Date: April 9, 2014

Subject: Comments to FWS on the Draft Environmental Assessment for Mosquito Control at Bandon Marsh National Wildlife Refuge

The Xerces Society for Invertebrate Conservation (Xerces) and the Center for Food Safety (CFS) hereby submit these comments regarding the U.S. Fish and Wildlife Service (FWS)’s draft Environmental Assessment (EA) for Mosquito Control at Bandon Marsh National Wildlife Refuge.

We are pleased that U.S. Fish and Wildlife Service (FWS) is attempting to implement an Integrated Marsh Management plan including mosquito monitoring, correcting restoration errors by expanding the tidal channel network, and excluding the use of adulticides. Still, we have significant concerns with the EA and with the preferred alternative in particular. While we recognize that the mosquitoes are a nuisance, the EA strongly overstates potential health threats, as there is no reasonable risk of mosquito-borne disease in the county at this time. If proper surveillance of egg hatch and larval populations is done, appropriately timed and targeted 2 applications of Bacillus thuringiensis israelensis (Bti) will reduce mosquito numbers without the need to resort to more toxic options such as methoprene and/or CocoBear.