walking with small children and pets heavily use the trail. My office as do many others overlooks the Canal and trail giving a view of a rare island of urban wildlife just outside the clinic's office windows. Many of us came to enjoy this rich scene of a wide range of wild life. Owls, song birds, red tail hawks, turkey vultures, doves, ground squirrels, coyotes and a bobcat were present. Hikers with their pets and children added to the view. I felt privileged to have such a wonderful scene outside my window. The ground squirrels[1] were particular attention grabbers. Their social organization and interaction was a joy to watch. Social groups and individual squirrels became identifiable. What a treat. In the spring the population increased dramatically with the birth of babies. As summer approached the play of the babies and interaction with their parents enriched the view. I estimate that 30 squirrels were present in our view by summer. My walks further down the trail from our clinic revealed a similar population density. As summer wore on into August a sharp declined in population to less than 15 squirrels was apparent. This was clearly due to the action of the predators in the area, the raptors, coyotes, bobcat and others. A clear example of the wild life ecosystem's ability, even in a small area, to maintain a natural balance. Then in mid August an ATV that resembled a supped up golf cart was seen dropping small pellets from a contraption attached to its rear both on the hillside above on one side of the canal and along the bank on the downhill side. I was concerned this might be an act of vandalism dropping poison in a wildlife area along the county's drinking water supply. After calling the Contra Costa Water District Offices to report this I instead found out dropping the poison pellets was a result of the water districts arrangement with county agriculture.[2] Even more surprisingly I was told a second application was planned. I was told this poison was diphacinone an anti coagulant. I am familiar with this family of chemicals, the type used in medicine is known by the name Coumadin. When used in medicine it is a valuable health aid. However an overdose is a long, painful and horrible death caused by internal bleeding.[3] After the poisoning I watched in horror the entire wildlife ecosystem collapse just outside my office window. The ground squirrels over a few days became lethargic , clearly in pain, most retreated to their burrows to die but not all. Several squirrel carcasses were in view. The song birds disappeared, the owl family nesting at the top our building was gone. One red tail hawk was observed to be sick but couldn't be approached. No other red tail hawks were observed after this. There were several bird and squirrel carcasses on the uphill side of the canal in the area of the dirt access road. The doves, songbirds, turkey vultures and the bobcat were also gone.[4],[5] I was told the use of poison was necessary to prevent the squirrels damaging the bank on downhill side of canal. On the other side of the canal there is hillside that rises steeply from the canal. The steep rise is broken by an unpaved access road before it continues to rise steeply to the top of the hill. The canal itself is lined on its sides and bottom by concrete, In much the same way the as the LA river. There is no levee holding back a river or tidal surges. This is a unique situation.[6] The canal provides drinking water to county residents. The poison was not only dropped on the downhill bank but also on the uphill side along the access road. Could it reach the canal and thus the county's drinking water? Now that the rains have begun is this even more likely as the rain runoff washes into the canal ? So why the poison? Why wipe out wildlife in the area, endanger pets and children unknowingly using the trail and most importantly endangering the county's drinking water? The natural predator prey ecosystem was keeping the squirrel population in balance before the poison treated honey dipped rolled oats were dropped. The predators present were the beautiful red tail hawks, coyotes and the bobcat to name a few.[7] These predators were performing their function at the top of the food chain. A few squirrels were left before the poison but in a low density. Is zero population not only of the squirrels but also of most other wildlife in the canal area the goal? The entire wildlife system was wiped out.[8] Any hope that wildlife will returned is blown away by the knowledge that any animals that do return's fate is to die painfully by this type of poisoning in August. In addition to the rodenticide poisoning, in spring I also witnessed on two occasions a truck spraying a herbicide along both sides of the paved trail that runs along on top of the canal on the downhill bank. On each occasion early rains fell soon after each spraying. As the rain water ran down the downhill bank a pattern of brown dead plants in the growth along the bank was apparent. Directly on the other side of the trail is a short steep grade falling off into the canal. Rain water surely carried the herbicide into the canal. Not long after the second spraying the area was mowed. Overkill? Why not just mow? I respectfully ask that these observations be taken into consideration as the approval ofthis type of poisoning by the county is considered. I also point out the area around the canal is unique and should be considered in even more detail before dropping the poisoned oats. It provides the county with drinking water and the trail is used by many people, children and pets.[9] What impact could all this poisoning be having on county residents? Of concern is a report from veterinarians at UC Davis indicating an increase in dog poisoning by this type of poison in August.[10] There are other safer methods available. Sincerely Thomas Jones MD [1] The California ground squirrel, Spermophilus beecheyi, a native California species.
[2] Was this legal ? Final Risk Mitigation Decision on 10 Rodenticides [including Diphacinone],
http://www.epa.gov/oppsrrd1/reregistration/rodenticides/finalriskdecision.htm.
[3] Acute Toxicity, Histopathology, and Coagulopathy In American Kestrels following Administration of The Rodenticide Diphacinone, Environ. Toxicol. Chem. 2011; 30:1213–
1222. © 2011 SETAC [4] http://www.nature.com/news/killing-rats-is-killing-birds-1.11824
[5] Anticoagulant Exposure and Notoedric Mange in Bobcats and Mountain Lions in Urban Southern California, Journal Of Wildlife Management71(6):1874‐1884;2007 6 A goggle street view for 3454 Hillcrest Ave in Antioch gives several views of the area from the trail. [7] Possibly a golden eagle nesting in a high power line tower in the distance. Whatever this large bird was, it too was gone soon after the poisoning. [8] All that's remains is an over abundance of black birds. [9] Toxicology Brief, Veterinary Medicine, October2002 [10] http://news.ucdavis.edu/search/news_detail.lasso?id=10337
Mount Diablo Audubon Society
P.o. Box 53, Walnut CreeR, CA 94597-0053
www.diabloaudubon.comlindex.php
December 6, 2012
To:
TWIC Members - Supervisor Federal Glover and Supervisor Mary Piepho
Cc:
Supervisor John Gioia, Supervisor Candace Andersen, Supervisor Karen Michoff
Re:
Concerns About Continued
IPM Program Status Report
Use of Rodenticide
as Outlined
in the 2012 Annual
Honorable Members of the TWIC,
Mount Diablo Audubon wishes to provide some comments and suggested revisions for your
consideration on the 2012 AnnuallPM Program Status Report, prior to your forwarding the
Report to the Full Board for their consideration.
While we applaud the County Staff and Departments on making much needed progress in the
IPM Program, we find significant and continuing problem specifically in the use of rodenticides
for the control of rodents along our roads, levees and the environmentally sensitive areas of
the County.
The proposed 2012 IPM Status Report is factually misleading and flawed in its presentation of
the "problem" and then the economic assessments for the continued use of rodenticides.
Further the County Land Use Process for enforcing permits relating to the prohibition of
rodenticides as conditions of approval has been and continues to be ignored by the County Ag.
Commissioner in potential violation of State law.
MOUNT DIABLO AUDUBON IS CONCERNED ABOUT THE CONTINUING SECONDARY
IMPACTS TO CRITICAL WILDLIFE IN CONTRA COSTA COUNTY
Why are we concerned?
1. The USEPA in October 2012 announced new measures to mitigate risks in ten
rodenticides (please see attachment 1). The USEPA reasons quoted below echo
Mount Diablo Audubon's local observations and are the reason we continue to ask
the County to stop using rodenticides for ground squirrel control.
Risks to Wildlife - Rodenticides pose significant risks to non-target wildlife including
birds, such as hawks and owls, and mammals, including raccoons, squirrels, skunks,
deer, coyotes, foxes, mountain lions, and bobcats. Rodenticides applied as bait
products pose risks to wildlife from primary exposure (direct consumption of
rodenticide bait) and secondary exposure (predators or scavengers consuming prey
with rodenticides present in body tissues). Several reported incidents have involved
Federally listed threatened and endangered species, for example the San Joaquin kit
fox and Northern spotted owl, in addition to the Bald eagle, which is protected under
the Bald and Golden Eagle Act.
The second-generation anticoagulants are especially hazardous for several reasons.
They are highly toxic, and they persist a long time in body tissues. The secondgeneration anticoagulants are designed to be toxic in a single feeding, but since timeto-death is several days, rodents can feed multiple times before death, leading to
carcasses containing residues that may be many times the lethal dose. Predators or
scavengers that feed on those poisoned rodents may consume enough to suffer harm.
USEPA- Final Risk Mitigation Decision for Ten Rodenticides - October 2012
2. Attachment 2 is a 2000 abstract from Robert Hosea at Cal Fish & Game outlining
secondary impacts from the use of rodenticides in California.
3. The continued use of any rodentidies on County Roads, Levees and other facilities
where public safety is not directly impacted contradicts FOOD AND
AGRICULTURAL CODE Sections 11501-11518:
(b) To protect the environment from environmentally
harmful
pesticides by prohibiting,
regulating, or ensuring proper
stewardship of those pesticides.
(f) To encourage the development and implementation
of pest
management systems, stressing application of biological and
cultural pest control techniques with selective pesticides when
necessary to achieve acceptable levels of control with the least
possible harm to nontarget organisms and the environment.
4. Attachment 3 shows the growing local cost to pets and wildlife from rodent poisons
(courtesy of the Alexander Lindsey Museum).
Reference to protecting the environment and reducing secondary impacts to the environment
from rodenticides needs to be more than window dressing in the Departments Mission
Statement.
The Board should direct staff to develop a plan and metrics to show progress in the
elimination of secondary impacts from poison bait in Contra Costa County in 2013.
That direction should be outlined in this Report before it is sent to the full Board.
ROODY RANCH GOLF COURSE PERMIT VIOLATION
In the late 1990's, after considerable debate about the permitting of a golf course called Roddy
Ranch and the completion of the Project CEQA Process, the permit was approved by the
County with a number of conditions. Those conditions were established to protect the local
ecosystem and the rare and endangered species that lived in the area. One specific condition
required no use of poisons for rodent control- only trapping. All parties to the process,
including the applicant, agreed to these conditions
When Audubon found poison on the course in the winter of 2006/2007, we raised this violation
with the golf course. We were told by the golf course staff that; "the County Ag folks said it
was ok". When we raised the issue with the County staff, they presented us with a letter telling
us that they could ignore the permit conditions (please see attachments 4).
Even though Audubon raised the issue and Fish & Game indicated that the Ag Department
was violating County Permit Conditions (please see attachment 5) - nothing was done to
correct the problem and nothing has changed at Roddy Ranch since 2007 (please see
attachment 6 & 7). The County continues to allow the golf course staff to use poison in
potential violation of State law (CEQA) and the land use permit approved by the Board
of Supervisors.
If Board approved Project conditions are being ignored by County staff at Roddy Ranch where else is it happening? This Annual Report should confirm what actions are being taken
in the IPM Program to correct the Roddy Ranch situation and any other noncompliant activities
on other Projects with Permit Conditions that prohibit the use of poison for rodent control. Live
trapping is done at other golf courses in the area - it can certainly be done at Roddy Ranch.
THE AUGUST 2012 PRELIMINARY COST ASSESSMENT
POISION BAIT CONTROL IS SIGNIFICANTLY FLAWED
ON LIVE TRAPPING VS.
While we are thankful that staff is attempting to start assessing the costs of non-poison
programs for rodent control (please see attachment 8), we find a number of errors and flaws in
the preliminary information related to those preliminary results as presented in this Annual
Report. For example:
1. The cost for both options (it would appear), include mileage from Martinez to Empire Mine
Road - 46 miles and 2 hours if traffic is good on Highway 4. Is travel time also included?
A correct assessment should look at either local staff (East County) or local contractors to
perform the work so that time and vehicle costs are spent trapping and not driving to and
from the site. Such an approach would significantly reduce the trapping cost option, and
somewhat reduce the poison option costs. If travel time was not included - then why
include travel mileage? Certainly overtime (which was only included in the cage option)
should not be a part of any objective assessment unless it is a seasonal limited time
program - which would be better handled by double shifts or 4 X 10s with no overtime.
2. The staff then quadruples the any possible labor and mileage cost estimating errors by
extrapolating from 1200 feet to one mile to get an estimated 1 mile cost ($7,340 to trap vs.
$220 to poison). If this is truly what they think it costs to trap - we suggest they do a
completive bid based on a bounty for each trapped and killed squirrel and see if they get a
per squirrel cost closer to $3 than the $11 number they cite. $3 per squirrel and no
secondary impacts is a lot less costly than tossing our poison and killing unknown numbers
of squirrels and other animals.
3. While 152 squirrels were captured in the trapping assessment, there is no documentation
of any squirrels being killed by the poison option. While it is presumed that some rodents
ate the poison bait and died, how many? We know catching rodents kills them and nothing
else, but we suspect staff does not know precisely how many rodents and other animals
are killed by the use of poison in their test case.
4. There is significant data nationally confirming the primary and secondary impact
(costs) to non-target species including many hawks, owls, foxes, badgers etc, as
outlined earlier in this memo. Those costs are significant and can not be ignored
particularly when the staff can provide no hard empirical data showing how many
squirrels were killed, and to what degree the use of poison bait under the program
does not impact any other species.
We would request that the Board ask the staff to remove any references to live trapping being
more expensive than or 33 times as expensive as the poison bait Program. Further we would
require goals and metrics for 2013 that specifically request the County staff to provide hard
evidence that the use of poison bait along County Roads and levees near open areas or fields
has any positive impact on solving the problem. Trapping is a lot less costly than
redesigning roads and levees.
We would contend that an aggressive live trapping program during critical times of the year at
critical locations is much more productive in managing rodent populations and less impacting
to a number of secondary species than the use of poison. We would encourage the Board to
challenge the staff to prove us wrong with hard empirical evidence before they jump to
unsubstantiated claims about the true costs and benefits of a poison program for rodents in
Contra Costa County.
Other Counties in the Bay Area with just as much agricultural open space as Contra Costa
have stopped using poison - it is time for us to start working towards a poison free
environment.
We appreciate the opportunity to comment.
Please free to contact me at 925 258 0773 if you have any further questions.
Kent Fickett
Advisor to the President and Board
Final Risk Mitigation Decision for Ten Rodenticides
I Pesticides I US
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EPA
Page 1 of 5
Pesticides: Rereg istrat' on
a E- here EPA Home •• Pesticides" Regulating Pesticides" Reregistration»
Status •• Rodenticides It Final Risk M ligation Decrsion for Ten Rodentrcides
Pesticide Reregistration
YOL.
Final Risk Miti ation Decision for Ten Rodenticides
;,.
Current as of October 2012
After fully assessing human health and ecological effects, as well as
benefits, EPA is announcing measures to reduce risks associated with
ten rodenticides:
•
•
•
•
•
•
•
•
•
•
_
.
Resources
.;
•
Rodenticides Reregistration
Web page
• Rodenticides Background
• Controlling Rodents
Brod ifacou m
Bromadiolone
Bromethalin
Chlorophacinone
Cholecalciferol
Difenacoum
Difethialone
Diphacinone
Warfarin
Zinc phosphide
New safety measures announced by the U.S. Environmental Protection Agency will protect children
from accidental exposure to rodent-control
products. These measures will also reduce the risk of
accidental poisonings of pets and wildlife. With the Agency's risk mitigation measures in place,
rodenticide products will be safe, effective, and affordable for all consumers.
On this page:
•
•
•
•
•
•
Rodenticide Safety Concerns
Final Risk Mitigation Measures
Summary of New Restrictions
Proposed Mitigation Measures are Protective and Flexible
Integrated Pest Management Will Improve Effectiveness
More Information
Rodenticide Safety Concerns
Rodenticides are important products for controlling mice, rats and other rodents that pose threats to
public health, critical habitats, native plants and animals, crops, and food supplies. However, these
products also present human and environmental
safety concerns.
Exposures to Children - Rodenticides are an important tool for public health pest control, including
controlling mice and rats around the home; however, the use of these products has been associated
with accidental exposures to thousands of children each year. Fortunately, only a small number of
exposed children experience medical symptoms or suffer adverse health effects as a result of their
exposure.
http://www.epa.gov/pesticides/mice-and-rats/fmalriskdecision.htm
12/6/2012
Final Risk Mitigation Decision for Ten Rodenticides
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Page 2 of 5
The Agency believes, however, that the number of exposure incidents is unacceptably high. Further,
data indicate that children in low income families are disproportionately
exposed. EPA's risk mitigation
measures address this situation by significantly reducing the likelihood of rodenticide exposure to
children, including those children who may be disproportionately
at risk for exposure.
Risks to Wildlife - Rodenticides
pose significant risks to non-target wildlife including birds, such as
hawks and owls, and mammals, including raccoons, squirrels, skunks, deer, coyotes, foxes, mountain
lions, and bobcats. Rodenticides applied as bait products pose risks to wildlife from primary exposure
(direct consumption of rodenticide bait) and secondary exposure (predators or scavengers consuming
prey with rodenticides present in body tissues). Several reported incidents have involved Federally
listed threatened and endangered species, for example the San Joaquin kit fox and Northern spotted
owl, in addition to the Bald eagle, which is protected under the Bald and Golden Eagle Act.
Differences Among the Rodenticides - The ten rodenticide
active ingredients
covered by this
action can be divided into three categories:
• first-generation
anticoagulants:
warfarin, chlorophacinone,
and diphacinone;
• second-generation
anticoagulants:
brodifacoum, bromadiolone, difenacoum,
and
• non-anticoagulants:
bromethalin, cholecalciferol and zinc phosphide.
and difethialone;
The anticoagulants interfere with blood clotting, and death can result from excessive bleeding.
Bromethalin is a nerve toxicant that causes respiratory distress. Cholecalciferol is vitamin D3, which
in small dosages is needed for good health in most mammals, but in massive doses is toxic, especially
to rodents. Zinc phosphide causes liberation of toxic phosphine gas in the stomach.
The second-generation
anticoagulants are especially hazardous for several reasons. They are highly
toxic, and they persist a long time in body tissues. The second-generation
anticoagulants are
designed to be toxic in a single feeding, but since time-to-death
is several days, rodents can feed
multiple times before death, leading to carcasses containing residues that may be many times the
lethal dose. Predators or scavengers that feed on those poisoned rodents may consume enough to
suffer harm.
Final Risk Mitigation Measures
EPA's decision reduces rodenticide exposures to children and wildlife, while still allowing residential
users, livestock producers, and professional applicators access to a variety of effective and affordable
rodent control products.
Childrens' Risk Mitigation - To minimize children's exposure to rodenticide
products used in
homes, EPA is requiring that all rodenticide bait products available for sale to consumers be sold only
with bait stations. Loose bait such as pellets will be prohibited as a bait form. A range of different
types of bait stations will meet the new requirements,
providing flexibility in cost.
Tiered Bait Station Requirements for Consumer-Use Products
• Tier 1 - Tamper-resistant
for children and dogs; weather resistant; tested according to
EPA protocols; indoor and outdoor use;
• Tier 2 - Tamper-resistant
for children and dogs; tested according to EPA protocols;
indoor use only;
• Tier 3 - Tamper-resistant
for children; tested according to EPA protocols; indoor use
only; and,
http://www.epa.gov/pesticides/mice-and-rats/finalriskdecision.htm
12/6/2012
Final Risk Mitigation Decision for Ten Rodenticides
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• Tier 4 - Self-certification;
packaging not reasonably anticipated to release other than
small quantities of bait; resistant to opening by a child less than six years old; indoor
use only; non-refillable (one-time-use only).
Ecological Risk Mitigation - To reduce wildlife exposures and ecological risks, EPA will require sales
and distribution and packaging restrictions for products containing four of the ten rodenticides that
pose the greatest risk to wildlife (the second-generation
anticoagulants - brodifacoum, bromadiolone,
difenacoum, and difethialone) to prevent purchase on the consumer market.
Sale and Distribution Restrictions
• The terms and conditions of registration for products containing brodifacoum,
bromadiolone, difenacoum, and difethialone must be amended to specify that the
registrants will control distribution of the products so that they shall only be distributed
to or sold in agricultural, farm and tractor stores or directly to peos and other
professional applicators, and that registrants will not sell or distribute products
containing brodifacoum, bromadiolone, difenacoum, and difethialone in channels of
trade likely to result in retail sale in hardware and home improvement stores, grocery
stores, convenience stores, drug stores, club stores, big box stores, and other general
retailers.
Minimum Package Size Requirements
• The Agency is requiring second-generation
anticoagulant bait products to be sold in
packages that contain ~ 8 pounds of bait for products that are labeled for use only
inside of and around agricultural buildings, and not for use in and around homes.
• For second-generation
anticoagulant bait products intended for use by professional
applicators, the minimum permissible amount of bait per package is 16 pounds.
Use Site Restriction
• For second-generation
anticoagulant bait products in packages with at least 8 but not
more than 16 pounds of bait, labels must state that products may only be used in and
around agricultural buildings (e.g., barns, hen houses), and bear the statement "Do not
use this product in homes or other human residences."
Summary of New Restrictions
"Consumer Size" Products (Products containing S 1 pound of bait)
• May not contain brodifacoum, difethialone, bromadiolone, or difenacoum (the secondgeneration anticoagulants).
• Loose bait forms such as pellets are prohibited.
• Each retail unit must include a bait station.
• Bait refills may be sold with bait stations in a single retail unit.
• All outdoor above ground use must be in a bait station and be applied within 50 feet of
buildings.
First Generation Anticoagulant and Non-Anticoagulant Products for Professional Users (Agricultural
and PCO)
• Products must contain at least four pounds of bait.
• Bait stations are required for all outdoor, above-ground placements of first-generation
anticoagulant and non-anticoagulant
products .
• Bait stations are required indoors if exposure to children, pets, or non-target animals is
possible.
• Distribution to and sales in "consumer" stores including grocery stores, drug stores, hardware
stores, club stores will be prohibited.
http://www.epa.gov/pesticides/mice-and-rats/tinalriskdecision.htm
12/6/2012
Final Risk Mitigation
Decision for Ten Rodenticides
• See the label for specific restrictions
I Pesticides I US
regarding
EPA
Page 4 of 5
outdoor applications.
Second-Generation Anticoagulant Products for Use Around Agricultural Buildings
• Products must contain at least eight pounds of bait.
• Bait stations are required for all outdoor, above-ground placements of second-generation
anticoagulant products.
• Bait stations are required indoors if exposure to children, pets, or non-target animals is
possible.
• Distribution to and sales in "consumer" stores including grocery stores, drug stores, hardware
stores, club stores will be prohibited.
• See the label for specific restrictions regarding outdoor applications.
Second-Generation Anticoagulant Products for Professional Applicators
• Products must contain at least 16 pounds of bait.
• Bait stations are required for all outdoor, above-ground placements of second-generation
anticoagulants.
• Bait stations are required indoors if exposure to children, pets, or non-target animals is
possible.
• Distribution to and sales in "consumer" stores including grocery stores, drug stores, hardware
stores, club stores will be prohibited.
• See the label for specific restrictions regarding outdoor applications.
Proposed Mitigation Measures are Protective and Flexible
In January 2007, to decrease the incidence of children's accidental exposures to rodenticides, EPA
proposed a requirement that all rodenticides sold "over the counter" for residential use be available
only in tamper-resistant
bait stations. The proposal also included a requirement that the secondgeneration anticoagulants be classified for restricted use, to minimize impacts on non-target wildlife.
EPA's final rodenticide decision achieves the same goal of protection of children and wildlife. In
response to comments concerning the costs of tamper-resistant
bait stations to protect children and
pets, the Agency adopted a tiered bait station system that allows for a variety of effective bait
stations at a range of prices. Provisions are also being put into place to prevent the sale and
distribution of the more highly toxic products on the consumer market, while maintaining their
availability for agricultural production and pest control operators. EPA believes that these steps will
significantly reduce the amount of product in the environment,
providing additional protection for
wildlife from poisonings by these more toxic and persistent products.
The Agency also evaluated and incorporated comments in its final decision from a wide range of
stakeholders, and continues its discussions with several federal agencies, including the Centers for
Disease Control, the the Department of Housing and Urban Development, the U.S. Department of
Agriculture, and the U.S. Fish and Wildlife Service.
Integrated Pest Management Will Improve Effectiveness
Integrated pest management (IPM), a multi-faceted approach to pest control, is essential for effective
management of rodents in and around households. In most situations, mice and rats cannot be
controlled using rodenticides alone. Effective rodent control also requires sanitation, rodent-proofing,
and removal of rodent harborage. Without habitat modification to make an area less attractive to
rodents, even eradication will not prevent new populations from recolonizing the area. Non-chemical
devices such as snap traps are also affordable and effective methods for rodent control.
http://www.epa.gov/pesticides/mice-and-rats/finalriskdecision.htm
12/6/2012
Final Risk Mitigation Decision for Ten Rodenticides
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Page 5 of5
and th
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For More Information
EPA's Final Risk Mitigation Decision for Ten Rodenticides (May 28, 2008) and supporting documents
are available in docket EPA-HQ-OPP-2006-0955 at Regulations.gov.
The Final Risk Mitigation Decision for Ten Rodenticides (May 28, 2008) (PDF)
is available from the docket in Regulations.gov.
(60 pp, 2.8 MB, about PDF)
The Controlling Rodents Web page provides information about preventing, identifying, and treating
rodent infestations. It also addresses regulation of rodent-control products and safe pesticide use.
For more information, please contact Rusty Wasem (wasem.russell@epa.gov), 703-305-6979.
http://www.epa.gov/pesticides/mice-and-rats/fmairiskdecision.htm
12/6/2012
Attachment 2
CALIFORNIA ROBERT C. HOSEA, California Department of Fish and Game Pesticide
Investigations Unit, 1701 Nimbus Road,
Suite F, Rancho Cordova, California 95670.
ABSTRACT: The California Department of Fish and Game collected and analyzed tissue samples
from non-target birds and mammals for anticoagulant rodenticides from 1994 through 1999. Many of
these animals were collected in recently urbanized areas adjacent to wildlands where they were either
found dead or trapped and euthanized as vertebrate pests. The results of the analyses radicate a high
frequency of exposure to the anticoagulant rodenticide brodifacoum. Fifty eight percent of the animals
examined had been exposed to brodifacoum, 19% to bromadiolone, 9% to diphacinone and 8 % to
chlorophacinone. All of the- identified anticoagulants are registered for use to control commensal
rodents found in and around structures and are available for sale "over-the-counter" for homeowner
use. Brodifacoum and bromadiolone are registered exclusively for commensal rodent control. This
paper assesses the frequency of anticoagulant rodenticide residues in tissues of non-target mammalian
and avian wildlife and the possible impacts.
KEY WORDS: anticoagulant, brodifacoum, bromadiolone, chlorophacinone, diphacinone, wildlife,
non-target, coyotes, golden eagle, raptor, carnivore, rodenticide
TIDS PAPER HAS BEE PEER REVIEWED. Proc. 19th Vertehr. Pest Conf. (T.P. Salmon & x.c.
Crabb, Eds.) Published at Univ. of Calif., Davis. 2000.
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Victims of Rodenticides in Contra Costa
County & CA
i~\
,
Lindsay Wildlife Museum: "The average cost of rehabilitating a Gray Fox suffering from
rodenticide poisoning takes a period of 35 days @ $15/day and costs over $500."
Department of Agriculture
2366 A Stanwell Circle
Concord, California 94520-4807 (925) 646-5250
FAX (925) 646-5732
Branch Office
Knightsen Farm Center
Delta Road @ Second Street P.O. Box 241
Knightsen, CA 94548 (925) 427-8610
FAX (925) 427-8612
February 15, 2007
Jimm Edgar, President
Mt. Diablo Audubon Society P. O. Box 53
Walnut Creek, CA 94597-0053
Edward P. Meyer
Agricultural Commissioner Director of Weights and Mea:
Re: Letter regarding use of poison bait for ground squirrel control at Roddy Ranch Golf Course
On January 23rd you faxed a letter to my office that was addressed to the County Board of Supervisors, Antioch Mayor
and Antioch City Council regarding the allegations of illegal use of poison bait for ground squirrel control at Roddy
Ranch Golf Course. The County
Department of Agriculture serves as the local enforcement arm for the California Department of Pesticide Regulation,
which is part of the California Environmental Protection Agency. As a result of your letter, we have investigated the
incident for compliance with applicable Federal and State laws in regard to the legal use of pesticides.
Our investigation focused on two primary issues:
. Was a ban on the use of rodenticides that was included in a Land Use Permit issued by the County, enforceable?
2. Was the application, including timing and method, performed properly
according to the label and were existing Endangered Species guidelines for applications in habitat areas followed?
:' ,..';
ISSUE #
The CalifomiaFood and Agricultural Code Section 11501.1 (a) addresses the first primary issue over the enforceability
of provisions of a Land Use Pemrit that prohibit the use of rodenticides. This code section states:
!;!
"This division and Division 7 (commencing with Section 12501) are of statewide concern and occupy the whole field
of regulation regarding the registration, sale, 1ransportation, or use of pesticides to the exclusion of a1llocal regulation.
Except as otherwise specifically provided in this code, no ordinance or regulation of local
government, including, but not limited to, an action by local governmental agency or department, a county board of
supervisors or a city council, or a local
regulation adopted by the use of an initiative measure, may prohibit or in any way attempt to regulate any matter
relating to the registration, sale, 1ransportation, or use of pesticides, and any of these ordinances, laws, or regulations
are void and of no force or effect. It
Our Department is charged with enforcement of regulations within the Food and Agricultural code. As a result of your
letter pointing out the provision of the Roddy Ranch Golf Course Land Use Permit banning the use of rodenticides, we
consulted with the Department of Pesticide Regulatiou to determine if this condition of approval was enforceable. Their
counsel has indicated that it is not.
As a further explanation, the State Legislature has recognized that the regulation of pesticides is of statewide concern.
They wanted to ensure that the regulation of pesticides is consistent through out the State and based on science. They
also wanted to ensure that the system is not confusing for industry to deal. with.
Pest Control Operators. Pest Control Advisors. and growers operate in numerous counties and cities throughout the
State. Pest control businesses and advisors are required to register with my office before performing pest control work
anywhere in the county.
Even if not using restricted materials. growers are required to get a grower m number issued by my office in order to
purchase agricultural fonnulations of pesticides. The system is set up to ensure that any local conditions and issues
regarding pesticide use can be obtained by visiting the County Department of Agriculture in the county where the
individual is working. The obvious concern is that if individual businesses are suddenly required to check with a
variety of local government entities or review land use permits to detennine what local restrictions may exist, that the
regulatory system would be weakened and made confusing.
The pesticide regulatory system in California evaluates the conditions under which a pesticide may be used. Public and
applicator safety as well as environmental impacts
have been coI1sidered in the process. As the County Agricultural Commissioner, I have full authority to condition
Restricted -Materials that require me to issue a permit for use. However, most materials are not restricted and just like
any other local government
entity; I have no authority to condition their use. I would need to petition the State for authority to condition use of a
non-restricted material and in doing so, I would have to document that a condition exists locally that makes us unique
when compared with other areas. The bait used at the Roddy Ranch Go]f Course was a non-restricted material. The
applicator is required by the Federal Insecticide, Fungicide & Rodenticide Act as well as California Law promulgated
from the Act to follow all label requirements and restrictions that our Department is char~ed to enforce.
ISSUE # 2
As a result of your letter, Biologists from my office visited the Roddy Ranch Golf Course, looked at the sites where
treatment had occurred and questioned the applicator about the procedures and techniques that were used. They also
contacted Mr. Fickett to compare descriptions of the application. The findings, as a result of the investigation, are
that the poison grain was used properly in accordance with the label and that the application followed the
Endangered Species Bulletin guidelines for Contra Costa County.
Endangered Species Bulletins for each county have been adopted and approved by the U.S. Fish and Wildlife
Service. California FiSh and Game and the California Department of Pesticide Regulations. The Endangered Species
Bulletin for Contra Costa County establishes the conditions for the use of rodenticide bait in habitat areas such as
that of the San Joaquin Kit Fox. The Bulletin for our County went through a thorough review process and California
Fish and Game worked closely on its development. US Fish and Wildlife gave a ruling on the rodenticide portion of
the bulletin of "Not likely to adversely effect". This ruling was described to me as the agency's "gold standard", as it
is the highest level of concmrence by the Fish and Wildlife Service.
Your description of the application in your letter tends to verify that the golf course employees followed proper
methods in using tile poison bait. Your letter states "When asked why tIley were spreading the grain broadly and not
placing it in squirrel dens he indicated tIlat 'tile County Ag folks told tIlem to spread it widely' ." We do recommend
tIlat the applicator scatter tile bait widely and altIlOUgh it wouldn't technically be a label violation, we would view
any application placing grain in ground squirrel burrows as a poor application. Ground squirrels will forage for grain
scattered on the ground rather tIlan feed on bait placed in tIleir burrows. They have a tendency to clear tile entrance
to tIleir burrows; this activity essentially buries tile bait around their burrow opening if bait
were placed in tile burrow. .
In most cases we would prefer the grain to be lightly scattered over an area rather than to place the ~n in bait
stations. The bait used has a low toxicity to most birds and is rolled and dyed so that it isn't attractive to theJ;n.
Lightly scattered, non-~gets aren't able to consume enough grain to be poisoned. The treated bait is formulated at
such low concentrations that ground squirrels need to feed on the bait numerous times over a 5 day period in order to
obtain control. Studies have shown that there is more chance for killing a non-target species when bait is
concentrated in one location rather than scattering it. Studies have also shown that the ground squirrels themselves
will carry higher concentrations of the rodenticide in their system and as a result present a greater threat for
secondary kill if allowed to gorge themselves from a pile rather than when they are forced to forage for scattered
grain.
Our investigation also looked at the timing and conditions for the application. We generally do not recommend
poison grain applications in the winter due to the availability of other feed and the inactivity of the ground squirrels.
So being notified of
an application occurring in January was a concern. However, our Biologists found that the ground squirrels were very
active in the area and that the treatment sites had little or no available feed due to a lack of rain and also due to a fire
that had occurred adjoining certain areas next to the golf course. An examination of the application,site found no
remaining bait, indicating active feeding by the squirrels. Since the application was stopped after the first treatment due
to Mr. Fickett's complaint, the treatment did not control the ground squirrels.
Our Department has a policy of going over the Endangered Species Bulletins and the conditions for use of pesticides
wheff meeting with property owners located within Endangered Species Habitat Areas. When questioned, the
employees applying the rodenticide clearly knew procedures outlined in the Endangered Species Bulletin, including
daily survey and removal of any squiIrels that are found above ground (although most will remain in their burrows).
There was no evidence of any violation occurring.
My office would be happy to meet with you to provide more details about our pesticide enforcement program or
ground squirrel control program. I can be reached in our Concord Office at 646-5250.
Sincerely,
GI'~)j~:1-C"""- .J
Ed Meyer
Contra Costa County Agricultural-Commissioner/ Director of W ei~ts and Measures
cc:
County Board of Supervisors
John Cullen, County Administrator Antioch City Council
Donald Freitas, Mayor of Antioch
Jerome Campbell, Assistant Director California Department of Pesticide Regulations
Mary-Ann Warmerdam Director
February 13,2007
Edward P. Meyer
Contra Costa County Commissioner! Sealer 2366 "A~' Stanwell Circle Concord, CA 94520
Dear Mr. Meyer:
Arnold SchwarzeneggE
- Governor
I have reviewed conditions number 42 and 51 in the Con1ra Costa County land use permit issued in October 1998 in
connection with the development of Roddy Ranch golf course that prom"bit the use of rodenticides and herbicides in
the project area. These restrictions on the. use of pesticides on private land constitute the local regulation of pesticides
that is expressly preempted by the state. Tberelevant law is Food & Agricultural Code section 11501.1 which reads m
relevant part as follows:
. ... no ordinance or regulation of local govermnent, including, but
not limited to, an action by a local government agency or department, a county board of supervisors or a city council, or
a local regulation adopted by the use of an initiative measure, may prohibit or in any way attempt to regulate any matter
relating to the registration, sale, transportation, or use of pesticides, and any of these ordinances, laws, or regulations
are void and of no force or effect."
n
The restrictions in the permit would be considered, in the words of the statute, an action by a local government agency
to prohIbit O,r attempt to regulate the use of pesticides. While the golf course may voluntarily agree not use
rodenticides and herbicides, any action to enforce the permit would likely be successfully defended on the basis of this
code section.
I hope this is of some assi$tance in resolving at least some of the issues surrounding this matter.
Sincerely,
Polly Frenkel Chief Counsel
(916) 324-2666
10011 Street. P.O. Box 4015 . Sacramento, California 95812-4015
0 A Depattment of the Cafifomia Environmental Protection Agency . -
.
www.cdpr.ca.gov
February 28, 2007
Mr. John Oborne
Community Development
Contra Costa County
651 Pine Street, 4th Floor - North Wing,
Martinez, CA 94553
Fax: (925) 335-1299
Dear Mr. Oborne:
Subject:
Roddy Ranch Golf Course-County Use Permit-Application # LP982030,
MS980006, RZ98358-Approved 10/27 198-Effective Date 10/27/98,
Contra Costa County
Department of Fish and Game (DFG) was involved in the review of the Roddy Ranch Golf Course
development in the late 1990s. This area is known to support a number of sensitive native species
including San Joaquin Kit Fox. The County considered input from DFG and the U. S. Fish and
Wildlife Service (USFWS) in developing conditions of approval for the project's development and
management, and set aside a number of areas on the Ranch and course as environmentally
protected for endangered or threatened species. The conditions were intended to, among other
things; reduce impacts from the golf course on sensitive native species and to preserve some of the
habitat value in the area.
The long list of conditions of approval included prohibition of rodenticide use. The intent of this
condition was to preserve the prey base for sensitive species, avoid incidents of secondary
poisoning, and to preserve the burrow availability on site. Burrow destruction and control of rodent
hosts and prey are known to contribute to population declines in the species of concern present in
the area of the Golf Course.
It has been reported that the rodenticide diphacinone is being used at the Roddy Ranch Golf
Course. The method of application was broadcast baiting with grain. At this time, we request that
the County send an immediate written directive to the Roddy Ranch Golf Course to cease
rodenticide use. The County should review the status of the Roddy Ranch Golf Course operations
and take necessary steps to ensure compliance with all the terms of the Conditional Use Permit.
DFG is available to provide support to the County staff as needed. DFG requests the County
prepare and provide a report detailing any compliance issues and proposed resolutions with
specific time requirements for implementation and follow up.
At this time, it is unclear if the annexation of this area to the City of Antioch has resulted in a
transfer of responsibility for compliance monitoring. If so, these comments will apply to the City's
actions and a plan for transfer of responsibility, and follow up by the City is requested. We also
request that any agreements and use permits restricting the use of rodenticides be provided to the
County Agricultural Commissioner's Office.
1
Mr.Oborne
February 28,2007
Page 2
We appreciate your consideration of our comments. DFG personnel are available to discuss our
concerns. If you have any questions regarding our comments, please call Janice Gan,
Environmental Specialist, at (209) 835-6910; or Scott Wilson, Acting Environmental Program
Manager, at (707) 944-5584.
Sincerely,
Original signed by Rick Macedo for
Charles Armor
Acting Regional Manager
Bay Delta Region
cc: Ms. Sheila Larsen
Mr. Ryan Olah
U. S. Fish and Wildlife Service
2800 Cottage Way, W2605
Sacramento, CA 95825
City of Antioch
Planning Department
3rd and H Streets
Antioch, CA 94531
Mount Diablo Audubon Society
PO Box 53
Walnut Creek, CA 94597-0053
es:
J. Gan, S. Wilson, Warden Kozicki, Warden D Bess
JG/dh
2
Mount Diablo Audubon Society
Cree!:?, CA 94597-0053
P.o. Box 53, Walnut
www.diabloaudubon.comlindex.php
March 5, 2007
To:
County Board of Supervisors, Antioch Mayor and City Council
Cc:
County Agriculture Commissioner
Re:
SECOND REQUEST FOR ENFORCEMENT ACTION - Illegal Use of Poison Bait for
Ground Squirrel Control at Roddy Ranch Golf Course
This letter is a second request to the City of Antioch and Contra Costa County to take
immediate action to confirm compliance by the owners of Roddy Ranch with their land use
permit conditions.
We echo the comments made by the State Department of Fish and Game in their
February 28. letter and ask for an immediate meeting at the golf course with the City and
County to access compliance.
We would also like to put the City of Antioch on notice that we have witnessed additional
actions on adjacent lands to the golf course which appear intended to degrade habitat value
and destroy seasonal wetlands. We would like to be notified of any meetings with consultants
or State and Federal representatives concerning any land being considered for development
within 200 feet of the Roddy Ranch Golf Course boundaries.
It is time for the City of Antioch and County to stop dragging your feet. The citizens of
this County and the City of Antioch look to their elected leaders to enforce the permit
conditions that are established as mitigation for new development. Failure to actively enforce
such conditions questions the public benefit that entire development permits process.
Please contact me (925-934-1334) or Kent Fickett (925 258 0773), to set up the meeting at the
Golf Course.
Sincerely
Jimm Edgar
President
Roddy Ranch Golf Course Conditions of Approval 10/27/98
Contra Costa County
Approved Permit
Application # LP982030, MS 980006, RZ983058
Approved 10/27/98
Effective Date 10/27/98
Conditions of Approval
42.
Gopher. ground squirrel. and other rodent control within the golf
course shall be limited to trapping. no rodenticides shall be used.
Conditions of Approval
22. All drainage from maintained golf course turf areas shall be directed to the
irrigation ponds in order to capture run-off for water quality testing.
23. At least 30 days prior to issuance of a building permit, a final "Golf Course
Operation Guidelines" shall be prepared and submitted to the County for
review and approval. These "Guidelines" shall include site-specific
performance standards and shall address the management of irrigation,
pest performance standards and shall address the management of
irrigation, pest control, weed control, and turf fertilization.
24. (in short) A Water Quality Management Plan shall be prepared with the
assistance of a hydrologist specializing in water quality
management. ..performance standards & monitoring ... Baseline
studies ... periodically tested for changes in water quality that could
adversely affect plant and animal life ... If adverse changes are detected
(standards are exceeded), then management practices shall be adjusted
(i.e., new pest control methods shall be instituted ... a contingency plan for
treatment shall be described.
32. Golf Course ponds shall be surveyed for the presence of RLF and
predators annually by a qualified biologist. .. If RLF are found, the USFWS
shall be contacted ...
33. A RLF and CTS Predator Control Plan shall be developed and
implemented to prevent bullfrogs and other RLF.CTS predators from
colonizing the golf course lakes and migrating to potential RLF/CTS
predatory to RLF, such as bullfrogs and mosquito fish. The golf course
ponds shall not be drained during the spring and early summer.
34. A Water Quality Management Plan shall be developed to prevent golf
course run-off from adversely affecting potential RLF breeding sites offsite.
39. Cover habitat shall be created near ponds 5 and 6 prior to golf course
construction. Cover habitat shall be constructed through the placement of
piles of woody debris and/or rocks in upland areas surrounding these
ponds.
40. A permanent curb barrier shall be constructed around the perimeter of the
golf course to prevent movement of CTS onto the golf course site
following construction to prevent colonization of the golf course ponds by
CTS.
41. A Water Quality Management Plan shall be developed to prevent golf
course run-off from affecting potential CTS breeding sites off-site.
42. Gopher, ground squirrel, and other rodent control within the golf course
shall be limited to trapping, no rodenticides shall be used.
44.An employee education program shall be conducted for any project that
has expected impacts to kit fox or other endangered species (in this case,
burrowing owls, red legged frogs, and badgers).
There are more NPDES mitigation conditions.
###
Contra Costa County Agriculture Department
Ground Squirrel Spermophilus beecheyi
Empire Mine Road Antioch, California
August 6-10,2012
Materials and Costs: (Needed to trap at one site: Empire Mine Road)
Materials
Traps
Re-bar
Hammer
Flags Markers
Untreated
Rolled Oats
Actual
Cost
(prorated)
Cost
Reusable
Unit
Total
Cost
$54.75
X
1 cage
$657
$33.73
$4.47
X
15 ft
$22.35
$7.45
3 ft/piece
life
$19.98
X
small
sludge
$19.98
$6.66
3 year life
$5.5
X
100 flags
$0.66
$0.22
Used one flag per trap site - 3 year life
50lbs
$82.28
$82.28
Four bags used
$20.57
Comment
Cages3 year life I 8 weeks of use per year 8/52
weeks in a year=O.154,cost for this application
I 24 pieces needed for 12 cages- 3year
I 5 year life
$200
X
1 chamber
$200
$40
$169.93
X
20 Ib tank
$169.93
$49.99
Tank $149.94 + CO2 $19.99 (per refill) 15year life
Plywood
$31.36
X
1 sheet
$94.08
$31.36
3 sheets needed to cover 12 cagestop and
bottom - 3 year life
Labor
$19.94
1 hour
$867.3~
Gas Chamber
CO2 Tank +
CO2
Overtime
Labor
Rubber
Gloves
$27.13
$3.48
1 hour
1 pair
-;
$298.4(
<,
$13.92
---
$867.39
$298.43
~J
+ Workers Camp Benefit£'4.5
I ••••••
- ~abor
<,
@ BaseSalary x~
"-
I'
$13.92
1
9 cubic feet gas chamber
2 pairs per week
Total
hrs tot;)
./'
or
~
hJ
Cable Ties
$3.98
Pliers
$7.58
Labels
$21.17
I 12 traps
20 ties
$4.78
$4.78
1 plier
$7.58
$2.53
I 3 year
100 sheets
$2.54
$2.54
Only 12 labels needed
washer +
gas
$603
$52
2 cables per trap
in experiment
Modify traps if necessary i.e. trap door stuck shut
Pressure
Washer
$599
Vehicle Cost
X
X
$0.555/per
mile
$169.61
$177.15
1 pressure washer + 1/2 gallon for fuel
rental
$50/day
$0.555/mile includes vehicle use and fuel (42.6 mi
round trip+l.5 mile stretch to Trap Location on
Empire Mine Road x 7 trips x 0.555)
$77.15
Total Cost Per
Site
I
$1,670.43
Total Cost per 1200 ft (live trapping)
Total Cost/linear Mile (Minus
$7,349.89
Reusable Items live trapping)
Total Cost Per Squirrel per 1200 ft (152
$10.99
ground squirrels)
Table 1: The table displays the material cost for live trapping at the site of Empire Mine Road Antioch, CA.
Materials
Cost
Reusable
Unit
Total
Cost
Actual
Cost
Comment
Broadcast 3.3 mile stretch of Empire Mine Road
Diphacinone
0.01%
63.50
50lbs
$401.96
(CDFA Research Surcharge @$0.50/LB) + Cost of
Treated Bait (6.33 bags used)
$401.96
Cost per week for Empire Mine 1 day Untreated
(
fJ1U::>'<'t:;)) Diphacinone
(PlaCeb~~1fI
~ grain bai (6 hours total)
Labor
19.94
1 hour
$119.64
$119.64
Untreated
Rolled Oats
20.57
50lbs
$82.28
$82.28
Road (4 bags)
1 Hopper
$710.00
$14.20
Spreader 5 year life (1/10) use
Rheostat)
Cost for
Seed Spreader
710.00
X
Br
$0.555/mile
Vehicle Cost
Total Cost Per
Site
0.555
Per Mile
$109.22
(
$1,589.14
$109.22
$727.30
--
.....
~Ie
I 42.6
treated
stretch of Empire Mind
I
(Spreader +
mi roundtrip + 6.6 miles
~~r Empire Mine Rd (x4 for three days
reatment/survey and placebo)
,
Total Cost for 3.3 mile stretch of Empire Mine
Road
Total Cost per mile (treated bait) on
$481.56
$220.40
Empire Mine Road
Table 2: The displays the matenal cost for spreading treated bait on Empire Mine Road Antioch, CA.
2