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HomeMy WebLinkAboutReceive and file the second three-month status report on Org Dept. ID PW 17-069 Page 1 of 3 Meeting Date:fiploow-b ��-f'1E�.11 7--0 _ CITY OF HUNTINGTON BEACH REQUEST FOR. CITY COUNCIL ACTION MEETING DATE: 12/18/2017 SUBMITTED TO: Honorable Mayor and City Council Members SUBMITTED BY: Fred A. Wilson, City Manager PREPARED BY: Travis K. Hopkins, PE, Director of Public Works SUBJECT: Receive and file the second three-month status report on Organic Chemical Pilot Study at Central Park West Statement of Issue: This is the three-month status report on the Organic Chemical Pilot Study at Central Park West which was initiated at the May 1, 2017, City Council meeting. Actions and findings within this three- month period (August-November) and Council follow-up questions are included. Financial Impact: Not applicable. Recommended Action: Receive and file the Council recommended three-month status report on the Organic Chemical Pilot Study at Central Park West. Alternative Action(s): Provide direction to staff on the Organic Chemical Pilot Study or select one of the four weed abatement options. Analysis: Follow-Up Responses from the first three-month progress report at the August 7, 2017, City Council Meeting. Through Council discussion, staff was asked to provide a cost for using RoundUp in the rights-of- way (ROW), sidewalks, and alleys and manual weed abatement in parks. This was not included in the first report because the direction was for full organic chemical usage and to remove the use of RoundUp. This option would be the least costly. Manually weed abating parks would cost approximately $312,000 per year and chemically treating ROW, alleys, and sidewalks would cost approximately $25,000 per year for a total of approximately $337,000 per year. HB -439- Item 22. - 1 Dept. ID PW 17-069 Page 2 of 3 Meeting Date: 12/18/2017 Listed below are the four options available for citywide weed abatement: Option Parks ROW Total 1 Contracted Organic Chemical Contracted Organic Chemical $600,000 $411,000 $1,011,000 2 Contracted Manual Contracted Organic Chemical $312,000 $411,000 $723,000 3 Contracted Manual Contracted Manual $312,000 $228,000 $540,000 4 Contracted Manual Synthetic Chemical $312,000 $25,000 $337,000 Discussion continued about the clarification related to glyphosate, the chemical used in RoundUp, being added to the Proposition 65 warning list, posting notifications, cost for signage, as well as the protocol for using RoundUp. Governmental agencies and public water utilities: All federal, state, and local government agencies, as well as entities operating public water systems, are exempt. Since the City is exempt from posting, there would be zero cost associated with posting signs. The protocol for using Round Up, as part of an Integrated Pest Management plan (IPM), is when the threshold for managing weeds is too high for manual abating. In the City's case, the cost for labor is too high, therefore Round Up is used as a cost effective measure to weed abate. Round Up is applied when winds are below 8 mph, 48 hours prior to a forecasted rain event, application is overseen by the rules and regulations of the California Department of Pesticide Regulation and all reporting of chemical usage is made to the County Agriculture Commission. It can only be applied by a qualified applicator. The City would not receive any credit for switching to an organic pesticide as it relates to the National Pollution Discharge Elimination System (NPDES), but any chemical reduced or removed from runoff is a positive step in eliminating pollution into the ocean. Discussion On August 25, city staff met with Dr. Cheryl Wilen Ph.D., who is an Integrated Pest Management (IPM) advisor with the University of California Irvine (UCI) Cooperative Extension and has worked with cities, such as Irvine, in creating effective IPM programs. Dr. Wilen informed city staff that going "organic" or using "cultural and mechanical methods" only, is not an effective IPM program for controlling weeds and pests. Dr. Wilen did not recommend the use of organic chemicals over synthetic chemicals or "vice versa." She discussed how to use synthetic chemicals more wisely as well as suggesting not using them around areas where children congregate, i.e., playgrounds. She also recommended against the idea of using a synthetic chemical that is listed on Prop 65 so as not to alarm citizens. It was suggested to post signs during herbicide application and leave the signs in place until the herbicide has dried. Dr. Wilen informed staff that one of her concerns with the use of organic herbicides and pesticides as the first course of action in an IPM program is that once weeds or pests are present in a garden at levels that meet the threshold for action, and after the cultural and mechanical methods have been exhausted, organic chemicals are more hazardous to the human chemical applicator. Because organic chemicals are less effective on the target weeds and pests than synthetic chemicals, they require more frequent use, thus increasing the duration and potential of harmful exposure to the person applying the organic chemical. Item 22. - 2 HB -440- Dept. ID PW 17-069 Page 3 of 3 Meeting Date: 12/18/2017 Dr. Wilen also suggested methods to help make organic chemicals more effective. Organics are affected by the water's pH and adding a surfactant will help with getting a better result in the field. For the test of organic herbicides, staff has started using a pH buffer and a surfactant with Suppress Herbicide EC mix. On September 27, 2017, city staff met with the Director of Facilities at Ocean View School District (OVSD), to learn how OVSD was conducting its chemical free program. OVSD has discontinued the use of synthetic chemicals and follows guidelines contained in the Healthy Schools Act of 2000 which requires OVSD to post signs 24 hours before herbicides can be applied and continue posting these signs for 72 hours after herbicides have been applied. Additionally, they must maintain records of applications to be shown to any parents or staff members that wish to see them. One of the ways OVSD accomplishes this is by utilizing a website that lists all of the District's school sites which parents and staff can then choose from to see which herbicides are used, the amount, and the date on which the application was made. OVSD maintains 27 landscaped sites within the district and is now trying to control the weeds with string trimmers and manpower, but does not have enough labor to keep up with the demand. The Maintenance Department of OVSD is looking into alternative methods to control weeds that would not be practical for the City of Huntington Beach to follow due to the large amount of landscape the City maintains. The Parks, Trees and Landscape Division has continued the organic chemical pilot program at the triangle in Central Park West. Staff has been spraying the triangle with a 9% solution of Suppress Herbicide EC and has recently started using Tank pHix, an acidifier, to adjust the water's pH to be more favorable for the Suppress Herbicide EC, as well as Target Pro-Spreader Activator, which is a surfactant to help the organic chemical stick to the weeds. This was done in an effort to reduce the amount of applications needed by Suppress Herbicide EC and ultimately reduce the amount of chemical used to control the weed growth. It is still too early in the use of the Tank pHix and Target Pro-Spreader to comment on their effectiveness. Staff also added 20 yards, nearly four-inches of mulch, to the bare areas in the planters to help reduce the amount of Suppress Herbicide EC needed to control the weeds. Lastly, staff has experimented with the frequency of spraying the weeds between once-a-month, twice-a-month, and four-times-a-month. For young weeds in a planter, spraying every two weeks is sufficient for control and for chemically edged pathways adjacent to an irrigated area, once-a-week spraying is needed during the active growing season. Environmental Status: This Organic Pilot Study is categorically exempt pursuant to the California Environmental Quality Act (CEQA) California Public Resources Code Section 15378 as there is no potential for direct or reasonably foreseeable direct or indirect physical change to the environment. Strategic Plan Goal: Improve quality of life Attachment(s): None HB -441- Item 22. - 3 Recommended Action: Adopt Ordinance No. 4142, "An Ordinance of the City of Huntington Beach repealing Chapter 3.52 of the Huntington Beach Municipal Code (Ordinance 3175) and Disestablishing the Parking and Business Improvement Area known as the "Huntington Beach Auto Dealers Business Improvement District." Approved 7-0 PUBLIC HEARING 21. WITHDRAWN - Public Hearing ,gem regarding r n to the City; Em_ MadiGa1 CPAGec (EMS) Fee SGhed de �:.',.`. been withdrawn .. agenda ADMINISTRATIVE ITEMS 22. Received and filed the second three-month status report on Organic Chemical Pilot Study at Central Park West Recommended Action: Receive and file the Council recommended three-month status report on the Organic Chemical Pilot Study at Central Park West. Approved 7-0 as amended to include in the third three-month status report a proposal to expand the program. 23. Approved for Introduction Ordinance No. 4143 amending Huntington Beach Municipal Code (HBMC) Chapter 1.13 to change the fiscal year for the City; and, adopted Public Financing Authority Resolution No. 23 and Successor Agency Resolution No. 2017-15 affirming the change of the fiscal year City Council/Public Financing Authority and Successor Agency Recommended Action: A) Approve for Introduction Ordinance No. 4143, "An Ordinance of the City Council of the City of Huntington Beach Amending the Huntington Beach Municipal Code by Amending Chapter 1.13 to Change the Fiscal Year for the City" to a July 1 to June 30 period, and, B) Adopt Resolution No. 23, "A Resolution of the Public Financing Authority of the City of Huntington Beach Changing the Fiscal Year for the City," and, C) Adopt Resolution No. 2017-15, "A Resolution of the Successor Agency of the City of Huntington Beach Changing the Fiscal Year for the City." Approved 7-0 24. Received and filed report on Downtown Huntington Beach maintenance and public improvements as directed by a Councilmember Item submitted by Mayor Mike Posey and Councilmember Patrick Brenden Recommended Action: Receive and file the compiled report on maintenance and public improvement efforts in downtown Huntington Beach. -9- City Council/PFA &Special Meeting of the Successor Agency Action Agenda —Monday, December 18, 2017 12/18/2017 The Science of Endocrine Dis uption Bruce Blumberg, Ph.D. Department of Developmental and Cell Biology Department of Pharmaceutical Sciences Department of Biomedical Engineering University of California, Irvine Non-communicable Diseases On the Rise • Leukemia, brain cancer: over 20% increase since 1975 • Asthma: doubled between 1980 and 1995, stays elevated • Difficulty in conceiving and maintaining pregnancy: 40% more women in 2002 than in 1982 (doubted in women aged 18-25) • Autism diagnosis: increased 1000% over the past 3 decades • Obesity: Increased 3 fold in US over past WHY? Y?40 years doubled worldwide last 20 years v v • Non-communicable diseases account for 35 million deaths each year SUPPLEMENTAL COMMUNICATION o Da l a/Y-/7 1 12/18/2017 Endocrine Disrupting Chemicals (EDCs) affect many organ systems - "Endocrine Disruptor - an exogenous / i chemical, or mixture of chemicals, that a a. interferes with any aspect of hormone action." - The Endocrine Society, 2012 - Wrong signal, loss of signal, wrong place or wrong time - Act on specific hormone receptors - Hormones work at low concentrations and so do EDCs • EDCs are often persistent pollutants or dietary components r Disturb development, reproduction, and physiology w Increase risk of many cancers • Breast, ovarian, prostate 11^ • Leukemia, non-Hodgkins lymphomas • Brain cancers 04 Endocrine Disrupting Chemicals (EDCs) HERBICIDES INSECTICIDES INDUSTRIAL CHEMICALS 2010► 2,4,-D Aldicarb Bisphenol-A 2,4,5,T beta-HCH Polycarbonates Alachlor Carbaryl Butylhydroxyanisole Amftro Chlordane Cadmium Atrazine Chlordecone Chloro-R Bromo-diphenyl no*Glyphosate DBCP Dioxins Linuron Dicofol Furans Metribuzin Dieldrin Lead Nitrofen DDT and metabolites Manganese Trifluralin Endosulfan Methyl mercury Heptachlor/H-epoxide Nonylphenol FUNGICIDES Lindane(gamma-HCH) Octylphenol Benomyl Malathion Organotins Ethylene thiourea Methomyl PBDEs Fenarimol Methoxychlor PCBs Hexachlorobenzene Oxychlordane Pentachlorophenol Mancozeb Parathion Ponta-to Nonylphenols Maneb -a* Pyrethroids Perchlorate Metiram-complex Trammonachlor PFOA Triorganotins Toxaphene p-tert-Pentylphenol Vinclozolin Zineb Styrene Estrogen receptor agonist Thyroid hormone disruptor Androgen receptor antagonist 2 12/18/2017 Not everyone agrees about EDC hazards (e.g., industry and its PR machine) 9NS, lre k-112 TR00W-14(101NG We in the business CHV�rtItAlS IN1W community prefer EM 47014HENTSUS9C{iF9 a cautious Of WiDfi•RAKGING 1�,wait-and-see' $+OWGIM As,iorfatlfI. 7 r approach over (iaiCLuDIN6 needless media is QMAVH KM `�.�/ scare-mongering... ,wv tawea . ST'EYtM Crk1N7S IN •r x; '• i `/ We all Carry a Chemical Body Burden Environmental Working Group/Commonweal - 2005 • A random survey of cord blood for 417 chemicals found 287 chemicals (range of 154 - 231 for each child) - 180 of these cause cancer in humans or animals - 217 are neurotoxic in animals - 208 are developmental toxins • Did any of these moms or children give informed consent for exposure to these chemicals? ;•; • Did they benefit from their chemical exposures? • Is this really a good idea? 3 12/18/2017 Myths and Realities in EDC Science Myth Reality • EPA under the aegis of FIFRA, EPA tests NOTHING and requires TSCA and other laws tests the only that manufacturers perform effects of chemicals on human, rudimentary testing for toxicity animal and environmental health and carcinogenesis • EPA practices the "precautionary Opposite - substantial certainty Principle" (better safe than sorry) of harm to humans is required in regulating chemicals before a chemical is unlicensed • EPA, USDA, CDC and/or FDA • Exposure assessments are based measure real life levels of on modeling and rarely, if ever, chemicals and protect us from measure actual exposures. exposures to dangerous chemicals — Relevant for low dose effects • EPA and other agencies use "state • "Science" used by EPA, et at. is of the art" science to evaluate archaic and heavily influenced by chemical safety for risk registrants assessment — EDC screening battery • Data supporting adverse health effects of herbicides and pesticides are very strong. Even if one accepts that there may be some "uncertainty" in study results, which way should we err in decision making - public safety or business as usual ? • What will be the cost of waiting for evidence showing "substantial certainty" of harm in humans before acting to reduce exposure ? • Aren't our children, grandchildren and fire generations the most important consider on ? 4 12/18/2017 Testing for Effects of Chemical Exposure UM,,,WE Do TEST FOR 11IE .0 FETY OF r9 PESTICIDES IN VOuR FOOD, AND ENVIRONMENT ITS KIND OF q Low. MM Mr. c" 5 HUNTINGTON BEACH TOMORROW Making a difference today for Huntington Beach tomorrow P.O. Box 865, Huntington Beach, California 92648 www.HBTomorrow.com I info@hbtomorrow.org HBT's Mission: December 17, 2017 To promote and maintain a high quality of life Hon. Mayor Posey and City Council Members in Huntington Beach. "Supplemental Report"to Staff's Second Three-Month HBT advocates for: Report on Organic Pilot Study at Central Park West Citizen Participation Dear Mayor Posey and Council Members: Clean&Healthy Environment HB Tomorrow continues to support the City and its Staff in their Efficient&Safe Traffic Flow efforts to formulate a plan to make our City non-toxic through an Open&Responsive Government organically driven Integrated Pest Management policy. To date, the following local municipalities and school districts have gone Preserve Open Space non-toxic using this approach: Preserve Our Quality of Life . City of San Juan Capistrano & their school district Recreational Opportunities for All CUSD—April 2017 Responsible Planned Growth • City of Burbank (1st City in LA County) and their school district BUSD— July 2017 Sound Infrastructure Sustainable Tax Base • City of Tustin and their school district TUSD— November 2017 Board of Directors: • City of Carlsbad (1st City in San Diego County) and their Karen Jackle President school district— December 2017 Vice-President Costa Mesa and Mission Viejo are also working with Non Toxic Mary Jo Baretich Irvine and their advisors transition to organically driven Treasurer landscaping practices. Tim Kowal Staff have told us how very impressed they are with what they Secretary are seeing in Irvine. Staff have personally toured Irvine's organic Greg Griffin facilities, which have drastically cut watering up to 80%, reducing watering days from six to two. Their fields have noticeably Linda D. Couey improved in color and absorbency. The cost-curve of organic Monica Hamilton products continues to bend downward. See photos below. Robert Sternberg We reviewed the staff's "Second Three-Month Status Report on Organic Chemical Pilot Study at Central Park West" and were SUPPLEMENTAL COMMUNICATION pro: 1a_18 -f� No., - o4 b December 17,2017 Hon.Mayor Posey and City Council Members .Supplemental Report"to Staffs Second Three-Month Report on Organic Pilot Study at Central Park West Page 2 of 5 surprised to find none of these factors reflected there. We wish to provide some supplemental information to address the questions the Council asked at prior meetings. Comparing Costs for the Continued Use of Synthetic Chemicals: At the August 7 Council meeting, several Council Members were anxious to compare apples to apples to understand the true costs involved not only in transitioning to non-toxic practices but in continuing to use harmful chemicals in our public spaces. For example, the Council's unanimously-passed motion asked Staff to analyze the costs for "posting temporary alerts (signage) during chemical application." The Staff Report states: Governmental agencies and public water utilities: All federal, state, and local government agencies, as well as entities operating public water systems, are exempt. Since the City is exempt from posting, there would be zero cost associated with posting signs. But this is nonresponsive to the Council's directive. Indeed, the Staff Report later states, a UCI botanist "suggested [that the City] post signs during herbicide application and leave the signs in place until the herbicide has dried." The Report also relates that Ocean View School District "follows guidelines contained in the Healthy Schools Act of 2000 which requires OVSD to post signs 24 hours before herbicides can be applied and continue posting these signs for 72 hours after herbicides have been applied." HBT presumes the City will do no less to protect its children. Thus, the Council's questions on this issue remain unanswered. This makes it difficult to truly compare apples to apples. Cost and Efficacy of Organic Methods: The Staff Report states: Dr. [Cheryl] Wilen [IPM advisor at UCI] informed city staff that going "organic" or using "cultural and mechanical methods" only, is not an effective IPM program for controlling weeds and pests. Dr. Wilen spoke in support of Irvine's IPM, however, which is substantively identical to the IPM Council is exploring here. That IPM is not based on an organic/mechanical-only program, but rather on organic/mechanical-first. Since Dr. Wilen is supportive of that IPM, many of her other comments reflected in the Report are confusing and possibly misleading. December 17,2017 Hon.Mayor Posey and City Council Members `Supplemental Report"to Staffs Second Three-Month Report on Organic Pilot Study at Central Park West Page 3 of 5 For example, over the past 22 months the City of Irvine has been able to successfully maintain all pest pressure from weeds to rodents without synthetic pesticides for more than 570 acres of community and neighborhood parks and athletic fields; over 800 acres of public right-of-way, including street medians and parkways, 70,000 plus trees; and nearly 1.5 million square feet of facilities. While Irvine's IPM is organically driven per the policy, it uses "EPA Level pesticides in a targeted manner, and only if deemed necessary to protect public health and economic impact by a licensed pest control adviser and City staff, when pests cannot be managed by other methods." Moreover, the Staff Report does not reflect the substantial water savings and improvement to turf health they have now personally surveyed in Irvine.' It also does not reflect that Irvine's latest cost profiles show non-toxic alternatives actually saving money. In Staff's recent site visit to an organics-first Irvine site, the field looked substantially greener, and its sponginess underfoot spoke to its improved absorbency. This field was transitioned from synthetic maintenance to an organic systems approach at no additional cost— in fact, it came in $100.43 cheaper than the prior year. The soil reports show that in under two years they have been able to reduce their irrigation schedule at the site from six days to just two. These are truly impressive results the Council should be aware of. Without analysis of this information, again, the cost matrix in the Staff Report does not compare apples to apples. And in fact, the benefits of moving to an organics-first IPM — over and above the needless risks in continuing to use synthetics —are simply overwhelming. Dangers of Pesticides: Dr. Wilen "recommend[s] against the idea of using a synthetic chemical that is listed on Prop 65," e.g., such as glyphosate-containing Roundup products. But the Staff Report goes on to relate the following additional concern of Dr. Wilen's: After the cultural and mechanical methods have been exhausted, organic chemicals are more hazardous to the human chemical applicator [because] they require more frequent use, thus increasing the duration and potential of harmful exposure to the person applying the organic chemical. And obviously it cannot reflect the appreciation felt by its residents, as seen in this short clip: https:/fyoutu.be/rA8rAz9lYN4. December 17,2017 Hon.Mayor Posey and City Council Members "Supplemental Report"to Staffs Second Three Month Report on Organic Pilot Study at Central Park West Page 4 of 5 This is a confusing statement because it is not clear: more hazardous than what? More than "cultural and mechanical methods"? That may be true. More than synthetic pesticides? That would be a more surprising — and, we think, false —claim. As for the "hazard" in applying organic and acid-based products, these only present a risk to the applicator if they are not wearing the required personal protective equipment. And the Report does not similarly evaluate the applicator's risk when it comes to synthetics, as reported on PubMed.gov.2 That risk, which may take years to develop, is much graver and more costly. Aside from public health considerations, the Staff Report does not reflect the potential financial and legal liabilities related to allowing a known carcinogen to be applied in the city's playgrounds and parks exposing the most at risk population — particularly when this is to be done for purely cosmetic reasons. We are asking that the City move away from toxic landscaping practices and liabilities and switch to proven, cost-effective and safe solutions. In conclusion, the City's Staff, as always, have been a pleasure to work with. Staff understands the risks presented by continuing to use certain synthetic products and is responsibly exploring alternatives to protect the health of our residents, children, and pets. Nor do we need to remind the Council of the needless risks presented by these synthetic chemicals. HBT believes that the costs of transitioning off of toxic chemicals will be negligible to begin, and a cost-saver within a couple years, as Irvine's experience bears out. While the Council is the custodian of every dollar in its budget, the options to take our City non-toxic represent amounts similar to budget increases in landscaping and other non-essentials the Council just recently approved. We urge the Council not to balk at these very modest expenses and to immediately implement these changes to mitigate the needless health risks to our community. Very truly yours, /s/Tim Kowal Tim Kowal Huntington Beach Tomorrow 2 E.g., Alavanja et al, Increased cancer burden among pesticide applicators and others due to pesticide exposure, CA CANCER J CLIN., 2013 Mar-Apr. ("Although the review is not exhaustive in its scope or depth, the literature does strongly suggest that the public health problem is real."), available at https://www.ncbi.nlm.nih..qov/pubmed/23322675. December 17,2017 Hon.Mayor Posey and City Council Members "Supplemental Report"to Staffs Second Three Month Report on Organic Pilot Study at Central Park West Page 5 of 5 Before and after photos of IUSD's Vista Verde organic pilot site: Lm Ste" E �I 4, y � 4 12/18/2017 Central Park West Pilot Study Status Report - 00 -- - CITY COUNCIL MEETING DECEMBER 18, 2017 Maintenance Responsibilities Overview - - -_ 0. _ _-I • Over 58o acres of community and neighborhood parks • 800 plus acres of right-of-way • 6o,000 Trees • Approximately 1.7 million square feet of facilities AL COMMUNICATION Deb: -*a�, 1 12/18/2017 Weed Abatement Options Listed below are the four options available for citywide weed abatement: Option Parks ROW Total 1 Contracted Organic Chemical Contracted Organic Chemical 5600,000 $411.000 $1,011,000 2 Contracted Manual Contracted Organic Chemical $312,000 $411.000 $723.000 3 Contracted Manual Contracted Manual $312,000 $228.000 $540,000 4 Contracted Manual Synthetic Chemical $312,000 $25,000 $337,000 Suppress EC 9% Application Monthly ; r i 2 12/18/2017 Suppress EC 9% Application Bi-Weekly Suppress EC 9% Application Weekly I 3 12/18/2017 Results & Next Steps 0- • Orange County IPM Manager suggested methods to make organic chemicals more effective Add a PH buffer and a surfactant with the Suppress EC Staff found this effective • Continue meeting with stakeholders to find new products • Continue Pilot Study 4 Harper, Gloria From: Dombo, Johanna Sent: Monday, December 18, 2017 9:20 AM To: Agenda Alerts Subject: FW: Re Item 22,re Dec. 18, 2017 CC meeting, three-month status report on Organic Chemical Pilot Study at Central Park West From: Dan Jamieson [mailto:daniamieson4@hotmail.coml Sent: Monday, December 18, 2017 8:54 AM To: Dombo,Johanna Subject: Re Item 22,re Dec. 18, 2017 CC meeting,three-month status report on Organic Chemical Pilot Study at Central Park West Dec. 18, 2017 Re Item 22, Dec. 18, 2017 CC meeting, three-month status report on Organic Chemical Pilot Study at Central Park West SUPPLEMENTAL COMMUNICATION Dear City Council: Walling Dab; IA-/8-/7 Agenda Nem Na: *,:7zOZ As residents of Huntington Beach, we support expansion of the City's program to use integrated pest management (IPM) in City parks. We urge the City and staff to continue to work with HB Tomorrow and non-Toxic HB to develop an effective organically-driven IPM program. An organic/mechanical-first program (using Roundup and other poisons only as a second choice and where necessary, and where the public is unlikely to come in contact with the compounds)has proven effective in other cities. We understand Irvine, for example, has adopted such an IPM program citywide, and has overall been encouraged by the results. The latest City staff report seems misleading in that it cites an IPM consultant as saying organics-only IPM is ineffective, and possibly more dangerous than synthetic pesticides. But IPM programs generally do not rule out the use of synthetic pesticides where their use is needed; the goal is an organic/mechanical-first program. t The consultant also suggested not using poisons around areas where children congregate, using synthetic chemicals listed on Prop 65, and leaving signs in place until the herbicide has dried. The City should follow all these recommendations. The City's staff report indicates that staff is still climbing the learning curve on using new techniques under the IPM program. We urge the Council to direct City staff to continue developing expertise in implementing the IPM program, and expand it as appropriate. Sincerely, Dan Jamieson Roxanne McMillen Huntington Beach, CA 2