IFCA and Illinois ag groups are coordinating our efforts to work with Illinois EPA to ensure that the NPDES pesticide permit requirements do not impact agricultural production practices in Illinois.  Currently, Illinois EPA is proposing that pesticide operators who apply pesticides on or near water are subject to the permit requirements.  IEPA's current stance is that even dry ditches and waterways in crop fields would fall under the definition of "water of Illinois" because these structures, even when dry, could convey water at some point.  The USEPA guidance on the permit program was not intended to apply to terrestrial agricultural applications, so you can understand why we in Illinois must work very hard to ensure that IEPA does not expand the scope of the NPDES program to pull in agricultural applications.  IFCA and the industry will be submitting our comments to IEPA by January 7.  This NPDES pesticide permit requirement goes into effect on April 9, 2011.  Those treating any water bodies directly for mosquitoes, aquatic weeds or nuisance animals and treating forest canopies will be subject to the permitting requirements and the subsequent required reports.  IFCA will provide more information on the NPDES program at the IFCA convention on Jan 20, 2011.  In the meantime please know that bringing reason to the IEPA pesticide permit is a high priority for the IFCA.