Happy Patriots’ Day, West Chester, from the Chesco Health Department

[Subsequent note: spraying did occur in West Chester at the scheduled time, but not at WCU, not on S. High St., and because of rain not in the NE part of the Borough.]

Anyone reading this knows that when the County planned to spray West Chester last month, Borough Council unanimously passed a resolution opposing that spraying.

After some verbal and legal back-and-forths, the County has now scheduled spraying again, now for Tuesday evening 9/11, 7:30-11:30 p.m. The affected areas are in the South and Northeast of the Borough (see maps below), impinging on the downtown area where visitors will, as usual, be circulating and enjoying the Borough’s many amenities such as outdoor dining.

This is late in the season to be spraying, and the hot weather on which mosquitoes thrive has now broken (as of Sept. 8), thus presumably reducing mosquito populations soon in any case.

Download the full press release here: 17_2018_WNV_West Chester Spray. See our post “In case of spraying: Help us / Help yourself” here.

We note some interesting changes of wording in the County press release, which begins:

Mosquito control treatment scheduled for West Chester Borough to prevent West Nile Virus

“Following the contractual guidelines/agreement with the Pennsylvania Department of Environmental Protection, the Chester County Health Department will conduct a mosquito control treatment spray in portions of West Chester Borough on Tuesday, September 11th from 7:30 to 11:30 p.m. The rain date for this event is Wednesday, September 12th from 7:30 pm to 11:30pm. The treatment is occurring because of the extremely high level of mosquito samples in areas of the Borough that have tested positive for West Nile Virus. Maps of the area being sprayed are below.

“The Chester County Health Department monitors the presence of mosquitos infected with West Nile Virus and utilizes strategies to prevent and control mosquito larvae. Despite such measures being undertaken in West Chester Borough, numerous mosquito samples have tested positive for West Nile Virus which require mosquito control treatment spray to reduce the risk of transmission. …”

What’s new there from previous wordings (compare to the wording for the release regarding the Sept. 5 spraying of Phoenixville)?

For the first time, the text starts with the phrase “Following the contractual guidelines/agreement with the Pennsylvania Department of Environmental Protection…

This wording is clearly designed to silence the Borough. We have never heard of or seen such a “contractual guidelines/agreement” before. What does, in fact, “contractual guidelines/agreement” mean? Is it a legal contract between the County and the State? Signed by whom and when?

Also note that the expression “which require mosquito control treatment spray” has also crept in. Nothing “requires” spraying; it is a decision made by human beings.

Nothing we have ever heard before suggests that the State obliges the County to spray. We have always understood that the State merely supplies information and guidance but the County makes the decision whether and when to spray. Many counties do not spray and have no mosquito control program at all. No one “requires” them to spray.

And Vector Index levels — to which the public no longer has timely access, since the site that used to have them has not been updated since July 30, and which appear to us scientifically dubious — vary so widely when used to justify spraying that it is clear that spraying is a matter of discretion, not science. Whose discretion? — that is the question.

Now, suddenly we are confronted with a new example of “state preemption,” recalling the claim that municipalities (and presumably the County as well) have no right to put any conditions on the siting, construction, or operation of gas and other pipelines.

In our view, this new example of state preemption runs totally counter to West Chester Borough’s Home Rule Charter as amended with the Community Bill of Rights (section 904) approved by Borough voters in 2015, and notably (A6):

“Right to Clean Air. All residents, natural communities and ecosystems in West Chester Borough possess a fundamental and inalienable right to breathe air untainted by toxins, carcinogens, particulates, and other substances known to cause harm to health.”

Also for the first time, the County press release does not claim to spray only “After exhausting all other available mosquito control strategies….” There we certainly agree: the County has indeed not been “exhausting all other available mosquito control strategies.” In fact, they can’t even tell us where they have larvicided to kill larvae, the chief non-toxic and most effective means of mosquito control.

Instead, the release says: “The Chester County Health Department monitors the presence of mosquitos infected with West Nile Virus and utilizes strategies to prevent and control mosquito larvae.” Of course, we’d like to see more of those strategies. “Kill mosquitos in the water, not in the air!”

The release does not make another change that we have often suggested, in its claim that spraying can “prevent West Nile Virus.” One cannot “prevent” a virus or (in the paragraph just above) “prevent” larvae. One can set out to reduce the number of mosquito or larvae or to reduce the likelihood of disease, but one cannot “prevent” them.

As usual, the release uses euphemisms like “treatment” and avoids the terms “insecticide” and (until the boilerplate language at the end of the release about the Pesticide Environmental Stewardship Program ) “pesticide.”

These are not semantic quibbles. Like the scientific and procedural claims that often come from the pesticide industry itself and that we have often criticized, these choices of words tend to mislead the public and office-holders into thinking that spraying is a helpful and healthful “treatment.”

See maps of planned spray areas below. These are the same as planned last month, as it happens. We can’t compare to any evolution in “Vector Index” scores, because those are not longer available to the public. To line up the maps (which are on different scales), look for High St. running N and S (tilting some to the left) in both maps or for Fugett Park, the spot of green below the top map and above the bottom map. In the downtown area, Gay St. and much of Market are not on the direct spray route, but the 200 block of E. Market is. And, naturally, spray drifts; if it didn’t drift, it would stay on the streets where the spray truck passes, and the whole point of the exercise is to spread the pesticide around in people’s yards.

NE West Chester:

Southern West Chester:

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DeltaGard, deltamethrin

In the past, Chester County has sprayed pyrethrin in an effort to attack mosquitoes. No chemical pesticide is selective; a poison that kills adult mosquitoes will inevitably affect other forms of life. (Biological agents such as larvicides are much more selective.)

Now the County seems to have gone over to another member of the pyrethroid chemical group, DeltaGard, whose active ingredient is deltamethrin.

The information below is mainly about the DeltaGard variant for use in gardens and landscaping, which has the same active ingredient as the DeltaGard insecticide used against mosquitoes. For more on the mosquito spray, see here.

What’s deltamethrin? Of course, the industry doesn’t think it’s dangerous. Some other sources beg to differ. A relatively recent post in Chemicals.News (no friend to the chemical industry) says:

“Deltamethrin — toxicity, side effects, diseases and environmental impacts”

12/05/2017 / By Rita Winters

Deltamethrin is a pyrethroid insecticide that is registered for use in commercial, agricultural, and residential areas. It plays a role in controlling malaria and targets other insects like cockroaches, spiders, ants, fleas, silverfish, bed bugs, bird mites, house flies, and beetles. Deltamethrin products are one of the most popular and widely used pesticides in the world and are very popular with government pest control operations in the country. It is highly toxic to the environment, especially to aquatic life forms like fish and crustaceans. Deltamethrin is also known to be toxic to humans. As a neurotoxin, it attacks the nervous system and causes a variety of negative side effects and fatality. In 2011, a Japanese woman ingested large doses of pesticides that contained deltamethrin, which resulted in motor neuron death.

This chemical compound acts by blocking the closure of the ion gates of sodium channels during repolarization. It then disrupts the transmission of nerve-related impulses causing depolarization of the nerve cell membranes. It is very effective on insects, especially those considered as pests. However, it also affects beneficial insects including honey bees….

read more at Chemicals.News

According to the National Pesticide Information Center: “While children may be especially sensitive to pesticides compared to adults, it is currently unknown whether children have increased sensitivity specifically to deltamethrin….” (Parents will not wish to experiment to find out.)

Also: “When deltamethrin gets in the soil, it has a tendency to bind tightly to soil particles. It has a half-life ranging from 5.7- 209 days. Half-life is the measure of time it takes for half of the applied amount to break down…. Deltamethrin has a half-life of 5.9-17 days on plant surfaces. It is unlikely to be taken up by plants, since it binds to soil particles so tightly….” (So that could be reassuring if you are out for a walk in the street, but not so much if you’d like to consume your own organic produce or turn over your garden knowing that may have pesticide residue in it for up to 7 months.)

“NPIC provides objective, science-based information about pesticides and pesticide-related topics to enable people to make informed decisions. NPIC is a cooperative agreement between Oregon State University and the U.S. Environmental Protection Agency.” Download the pdf of its deltamethrin report here: Deltamethrin General Fact Sheet

See some other sources at these sites:

https://www.ncbi.nlm.nih.gov/m/pubmed/28551743/
https://www.ncbi.nlm.nih.gov/m/pubmed/22079160/
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4502505/
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1257607/#!po=76.0417
https://www.ncbi.nlm.nih.gov/m/pubmed/29444244/

Deltamethrin molecule
The manufacturer’s label (download here: deltagard-5sc-label ornamental) contains an immense list of insects as well as spiders that DeltaGard kills when used on lawns and landscaping. The list includes ants, caterpillars, crickets and grasshoppers, among others that most of us might not see as pests but as important members of the environment; and many of the target species are important food sources for birds, amphibians, and reptiles.

And that is just for the supposed pests. Of course they don’t list the other species than can be killed, such as adult butterflies and dragonflies.

And the label says, not reassuringly for those of us with home gardens:

“DO NOT apply this product to edible crops.”

If you want further non-reassurance, download the manufacturer’s Safety Data Sheet relevant to mosquito spraying here: DeltaGard_Insecticide, including statements such as:

“This product contains material which are Trade Secret and may have Occupational Exposure Limits.”

“Do not allow to get into surface water, drains and ground water.”

Phoenixville and Schuylkill the next to be sprayed

Chester County press release:

West Chester, PA – The Chester County Health Department will conduct a mosquito control treatment spray in portions of Phoenixville Borough and Schuylkill Township (see maps below). The treatment is scheduled for Wednesday, September 5th from 7:30 pm to 11:00 pm. The rain date for this event is Thursday, September 6th from 7:30 pm to 11:00 pm….

Read the full release at the above site.

This planned spraying with the pesticide deltamethrin involves big chunks (see maps online) of densely populated neighborhoods. (Isn’t it odd how the press release text finds euphemisms so as not to use the term “pesticide,” which occurs only in the EPA-related statement at the very end?)

As mentioned in “Mosquito spraying and public information,” the public and their elected representatives can’t find the underlying data online because the usual sites have not been updated recently. “Just trust us”?

On the futility of this kind of spraying, see “Why don’t they just spray and kill all the mosquitoes?

If you are in one of the spray areas, please see “In case of spraying: Help us / Help yourself.” You should protect yourself and y our family, but also your observations can help us catalogue the conditions and effects of spraying.

“Why don’t they just spray and kill all the mosquitoes?”

Yes, people may wonder: “Why don’t they just spray and kill all the mosquitoes?”

First, it’s impossible to kill all the mosquitoes. Any spraying, including from a truck as done by the County, kills only the portion of mosquitoes that happen to be flying around at the time and encounter toxic droplets. We have seen figures of up to an 80% kill rate (yes, this is a serious poison) but no really authoritative figure.

But suppose 20+% of adult mosquitoes survive (and any out of the spray zone, sheltered at the time in thick foliage, or in inaccessible areas like inside bulkheads or hollow trees, will not be affected). The females, at least, will be happily flying around the next day biting people and laying eggs as usual.

The hundreds of eggs that each female lays in stagnant water are affected by spray. Those eggs will become larvae, pupae, and adults, all within a week in hot weather like now.

And current larvae and pupae will not be affected by spray either.

And not all mosquitoes are created equal. Specifications require that spraying occur only in the evening, when honeybees are less active. Disaster for bees ensues if spraying occurs at other times.

Our home-grown mosquitoes, the ones that at least give us an auditory warning hum as they circle us looking for bare skin, tend to be active in the evening; however, the recently established “Asian Tiger” mosquitoes, the silent biters, tend to be active during the day and therefore are not much affected by spraying. Killing off some of the “regular” mosquitoes probably just opens the airways to more Asian Tigers.

Furthermore, anti-mosquito spray actually kills mosquito-eaters like dragonflies and toads, to say nothing of insects that we enjoy seeing or that are important to ecological balance like butterflies.

The County Health Department does not spray for the comfort of people who wish to be outside without the recommended bug repellents, long sleeves, and long pants. People outside need to weigh those nuisances against the nuisance of being bitten. The Health Department is not the Department of Outdoor Living.

Finally, proper public policy is to spray only, in the words of the Chesco Health Department, “after exhausting all other available mosquito control strategies.”

The prime non-toxic mosquito control strategy is larviciding suspect standing water. Individuals can larvicide on their own property but not on public property. We are glad to say that the Borough of West Chester is taking steps for two employees to receive the relatively simple licensing to do that, and we hope other municipalities will do the same.

Currently, the County does the larviciding but obviously needs to be informed where the problem areas are in such a large county. In West Chester, our Adopt A Drain program is clearing drain grills of plastics and other detritus and informing the Borough of drains that need cleaning below grill level or larvicing where they are holding standing water.

Example, as of Aug. 30, 2018: the storm drain at the NE corner of E. Nields and S. Matlack streets. If you check it out, you’ll see a water reflection at the bottom. After the dry last week in August, this drain could already have released swarms of adult mosquitoes to the neighborhood. In dry weather, mosquitoes could also be breeding in stagnant areas of Goose Creek and Plum Run, including water backing up in drainage pipes entering the stream. (Water samples are needed to check it out.)

If residents anywhere are aware of storm drains with standing water, they should inform their municipality. And of course, we should all patrol our own property, even for something as small as a bowl holding water under a potted plant, and put in a helpful word to neighbors who may not be addressing the issue. For some egregious “Case studies in what to avoid,” see here.

Mosquito spraying and public information

(Reference are current as of 8/29/18; of course, we are hoping that the state and County sites linked below will soon be updated so that we will have more data to study and share)

Don’t Spray Me! wishes to work factually and democratically to convey our negative view of pesticide spraying. We believe that the different levels of government should in turn work openly with citizens and taxpayers.

In its press releases about pesticide spraying, the Chester County Health Department says that it sprays “after exhausting all other available mosquito control strategies.” To us, this would mean at a minimum:

1) Reaching out to the County’s 73 municipalities to help them educate their residents about mosquito control, and to suggest the many precautions that residents should take in the regrettable case of airborne pesticide actually being disseminated in their community.

West Chester Borough and its citizens have dialogued exhaustively with the County Health Department and have taken on some of the needed education and outreach roles. We do not know that that has happened anywhere else in the County, except to some degree in East Bradford.

2) Larviciding (or helping municipalities to larvicide) pools of water and storm drains as needed to prevent the development of larvae from mosquito eggs there. This is the primary non-toxic mosquito control strategy.

DSM has had to file a Right To Know request with the PA Dept of Health asking when and where the County has conducted larviciding in West Chester Borough. The Health Department has said it either does not have records (2015-17) or does not have time (2018) to find out and has encouraged us to ask the State.

Furthermore, the County informs us of the general location of traps when it wishes to share high Vector Index readings or wishes to spray but not as a matter of course. Thus of the 31 mosquito traps set in the Borough, we have a general idea of where just 7* are. Therefore, we have no way to understand what role the readings from the other 26 traps played in the recent plan to spray much of the Borough — which Borough Council unanimously opposed (and which has not occurred).

According to the PA West Nile site, spraying has been conducted this year in 27 of the state’s 67 counties (as of Aug. 14; the chart is outdated). So are those 27 the only counties with supposedly high levels of risk for West Nile virus?

Not at all! According to “Recent West Nile Hot Zones in Pennsylvania in 2018” (also as of 8/14), 29 counties are described as: “There is no active county surveillance program in this county. DEP biologists do perform minimal surveillance in this county.” Of those 29 counties, 10 are said to be at “high risk” for WNV but they have not been sprayed. If WNV is such a crisis that in Chester County environmental and human health must be risked to broadcast pesticides in our communities, why do those 29 counties and especially the 10 “high risk” counties escape the same level of “treatment”?

The County justifies spraying on the basis of Vector Index scores. Although the math behind those numbers appears impenetrable to our statistician, the Vector Index level at which the County sprays municipalities varies widely, and some municipalities that have not been sprayed have higher Vector Indexes (per the information available online) than others that have been sprayed. How can there be such a discrepancy if the Vector Index is a reliable scientific tool?

And is it reasonable to think that WNV stops at municipal boundaries? Almost all of the County’s 24 untested municipalities are adjacent to municipalities with testing. For example, Parkesburg Borough (1.2 square miles) was sprayed on Aug. 9, but (as of 7/30/18) none of the 3 much larger adjacent municipalities was even being tested. Mosquitoes do know how to fly, and so do crows, the chief reservoir of the virus. But since almost no humans ever are aware of contracting the virus, what’s the big fuss anyhow?

If you wish to check the Vector Index for Chesco municipalities, see here. However, good luck in finding the levels for this month, as the posting stops as of 7/30/18. Since the County uses a 3-week window to justify spraying, that means that the public and elected officials have no online information to show any data that might underlie any recent spraying on the municipal level, nor any information either on the location of actual traps.

Citizens and their elected representative are being denied the information and data they need to form educated opinions in this important matter of environmental and human health (and the hundreds of thousands of taxpayer dollars being spent).

*8/30 just updated from 5 to 7 traps whose general locations we know in West Chester Borough, as we found out 2 more, in all:

• Greenfield Park
• College Avenue Pump Station (700 block of College Ave.)
• Everhart Park
• Kathy McBratnie Park
• Marshall Square Park
• 100 Block Magnolia Street
• 500 Block of East Miner Street

N.b. So 24 to go! Even if we knew precise trap locations, we wouldn’t publish them, because the Health Department fears interference with their traps and we don’t want to be blamed if there is any. And we do believe in valid data, when we can get it. Please note that where mosquitoes are trapped is not necessarily where they breed or spend most of their time.

The Truth About Mosquitoes, Pesticides and West Nile virus

This is a very thorough indictment of the expansive tendency in mosquito spraying. We give just a few excerpts here. Please see the full article for all details.

A Beyond Pesticides Factsheet

While communities have good intentions, many existing policies and programs may be dangerous to children, adults and wildlife and inadequate by relying too heavily on spraying pesticides to kill adult mosquitoes….

Less than one percent of those infected with WNv will develop severe illness, according to the Centers for Disease Control. The vast majority of people (about 80%) who become infected with WNv will show no symptoms and never become sick. Some 20% may experience mild flu-like symptoms within 3 – 15 days….

A person who has been infected with WNv may have life-long immunity even if they show no symptoms….

PESTICIDE SPRAY PROGRAMS ARE INEFFECTIVE

According to the Centers of Disease Control and Prevention (CDC), spraying adulticides, pesticides intended to kill adult mosquitoes, is usually the least efficient mosquito control technique.

Adulticiding programs spray pesticides indiscriminately and do not get at the mosquitoes until they have matured. They also do not restrict, control, or prevent mosquitoes from carrying WNv or continuing to breed.

Close to 99.9 % of sprayed chemicals go off into the environment where they can have detrimental effects on public health and ecosystems, leaving 0.10% to actually hit the target pest.

Mosquitoes develop resistance to pesticides over time, rendering the chemicals ineffective. A 2003 study finds that mosquitoes carrying West Nile virus and malaria developed resistance to organophosphate and carbamate insecticides as a result of a single genetic mutation.

After Hurricane Floyd caused a surge in mosquito populations in Florida, state officials took bite counts before and after widespread aerial spraying and found that mosquito populations surged back to pre-spray levels within three days of the treatment….

In 2003 the city of Boulder, CO did not adulticide and showed an 80% reduction in mosquito populations and lower rates of serious illness per population than surrounding cities where adulticiding took place….

see lots more info, including non-toxic methods of mosquito control, at Beyond Pesticides

E. and N. Coventry are next

Mosquito control treatment scheduled for East Coventry and North Coventry Townships to prevent West Nile Virus

West Chester, PA – The Chester County Health Department will conduct a mosquito control treatment spray in portions of East Coventry and North Coventry Townships (see maps below). The treatment is scheduled for Monday, August 20th from 8:00 pm to 11:30 pm. The rain date for this event is Tuesday, August 21st from 8:00 pm to 11:30 pm….

Keep reading at Chester County archive

Those in the spray area, please see our post “In case of spraying: Help us / Help yourself.”

Mosquito Spray DELAYED

[Many thanks to all concerned!]

West Chester Borough Web site

UPDATE: August 16, 2018 @ 1:26PM – Please be advised that the Mosquito Spraying scheduled for this evening, August 16 @ 8:00 PM has been DELAYED by agreement between the Borough and Chester County.

The Borough and Chester County will be continuing discussions on this matter as soon as possible and any further decisions to spray will be communicated to the public.

Will the Borough be sprayed or not?

The wheels of democracy and of human and environmental rights are turning. The County should now put this spraying, still scheduled for this evening, on hold.

Last eve after lengthy public discussion, West Chester Borough Council passed three motions unanimously.

First was to instruct the Borough solicitor to draft an ordinance banning spraying in the Borough.

Second was to instruct the Borough Manager to notify the County to tell them not to spray the Borough.

Third was to instruct the solicitor to file an injunction to halt today’s scheduled spraying by the County.

This is representative government at its best! We are grateful to the 7 members of Borough Council and to Mayor Herrin and to all who participated in that epoch-making meeting.

Please stay tuned.

Background reading from the Community Bill of Rights adopted 3 years ago as part of the Borough’s Home Rule Charter, section 904:

(5)
Right to Water. All residents, natural communities and ecosystems in West Chester Borough possess a fundamental and inalienable right to sustainably access, use, consume, and preserve water drawn from natural water cycles that provide water necessary to sustain life within the Borough.
(6)
Right to Clean Air. All residents, natural communities and ecosystems in West Chester Borough possess a fundamental and inalienable right to breathe air untainted by toxins, carcinogens, particulates, and other substances known to cause harm to health.
(7)
Right to Peaceful Enjoyment of Home. Residents of West Chester Borough possess a fundamental and inalienable right to the peaceful enjoyment of their homes, free from interference, intrusion, nuisances, or impediments to access and occupation.

Health Dept. wants to spray West Chester

And we don’t want them to. Stay tuned.

Download the Health Dept. announcement here: West Chester Spray 8-16-18

We keep having to point out that the phrase “to prevent West Nile Virus” in the press release title makes no sense. The West Nile virus is carried in birds, especially crows, and then is picked up by mosquitoes that bite the birds, and those same mosquitoes can then bite people. But the transmission chain to humans must be really weak, because this whole year PA has had only one possible identified human case, not definitely verified and not critical.

About this particular spray plan: Note from the maps below that the proposed spray area would include almost all of the S. half of the Borough and most of the NE (including Marshall Square Park, where the Borough fended off spraying 3 years ago).

The County Health Department’s press release says: “People who are concerned about exposure to mosquito control products can reduce their potential for exposure by staying indoors with children and pets when their neighborhood is being sprayed.” That is a very low-level warning. Of course, everyone ought to be concerned about any pesticide being directly sprayed on them or infiltrating their dwellings.

But how does that advice play out in an urban area like downtown West Chester? What will people here be doing on a Thursday eve, other than sitting at home with their children and pets?

Although spraying is not scheduled right on Market and Gay Streets, it would pass really close to them, and of course spray drifts. Are people enjoying their outside drink or dinner in the center of town going to have methoprene drifting onto them and their food and into their lungs? Is West Chester going to earn the reputation of a place to avoid patronizing?

If just one hypersensitive person dining outside or inadvertently walking through the spray area has a serious adverse reaction, or one small asthmatic child in tow has to be rushed to the ER, that is going to be big liability. For whom?

For the County, which does the spraying? (Let’s be clear: the County decides when to spray, not the State.) The restaurant owner who could be said to have the duty to close down outdoors for the evening? The Business Improvement District, unless it acts to get downtown closed off? The Borough, if it does not make the decision to close the parking garages and post warning signs? This is a real morass. It’s not like spraying a rural area where houses are 500 feet apart with long driveways.

How about West Chester University? The whole campus north of Rosedate is in the spray area. Are all the students going to be told to stay in their rooms from 8 p.m. till the next day? How about those coming back from an off-campus job or the Library?

The Health Department really has not thought this through. If they wanted to make a more reasonable case, they would be proposing to spray only in the immediate vicinity of what are apparently the 3 trap sites with high readings: College Ave at the pumping station, Green Field, and Magnolia St.

The Health Department releases its info selectively to make its own pro-spraying case. Where are the other 28 traps in the Borough? What are their readings? Why do they want to spray the NE but not the NW? It’s full of mysteries, and that’s the way they seem to want it. But we don’t. “Trust us” doesn’t work any more, and especially now that Chester County has become all too familiar with the PA DEP, which is the state resource on both pipelines and mosquitoes.

When Don’t Spray Me! filed a Right To Know request, the Health Department said it did not know where it larvicided in 2015-17; and they also say they don’t have time to tell us where they larvicided this year. They say they spray only “after exhausting all other available mosquito control strategies” and they don’t even know where they have larvicided, which is the most effective anti-mosquito treatment in known breeding sites like storm drains and stagnant bodies of water?

If the HD can’t do better to explain its actions and consider the effects on a complex urban population, it needs to be stopped until there is greater accountability in the interest of the public and the environment.

NE West Chester:

 

Southern half of West Chester: