Comments to Utah Department of Environmental Quality on SLCMAD permit

Utah Physicians for a Healthy Environment (UPHE) and other environmental groups have been concerned about the inappropriate use of pesticides by the state’s mosquito abatement districts, Salt Lake City Mosquito Abatement District (SLCMAD) in particular, since we found out
about their request to involve the US Air Force last year. In investigating that request, and SLCMAD’s Environmental Assessment for that request, UPHE learned for the first time that for many years SLCMAD has engaged in yearly, repeated, widespread aerial spraying of pesticides over approximately 160,000 acres in the Northwest Quadrant of SLC. UPHE subsequently developed an extensive, heavily referenced report that concluded there are multiple reasons why SLCMAD’s use of pesticides, especially aerial sprayed pesticides, is extremely poor public policy. That report is attached, and we ask that the relevant staff of the Utah Division of Water Quality and Utah Water Quality Board read the report before reissuing the Pesticide General Permit for mosquito districts. Though the general permit is applicable state wide its application to SLCMAD is arbitrary and capricious, and as it relates to this district, the permit should be terminated.