NACWA has asked EPA to consider the risks to utility operations, the aquatic environment, and resource recovery in its evaluation of neonicotinoid pesticides, which are used in pet flea treatment products.  EPA’s Draft Biological Evaluation of neonicotinoids did not consider how these pesticides can be washed or drained into the sewer system. 

NACWA’s comments explained that pesticides may be washed or drained into the sewer system or stormwater systems, and even utilities with advanced treatment technologies cannot remove all pesticides.  POTWs cannot control domestic use of pesticides, and most states do not allow regulation of pesticides at the local level. 

Accordingly, NACWA stresses that it is necessary for EPA to protect the wastewater treatment process, recovery of resources from wastewater, stormwater systems, and the aquatic environment by evaluating and mitigating the risks presented by pesticides.  The Draft Biological Evaluation for neonicotinoids did not accomplish this, and NACWA asked that EPA add wastewater impacts to its evaluation. 

NACWA also submitted comments on EPA’s Proposed Interim Decision for the Pyrethrins Registration Review.  Pyrethrins are also used to control fleas, lice, and other pests, and NACWA previously asked EPA to provide better labeling to reduce outdoor use of pyrethrins and to ensure that pesticides are not disposed of down the drain.  EPA has proposed labeling language that responds to this request, and NACWA supports the Agency’s Proposed Interim Decision. 

NACWA is working with the Bay Area Clean Water Agencies (BACWA) to advocate for improved consideration of pesticide impacts to POTWs and stormwater systems.  NACWA members with questions or information about pesticide impacts should contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.