A Call for Mosquito Reform
Existing Mosquito Control Program
Mass Audubon recommends that Massachusetts Department of Public Health’s Massachusetts Arbovirus Surveillance & Response Plan be followed in response to West Nile Virus and Eastern Equine Encephalitis. We call upon the State Legislature to reform the outdated and inconsistent mosquito control “system” in Massachusetts.
The Massachusetts Executive Office of Energy and Environmental Affairs’ Department of Agricultural Resources Division of Crop and Pest Services houses the State Reclamation and Mosquito Control Board that oversees the 11 mosquito control districts. The Board has produced a Generic Environmental Impact Report and Operational Response Plan to Reduce the Risk of Mosquito-Borne Disease in Massachusetts.
These documents and the Board provide broad oversight of mosquito control programs. However, the nine mosquito control districts in Massachusetts operate with a good deal of autonomy and standard practices vary from district to district. Mosquito control activities carried out by districts are exempt from the Massachusetts Wetlands Protection Act and can often alter wetlands without any permits or environmental standards.
Recommendations for Reform
There should be increased oversight of mosquito control by state and local environmental and public health authorities, with environmentally sound standards consistent with the Department of Public Health’s mosquito-borne diseasePlan, as well as increased public education on mosquito-borne diseases, risk, and protection.
Many of the recommendations outlined below require funding, studies, and/or legislative changes to the organizational structure of mosquito control practices in Massachusetts. Nevertheless, there are steps that municipalities can take immediately, without incurring direct financial costs.
In order to more effectively protect the public health and environment, we urge that communities consider this option and the other recommendations outlined below as they prepare for town meeting votes regarding participation in mosquito control districts.
Organizational & General Focus Recommendations
Reorganize mosquito control in MA to focus on public health protection as the primary goal
The State Reclamation and Mosquito Control Board should be re-constituted and re-named, with the Department of Public Health providing oversight and Department of Fish and Game providing expertise in ecological management for mosquito control. The regional districts should be continually improved and coordinated, with enhanced roles for local boards of health, other municipal representatives, and experts. Nuisance control should be de-emphasized and non-target and wildlife exposures due to mosquito control pesticides applied for nuisance control purposes should be reduced.
Scientifically-based statewide Integrated Pest Management (IPM) strategies need to be continually updated & refined
A strong IPM strategy for Massachusetts mosquito control should include the following components:
- Monitoring protocols for both efficacy and non-target impacts.
- Action thresholds.
- Best Management Practices (BMPs).
- Record keeping standards and systems (mandated to provide consistent and publicly accessible data on all mosquito control activities and results).
- Adaptive management, providing for continual improvements to mosquito control practices based on monitoring program results and evolving techniques.
Wetlands & Stormwater BMPs should be employed
The State Reclamation and Mosquito Control Board has prepared a Best Management Practices (BMP) manual and supplement for freshwater wetlands mosquito management practices to guide ditch cleaning and other mosquito district activities in wetlands. The BMPs include measures to avoid and minimize adverse impacts to sensitive areas (e.g. rare species habitats, fish bearing waters, vernal pools, and water supply areas).
Low Impact Development (LID) & Green Infrastructure techniques should be used
Local stormwater management practices and standards play an important role in mosquito management. LID and green infrastructure techniques like vegetated swales and rain gardens direct rainwater and runoff into small, vegetated areas where it quickly infiltrates into the ground, a system preferable to stormwater collection systems with catch basins that often create mosquito breeding areas.
LID and Green Infrastructure have many other benefits, including protection of water quality and fish habitat. Municipalities can promote the use of these techniques both through land use regulations for new development or redevelopment and through voluntary measures such as retrofitting of existing development. Restoration of fish habitat, such as by removing obsolete dams or upgrading culverts that prevent fish from reaching sections of streams and wetlands should also be a priority.
Municipalities are faced with a dilemma under the existing mosquito control framework. They can join a mosquito control district and risk receiving pesticide applications, wetland ditching, and/or nuisance control activities they may not want or need; or they can stay out of the district and have inadequate capacity to monitor for or respond to West Nile Virus or EEE.
Some of the mosquito districts offer “menu-based” services that allow municipalities to select only the services they want, maintaining the right to refuse certain activities like nuisance control. We encourage local officials to work with the districts to reach such agreements, based on a proactive approach that maximizes public health benefits and protects the environment.
Municipalities should be able to access Massachusetts Department of Public Health surveillance services without joining a mosquito control district. The mosquito control districts should also develop cooperative programs with local departments of public works, planning boards, conservation commissions, and boards of health to ensure that stormwater systems and culverts are designed and maintained to minimize mosquito breeding and promote habitat for fish and other mosquito predators.
For instance, regular cleaning of catch basins and proper maintenance of detention basins reduces mosquito breeding while also protecting water quality. Mosquito districts should also conduct systematic roadside surveys, in cooperation with local officials and MassHighway, to identify and reduce sources of erosion and sedimentation from roadways.
If a community is a member of a mosquito district, Mass Audubon recommends that a request be made that the district voluntarily limit itself to the actions called for in the DPHPlan, and that no nuisance control spraying be conducted. However, under a Declared Public Health Emergency by the Governor, the Department of Public Health is the ultimate decision maker on any mosquito control activities.
Additional studies on the effects of mosquito control pesticides on humans, other non-target organisms, & ecosystems
The long term, subtle effects of pesticide exposure on endocrine and immune systems, behavior, and cancer, as well as indirect food chain and other ecological effects are not adequately understood. Studies of this type are difficult and take many years.
These areneeded to better understand the effectiveness of various approaches to mosquito control in reducing human health risks from WNV and EEE.
More Field Research
As opposed to laboratory research, more field research is needed to account for possible ecological and synergistic variables. Field research should focus on improved documentation of nontarget organism impacts (e.g. testing for mortality of nontarget invertebrates through the use of drop cloths and caged insects placed in spray areas prior to spraying). Standardized and centralized reporting systems should be implemented for tracking all complaints of possible human or nontarget organism exposures to mosquito control applications.
Required Impact Testing
The US Environmental Protection Agency (EPA) should require comprehensive, non-target impact testing for registration of new mosquito control pesticides. Although this is not an issue that the Commonwealth can address directly, Massachusetts officials should be aware of and take into account deficiencies in the EPA pesticide registration process when developing statewide BMPs.
The lack of data on health and ecological effects of “inert ingredients” and the cumulative effects of multiple chemical exposures in the environment should be considered when establishing state policy and procedures.
Should be provided to continue to refine BMPs, monitoring protocols, and computerized recordkeeping to form an integrated statewide system and replace the outdated and inefficient paper recordkeeping.