Comments on Montana’s Pesticide Permit

For decades our nation’s waterways have been polluted with hazardous pesticides and their degradates which impact aquatic populations of animals and plants, and decrease surface and drinking water quality.

Results from the U.S. Geological Survey’s National Water‐Quality Assessment Program studies show that pesticides are widespread in streams and ground water sampled within agricultural and urban areas of the nation.

Many of these pesticides accumulate in fish and other organisms, making their way up the food chain, to eventually be consumed by the American public. Recent studies find that government agencies may be underestimating children’s dietary exposure to pesticides and that they are a prime cause of attention deficit hyperactivity disorder, ADHD.  Similarly, pesticides are a leading cause of fish population decline because of chemicals’ toxicity to fish nervous systems.

Stronger regulatory action is needed to ensure that our waters, food and health are adequately protected from all industrial and agricultural pollution.

In Montana, the Dept. of Environmental Quality is supposed to protect communities and waterways from the negative effects of discharging pesticides to water via its MPDES permit program. Unfortunately, as our review of the summer 2016 draft General Pesticide Permit found, Montana’s pesticide permit program is woefully inadequate.  Some of the key problems we found include:

  • Secret pesticide management plans that are not subject to public review and scrutiny
  • Failure to consider, and require limitations, on pesticide pollution to local streams
  • Failure to apply existing water quality standards to streams in application area
  • Failure to consider pesticide spraying impacts on endangered species
  • Failure to require representative monitoring by permittees or understand baseline conditions

As a longstanding agricultural state which consistently allows thousands of acres to be sprayed with pesticides and herbicides, it is truly mind-blowing to discover that the state of Montana has done ZERO leg work to create and use a meaningful, proven pollution control system for pesticides.  Our legal bird-dogging of this permit is especially important considering the scope of Montana’s Pesticide General Permit: the General Permit will apply across the entire state, to more than 90 individual operators, plus at least 30 mosquito districts (millions of acres), 56 weed control and/or conservation districts, at least 50 irrigation districts, plus public lands managed by the USFS or BLM!

Click here to read our technical comment letter to DEQ on its Draft Pesticides General Permit for Montana.

Stay tuned as we await the state DEQ’s consideration of our comments and a final action on the permit!