HomeMy Public PortalAbout20130723 - Agenda Packet - Board of Directors (BOD) - 13-16 Midpeninsula Regional
Open Space District
Meeting 13-16
SPECIAL MEETING
BOARD OF DIRECTORS
MIDPENINSULA REGIONAL OPEN SPACE DISTRICT
Administrative Office
330 Distel Circle,Los Altos,CA 94022
Tuesday,July 23, 2013
SPECIAL MEETING BEGINS AT 6:00 P.m.*
AGENDA
6:00 SPECIAL MEETING OF THE BOARD OF DIRECTORS OF THE MIDPENINSULA REGIONAL OPEN SPACE DISTRICT—
STUDY SESSION
ROLL CALL
1. Study Session to Review and approve"in concept"the Draft Integrated Pest Management Policy,for Purposes
of Conducting Environmental Review.
INFORMATIONAL REPORTS—Reports on compensable meetings attended.Brief reports or announcements concerning
activities of District Directors and staff,opportunity to refer public or Board questions to staff for factual
information;request staff to report back to the Board on a matter at a future meeting;or direct staff to place a matter
on a future agenda.
A. Committee Reports
B. Staff Reports
C. Director Reports
ADJOURNMENT
Times are estimated and items may appear earlier or later than listed.Agenda is subject to change of order.
TO ADDRESS THE soARD: The President will invite public comment on agenda items at the time each item is considered by the Board of
Directors. You may address the Board concerning other matters during Oral Communications. Each speaker will ordinarily be limited
to three minutes.Alternately,you may comment to the Board by a written communication, which the Board appreciates.
Consent Calendar:All items on the Consent Calendar may be approved without discussion by one motion.Board members, the General
Manager,and members of the public may request that an item be removed from the Consent Calendar during consideration of the
Consent Calendar.
In compliance with the Americans with Disabilities Act,if you need assistance to participate in this meeting,please contact the District Clerk at(650)691-1200.
Notification 48 hours prior to the meeting will enable the District to make reasonable arrangements to ensure accessibility to this meeting.
Written materials relating to an item on this Agenda that are considered to be a public record and are distributed to Board members less than 72 hours prior to the
meeting,will be available for public inspection at the District's Administrative Office located at 330 Distel Circle,Los Altos,California 94022.
1,Jennifer Woodworth,District Clerk for the Midpeninsula Regional Open Space District(MROSD),declare that the foregoing agenda for the Regular Meeting of the
MROSD Board of Directors was posted and available for review on July 18,2013,at the Administrative Offices of MROSD,330 Distel Circle,Los Altos California,
94022. The agenda is also available on the District's web site at httrl:/www.openspacc.org.
Signed this 19`h day of July,at Los Altos,California.
District Clerk July 18,2013
Midpeninsula Regional
Open Space District
R-13-22
Meeting 13-16
July 23, 2013
STUDY SESSION AGENDA ITEM 1
AGENDA ITEM
Study Session to Review and approve"in concept"the Draft Integrated Pest Management Policy
GENERAL MANAGER'S RECOMMENDATION
Review and approve"in concept"the attached Draft Integrated Pest Management Policy, for
purposes of conducting environmental review.
SUMMARY
Following Board approval, the Draft Integrated Pest Management(IPM)Policy will guide the
development of the Integrated Pest Management Program and resulting project description for
purposes of conducting environmental review over the next year. The Board will subsequently
consider certification of environmental documentation and adoption of the final IPM Policy in
spring 2014. The adopted IPM Policy will be incorporated into the District's Resource
Management Policies (see Report R-12-05) and will replace the Invasive Species Management
chapter(Chapter 4).
DISCUSSION
The Board of Directors approved the Resource Management Policies on January 11, 2012 (see
Report R-12-05). The District is currently developing an Integrated Pest Management(IPM)
Program which will guide the comprehensive implementation of all pest management on District
property. As a result,the IPM Policy will replace the existing Invasive Species Management
chapter(Chapter 4) in the Resource Management Policies document.
Staff is working with an IPM consultant team,Ascent Environmental, to develop the IPM
Program (see Report R-13-06). The consultant team is reviewing trends and definitions of IPM,
examining pest management programs at other land management agencies, and interviewing
District staff to define an IPM Program that matches the District's land management goals.
The Draft IPM Policy presented here for Board consideration includes the following definition of
integrated pest management:
IPM is a long-term, science-based decision-making system that uses a specific methodology
to manage damage from pests. This methodology contains the following elements:
R-13-22 Page 2
* Correctly identify the pest and understand its life cycle;
0 Determine and map the extent of the problem or infestation;
0 Establish tolerance levels for control actions;
0 Utilize the least toxic suite of management tactics to control the target pest at the most
vulnerable stages of its life cycle; and
0 Monitor populations and effectiveness of control methods.
IPM requires the assessment of pest control alternatives and the monitoring of site conditions to
effectively control a target pest with minimum impact to human health, the environment, and
non-target organisms. IPM can be used for many types of pests and situations, including
invasive species, structural and agricultural pests, and other problem pest species(e.g.,
rattlesnakes and stinging insects).
IPM requires knowledge of the biology of pests, the available techniques for controlling them,
and understanding of the secondary effects of the control techniques, such as soil erosion,
pesticide drift, or bioaccurnulation. Control of a pest is only undertaken once a tolerance level
has been exceeded. The effectiveness, safety, and efficiency of control methods are important
considerations as they apply to the specific site conditions and life history of the target pest. IPM
requires monitoring site conditions before, during, and after treatment to determine if objectives
are being met and if methods need to be revised. IPM requires that the most effective, least toxic
method be used to obtain the desired level of control. If pesticides are necessary to meet a pest
control objective, the potential for harm to workers and the public must be carefully considered,
as are effects on the environment, and then the least toxic and most effective, efficient, and
target-specific pesticide is chosen to meet that specific objective.
Within the District, the situations that trigger the need for pest control fall into four distinct
categories:
* management of natural areas for the long-term preservation of natural resources;
* management of highly modified areas (e.g., offices, residential buildings, recreational
structures)to maintain site uses and protect the health of human occupants;
• management of managed landscapes (e.g. agricultural fields, forests, rangelands) to
maintain intended land uses; and
• management offocused visitor use areas (e.g.,parking lots, trails) to provide safe and
enjoyable human access to natural areas.
The District's IPM program will provide guidance for careful management of pests in each of
these four Pest Management Categories while protecting natural resources and public health.
FISCAL IMPACT
Approval "in concept"of the draft IPM Policy will not result in an increase to the budget.
Subsequent actions taken to implement the IPM Policy will be included in the annual Action
Plan/Budget Process for Board approval.
R-13-22 Page 3
BOARD COMMITTEE REVIEW
The Planning and Natural Resources Committee is scheduled to review the draft IPM Program
upon completion in the fourth quarter of this fiscal year. No additional Board Committee review
is planned.
PUBLIC NOTICE
Public notice was provided pursuant to the Brown Act and to persons indicating their interest in
resource management projects. No additional notice is required.
CEQA COMPLIANCE
Staff will use the Draft IPM Policy approved"in concept"by the Board to guide the
development of the IPM Program and to develop a project description for purposes of conducting
environmental review over the next year. The environmental impacts of the subsequent IPM
Program will be analyzed at the EIR level.
NEXT STEPS
Staff will continue to work with the consultant team to develop an IPM Guidance Manual, a pest
database, train staff, conduct public outreach and complete an environmental review on the IPM
Program. The schedule for completion of the final environmental review is May 2014.
Attachment
1. Draft Integrated Pest Management Policy
Responsible Department Head:
Kirk Lenington,Natural Resources Manager
Prepared by:
Cindy Roessler, Senior Resource Management Specialist
Contact person:
Same as above
,
ATTACHMENT 1
U�� INTEGRATED ������ �� � �� � ���N������
U �� . UU`N 8 ��»��K`v�� U �-�� PEST MANAGEMENT
POLICY
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�^^^��^^��n ^����/���
The District im responsible for managing all the resources on its lands. These are mostly natural
features, but also include built facilities such as offices, outbuildings, and trails. Sometimes,
management of natural resources and associated human uses on District lands requires control
of pests such as invasive plants, rodents or stinging insects. The District is committed to using
Integrated Pest Management(IPM)principles in developing and implementing programs to meet
its natural resource goals and to protect public health and human enjoyment of its preserves.
Within the District, the situations that trigger the need for pest control fall into four distinct
categories:
° management of natural areas for the long-term preservation of natural resources;
° management uf highly mnodifiadareas(*.Q.. offices, residential buildings, recreational
� structures)bo maintain site uses and protect the health of human occupants
�
� ° management of managed landscapes(e.g. agricultural fields,forests, rangelands)to
maintain intended land uses; and
� ° management of focused visitor use areas(e.g., parking lots,trails)to provide safe and �
� enjoyable human access to natural areas.
�
The District's IPM program provides guidance for careful management of pests in each of these
� four Pest Management Categories while protecting natural resources and public health.
Integrated Pest Management
IPM is a long-term, science-based decision-making system that uses a specific methodology to
manage damage from pests. This methodology contains the following elements: |
° Correctly identify the pest and understand ita|ifeoyo|e;
° Determine and map the extent of the problem orinfestation;
° Establish tolerance levels for control actions;
° Utilize the least toxic suite of management tactics to control the pest at the most vulnerable
stages ofits life cycle; and
° Monitor populations and effectiveness of control methods.
IPM requires the assessment of pest control alternatives and the monitoring of site conditions to
effectively control a target pest with minimum impact to human health, the environment, and
non-target organisms. IPM can be used for many types of pests and situations, including
invasive species control, control of structural and agricultural pests, and control ofother
problem pest species(e.g.. rattlesnakes and stinging inmecto).
|PK8 requires knowledge cf the biology of pests, the available techniques for controlling them, and
1 |
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ATTACHMENT 1
understanding of the secondary effects of the control techniques(such as soil erosion or pesticide
drift or bioaccumulation). Control of a pest is only undertaken once a tolerance level has been
exceeded. The effectiveness, safety, and efficiency of control methods are important
considerations as they apply to the specific site conditions and life history of the target pest. IPM
requires monitoring site conditions before, during, and after treatment to determine if objectives
are being met and if methods need to be revised. IPM requires that the most effective, least toxic
method be used to obtain the desired level of control. If pesticides are necessary to meet a pest
control objective, the potential for harm to workers and the public must be carefully considered,
as are effects on the environment, and then the least toxic and most effective, efficient, and
target-specific pesticide is chosen.
[sidebar)Pesticide is a broad term that includes any material(natural, organic, or
synthetic) used to control or prevent pests including herbicides(weed or plant killers),
insecticides(insect killers), and rodenticides (rodent killers) as a few examples.
[sidebar]Tolerance levels, as used in IPM, refer to the level at which pests can be
present without disturbing or disrupting natural processes;causing economic damage;
degrading intended uses or human enjoyment of built facilities;or resulting in an
unacceptable human health risk.
Management of Natural Areas and the Problem with Invasive Species
Management of the District's natural areas focuses primarily on the control of invasive species
that threaten natural resources. Natural Areas make up the majority of District lands, and typically
experience low levels of human use.
Invasive plants have greatly altered many of California's natural plant communities. Because
they originated elsewhere, many invasive plants are not susceptible to predation, herbivory,or
diseases of this region. Invasive plants are extremely adaptable and can thrive in a wide range of
conditions.They can grow quickly, reproduce early, produce many long-lasting seeds, and
tolerate disturbance. Invasive plants can reduce native biodiversity in natural areas by gradually
crowding out or competing with native plants for water and sun, and by reducing or modifying
wildlife habitat.
[sidebar]The California Invasive Plant Council maintains an Invasive Plant Inventory that
rates the threat of non-native plant species by evaluating their ecological impacts,
invasive potential and ecological distribution. Along with local knowledge, the District
uses this list to evaluate the invasive risk of existing and new non-native plants found on
District preserves.
Invasive animals pose another threat to natural areas. Escaped/released domestic animals and
other non-native wildlife species can thrive in the favorable climate of the San Francisco
peninsula. Once established in a preserve, they compete for valuable resources and disturb the
sensitive balance of natural food webs. Bullfrogs and wild pigs are examples of invasive
introduced animals found in District preserves that physically displace or consume the native
plants and wildlife that normally inhabit natural areas.
[sidebar]Wild(feral)pigs are an example of an invasive wildlife species with obvious
impact on District lands. They have been widespread in the central coast of California
since about 1970, reproduce rapidly, dig up meadows and wetlands, and carry diseases
that can affect people and livestock. They eat acorns, bulbs, and soil animals, and are
difficult to control. Feral pigs were abundant in the South Skyline region in the 1990s. The
District has been trapping feral pigs since 2000 and has substantially reduced their
population and damage from their rooting.
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ATTACHMENT 1
Programs ho control invasive plant and animal species often require a long-term commitment.
With many invasive species, short-term lapses in management activity may negate years of
expensive control programs. IPM offers a suite of strategies that can be used to effectively control
invasive species on District lands.
Management of Highly Modified Areas
Management of highly modified areas focuses on maintaining intended uses and providing for the
comfort and safety of the people occupying or visiting the built facility.
The District manages over 150bui|dinga. including on administrative office inocity; and field
offices, residences, and numerous outbuildings such as barns and sheds in the preserves.At
these locations, population levels of certain animals and plants may threaten the primary use of
these structures. For example, rodenbs, ants and similar structural and problem pest species are
typically controlled in occupied structures when their population numbers may result in structural
damage or heath risks to humans.Weeds are often controlled in landscaped areas around
� buildings in preserves to maintain planned site uses. Sbo&*law requires that defensible space
be maintained around buildings by selectively managing surrounding vegetation, and that
emergency vehicle access be maintained by keeping rural roads and trails within the District's
preserves clear of obstructing vegetation.
� The traditional approach to structural pest control is often modified because District structures are
located in natural srnao� For example, rodent control at�e|d storage fooi|ideeioimpodantbn
�
protect staff from exposure to diseases such as Hantavirus. However, because hawks, bobcats
� and other predators that inhabit District lands often feed on rodents, control of such pests must
consider the sensitivity of the surrounding areas to the selected control treatments. IPM |
procedures provide a context for addressing health and human safety concerns with the /
protection cf natural resources.
� |F»K8in Managed Landscapes
�
� Management of managed landscapes such as agricultural fields,forests and rangelands focuses
� on requires a landscape-level approach that focuses on maintaining the long-term functioning of
� each type of managed landscape's natural resources for its intended uses(e.g., growing crops in
� agricultural fields, maintaining grassland forage quality for livestock).
The District occasionally acquires lands that support active agricultural production, and these
� lands often have unique pest conditions.Weeds are removed from row crops, vineyards, and
orchards, and plant diseases, insects, and rodents are controlled on farm products and in
agricultural buildings. For these properties. the District develops individual Agricultural
Management Plans to guide agricultural uses, and ensure compatibility of natural resource
protection and management, low-intensity public recreation and ongoing agricultural uses. IPM !
provides management solutions that address agricultural pest control in the context of the i
surrounding natural areas with recreational use.
�
Likewise, the District manages forests for overall forest composition and functioning.Where
undesirable forest vegetation such as invasion of forests by Douglas fir begin to change the
overall functioning of a forest, or where forest composition is altered by disease such as the loss
of oaks due to sudden oak death, the District would first track the change, then develop a
landscape level approach to pest control when such changes exceed a tolerance level.
For rangelands,the slow incremental conversion of grassland to shrubland(invasion by coyote
bush)that is attributed to climate change can reduce the value of grasslands for livestock grazing.
When such conversions exceed tolerance levels,the District would consider pest control -in this /
case active removal of shrubs for managed grazing lands.
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ATTACHMENT 1
Management of Focused Visitor Use Areas: Balancing the Natural Experience �
and Public Safety
Management cf focused visitor use areas such na parking lots and bai|heado emphasizes human
access, health, and comfort.
In focused visitor use areas, problem pest species such as rattlesnakes and stinging insectscan
threaten the enjoyment or health of visitors, staff, and residents, and may require active
management.
[sidebarl An example of problem pest species control would be treating yellow jacket
nests where they occur near ba0/ead4 heavily travelled hiking trails, and similar high
human use areas. IPM seeks to balance the need to maintain a healthy natural
ecosystem with the need to achieve a tolerance level for each species that results in a �
�
reasonable level of safety for hunnmm1peotinteractions. �
� Where pest populations exceed tolerance levels at a specific site, the District will consider options �
for treating the specific pests using IPM. Tolerance levels are low for some problem species that �
� have high potential for harm to visitors, while tolerance levels for other problem pest species �
are higher where there is a low potential for harm to visitors. For example,there is a low tolerance
level for venomous snakes at picnic areas and campgrounds, and relocation will be considered
� when even one rattlesnake io observed frequenting these areas. On the other hand, minor
�
amounts of mosquito bites are expected while recreating outside, and visitor education is often
� considered on appropriate response. Management of focused visitor use omeme also includes
� vegetation management for fire risk vnducUon, and brush control to maintain trail use. Pest control
� options for focused visitor use areas manage human/pest interactions for human safety and
� visitor enjoyment, while adjusting the levels of control for each problem pest species and
situation.
�
� Ah�T��������� ����T MANAGEMENT GOALS, POLICIES,
� .. . ^ .-~~.INTEGRATED~_�� PEST. .,~ ~~ .. ~.~~-..,~-. . , -~.~. ~__', �
� AND IMPLEMENTATION MEASURES �
�
� The following goals, policies, and implementation measures are intended to address pest
� management on District lands, including management ofnatural armoo, highly modified areas,
and focused visitor use areas.
Goals
Goal VPW@- Control pests by consistent implementation of UPK8 principles to protect
and restore the natural environment and provide for human safety and enjoyment
while visiting and working on District lands.
Policy UPyN-1 Develop specific pest management strategies and priorities that
address each mf the four Pest Management Categories.
* Manage invasive species in natural areas and set priorities for their control based on (
the potential risk to sensitive native species and loss of native biodivemity.
|
* Manage pests at highly modified areas such as buildings and recreational facilities to �
support existing uses, while also protecting human health and surrounding natural
namoun:eo.
ATTACHMENT1
v Manage pests in managed landscapes such ao agricultural fields, rangelands, and �
' forests to support existing uses, while also protecting human health and surrounding
natural resources. �
�
* Manage pests and potential human interactions at focused visitor use areas to !
minimize conflict, ensure visitor safety and enjoyment, and protect the surrounding
natural resources.
Pol|cy8PM-2 Take appropriate actions to prevent the introduction of new pest �
species to District preserves, especially new invasive plants in natural �
areas and weeds in agricultural areas.
/sidebar]Infestations of new pest species that are known to cause ecological harm
elsewhere can often be effectively controlled or eradicated soon after detection.
However, if treatment/o delayed, such new pests can spread exponentially,
potentially causing much more ecological harm, human health concerns, and
exponentially increasing management costs/n the future.
° Stay informed on potential new pest species, their threat to District resources, likely
vector pathways, control methods, and monitoring techniques.
Participate in local weed management area programs, ranch and agriculture forums,
� and |PK4 training to stay informed on new pests in the region that could potentially
occur on District lands, and careful and effective methods ofcontrol.
* Use best management practices(BMPs)during maintenance of structures and �
|
facilities bo avoid introducing or spreading pest species on District lands.
�| * Conduct education and outreach to keep visitors, staff, and neighbors informed of the �
� threat nfpests, identifying actions the public can take to prevent and control their �
/
� spread, and informing the public about District pest control treatments.
� PoyicyUPWq-3 NNmmsge pests using the procedures outlined in the following eight
� Implementation Measures.
+ Develop and implement tolerance levels for pests within each of the three Pest
� Management Categories 0n determine when to undertake pest control.
^ Determine the biology and life cycle of the pest species, its disruptive potential and
relevant site conditions prior to implementing a pest control activity. Review pest
control objectives for consistency with other site goals and establish tolerance levels
that must ba exceeded before pest control ioundertaken. |
/
^ Choose site-specific strategies and times cd treatment that provide the best
�
combination of protecting preserve resources, human health, and non-target
organisms and that are efficient and cost effective in controlling the bmrDot pest. Direct
the control method narrowly otthe most vulnerable point in the target organism's life-
cycle to avoid broad impacts.
* Methodically monitor results and modify control methods over time as site conditions
and treatment techniques change and ao needed to obtain on effective level of
control.
� |
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ATTACHMENT1
* Use the least toxic me1 od(o)1nuontndidendOedpeats. Where the use ofpesticides
is necessary, apply according to the label using all safety precautions and take all
| measures needed to protect the environment, the health and safety of visitors,
employees, neighbors, and the surrounding natural areas including water and soil
resources.
* Plan for repeat treatments as indicated by the pest's regenerative capabilities.
* Coordinate and cooperate with adjacent landowners, neighbors, and other �
responsible agencies 0o control pests and limit secondary effects.
� * |f eradication ofapest from a distinct location in not feasible, apply measures to
�
achieve containment, sustained nontnz|, cx slow down a peot'm rate ofspread.
Policy UPM-4 Monitor pest occurrences and results mf control actions and use �
adaptive management to improve results. !
+ Periodically monitor District preserves and facilities bo detect pests ed early stages.
* Monitor pest control activities to assess the effectiveness of different treatment
methods on target and non-target species and use the results to guide future actions
a1 similar sites(Adaptive K4anaQomont).
* Maintain GIS database of the location of pests on District preserves, and use this
� information to plan control actions.
�
* Share mapping information with adjacent landowners and other responsible agencies
bz assist in collaborative control efforts.
* Keep records of all pesticides applied and submit monthly and annual reports to the �
County AgriculturalDepartments. Obtain pest control recommendations and provide �
staff safety training in the storage, mixing and application of pesticides. Continue to
follow all federal, state, and local regulations regarding the use ofpesticides.
� Po1icyUPM~5 Develop and Implement amVPM Guidance Manual to standardize pest
�
management and UP88 procedures on District lands.
� ^ Define pests, prevention, prioritization, tolerance levels and management
� strategies specific to each mf the four Pest Management Categories.
* For each approved pesticide, provide information on its approved use and a risk
aooeooman1
* Describe requirements for licenses, training, notification, reporting and monitoring.
+ Develop a pest database for tracking and reporting pests and pest management.
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ATTACHMENT 1
��A ��������
��"�������^", ^ ^
| Pest Species are insect, animal, or plant species that are incompatible with the District's goal of
protecting and restoring the natural environment and. �
learn about the natural environment. Several categories of pest species are defined below as well �
as their association with the three categories of pest management described above.
Invasive species are animal or plant species that invade and dominate sufficiently large areas,
causing a reduction in biodiversity.They proliferate in the absence of natural control and
� interfere with the natural processes that would otherwise occur in natural areas. Once
established, invasive species can become difficult to manage and can eliminate native species or
otherwise alter the ecosystem. Invasive species are targeted in natural areas.
[sidebar.] Invasive species can alter ecosystem processes by changing biotic ecosystem
characteristics(such as plant community composition, structure, and interactions;trophic
relationships;and genetic integrity) and ob/obc characteristics and processes(such as
| fire regimes, erosion, sedimentation, hydrological regimes, nutrient, and mineral
|
conditions, and light ova&ability).
Structural and agricultural pests include insect, plant, and animal pests that damage occupied
buildings,formal landscapes, or agricultural crops, or pests that are a health threat to humans
working in, living in, or visiting the buildings. Examples of structural pests include termites, ants,
rodents, and stinging insects in buildings,and weeds in formal landscaped areas. Examples of
� agricultural pests include insects,weeds, and burrowing mammals such as moles and voles that
� damage crops. Structural and agricultural pests are targeted in highly modified areas.
Problem pest species include species that commonly occur on District lands, such as stinging
insects, but whose presence can be incompatible when their proximity or behavior conflict with
focused human use of facilities built in the preserves. For example, hornets that locate their
ground nests in trails must be removed if they are stinging hikers and horses using the trail.
Branches and other types of vegetation must be trimmed back from trails, parking lots, picnic
tables, and benches to allow their use byvisitors. Similarly, vegetation must be cut back from the
sides of roads to keep them open for patrol, maintenance, and emergency vehicles. Problem
pest species are targeted in areas with focused visitor use.
Herbivory is a type of predation typically used to describe the consuming of plants by animals.
Herbivory has an impact on the health, structure, and diversity of natural plant communities. For
example, low level herbivory can remove aging roots and leaves, allowing new growth of young
roots and shoots. The new roots and shoots that grow provide better nutrients for absorption and �
reproduction. The feces of herbivores enrich the soil, which increases the chances of successful
plant establishment. Herbivores also prune p|mnba,which allows for more light passage and
makes it easier for seeds to establish near parent plants. Ad high levels, herbivory can damage
plants, changing the composition, and reducing the quality of the natural plant community.
�
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Santa Clara Valley
Audubon Society
July 23, 2013
Board of Directors
Mid Peninsula Open Space District
Re: 7/23/2013 Study Session: Rodenticide inclusion in Integrated Pest Management Policy
I write on behalf of the Santa Clara Valley Audubon Society to urge the Board of Directors of the Mid-
Peninsula Open Space District(MROSD)to exclude the use of rodenticide bait products from any
Integrated Pest Management(IPM)program,and to develop a policy and ordinance similar to the ones
developed by Marine County,the City of San Francisco and other government agencies to eliminate use
of rodenticides on MROSD property.
Throughout California, the use of poison baits used to control rodents has injured and killed numerous
wild animals and pets. This is because predatory and scavenging birds and mammals like owls,hawks,
raccoons,foxes,skunks and coyotes that eat dead or dying rodents that have consumed these baits will
also be poisoned. Because of documented hazards to children,pets and wildlife the U.S. Environmental
Protection Agency is in the process of canceling a list of products that do not comply with safety
requirements(see)vw_w.epa gov/pesticideslmice-andrat�. This welcome effort by the EPA would
remove unsafe products from supermarket shelves and provide better bait boxes to exterminators,but is
not expected to protect pets and wildlife from secondary poisoning.
California Counties and Cities are taking initiative in developing resolutions,policies and ordinances to
protect children pets and wildlife from both direct and secondary poisoning. For example,under Marin
p
County's Integrated Pest Management Ordinance,the only time rodenticides can be used is if all other
methods of IPM have been tried and failed,and the County Health Officer declares a public health
emergency. Since 2009,Marin County has successfully controlled the rodent population without the use
of any rodenticides in their parks and open space or in buildings in urban and rural environments.Please
— risks of rodenticides and the
see lit :llwww. outube.comlwatch.v—ZW f ftR.k88w for information on the
Marine County program.
Please consider setting an example among park and open space districts and authorities in removing
rodent bait products from the IPM"tool box",and in developing and adopting an ordinance similar to the
one developed by Marine County.
Please contact me if I can be of help(650) 868 2114
Sincerely,
Shani Kleinhaus,Ph.D.
Environmental Advocate
22221 McClellan Road,Cupertino,CA 95014 Phone: (408)252-3748 * Fax: (408)252-2850
email: scvas(&scvas.Or1 * www.scvas.org
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