By Henry Curtis on 1 June 2012 for Life of the Land -
Image above: John Deere pesticide rig used by Pioneer for use on food crops. From (https://www.pioneer.com/home/site/mobile/template.CONTENT/agronomy/corn-troubleshooting/fertility-weather/guid.569F60ED-7B8A-B484-053C-2DC6AFE02B4B).
A recent U.S. federal court ruling established that pesticides must for the first time be regulated as “pollutants” under the Clean Water Act. Every state must now have a permitting system to regulate the use of pesticides discharged into water. Hawaii’s Dept of Health has just issued their plan and want to know what you think about it.
This gives Hawaii's citizens an opportunity to better protect Hawaii’s environment and our public health from pesticide pollution. Unfortunately industry and agency lobbyists got in on the process early and succeeded in inserting so many loopholes that Hawaii’s permit program largely fails.
Please use the talking points in the example below to help you write your own letter, or copy, sign and send the letter below.
June 4, 2012 Clean Water Branch Environmental Management Division Hawaii Department of Health 919 Ala Moana Boulevard, Room 301 Honolulu, Hawaii 96814-4920
Re: State of Hawai‘i Department of Health Proposed Revision of Hawai‘I Administrative Regulations (H.A.R.), Chapters 11-54 & 11-55 to Add a National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges from the Application of Pesticides to State Waters
1. Strengthen the public’s right-to-know Strengthen the public’s right-to-knowThe public should be able to access on DOH’s website all notices of intent to discharge pesticides, pesticide treatment plans, and monitoring records. We have a right to know where, when and which pesticides are being discharged, so we can adapt our activities or use of that water, monitor impacts, comment and suggest alternatives ahead of time. We also want immediate notification of all spills and accidents. DOH’s permit allows applicators to keep most of this information to themselves.
2. Protect Our Drinking Water & Endangered Species Protect Our Drinking Water, Class 1 and AA waters, and Endangered Species DOH’s permit makes numerous exceptions to allow for the discharge of pesticides into our drinking water, our most protected class 1 and AA waters, and impaired waters. It also does little to ensure the protection of waters that may be critical habitat for Hawaii’s many endangered species. DOH should apply the strictest standards when any of these waters are affected
3. Require that applicators select the least toxic alternatives Only large applicators are asked to evaluate alternatives to pesticides, and they are given broad license to decide when and how pesticides should be used. DOH should set objective standards raising the bar for when pesticide use is allowed, with less toxic alternatives clearly favored and best practices to minimize harm detailed.
4. Strengthen site monitoring requirements DOH asks only that applicators do a brief visual “spot check” for impacts upon discharge, at the applicator’s discretion. Ambient water quality monitoring should be required before and after application for all discharges, and imperative for the most toxic pesticides, examining for the specific known and suspected effects of each pesticide.
5. Expand the range of pesticide users covered by the permit DOH’s permit applies its most stringent standards to a far too limited number of potential applicators; primarily those applying pesticides over 6400 acres or 20 linear miles. These mainland-scaled thresholds are too high to capture many of Hawaii’s most significant pesticide discharges. Know of a water body that doesn’t make the cut? Let DOH know about.
HOW TO BE HEARD ON THIS ISSUE
Deadline: Monday, June 4, 2012
Go to http://healthuser.hawaii.gov/health/environmental/water/cleanwater/prc/pubntcs/eGeneralFile/04023PDCL.12.pdf for video conference locations on Kauai, Maui and Hawai`i island.
2. Email your comments CleanWaterBranch@doh.hawaii.gov with subject line: Docket No. R-1-12
4. Pass it on Send these talking points to others you know care about protecting Hawaii’s water.
DOH, Notice of public hearing, http://healthuser.hawaii.gov/health/environmental/water/cleanwater/prc/pubntcs/eGeneralFile/04023PDCL.12.pdf
Henry Curtis Executive Director Life of the Land 76 N. King Street, Suite 203 Honolulu, HI 96817 phone: 808-533-3454. cell: 808-927-0709 www.lifeofthelandhawaii.org email@example.com