NATIONAL
 ESTUARY
 PROGRAM
                   URBAN   PESTICIDES
                  The San Francisco Estuary Partnership (SFEP) supports a nationally unique effort to reduce widespread pesticide toxicity in urban creeks. The problems
                  are complex: although major contributors to urban creek toxicity were phased out by 2004, the pyrethroid pesticides (synthetic pesticides based on com-
                  pounds in chrysanthemum flowers, but much stronger and more toxic) that replaced them created a new toxicity problem. Local agencies responsible for
                  resolving toxicity in their jurisdictions could not directly control pesticide use, and they were frustrated that one pesticide toxicity problem had given way to
                  another.

SFEP approaches this difficult problem by working to bridge water quality and pesticide regulation. SFEP's Urban Pesticide Pollution Prevention Project educates pesticide regula-
tors about water quality and water quality managers about pesticides. The project tracks regulatory processes for pesticides of concern to surface water quality, connects new
scientific and monitoring data to regulatory reviews, and helps local governments get involved in those processes. The project's consistent voice for urban water quality has helped
to change the way pesticides are regulated at both the California and  Federal levels.
THE NATIONAL ESTUARY PROGRAM  IN ACTION
                                                                                             San Francisco Estuary  Partnership
In  California, pesticide-related
toxicity is  more severe—and
more widespread—in urban ar-
eas than in agricultural areas.
Currently,  most  toxicity  comes
from pyrethroids. Generic pyre-
throid names often end in '-thrin,'
such as bifenthrin  and  cyper-
methrin, and they are sold under
hundreds  of  formulations and
brand names.   Pyrethroids are
widely used nationwide, but tox-
icity measurements and data are
still rare outside  of California. In
California, pyrethroids are pri-
marily used to control the state's
                             most common  pest problem,
                             ants, in homes and buildings.

                             Ant control in California often in-
                             volves spraying pyrethroids on a
                             wide band (up to 10 feet) around
                             a  building.  These  perimeter
                             sprays, which  are usually  ap-
                             plied by professional applicators,
                             often cover impervious surfaces,
                             and runoff can bring  pesticides
                             to  storm  drains and  creeks.
                             While the wash-off fraction may
                             be tiny (perhaps less than 1 % of
                             the total application), pyrethroids
                             can be toxic to aquatic  life in
creeks at concentrations as low
as 10 parts per trillion. A typical
container of pyrethroid pesticide
can contaminate up to 50 billion
gal Ions of water. Even rigorously
following label instructions does
not always prevent pollution and
toxicity in local creeks.

The root cause of this toxicity
can be traced back to a regula-
tory gap. Because the way pesti-
cide  laws  are   implemented
doesn't fully take water quali-
ty—particularly   urban  water
quality—into account, pesticides
Toxicity of Bay Area Pyrethroids Use Almost
        Tripled Between 2001  & 2004
   Increase coincident with diazinon phase out
                                                                                                  2001        2002        20D3        2004
                                                                                       Estimated use of study list pyrethroids in the San Francisco Bay Area 2001-2004 (permethrin equivalents)
 EFFECTIVE
                                       EFFICIENT
                   ADAPTIVE
                       COLLABORATIVE

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    can be registered for uses that
    will cause Clean Water Act viola-
    tions. While cities are responsible
    for pesticides in  surface waters
    under their NPDES permits, they
    have little direct control because
    California  law  precludes   local
    government from banning or reg-
    ulating pesticides.

    SFEP's Urban Pesticide Pollution
    Prevention   Project   works  to
    bridge  this  regulatory gap  by
    consistently bringing water qual-
    ity issues to pesticide regulators.
    The process begins with a tech-
    nical consultant reviewing state
    and Federal pesticide regulatory
    actions to find those of interest
for water quality. This screening
is a significant task: at the state
level alone,  California's  Depart-
ment of  Pesticide  Regulation
manages more than 7,000 pes-
ticides regulatory activities each
year.

Once a specific pesticide item of
interest is identified, SFEP helps
share relevant scientific infor-
mation  and  insights between
water quality agencies and pes-
ticide regulators.  Informal com-
munication facilitated by SFEP is
usually followed  up with formal
letters from  local agencies,  in-
cluding  stormwater  programs,
wastewater  treatment   plants,
and California's State Water Re-
sources Control  Board and Re-
gional  Water  Quality   Control
Boards,  to  state  and   Federal
pesticide regulators.

The SFEP's Urban Pesticide Pol-
lution Prevention  Project also
supports communication, edu-
cation, and collaboration among
stormwater   and   wastewater
agencies, pesticide  regulators,
water quality agencies, pesticide
manufacturers, concerned  citi-
zens, and technical experts.  It
holds  regular  meetings  of  a
working group, the Urban Pesti-
cides Committee; issues techni-
cal  reports on annual pesticide
usage, science and  monitoring
data, and  regulatory changes;
and   makes  presentations  to
stakeholders.

The  regulatory  process  works
slowly, but it can make signifi-
cant changes  in  pesticide  use.
For selected pesticides, the proj-
ect's work has secured changes
in label directions to reduce re-
leases,  limited outdoor uses  to
spot  treatments  rather  than
broadcast applications, and ter-
minated  applications to  boat
hulls and other areas that drain
directly  to  waterways.   The
SFEP's Urban Pesticide Pollution
Prevention  Project has affected
the uses of a wide range of pes-
ticides, including  numerous py-
rethroids,  pyrethrins,  piperonyl
butoxide and  MGK-264  (two
synergists),  lindane (lice treat-
ment), metaldehyde (snail bait),
and metam-sodium (sewer sys-
tem root control).  More impor-
tantly,  because of the project's
work,  both  California and  U.S.
EPA  pesticide regulators  have
revised the methods they use to
assess  pesticides.   Regulators
more  commonly  include water
quality in the scope of their risk
assessments—and   are   more
likely to consider urban pesticide
use patterns.

While  SFEP's Urban  Pesticide
Pollution Prevention Project cur-
rently focuses on California, its
water quality communications to
Federal regulators have secured
changes to pesticide regulation
at a national level.

Visit   www.sfestuary.org to
learn more about this and other
SFEP efforts.

EPA's  National Estuary Program
(NEP) is a unique and successful
coastal watershed-based program
established in 1987 under  the
Clean  Water Act Amendments.
The NEP involves the public and
collaborates with  partners to pro-
tect, restore, and maintain the wa-
ter quality and ecological integrity
of 28 estuaries of national signifi-
cance located in 18 coastal states
and Puerto Rico.

For more information about  the
NEP go  to  www.epa.gov/owow/
estuaries.
The  NEP:  Implementing the Clean Water Act in ways that are Effective, Efficient, Adaptive, and Collaborative.
                                                                                                           EPA-842F09001

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