Protect your pollinators from BLSG

BLSG drives their spray trucks along the entire length of private driveways and sprays pesticides. They have defended their authority to do this uninvited, unannounced, and without permission. Not all driveways are sprayed, and choosing which ones get sprayed appears to be left to the whim of the driver.

Last summer, a BLSG truck sprayed the driveway of Dennis Reisenweaver of Brandon. The next day he noticed that all of the honey bees in his beehive were dead. At a Select Board meeting in Brandon last month, Mr. Reisenweaver told this story to Ben Lawton, the chairman of the BLSG Board of Directors: “I lost a hive of honey bees. I had the State come out and they took samples and they told me that it was because of the spraying. So, I’m wondering why they come up private driveways.”

Dr. Lawton’s response was, “We have both a commercial and a public license so that we can spray private roads under the public license.” He continued to avoid Mr. Reisenweaver’s question by suggesting that Mr. Reisenweaver was at fault for not requesting that his property be posted: “The procedure to opt out from spraying annually is in our report when we put it in the newspaper in April before we start the season.”

Mr. Reisenweaver was still perplexed by this policy: “I don’t understand why they come up private driveways, that’s a concern, and the state did not either. They said they considered that trespassing.” Dr. Lawton never addressed this question but instead pivoted to: “I have studies that have put the pesticides that we use in with bees and it hasn’t killed them. So I don’t know what the situation was, but I do have studies to that effect from EPA.”

So BLSG’s official response to the question of why they spray private driveways without permission is 1) Nobody has the authority to stop us, 2) It’s your job to protect yourself from us, and 3) We’re not very good at science or logic.

The pesticides sprayed along public roads, private lanes, and private driveways in the BLSG District kill hundreds of species of insects other than mosquitoes. If you don’t want this happening on your property, your only recourse is to opt out of roadside spraying.

Even if you opt out of spraying, BLSG will spray right up to your property line. So if you have a small property or if your house or garden is near a property corner, it helps when your neighbors opt out as well.

BLSG seems to be refusing to accept requests to opt out via email, so you might be required to put your letter and a map of your property in an envelope and mail it. You can get a free copy of your property map and see the opt out procedure here: http://mwwvt.org/tax-maps/. Your map will be emailed to you within a day or so, and you should submit your request to BLSG before mid-April.

The response I would expect from a reasonably managed BLSG would be to immediately:

  • End its policy of spraying private driveways without permission.
  • Begin accepting opt-out requests by email.
  • Stop spraying pesticides within 200 feet of properties which are opted out.

Making these changes would not require additional effort or cost for BLSG and instead would save them time and materials. And it would suggest that there is at least a hint of willingness to work with the community they serve.

The BLSG Adulticiding Program: Fear mongering, mission creep, and questionable use of taxpayer dollars

The following is a letter by Kip Andres of Salisbury. It was submitted to the Addison Independent as a letter to the editor on Sunday March 3.

I am writing this letter in response to Angelo Lynn’s editorial addressing the lawsuit pending against the Brandon Salisbury Leicester Goshen (BLSG) Insect Control District.  Insect control efforts as carried out by the BLSG are complicated, and I can’t adequately comment on the BLSG’s history, State permitting and oversight, and action thresholds in the detail they deserve here.  For anyone interested in learning more about these topics, I urge them to consult http://mwwvt.org/, which contrary to Lynn’s assertion, is a useful source of information.  They should also attend the BLSG’s meetings.  While the BLSG seeks to avoid public scrutiny, the group is funded by taxpayer dollars and is, at least in theory, operating at the behest of its member towns.  With this in mind, it is the public’s right to attend monthly board meetings and to have knowledge of its activities.  The fact that Salisbury has just appointed two extremely competent and qualified representatives to the board means that interested citizens will be more welcome at meetings than they have been in the past.

As a former member of the BLSG board, I feel obligated to respond to Mr. Lynn’s recent discussion of the organization.  While I have always found Mr. Lynn’s editorials outstanding, I was extremely disappointed by his recent commentary.  Until now, Lynn’s discussions have been fair, civil, thought provoking, and above all, well researched.  Not so with his latest offering.  In fact, his editorial on the BLSG is so problematic that one has to wonder if it was even written by Lynn!  Unfortunately, his editorial is incomplete – at best – and assumes an uncharacteristically simplistic and slanted approach to a troubling situation that has been brewing for years.  It also portrays Chris Fastie, a justifiably concerned and respected member of the local scientific community in an insulting and unfairly dismissive manner.

To provide some context, I served as one of Salisbury’s representatives to the BLSG for a two year period from 2013 to 2015.  Having grown up in Salisbury, I remember only too well summers made miserable by clouds of mosquitos.  I am neither a radical environmentalist nor someone who sees himself as an activist.  Before my association with the BLSG I had no objection to the group’s adulticiding activities (the practice of targeting already hatched mosquitoes with airborne pesticides).  The group’s multi-prong approach – parallel adulticide and larvicide programs – is complex, and I initially kept my head down, taking the minutes as the board’s secretary as I became familiar with the issues.

The more I learned, however, the more uncomfortable I became with the BLSG’s practices.  My membership on the board came at a politically fraught time, when, as I would soon discover, several board members and the coordinator of the larviciding program – who were important voices of reason – were being displaced by more traditional hardliners.  The District was also experiencing a variety of public relations challenges.  Some, including a fish die off in Fern Lake, were falsely attributed to BLSG activities by local adulticide opponents.  Others, however, including confrontations between BLSG personnel and members of the public, and repeated instances of unauthorized spraying of private property, were legitimate examples of self-inflicted damage.  The extended monthly meetings were exhausting affairs: the remaining board members ranted and raved, stubbornly defended their practices, and introduced a level of emotion into the business of insect control that I could never have imagined.

Most troubling were the board’s attitudes towards their constituents and the State of Vermont.  The BLSG exists to serve its member towns and operates under the State of Vermont’s oversight.  In theory, at least, the District also has a cooperative relationship with Vermont’s Department of Agriculture.  Most meetings, however, devolved into angry tirades over State regulation.  Board members were also consistently disdainful of members of the public who had the temerity to question BLSG practices.  The organization’s culture – which by all accounts persists today – was one of self-righteous indignation and stubborn resistance to change.  Long-serving board members railed against action thresholds, paperwork requirements, and bent over backwards to practice information control.  In an effort to keep controversial details under wraps, substantial portions of most meetings were conducted in executive session to mask the District’s problems.  I found this end run around Vermont’s Open Meeting Law particularly disturbing as the one tasked with making information about the organization’s activities publicly accessible.

Unfortunately, Mr. Lynn has clearly had a long conversation with Benjamin Lawton, the chair of the BLSG board, and has uncritically allied himself with the organization. Lynn then promptly turned around and perpetuated a number of BLSG talking points that are problematic or simply untrue.

(1) Contrary to District claims, insect control in the member towns does not need to be an all or nothing approach.  The BLSG emphasizes adulticiding for the simple facts that it is the traditional approach and a highly visible course of action that placates property owners.  (I sat through meetings where longtime board members unabashedly discussed how the adulticide program has no long term impacts on insect populations and primarily serves to pacify property owners, and those with homes on Lake Dunmore in particular.)  Larviciding, as practiced by the BLSG, involves treating seasonally flooded areas with granules of Bacillus thuringiensis israelensis (BTI), a bacteria that is ingested by, and kills, mosquito larvae.  In contrast to adulticiding – which employs synthetic pesticides that may ultimately be found harmful and be banned (as was DDT in 1972) – larviciding is the safest, lowest impact, and most pre-emptive approach employed.  Since larviciding kills mosquitoes before they hatch, it is the preferred approach, provided it is timed correctly.  To therefore imply that the Town of Salisbury’s questioning of the BLSG’s adulticiding program will mean that local residents will be besieged by mosquitoes is completely untrue.  The BLSG likes its adulticide, but it is a fleeting and minimally effective Band-Aid approach.  To be clear, one can be a proponent of insect control, as I am, and at the same time oppose the use of adulticides. 

(2) While Lynn parrots Lawton’s standard line about the perils of mosquito borne diseases, the BLSG was not founded to protect public health and safety.  Since its establishment in 1979, the BLSG’s express mission has instead been to address comfort related concerns involving nuisance mosquitoes.   Yes, discovery of low levels of West Nile Virus and Eastern Equine Encephalitis (EEE) in Vermont’s mosquito pools prompted a whole new conversation.  These potential threats came to the forefront in 2012 following the tragic deaths of two Rutland County residents.  As Lynn relates, Lawton’s wife had – at an earlier time – become ill with a possible mosquito borne disease, and this newly perceived public health threat played directly into Lawton’s experience and concerns.  I am in no way making light of the Lawton’s tragedy, but based upon his personal history, the emergence of broader concerns over mosquitoes as disease vectors in 2012 was the point at which the BLSG’s “mission creep” really begun.  In light of the general public’s justifiable concern, this threat has been emphasized by the BLSG, and the organization, in its mind, has become a defender of public health and safety.  However, it is critical for members of the public to understand that the BLSG, as a quasi-governmental organization, is not only operating in a self-appointed capacity in this regard, but is in fact overstepping its mandate.  In reality, the responsibility for surveillance against insect borne threats to human health lies exclusively with the State of Vermont.  Once again, Mr. Lynn fails to make this important distinction.

(3) Clearly, discovery of West Nile Virus and EEE in Vermont is unwelcome news.  However, it is inappropriate that the BLSG and Lynn are using this to play upon people’s fears to advocate for adulticiding activities.  The BLSG has an unfortunate history of such practices.  To this extent, a member of the BLSG board of directors published a piece in the Rutland Herald (Friday, January 4, 2019) chastising the paper for devoting inadequate attention to the threats of mosquito borne diseases.  In this letter, this board member sought to drum up support for the BLSG’s activities by stating that residents should be fearful due to the presence of the Zika virus in Vermont, an assertion that is patently false.  This statement prompted Alyson Eastman, Deputy Director of the Vermont Agency of Agriculture to issue a rapid response on January 10, 2019 indicating that Zika does not currently exist and has in fact never been identified in the State.  In so doing, the Agency of Agriculture issued a strong rebuke, stating that the board member’s actions were “regrettable and irresponsible” and scolding this individual for spreading “misinformation”.  Remarkably, the BLSG then turned around and made reference to Zika in its annual statement which was included in the Salisbury Town Report.  This is the level of incompetence and outright manipulation of information that has plagued the BLSG, and Lynn should be ashamed for carelessly serving as the organization’s mouthpiece.         

(4) Finally, Lynn once again led readers astray with his portrayal of the Insect Control District as the innocent victim of a frivolous lawsuit filed against it by a hostile environmental fringe group.  The fact of the matter is that the BLSG, which has a history of sloppy, arrogant, and incompetent practices, submitted an incomplete pesticide application to the State of Vermont and the State erroneously approved it.  The plaintiffs in the case became aware of this fact and filed suit against the BLSG and the State of Vermont to have this situation rectified.  While the BLSG and Lynn dismiss this situation as a mere technicality that has been latched onto by a hostile party, it is more complicated than this.  In fact, the part of the application in question reportedly requires the BLSG to verify that the pesticides they use do not have harmful effects/will not negatively impact other species in the environment.  Reportedly, the BLSG submitted an application where this section was left entirely blank, presumably because this is information they do not have access to.  All of this leads to an obvious conclusion: if one is seeking to broadly apply chemicals throughout the community which he or she cannot verify are safe, he or she probably shouldn’t be using them in the first place!

In conclusion, the BLSG is an under-funded, largely volunteer organization run by generally well-meaning people who are dealing with a complex set of problems.  However, this does not explain away the fact that the BLSG is a flawed entity that has been operating in dubious fashion for many years.  While there is every indication that the BLSG’s larviciding activities are safe and effective, its adulticiding practices are archaic and questionable.  To this point, the District has survived because it has experienced inadequate oversight by the State and has gone out of its way to avoid public scrutiny (arguably in violation of Vermont’s Open Meeting Laws).   Clearly, the world is a more complex place than it was in the 1970s and it is unrealistic for the BLSG to expect to operate today as it did then.  At present, the board is composed of individuals who are not only in over their heads, but who have allowed their personal emotions to cloud the organization’s mission.  It is time for change, and the lawsuit that has been filed against the BLSG will hopefully be an agent of this change.  Most disappointingly, Mr. Lynn has done the voters of Salisbury a disservice by publishing his editorial just before Election Day and leaving little to no time for correction of his one-sided and error-ridden journalism.  From this perspective, Mr. Lynn’s actions are an attack on the Salisbury Select Board’s responsible effort to provide Salisbury residents the chance to opt out of the BLSG’s self-incurred legal expenses, and amount to a disappointing misuse of the power of persuasion inherent in his editorial platform.  

And Mr. Lynn, please issue Mr. Fastie a formal apology.  You certainly owe him one.

How bad was it back then?

There has been a good recent discussion on Front Porch Forum about mosquito control in the Brandon Leicester Salisbury Goshen area. The discussion reveals a common sentiment in the community that mosquitoes in the BLSG District were much worse before BLSG mosquito control began. This idea is then associated with another idea, that BLSG’s activities are responsible for the improvement. Here are a few things to keep in mind when evaluating these claims.

Are there fewer mosquitoes now?

There isn’t any scientific evidence that mosquitoes are less numerous in the District now than they were in any previous decade because nobody has collected data that could answer that question. It is certainly possible that mosquitoes were worse in the past than they are now. Everyone has stories about particular times when there were a lot of mosquitoes, and particular months were very bad (ask Governor Kunin about June 1989).

We hear fewer stories about summers without so many mosquitoes but that doesn’t necessarily mean there were always lots of mosquitoes. It is likely that the absence of mosquitoes in some years does not create the vivid memories that buggy years do. It would be good to find someone with journal entries or some other record that spanned a couple of decades and provided some evidence for changes in mosquito numbers. Until then, there are a few other pieces of information that might shed some light on the veracity of the anecdotes.

BLSG’s history

The Lake Dunmore Fern Lake Association presents the following history of mosquito control around the lakes:

“Mosquito control efforts were started in the 1960s by the Lake Association. Debbie Britten, Executive Secretary/Treasure began the operation.  Heydon Hooker drove the spray truck over every road at both lakes.  This process continued into the 1970’s when Virginia Wolf took over as Executive Secretary/Treasure….In those days, the chemical used was DDT.

According to the BLSG website, BLSG got its start in 1979, 10 years before Governor Kunin was carried away by mosquitoes.

So there has been roadside spraying of pesticides around Lake Dunmore since the 1960s, and some of our collective memories of horrible mosquito years are from these times when roads were already being sprayed. If we are trying to make an argument that BLSG activity has reduced mosquito density we will have to pin down our memories and determine whether they date to years before roadside spraying was happening.

2004 and 2005

There were a lot of mosquitoes in 2004 and 2005. I remember hearing that the only way to swim in Lake Dunmore was to run out of your house and keep running until you were under water. BLSG was in full operation then and using more or less the same chemicals and equipment it is using now. That fact is hard to reconcile with the idea that BLSG activities reliably eliminate the nuisance of mosquitoes.

The Mountain Spring Hotel on Lake Dunmore (near the current Waterhouses). This photo was probably taken about 10 years after it was built in 1892. The large porches are not screened.

Lake Dunmore’s history

Before anyone was spraying poisons around Lake Dunmore, people had enjoyed summer recreation there for more than 100 years. Here is a list of the major hotels on Lake Dunmore and approximately when they operated:

  • Lake Dunmore House   1854-1877
  • Second Lake Dunmore House   1878-1906
  • Mountain Spring Hotel (Lake Dunmore Hotel)   1892-1957
  • Cascade House   1895-1919
  • Moosalamoo Park House   1902-1960s

These hotels were successful for decades because people came from all over the east coast to fish, hike, boat, swim, and sit on the huge open porches. There were no chemical insecticides during most of this period. This history is not compatible with the idea that summer life in Salisbury and Leicester is tolerable only when BLSG is spraying pesticides every week.

View of Mount Moosalamoo and Lake Dunmore from the Mountain Spring Hotel grounds. This photo was probably taken around the turn of the 20th century. The gazebo is not screened.

In the twentieth century, tourism shifted away from big hotels to camping and summer cottages. Keewaydin Camp has been in operation since 1910, and by 1969 there were summer campers at Branbury State Park, Waterhouses, and Kampersville. More than 400 private cottages and houses were built on Lake Dunmore in the twentieth century because it is a spectacular place to swim, boat, fish, hike and live. This history includes no indication that prior to BLSG, mosquitoes made Lake Dunmore an intolerable place to live or enjoy outdoor activity. It indicates just the opposite, that mosquitoes probably ruined the summer fun at Lake Dunmore very rarely.

What will happen in Pittsford?

In 2018 Pittsford joined the BLSG District and spray routes there received roadside ULV adulticide treatment for the first time. According to the local collective experience, mosquito populations in Pittsford should soon plummet from horrendous to acceptable. Instead, there will probably be so little difference between before and after that someone would have to carefully collect data to detect it. It’s too late now to get those before data, but it would nonetheless be good to hear from people in Pittsford about any changes they experience.

What should we conclude?

There is every indication that people enjoyed outdoor activity and that tourism thrived in the BLSG District for a century before any mosquito control was done. There is no evidence that mosquito density changes very much after BLSG sprays the lake routes once or twice a month as they did in 2018. So there is very weak support for the argument that BLSG spraying is the only thing that prevents mosquitoes from ruining life in the District.

Which towns does BLSG treat properly?

In BLSG’s new annual report, they indicate that there are 7,000 acres of mosquito breeding ground in the BLSG District which can be treated by helicopter. Most of this is in the floodplain of Otter Creek or Leicester River or in nearby lowland areas. The goal is to use a helicopter to spread granules of bacterial larvicide over this area.

BLSG reports that in 2018 only 3,000 acres received aerial treatment of larvicide. BLSG explains that the reason more than half of the mosquito breeding ground got no aerial treatment in 2018 is that the state did not allocate enough money. This seems like a very serious failure of the system.

The state requires that mosquito control be done using integrated pest management (IPM), a system in which the least dangerous, non-toxic prevention and control methods are used before chemical pesticides are applied. If most of the BLSG District never gets the safe prevention and control measures (e.g., aerial larvicide), whatever happens next is not integrated pest management. If the Vermont Agency of Natural Resources is truly committed to IPM, it should not support an insect control district which it has no intention of funding well enough to allow IPM to happen.

Fixing this broken system can involve different approaches (more money, less pesticides, shifting money from pesticides to larvicides) but it might be important for everyone to first agree that the system is broken.

In the meantime, I have a question about the 3,000 acres which were treated with larvicides by helicopter in 2018: Which 3,000 acres got treated? In early May of 2018, BLSG announced on their website the upcoming helicopter treatment:

On 5-5-18 the BLSG Insect Control District will be applying Bacillus thuringiensis israelensis (BTI) to surface waters where mosquito larvae are present.  Aerial applications will be made in the towns of Pittsford, Brandon and Leicester.

Salisbury was not mentioned. This was the only announcement of aerial application of larvicides in 2018, and I think there was only one helicopter flight in 2018. Does that mean that no place in Salisbury ever received aerial treatment with larvicides? Is that why people were asking me last summer why the mosquitoes were so bad along Leland Road and Shard Villa Road (which are right above Salisbury’s floodplain fields along Otter Creek)?

Swamp Road in Salisbury with flooded agricultural fields along Otter Creek. The far end of Swamp Road (left center) is where the covered bridge over Otter Creek used to be. These fields are prime breeding ground for mosquitoes but might have received no aerial treatment in 2018. This panorama is stitched together from 16 photos taken by a remotely operated camera hanging from a kite line. This was the first time I tried kite aerial photography. May 8, 2011.

I understand that representatives from BLSG will be at the town meetings in the towns of the BLSG District. These might be good questions to ask those representatives. A more general question for everyone to consider is: If BLSG can ask the towns in the District for $37,000 more than they contributed last year, most of it to pay lawyers, and get that money with few questions asked, why don’t they just ask for enough to fund another helicopter flight and actually do the IPM they say they are doing and that the state requires them to do?

And in Salisbury, people at town meeting might want to ask: Did Salisbury get what it paid for last year?

BLSG annual report says it all

It’s nice to see a kite aerial photograph on the cover of the new town report.

Vermont’s town clerks will soon be mailing us our town reports, and Salisbury has already posted a pdf of the new 2018 Salisbury Town Report at its website. It includes an annual report from the Brandon Leicester Salisbury Goshen Pittsford Insect Control District (BLSG) which will appear in town reports throughout the District. The BLSG report includes some good information and some that is misleading.

BLSG does a good job describing the ongoing Toxics Action Center (TAC) appeal of the state’s decision to re-authorize BLSG to spray chemical pesticides. However, BLSG mischaracterizes a few aspects of the lawsuit.

  1. They report that “TAC has raised only procedural questions about whether the fifty-page plan was drafted in sufficient detail.” There is nothing trivially procedural about BLSG’s failure to evaluate how their activities might endanger water quality and wildlife. There are obvious justifications for the state to require that anyone spraying toxic chemicals on public and private property demonstrate that they have considered and understood the environmental dangers inherent in the activity. BLSG is not entitled to ignore or belittle this legal requirement.
  2. BLSG reports that “The District’s board suspects that TAC’S underlying motivations in filing the appeal is an attempt to take advantage of the District’s limited resources.” The District’s board is wrong. TAC’s motivation is to ensure that BLSG follows the law so people and the environment are not endangered. Also, when select boards in most of the District towns agree to hand over to BLSG whatever taxpayer money BLSG asks for to pay its lawyers, the District does not have “limited resources.”
  3. BLSG reports that TAC has “a long bucket list of items they want incorporated into the plan that would severely limit our ability to provide effective mosquito control.” Discussions among attorneys during settlement negotiations are confidential and should not be discussed publicly. If BLSG wants to abandon this confidentiality protection, they should do so officially.

As they do in all of their public statements, BLSG made sure to include misleading information in their annual report about insect-borne diseases. I and others have repeated many times that Zika is not transmitted by mosquitoes anywhere north of Texas and Florida, yet Zika is mentioned in BLSG’s report as if we should be concerned about it in Vermont. This continued misinformation campaign is not harmless, and it has recently earned BLSG a public reprimand from Alyson Eastman, the Deputy Secretary of the Vermont Agency of Agriculture, Food & Markets.

Last month, Stephen Belcher, a member of the BLSG board of directors, wrote a letter to the editor to the Rutland Herald in which he included misinformation about Zika (that it was found in mosquitoes in Vermont). Deputy Secretary Eastman responded in the Herald stating that “The Zika virus has never been found in any mosquitoes in the state of Vermont.” She went on to explain that the mosquito species that transmit Zika don’t even live in Vermont: “Our targeted and more general surveillance has never turned up the presence of primary Zika vectors in Vermont.”

Eastman’s strongest rebuke is one that should be a wake-up call to residents in the BLSG District: “It is regrettable and irresponsible that this misinformation made its way into the public forum, particularly given that the source of the misinformation was someone who should understand the issues and concerns of their community.”

We should all want the organization with permission to spray toxic pesticides on our properties to be well informed, rational, and responsive to community concerns. It is obvious that BLSG is not there yet, and vowing in their annual report that “the BLSG Insect Control District has no intention of backing down” will not get them any closer.

Does BLSG threaten endangered species?

Nine species of bat live in Vermont, and five of them are so uncommon that Vermont has listed them as threatened or endangered species. The Vermont populations of these bats have decreased because of white-nose syndrome, a disease that started killing bats around 2006. All the listed bat species spend the winter clustered in caves or mines where white-nose syndrome can infect new bats.

Scott Darling of Vermont Fish & Wildlife examines a federally endangered Indiana bat captured during a workshop at the Salisbury Community School. August 8, 2008

Two of the state-listed bat species are also rare nationwide and are listed as federally threatened or endangered species. The northern long-eared bat was first listed as federally threatened in 2015 because its populations had declined due to white-nose syndrome. The Indiana bat was listed as a federally endangered species in 1967 long before white-nose syndrome was identified.

All five of these state and federally listed bat species live in the insect control district serving Brandon, Leicester, Salisbury, Goshen, and Pittsford (BLSG). BLSG controls mosquitoes by killing larvae in standing water and spraying chemical pesticides along roads to kill adult mosquitoes.

The federally endangered Indiana bat has a large maternity colony at the northwestern corner of Salisbury and in neighboring Middlebury. In the summer, females raise their young and spend the daylight hours on large trees. At night, Indiana bats fly throughout Salisbury and probably other BLSG District towns to feed on insects. Indiana bats are currently being studied in the BLSG District by Vermont Fish & Wildlife Department biologists.

This is one of two federally endangered Indiana bats we captured that evening at the Salisbury Community School. A new pair of sterile gloves is used for each bat to prevent spreading diseases among bats. August 8, 2008

While navigating the landscape at night, Indiana bats often fly along the edges of forests instead of flying through forests or across fields (more here). This behavior can result in Indiana bats flying along roads that follow the edge of forests. Road corridors through forests are also followed by bats.

One pesticide used by BLSG is malathion, a broad spectrum insecticide which is highly toxic to most types of insects and many vertebrate animals. The US Environmental Protection Agency (EPA) found that malathion is “likely to adversely affect” the Indiana bat and most of the other federally threatened and endangered animal species. The EPA is currently being sued for failure to regulate malathion to prevent harm to threatened and endangered species.

In addition to a mist net, this harp trap was in place to catch bats. The vertical monofilament lines stop the flying bats which slide unharmed into the trough below. August 8, 2008

One of the primary control practices of the BLSG Insect Control District is to spray a cloud of malathion along roads after dark. This toxic cloud floats over the roads at the same time bats are flying. It is therefore likely that due to BLSG’s practices the federally endangered Indiana bat will be directly exposed to malathion or will eat insects contaminated with malathion. This is exactly the type of situation which BLSG was required to report in its application to be authorized to spray malathion, but BLSG left that part of its application blank. This blatant omission was costly to local taxpayers; because of this gap in the permit application, a lawsuit was filed by Toxics Action Center in June 2018. Now BLSG is asking all the towns in the BLSG District to contribute more than $30,000 to cover its legal expenses for the ongoing suit.

The third bat caught was this northern long-eared bat, now a federally threatened species. Later, little brown bats and big brown bats were also captured. August 8, 2008

The maximum penalty for harming or killing a federally endangered species is currently $49,467. That does not include legal fees if you contest the fine in federal court. BLSG does not have the resources to cover such expenses, but fortunately for them, local taxpayers do. This time around, select boards in most of the towns in the BLSG District have agreed to add to their budgets exactly what BLSG has requested to pay its attorneys. BLSG’s continued use of malathion might be putting the taxpayers in the District towns at risk of new legal expenses which dwarf the current BLSG legal bill just handed to the towns.

It is fitting that one of the towns, Salisbury, will let the residents decide whether BLSG should get additional money to pay its current lawyers. The proposed general budget for Salisbury will cover the town’s share of BLSG’s operating expenses, but a separate article on the Australian ballot will determine whether BLSG gets an extra $5,500 from Salisbury for its lawyers. The Salisbury Town Meeting vote on Tuesday March 5 includes Article 11, which reads:

‘Shall the voters appropriate $5,500.00 to the Brandon Leicester Salisbury Goshen Pittsford Insect Control District to fund their additional budget request to meet anticipated legal costs, in addition to the $20,000.00 included in the general fund budget to fund their operational budget?

A vote against this article will not affect the mosquito control activities in Salisbury but will send a message that Salisbury should not be held responsible for legal expenses caused by BLSG’s disregard for the environmental impacts of its practices.

Cause and effect

There has been a lively recent discussion about mosquito control on the Front Porch Forum for Salisbury, Leicester, Ripton, and Goshen. A common observation made by local residents is that mosquitoes were once a terrible problem in the BLSG district, but since the BLSG-administered roadside spraying began years ago, the mosquitoes are not nearly as bad. The implication is that roadside spraying of chemical pesticides has been responsible for a long-term easing of the mosquito problem.

Evidence from this spring does not support that argument. The last time BLSG did roadside spraying anywhere in the district was June 8 which was 11 days ago when five routes were sprayed.  Nineteen days ago, another five routes were sprayed, and 21 days ago seven different routes were sprayed.  So as of today, all of the routes in the district have gone for at least 11 to 21 days without being sprayed.

The spray mist stops killing mosquitoes a few hours after the truck drives by. There is little or no long-term effect of this type of spraying because mosquitoes that weren’t flying or mosquitoes a couple hundred feet from the road are not affected. About 90% of the district is more than a couple hundred feet from a spray route, so most mosquitoes never encounter the pesticide. And it does little to stop new eggs from being laid or new larvae from hatching.

If it were the roadside spraying that keeps the mosquito population down and the district has gone 11 to 21 days without spraying, the mosquitoes should be as thick as they were back in the bad old days. But they are not. The mosquitoes are like they are most years in June–a minor nuisance at dusk and dawn just like they typically are everywhere else in Vermont this time of year.

If there is a long-term improvement in the mosquito situation it should not be attributed to roadside spraying of chemical pesticides. The cause might be natural variation in mosquito populations, or it might be the state-funded program of aerial larvicide application. That program prevents mosquito larvae from hatching into adults over thousands of acres of breeding areas and can have a substantial and long-term effect on the number of mosquitoes that residents experience. Our neighboring towns in the Lemon Fair Insect Control District use only larvicides to control mosquitoes.

The BLSG administration recently learned that they probably will not have enough money to apply the desired amount of larvicides during the next year. We should all be working to ensure that the Vermont Agency of Agriculture supplies adequate funding for this program. Unlike the chemicals sprayed along roads, the bacterial larvicides applied have trivial potential for health or environmental consequences.

The program of roadside spraying of chemical pesticides to kill adult mosquitoes is funded directly by the towns in the district. The last few weeks provide good evidence that this roadside spraying is not responsible for any long term or sustained reduction in the mosquito population. Select Board members in the towns of the BLSG district should think carefully about the tens of thousands of tax dollars being spent every year to repeatedly spray toxic chemical pesticides in residents’ front yards.  What evidence do you have that these dangerous chemicals aren’t doing more harm than good?

Comment on the Lemon Fair Insect Control District NOI

The two insect control districts in Vermont have submitted requests to continue their operations for the next five years. This request is referred to as a Notice of Intent (NOI) to apply pesticides according to Vermont’s Pesticide General Permit (PGP). The two districts are the Brandon-Leicester-Salisbury-Goshen-Pittsford Insect Control District (BLSG) and the Lemon Fair Insect Control District (LFICD) which includes Bridport, Cornwall, and Weybridge. The Vermont Department of Environmental Conservation (DEC) will make a decision about both NOIs very soon.

The Lemon Fair NOI was submitted recently and the public comment period is open until May 14. The LFICD controls mosquito larvae using the same bacterial larvicides as the BLSG. Unlike the BLSG, the LFICD does not also use methoprene, an insect growth regulator, to kill larvae. The LFICD does not do any roadside spraying of chemical pesticides (adulticides) to kill adult mosquitoes, while the BLSG has an extensive program of roadside spraying of permethrin and malathion to kill adult mosquitos.

We submitted a comment to the DEC and included six points which are summarized below. We are impressed with the LFICD’s plan to control mosquitoes without chemical pesticides. The LFICD confronts essentially the same mosquito problem as the BLSG, but unlike BLSG, LFICD recognizes that the environmental and health risks associated with pesticides like methoprene,  permethrin, and malathion might be more serious than the nuisance of some additional biting mosquitoes.

An outstanding question is: Can DEC approve two radically different plans to address the same mosquito problem?

1. The LFICD’s NOI correctly identifies its objective as controlling nuisance mosquitoes—not vector mosquitoes.

While recognizing that mosquitoes are potential vectors of arboviruses, the LFICD NOI does not attempt to justify its work with reference to serious, but locally rare diseases. In contrast, the BLSG’s NOI—currently pending review by DEC—frequently mentions mosquito borne illnesses, including some diseases that do not occur in Vermont, as their primary rationale for pesticide application.

According to Vermont Mosquito Control statutes, the jurisdiction to control vector mosquitoes lies with the Department of Health—not the BLSG or LFICD[1]. The Agency of Agriculture and Food Markets classifies the BLSG and LFICD as “nuisance” mosquito control districts.[2]

2. The District’s NOI is consistent with the intent of the Pesticide General Permit.

The LFICD’s philosophy and approach toward nuisance mosquito control is consistent with Vermont’s 2017 PGP and Integrated Pest Management (IPM). The PGP specifies that Operators should minimize the discharge of pesticides to waters of the State.[3] To accomplish this Operators are required to use Pest Management Measures, along with developing Action Thresholds, and a Pesticide Discharge Management Plan (PDMP), which deploys a Pest Management Options Evaluation—clearly specifying that pesticides are only to be used “if all other methods are unreasonable and have been exhausted.”[4]  In this case, the LFICD’s approach and practices demonstrate their efforts to minimize discharges of pesticides to surrounding waters. Specifically, the LFICD does not use chemical pesticides—unlike the neighboring BLSG. Rather, the LFICD uses only non-harmful bacterial larvicides.

3. The District’s Pesticide Discharge Management Plan is complete and well-structured.

The LFICD’s Pesticide Discharge Management Plan (PDMP), provided within their NOI, is well-structured, complete, and thorough. In particular, the PDMP accurately identifies a description of the Pest Management Area; the PDMP Team; Pest Problem Description—citing to nuisance mosquitoes, not vector mosquitoes; robust and detailed Action Thresholds; a Pest Management Options Evaluation; along with response procedures. Moreover, the provided Addendum regarding the District’s Action Thresholds in their PDMP fills in any gray areas that might arise upon reviewing the PDMP. But again, following a common theme throughout this comment, the LFICD’s PDMP stands in stark contrast to the BLSG’s PDMP that is currently under review.

4. The District’s Action Thresholds are robust and supported by sound data.

The synopsis provided in their Action Threshold addendum within the NOI demonstrates thoughtful consideration, context, and accuracy in developing a sound Action Threshold for biological larvicide application. Moreover, LFICD specifies that there must be over 10 dips representing a 200 acre area in order for the Action Threshold for larvicide application to be met. LFICD provided a thoughtful and complete explanation of the process and reasoning behind their action thresholds. In contrast, the BSLG’s NOI simply cited “10 per white dip cup” and “15 per trap/net sweep” with no context or justification. Not only does the LFICD include a higher Action Threshold (20 larvae per dip) for larvicide application than the BLSG (10 larvae per dip)—it’s thorough with the inclusion and requirement of over 10 dips representing a 200-acre area.

5. For the control of mosquito larvae, the District’s NOI proposes to apply bacterial larvicides, not the more widely toxic methoprene, an insect growth regulator.

The LFICD NOI specifies that they do not intend to use methoprene, an insect growth regulator, during their larvicide applications. This too, is consistent with the intent of IPM and the PGP of using the least harmful method for mosquito control. Again, this is in contrast to BLSG’s proposal in their recently submitted Notice of Intent, which outlines their intent to use methoprene without specifying how the dose will be determined—therefore leaving zero assurance that many aquatic invertebrates and vertebrates will not be harmed. Vernal pools—a critical habitat for vulnerable species (e.g., fairy shrimp, fingernail clams, amphibians)—are specifically targeted for application of methoprene in the BLSG NOI. We support the LFICD’s conservative approach to larvicide control, which poses minimal threat to wildlife.

6. The District proposes controlling nuisance mosquitoes without using harmful adulticide chemicals like malathion and permethrin.

Not only does this comply with the intent and philosophy of IPM, but it minimizes the discharge of pesticides to waters of the State of Vermont—a foundational aspect of the PGP. This approach lies in stark contrast with that of the BLSG. Specifically, mosquitoes in the LFICD region arise from same type of low-lying swamps and surrounding agricultural fields as in the BLSG. In fact, the town with the largest area of forested swamp (Cornwall Swamp) is located in the LFICD. Yet, the BLSG argues that roadside spraying of adulticides is a necessary part of their control method. We are not aware of any scientific evidence that mosquito density differs markedly between the two districts. Therefore, State’s approval of two radically different control strategies is both inconsistent and arbitrary. We applaud the past success of the LFICD in reducing mosquito populations without resorting to chemical pesticides, which have been proven to have deleterious environmental and health effects.

[1] See 6 V.S.A. §1083(6) (providing authority of the Secretary of Agriculture to issue permits “when the commissioner of health has determined that available information suggests that an imminent risk to public health exists as a result of a potential [disease] outbreak …)
[2] Mosquito Control Districts in Vermont,
 http://agriculture.vermont.gov/plant_pest/mosquitoes_ticks/mosquitoes/control_Districts
[3] 2017 Vermont Pesticide General Permit, Section 3.1, Operator Responsibilities.
[4] 2017 Vermont Pesticide General Permit, Section 6.1.3, Pest Management Options Evaluation.

Where does BLSG spray to kill adult mosquitoes?

The BLSG Insect Control District sprays many miles of roads with a fog of pesticides to kill adult mosquitoes. You can learn if your property is on the mapped spraying routes at the BLSG website.

The road routes followed to spray pesticides to kill adult mosquitoes in Brandon. From the BLSG website.

Property owners in the insect control district can request that spraying not happen along their property. You must include a tax map when you submit your request that your property be a no-spray zone. For more information and to get a copy of the tax map of your property in Brandon, Leicester, Salisbury, Goshen, or Pittsford, visit our Google form. We will email you a free copy of your tax map.

Become a no-spray zone

The BLSG Insect Control District allows property owners along spray routes to request that no spraying be done along their property. To “opt out” you must mail a letter with your name and address and a copy of your property’s tax map. Letters must be sent by early April each year. If you would like a copy of your property’s tax map in Brandon, Leicester, Salisbury, Goshen, or Pittsford, submit your information at this Google form. MW&W will send you an email with an image of your parcel. Instructions for submitting your request are on the Google form.

This type of parcel map must accompany your request to opt out of spraying for adult mosquitoes. Click here to get yours.

 

Promoting a safe and healthy Moosalamoo region

Moosalamoo Woods & Waters is a local citizens group promoting safe and healthy environments in the Moosalamoo region of Addison and Rutland counties, Vermont.

We are residents of Brandon, Leicester, Salisbury, Goshen, and Pittsford which are in the BLSG Insect Control District. Sometimes mosquitoes are a serious nuisance in parts of these towns, so the state and member towns fund a quasi-municipal group to monitor and reduce mosquito larvae and to control adult mosquitoes along roads.

Our interests include answering questions about the biology of mosquitoes, the practicality of pesticide spraying, and alternate methods of mosquito control.