EXHIBIT 2 603 FW 2

COMPATIBILITY DETERMINATION USE: Conduct Mosquito Monitoring and Control Operations REFUGE NAME: Big Branch Marsh National Wildlife Refuge DATE ESTABLISHED: October 24, 1994. ESTABLISHING AND ACQUISITION AUTHORITY (IES):

Emergency Wetlands Resources Act of 1986, 16 U.S.C. §3901 (b); North American Wetlands Conservation Act, 16 U.S.C. §4401 2(b)

REFUGE PURPOSE: As defined by the Emergency Wetlands Resources Act of 1986, 16 U.S.C. §3901 (b): (1) “For the conservation of the wetlands of the Nation in order to maintain the public benefits they provide and to help fulfill international obligations contained in various migratory bird treaties and conventions.” As defined by the North American Conservation Act, 16 U.S.C. §4401 2(b): (1) “To protect, enhance, restore, and manage an appropriate distribution and diversity of wetland ecosystems and other habitats for migratory bird and other fish and wildlife in North America; (2) to maintain current or improved distributions of migratory bird populations; and (3) to sustain an abundance of waterfowl and other migratory birds consistent with the goals of the North American Waterfowl Management Plan and the international obligations contained in the migratory bird treaties and conventions and other agreements with Canada, Mexico, and other countries.” Further defined in the 1994 Final Land Protection Plan and two subsequent Supplemental Environmental Assessments (1996, 1998) for expansion of Big Branch Marsh National Wildlife Refuge (Refuge or NWR) as the following: (1) To provide habitat for natural diversity of wildlife; (2) to provide wintering habitat for migratory birds; (3) to provide nesting habitat for wood ducks; (4) to provide habitat for non-game migratory birds; and (5) to provide opportunities for public outdoor recreation, such as hunting, fishing, hiking, bird watching, and environmental education and interpretation, whenever they are compatible with the purposes of the refuge. NATIONAL WILDLIFE REFUGE SYSTEM MISSION: The mission, as defined by the National Wildlife Refuge System Administration Act of 1966 as amended in 1997 (National Wildlife Refuge System Improvement Act of 1997) (Public Law 105–57; 111 Stat. 1282), is:

... to administer a national network of lands and waters for the conservation, management, and where appropriate, restoration of the fish, wildlife and plant resources and their habitats within the United States for the benefit of present and future generations of Americans.

DESCRIPTION OF USE: (a). What is the use? The use is to conduct mosquito management activities on Big Branch Marsh NWR to protect public health when local, current mosquito monitoring data indicates that mosquitoes on the refuge are causing, or are expected to cause a public health threat. The Refuge, using the information provided by the local public health agency or an authorized designated representative. St Tammany Parish Mosquito District (District) will determine the most effective method or combination of methods of treatment that pose the lowest risk to fish, wildlife, and their habitats (Handbook for Mosquito Management on National Wildlife Refuges, 2018). Big Branch Marsh NWR will use an integrated mosquito management (IMM) approach as mosquito and mosquito-borne disease management is not a priority public use of the Refuge System under the National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-668ee), as amended by the Refuge Improvement Act. Mosquito management activities on refuges are considered a use of a refuge and require a Special Use Permit (SUP). Public health authorities may work with refuge staff to implement integrated pest management principles that include the following: (Handbook for Mosquito Management on National Wildlife Refuges, 2018). (1) Identifying mosquito species in the area and understanding their life history and conditions that support their production; (2) Monitoring mosquitoes and mosquito borne pathogen surveillance (as needed) to provide relevant information to refuge staff; (3) Establishing action thresholds that help the Refuge Managers make informed decisions about actions such as pesticide treatments, when needed; (4) Recording decisions and effectiveness of actions implemented; and (5) Monitoring for efficacy, compliance, and non-target impacts. (b). Where would the use be conducted? The Refuge encompasses a variety of habitats along the north shore of Lake Pontchartrain stretching from near the Mississippi/Louisiana state line in the east to Cane Bayou in the west. These habitats include marsh, forested wetland communities and some upland plant communities, all of which contain potential mosquito breeding sites. Larvacides: There are approximately 60 square miles (38,000 acres) of marshland along the southern border of the parish, which breed a variety of floodwater and permanent water mosquitoes. Of those 60 square miles, the refuge encompasses 8,000 acres of marshlands. Within those marshlands, Gambusia sp. consume and control most of the mosquito larvae where there is tidal flow. Ponds and ditches that are only intermittently connected to the tide are areas of most concern to the parish for larvacide spraying. The most common species that breed in the marsh are Culex salinarius, Culex nigripalpus, and Anopheles crucians, which produce about 16 generations a year. Culex salinarius is a competent vector for West Nile virus and St. Louis encephalitis and is the mosquito that bites at dusk and dawn. Extremely large numbers can be produced if left unchecked. Culex nigripalpus is a competent vector for St. Louis Encephalitis. Anopheles crucians can cause an extreme nuisance and will seek a blood meal throughout the night. High tides and/or heavy rainfall following extended drought conditions will produce extremely large numbers of Aedes sollicitans, the salt marsh mosquito, in many marshland locations. This mosquito is a primary vector

for eastern equine encephalitis and will migrate as far as 20 miles from its breeding site in search of a blood meal. Adulticides: Controlling mosquitos in and around developed areas near and within the refuge would require some refuge lands to be treated with adulticides. Areas identified encompass approximately 4,759 acres of pine flatwoods and mixed pine/hardwood forests (U. S. FWS 2007). Refuge areas to be treated coincide with flight paths over private lands. Currently these spray operations would potentially be conducted on forested refuge lands adjacent to private housing and urban areas. The potential exists for overspray of non-target marshlands and other non-wooded wetlands. However, the risk to these non-target environments are considered minimal under present label guidelines and the Environmental Protection Agency’s (EPA) Risk Assessment (Palmisano 2006).

Figure 1. Refuge map showing Adulticide mosquito management areas. (c). When would the use be conducted? Timelines:

• Known sites of mosquito development on the refuge monitored daily throughout the season (March- November).

• Spraying of larvicide would occur weekly as necessary based on results from monitored activities and established thresholds. Applications would occur as needed on and averages 12 to 21 applications per

year with an expected average 12 applications per year. Most of the refuge is tidally influenced and would not receive larvicide treatments.

• St. Tammany mosquito control district monitors and maintains the Centers for Disease Control traps 2-3 times throughout the week.

• Spraying for adult mosquito control would be conducted from March to November annually. Spray operations would be conducted at night from aircraft using ultra low volume spray technology or through trucks. (d). How would the use be conducted?

Mosquito-associated health threats would be addressed using an integrated mosquito management (IMM) approach including, when practical, compatible, non-pesticide actions that reduce mosquito production. St. Tammany Mosquito Abatement establishes thresholds on adult mosquitoes based on the average number of a given species trapped throughout the previous year. In 2019, the threshold for Culex salinarius is set at 85 female adults collected through one night trapping interval, for Culex nigripalpus it is set 150 female adults collected through one night trapping interval, and for Culex quinquefasciatus it is set to 39 female adults collected through one night trapping interval. In addition to adult mosquito thresholds, any detected arbovirus activity can trigger adult mosquito control efforts. Across 96 nights and 18 traps, more than 620,000 adult mosquitoes were trapped in 2018 and 2017. We would choose treatment options based on the Service’s Integrated Pest Management (IPM) policy (569 FW 1) and Biological Integrity Diversity and Environmental Health (BIDEH) policy (601 FW 3). We would base the choice on, in order of preference: human safety and environmental integrity, effectiveness, and cost. We would use human, wildlife, or domestic animal mosquito-associated health threat determinations combined with refuge mosquito population estimates to determine the appropriate refuge mosquito management response. Since 2002, the refuge has reached a positive threat (action threshold) of a virus in or immediately adjacent to the refuge annually, requiring spraying of larvicides and adulticides. Big Branch Marsh NWR is considered an urban refuge by U.S. Fish and Wildlife Service standards and would consider allowing pesticide treatment to control mosquitoes on refuge lands after we evaluate all other reasonable IMM actions. Based on monitoring data, we would determine the most appropriate pesticide treatment options for the relevant mosquito life stage. We would use current monitoring data for larval, pupal, and adult mosquitoes to determine the need for larvicides and adulticides, respectively. St. Tammany Parish Mosquito Abatement District (District), Slidell, Louisiana, would conduct the monitoring and control through the use of biological larvicides and chemical adulticides for the abatement and/or control of mosquito populations within Big Branch Marsh National Wildlife Refuge (Refuge) as identified in the 1995 Environmental Assessment For the proposed Application of Bacillus thuringiensis israeliensis (B. t. i.) for the control of Mosquito Larvae in the Big Branch Marsh National Wildlife Refuge in Lacombe, Louisiana (Palmisano 1995) and the 2006 Environmental Assessment, and the Proposed Application of Aerially Applied Ultra Low Volume Naled for the Control of Adult Mosquitos within the Big Branch Marsh National Wildlife Refuge in Lacombe, LA (Palmisano 2006). The refuge has predetermined special conditions that have allowed airboats to access marsh areas for surveillance and Off-Road Vehicles (ORVs) on designated trails listed in the permit. Additionally, the refuge is closed at night when air operations would be conducted. The District would send monthly reports to the refuge of all spraying of Adulticides and submit information for a pesticide use proposal and special use permit annually. The primary technique for larval population counts is the dip count (using a standard dip cup on the end of a pole). Dips are taken in undisturbed pools identified as representative of the breeding areas. Adult monitoring methods recommended are mosquito traps (Handbook for Mosquito Management on National Wildlife Refuges, 2018). St Tammany Mosquito Control District uses dip nets and mosquito traps. On-refuge treatment of mosquitoes with adulticides may be considered for authorization by the Refuge Manager if

treatment with larvicides has failed to provide the level of control necessary to avoid a human health emergency, as determined by a public health agency or their designated authorized representative. Adulticide treatment of nuisance mosquitoes are not allowed. The District operates an ongoing program throughout the year to monitor for the presence of mosquito borne viral activity. Whenever a virus is detected in a particular area, mosquito control procedures are intensified to reduce mosquito populations in order to reduce the potential risk for humans or animals contracting encephalitis. In most cases, the arbovirus surveillance program will detect viral activity before humans or animals come down with the disease. This gives the District time to react aggressively with controls to help prevent human and animal disease. The arbovirus surveillance is accomplished by the collection of mosquito pools. Mosquito and arbovirus surveillance, monitoring, and treatment within the refuge would continue as in the past and be focused on several small pools within the intermediate marsh along the forest/marsh transition zones on the refuge and along public roads. Treatment areas would be based on surveillance and monitoring results. Specific areas treated and the extent of treatment would vary from year to year depending on mosquito populations, the mosquito vector flight distance, and environmental conditions. LARVICIDES Larvicide use is considered preferable to using mosquito adulticides for several reasons listed in the 2018 Handbook for Mosquito Management on National Wildlife Refuges: (1) Larvicides prevent the emergence of adults; (2) Larvicides can provide up to a month (or longer) of control, rather than the few hours provided by adulticides; (3) Most larvicides are far less toxic than adulticides; and (4) Larvicides are generally applied to smaller spatial areas, thus impacting fewer non-target resources. Organophosphate mosquito larvicides are not recommended to be used on refuges (Handbook for Mosquito Management on National Wildlife Refuges, 2018). Woodlands are more inland from the marsh and in close proximity to area residents. The primary means of control of floodwater mosquitoes that breed in swales, potholes, and depression areas filled with water, is by the use of Altosid XR Briquets (methoprene) which are about the size of a role of lifesavers. The District has identified thousands of floodwater breeding sites throughout the parish. The briquets are applied in the early spring to known breeding sites as a pre-flood treatment or before larvae are present. When rainfall occurs and mosquito eggs hatch, the methoprene is slowly released from the briquets into the aquatic habitat and effectively kills the larvae. The briquets remain effective for about five months. A subsequent application is performed in the late summer or early fall. The district would inspect flooded ponds within the refuge through special use permit to determine the need for the use of methoprene. As identified in the 2018 Handbook for Mosquito Management Activities on Refuges, objectives for mosquito monitoring are to: 1) Determine if areas on the refuge exceed established action thresholds as a basis to determine if treatment is warranted. 2) Establish a baseline of mosquito species present and relative abundance. 3) Identify mosquito source habitats and determine the relative contribution of refuge sources to the regional vector populations. 4) Detect changes in relative abundance, and 5) Determine the seasonality for mosquito monitoring based on mosquito activity and life stages. The refuge has documented hundreds of marshland locations that breed mosquitoes. When mosquito breeding counts reach a specified threshold, as determined by analysis of inspection data, and depending on the species and size of area, larvicide treatments would be performed by an aircraft to reduce mosquito breeding. The aircraft can apply Bti as either a liquid or granule, depending on the circumstances. Evaluations of treatments have indicated excellent control with these applications. This would allow the District to reduce the amount of use of conventional insecticides on the refuge.

ADULTICIDES Adulticiding is the term used to describe the process of applying insecticides to kill the flying adult mosquito. Adulticide treatments are performed by aircraft equipped with Ultra Low Volume (ULV) aerosol sprayers. Adulticide treatments are primarily performed at night because most mosquitoes are active after dusk. During the summer, the air is more stable at night with less wind and less thermal uplifting caused by heating from the sun. Droplet size of the spray particles range from 20-25 microns in diameter for the aerial applications. The concept for the applications is to have small spray particles suspended in the air long enough for them to effectively impinge on the flying adult mosquitoes. All adulticide treatments would be performed after the analysis of mosquito and arbovirus surveillance data, and only when they are needed to reduce nuisance levels or for mosquito borne disease prevention. All products used for adulticiding are registered and approved by the EPA and when used according to labeled directions, do not pose any unreasonable risk to the environment or human health. State and local agencies commonly use the organophosphate insecticides malathion and naled and the synthetic pyrethroid insecticides prallethrin, etofenprox, pyrethrins, permethrin, resmethrin, and sumithrin for adult mosquito control. Mosquito traps would be utilized to collect data on adult mosquito activity in order to provide information on the relative abundance and distribution of species of mosquitoes in many locations throughout the parish. A landing rate is defined as the number of mosquitoes identified landing on a still human (inspector) in a one minute time period. Although this sampling method is an excellent means of estimating the adult mosquito populations of many species. Landing rates/bite counts are not a recommended monitoring methods on refuges to be used as trigger points for treatment. The Centers for Disease Control (CDC) trap is a portable mosquito trap and can easily be moved and deployed at many sampling locations. The trap uses carbon dioxide (CO2) and light as an attractant to enhance the collection. CO2 baited CDC light traps also serve to evaluate the effectiveness of adulticide treatments. In addition, these traps are used to collect live mosquito specimens that are sent to the Louisiana State University School of Veterinary Medicine Diagnostic Lab to be tested for West Nile virus, St. Louis encephalitis, and eastern equine encephalitis. It is very important that the District has information as to whether or not mosquito borne viral agents are in the parish. Another mosquito collection trap used is a no light CDC trap. These traps are primarily used to obtain information on the southern house mosquito, the primary vector for West Nile virus and St. Louis encephalitis. The specimens collected are then tested for the presence of West Nile virus and St. Louis encephalitis. A few CDC traps would be located on the refuge, especially along Sapsucker Road. Action thresholds (trigger points) to determine if treatment is necessary by adulticides are triggered by the presence of a human or animal with any of these diseases, and light trap collections of mosquitos (greater than ten/minute or when light trap collections of 100-300 or more mosquitoes per night), an increase of a potential vector species, any presence of viruses or mosquito-borne pathogens after analysis of bird sampled blood, mosquito pools show presence of the arthropod borne encephalitis virus, or any human cases of mosquito-borne disease in the area. The district would operate aircraft at an altitude of 300 feet at a speed of 140-150 mph. All spray operations would be approved by the Federal Aviation Administration (FAA). The crew would consist of a FAA qualified pilot and co-pilot. For extra safety measures, the co-pilot would be equipped with night vision goggles. Each aircraft would have a global position system (GPS) guidance system that the crew would use for following a predetermined flight path and spray grid. An onboard weather station would keep the pilot informed to actual wind speed and direction at the point of spraying and would make flight adjustments when necessary. Applications would be calibrated and performed with a swath width of 1,000 feet. The margin of error is three feet using a GPS system. A flight recorder on board would graphically record the spray mission so it can be overlaid on a map. Naled is a commonly used organophosphate for the control of adult

mosquitoes, but has been rarely used throughout refuges in the United States due to its known non-target impacts. However, the St Tammany Parish Mosquito Control has studied the use of other chemicals such as malathion which has shown to be ineffective (personal communication). Other chemicals that have been used such as Prallethrin Films, Etofenorox, Pvrethrins, Permethrin, Resmethrin, and Sumithrin, are not recommended because they are highly toxic to fish, aquatic invertebrates and bees. Although larvicides are the preferred method of control, the chemical Naled, under the trade name Dibrom, would be used for these applications when larvicides have been found to be ineffective. Naled would be sprayed at a rate of 0.75 ounces per acre, which is the midrange of the labeled rate. Aerial applications are reserved for those mosquito populations which cannot be effectively controlled by the ground ULV treatments. Spray operations would be conducted at night from aircraft or from the ground using ultra low volume spray technology. Spraying at night maximizes potential for exposure by mosquitoes to the insecticide since they are most active aerially at night. This also minimizes exposure by diurnal insects and wildlife, specifically red-cockaded woodpeckers (RCW’s). We would allow the use of adulticides only when there are no practical, effective alternatives to reduce a health threat. We would not allow pesticide treatments for mosquito control on the refuge without current mosquito population data indicating that such actions are warranted. We require an approved Pesticide Use Proposal (PUP) prior to an application of a pesticide on refuge lands and manage use through Special Use Permitting. Pesticide treatment may not be used on Big Branch Marsh NWR solely for nuisance mosquito relief, but may be considered when there is an action threshold demonstrated human or wildlife health risk and mosquito management actions will not interfere with refuge goals and objectives. Only pesticides identified in the SUP and for which a PUP has been submitted and approved will be used on the refuge. The preferred larvicide treatments for use on the refuge are Bacillus thuringiensis israelensis (Bti) or Bacillus sphaericus (Bs), because of the bacterium’s limited non-target effects. Bti/Bs is the preferred control option and will be used under appropriate conditions before methoprene is considered. We favor using the larvicide that would have the least adverse impacts on non-target invertebrates, produce fewer disruptions to food webs critical for migratory birds, and reduce lethal effects on natural mosquito predators, such as larval forms of odonates, hemipterans, and coleopterans. The District will conduct post-larvicide monitoring to determine effectiveness. Ultra low volume application of Dibrom, when warranted, would be used for the control of adult mosquitoes in the forested areas of the refuge and the continuation of such activities in other forested areas within the district, which may be added to the refuge in the future. The use of Dibrom would be restricted to the forested portions of the refuge. These areas serve as both production sites for certain mosquito species and as staging areas for saltmarsh breeding mosquitoes prior to their dispersal to other areas, including adjacent urban zones. The use of ultra-low volume spray technology provides for the application of the insecticide at rates determined to minimize potential risk to non-target insect species. Currently the District employs aircraft and truck mounted ultra-low volume sprayers to conduct adulticide operations. Truck mounted sprayers would aerosolize the insecticides into 15-20 micron particles and aerial applications would spray at 20-30 micron ultra-fine mist. Future additions of planes or pilots would not affect this determination. The District is currently engaged in testing of new equipment and techniques to further reduce the rates at which the insecticide would be applied. Chemicals would be applied at 300 feet elevation at speeds of 140 mph with a spray width of 1,000 feet along a general east west orientation using a global positioning system. Current application rates have been 0.75 oz/acre (0.077 lbs/acre within the last 12 years. Maximum label rate is 1 oz/acre. The average aerial application rate reported in 1998 by the Florida Coordinating Council on Mosquito Control was 0.88 oz/acre (Palmisano 2006). Treatment regimens will vary annually, depending on the current threat level; the process for determining the threat level will be clearly delineated in the District’s NWR Mosquito Management Plan. Because disease threat levels vary from year to year, mosquito management on the refuge is unlikely to include all phases in any given year. Action thresholds that trigger chemical interventions will incorporate various factors listed in Service Policy 601 FW 7, Exhibit 3, as developed with refuge staff, State mosquito control section, public human health services, and vector control agencies. Thresholds must be genus and life-stage specific and be

related to the refuge decision-making response matrix. Known sites of mosquito development on the refuge will be visited for monitoring and surveillance during periods of mosquito production by the mosquito district staff under the conditions of this compatibility determination (CD) and a Special Use Permit (SUP). The timing and frequency of monitoring is based on a number of factors, including history of mosquito production, tidal cycles, precipitation levels, and available resources, but could occur as frequently as weekly throughout the season. Mosquito control occurs irregularly when necessary to protect the health and safety of humans, wildlife, or domestic animals. Any mosquito control activities will be conducted based on mosquito sampling and inspection surveillance data. Without good inspection data, it would be virtually impossible to conduct an effective and efficient mosquito abatement program. Mosquito sampling methods used at the District are directed to collect data on mosquito adults and larvae. Strategies for control operations are based on the analysis of the data. The best indication that a site produces mosquitoes is to find mosquito larvae in the water. Inspection of mosquito breeding areas is one of the most time consuming parts of the mosquito management program. The District regularly inspects more than 2000 breeding sites across the parish. The size of these breeding sites can vary from as small as a few square feet to several hundred acres. These sites include areas such as marshes, woodlands and pastures, roadside ditches, swamps, and artificial containers. When a site is observed to be breeding mosquitoes, if practical, it is treated to prevent the mosquito from reaching the adult stage. Monitoring these areas also provides the District with a forecast of the types of mosquito problems to expect in the next few days. The forecast permits the District to plan strategies and ensures that the most effective control approach is in effect. Larval inspection is accomplished by the use of airboats, off-road vehicles, and on foot. Biologists and mosquito control inspectors perform these duties daily. Variations in annual permit restrictions may be necessary to accommodate wildlife breeding, roosting, and feeding activity, endangered species, administrative needs, public use management, research, or monitoring protocols. Other conflicts that may arise will be incorporated into the annual permit to ensure there are no significant adverse impacts on refuge wildlife and habitats. The District would be required to provide the refuge manager with an annual quantitative summary of refuge mosquito control activities on the refuge (e.g., type of pesticides applied, amount of pesticides applied, locations of application, and method of application). All surveillance and control activities would be spatially referenced as technologies develop at the District, e.g., use of global positioning satellites and GIS. (e). Why is this use being proposed? Mosquitoes are biting flies that cause mortality and morbidity worldwide with more than a dozen vector-borne diseases transmitted to humans in the U.S. alone (Palmisano 2006). Areas around and including the refuge lands prior to refuge establishment have been receiving adult mosquito control since 1969. The U.S. Fish and Wildlife Service (Service) recognizes that mosquitoes are a natural component of most wetland ecosystems but may also represent a threat to human, wildlife, or domestic animal health. Refuges are to collaborate with Federal, State, or local public health authorities and vector control agencies to identify refuge-specific health threat categories that represent increasing levels of health risks and are based on monitoring data. Refuges will not conduct mosquito monitoring or control, but may allow these activities under a SUP (Handbook for Mosquito Management on National Wildlife Refuges, 2018). The refuge does not currently have a Mosquito Management Plan or an Integrated Pest Management Plan. The St Tammany Mosquito Control has a mosquito Management Plan for the Parish of which portions have been adopted and described within this compatibility determination until the refuge develops its own Mosquito/Integrated Pest Management Plan.

The use is proposed to minimize health risks to humans and wildlife from mosquito-borne disease, including West Nile Virus, Dengue Fever, Chikungunya, La Crosse Encephalitis, Eastern Equine Encephalitis, St. Louis Encephalitis, Western Equine Encephalitis, and Zika Virus. Mosquito population monitoring is necessary to detect changes that indicate increased human or wildlife health risks. In addition, surveillance for incidence of mosquito-borne disease by testing wildlife, especially birds, and adult mosquitoes for pathogens is needed to help characterize the level of health risk. There is a documented history of human West Nile Virus (WNV) infections near the refuge, which warrant continuing to annually monitor mosquitoes for the near future. The goal of early mosquito larvae monitoring is rapidly detecting relative and absolute changes in population size that can indicate an increased short-term risk to human, wildlife, or domestic animal health. Some of these mosquitoes are bridge vectors, meaning these species feed on birds and other animals, thereby enhancing the risk of disease transmission to people. Almost every year for the past 40 years there has been evidence of mosquito borne virus within St. Tammany Parish, namely West Nile Virus, St. Louis encephalitis, and eastern equine encephalitis. In 1998, there was one human case of St. Louis encephalitis. In 1997, there was one horse death due to eastern equine encephalitis. Since 2002, there have been human cases of WNV each year averaging 13.5 human cases each year. The District had expanded their ability to control mosquito populations post-emergence on all refuge lands through the use of the chemical insecticide Dibrom (active ingredient Naled) in 2007. Prior to the acquisition of the forested areas into the Big Branch Marsh National Wildlife Refuge, Naled was used as a mosquito adulticide in the area. In 2007, the refuge approved the use of Naled as an adulticide on the refuge adjacent to public owned urban sites through the Comprehensive Conservation Plan (CCP) (U.S. FWS 2007) with subsequent special use permits and pesticide use proposals. The marsh and forested wetland areas of the refuge are considered by the District to be significant in both the potential production of mosquitoes and control of mosquito populations before they spread to adjacent urban areas. The species of mosquitoes found within the refuge include several species known or suspected to be important biological vectors of arthropod borne diseases, specifically malaria, St. Louis encephalitis (SLE), eastern equine encephalitis (EEE), LaCrosse encephalitis (LE), West Nile virus (WNV), and others. Both SLE and EEE have been documented in St. Tammany Parish and adjacent parishes. In 2002, a major outbreak of West Nile occurred in Louisiana with 329 cases and 29 deaths, of which 40 cases were in St. Tammany Parish near the refuge (Palmisano 2006). During 2018, 4,984 pools of mosquitoes or 228,853 individual mosquitoes from St. Tammany Parish were submitted to the Louisiana Arbovirus Disease Diagnostic Laboratory (LADDL) in Baton Rouge. Sixty-six pools tested positive for West Nile virus. The Louisiana Department of Health reported ten human cases of West Nile virus (seven of which were West Nile neuro-invasive disease cases) from St. Tammany parish in 2018. (Louisiana Arbovirus Surveillance Summary 2018). Big Branch Marsh NWR is an urban refuge and many public use goals in the CCP focus on increasing wildlife observation, photography, environmental education and environmental interpretation in the outdoor setting of the refuge. To provide these activities safely, we cannot put people in harm’s way by not taking steps to prevent viruses from attacking visitors. The plan encourages the refuge to work cooperatively with local, State, and other Federal agencies for visitor safety (U.S. FWS 2007). The 2011 Visitor Services Plan identified all refuge interpretive programs would provide safety oversight for all individuals (U.S. FWS 2011). The location, habitats, and climate of the refuge all contribute to the potential need for control of mosquito populations. Factors contributing to this need include the sub-tropical location in southeast Louisiana, large amounts of rainfall throughout the year (55+ inches), susceptibility to major rain events associated with hurricanes and other tropical storm systems, long warm/hot growing season, abundant vegetation, and wetland habitats. Adding to this are the large number of mosquito species including known disease vector species.

Several wildlife diseases have been found to be transmitted by mosquitoes. WNV has been discovered in St Tammany Parish annually since 2002 and the area has a history of mosquito-borne WNVand Equine Encephalitis. In Palmisano’s 2006 environmental assessment he stated that Equine Encephalitis attacks horses as well as humans and it’s reservoir for disease transmission by mosquitoes is passerine (including migratory) birds such as geese and sparrows which inhabit the refuge. Potential risk for amplification of these viruses is high without treatments. In 1995, the refuge approved the application of selected larvicides Bacillus thurigensis israelensis (Bti) and Bacillus sphaericus (Bs) for use within the refuge marshes based on the Palmisano 1995 EA. Application of Bs was approved after receiving the environmental assessment entitled Proposed Application of Bacillus thurigensis israelensis for the control of mosquito larvae in the Big Branch Marsh National Wildlife Refuge in Lacombe, LA, which addressed thresholds for control. Bti and Bs are selective microbial insecticides targeting mosquito larvae, with minimum impact to other non-target species. These larvicides are applied to aquatic environments where mosquito larvae occur since it must be ingested to be effective. Being ingested by larvae, it is largely species- specific as a stomach poison and poses a minimal threat to non-target vertebrate and invertebrate species. This bacterium produces a crystal-containing spore that causes a fragment toxicity when ingested by the mosquito larvae. Another non-conventional material used to treat mosquito larvae is methoprene, under the trade name Altosid. This material is considered to be a biorational product. Altosid is formulated either as a liquid, pellet or briquet. Methoprene is an insect juvenile hormone and acts to keep the mosquito larva from developing beyond its larva stage. The immature mosquito dies either as a larva or pupa and does not emerge as an adult. A natural soil bacterium, Bti, like other varieties of Bacillus thuringiensis (Bti), is a stomach poison that must be ingested by the larval form of the insect in order to be effective. Bti is an EPA toxicity class III general use pesticide and is practically non-toxic to animals (Extoxnet 1996). Bti is specific to certain primitive dipterans, especially mosquitoes, black flies, and some chironomid species (Boisvert and Boisvert 2000), and is not known to be directly toxic to non-dipteran insects; there are no toxic inert ingredients included in Bti products (Extoxnet 1996). Bti produces protein endotoxins, activated in the alkaline mid-gut of target insect species that bind to protein specific receptors of dipteran larvae species, resulting in mortality. Bti must be ingested by the target insect to be effective and is most effective on larval salt marsh mosquito instar stages 1 and 2; it is considerably less effective against instar stages 3 and 4; and has no effect on pupae or adult mosquitoes. This approval and the use of Bti and Bs remained in effect and has been an important tool for the control of mosquitoes pre-emergent by the District. By treating mosquito-breeding areas with Bti or Bs, the mosquito district has demonstrated that it can dramatically reduce the need for the use of adulticides on the refuge to control mosquitos. Refuge sites to be treated with larvicides include all areas of the refuge serviced by refuge or public roads. In addition, lands where ephemeral ponds exist that are not connected to tidal areas or have presence of Gambusia sp. would be treated with larvicides via air-boat or aerial applications of Bti or Bs. Naled has been identified as the most effective and economical adulticide out of the currently available registered mosquito adulticides for aerial applications through a USDA risk assessment (Palmisano 2006). Naled has been approved by EPA since 1959 for controlling adult mosquitoes. In addition, prior to the need for adulticides, the District would continue to apply BS, BTI, or other biological products labeled for control of mosquito larvae directly in aquatic environments that do not have the presence of Gambusia (mosquito fish) at a rate of up to 30 fluid oz/acre or 8-10 lbs. acre of granules by fixed wing aircraft or helicopter. Big Branch Marsh NWR is an urban refuge. Refuge lands are interspersed with private lands, making it impossible to develop separate mosquito spraying programs for both public and private lands within the urban interface. AVAILABILITY OF RESOURCES:

Based on a review of the Refuge’s budget allocated for this activity, there is adequate funding to ensure compatibility and to administer the use at its current and anticipated levels. The staff time for the administration of allowing St Tammany mosquito control is already committed and available to support this use. Most of the work needed to implement this activity would require annual special use permits, pesticide use reports, Section 7 concurrence in the Endangered Species Act, and associated reporting. The District will conduct all monitoring and control, coordinated with the refuge manager on an annual basis through the issuance of an SUP. (a). Resources involved in the administration and management of the use. Refuge staff would be responsible for administering this CD and associated National Environmental Policy Act (NEPA) compliance documents and monitoring the use and any impacts or damages to refuge resources. Administration of the signage and maintenance of the program would be supplied by the St Tammany Mosquito Abatement District. Administration of the program by refuge staff would consist of approximately five staff days per year or less than 2.5 % of refuge staff time dedicated to administering to this activity. (b). Special equipment, facilities, or improvements necessary to support the use. None by refuge resources. (c). Maintenance costs. There are refuge no maintenance costs associated with allowing this use. (d). Monitoring costs. Existing refuge resources are used to develop Pesticide Use Proposals (PUP), SUP, and report actions conducted by the District through PUPs, Servcat or other database storage. There are no additional monitoring costs associated with this use. (e). Offsetting revenue. None. ANTICIPATED IMPACTS OF THE USE: An Environmental Assessment (EA) was completed in 2006 by Chuck Palmisano, entomologist and director of the St Tammany Mosquito Control District (District), titled “Environmental Assessment. Proposed Application of Aerially Applied Ultra Low Volume Naled for the Control of Adult Mosquitos within the Big Branch Marsh National Wildlife Refuge in Lacombe, LA”. The EA identified impacts of monitoring and control of mosquitos on refuge lands described below. Direct impacts of monitoring and control include temporary disturbance to habitat and possible direct effects to non-target wildlife. Areas of vegetation may be crushed underfoot, with impacts ranging from temporary in nature to loss of habitat over time. Invasive weeds may be introduced or spread by foot. Indirect effects associated with mosquito control include impacts to food sources for wildlife, including reducing mosquito populations and other non-target species that serve as the base of food chains for wildlife species (especially red-cockaded woodpeckers). Impacts to birds as a result of physical access (trampling of vegetation, nests, and disturbance of airboat use) for mosquito management could occur, but are reduced during waterfowl seasons to not significantly affect bird populations of the refuge. Airboat use is restricted during all waterfowl hunt season dates on the refuge. Chemical Treatment Effects on Target Mosquito Populations: The use of mosquito larvicides generally is considered preferable to the use of adulticides because larvicides prevent the appearance of the blood feeding adults; larvicides can provide up to a month of control, rather than the few hours provided by adulticides; the commonly used larvicides are less toxic than the adulticides and the application method greatly reduces human exposure; and larvicides generally are applied to smaller areas than are adulticides. A natural soil bacterium, Bti/Bs, like other varieties, is a stomach poison that must be ingested by the larval form of the insect in order to be effective. Bti is an EPA toxicity class III general use pesticide and is

practically non-toxic to animals (Extoxnet 1996). Bti is specific to certain primitive dipterans, especially mosquitoes, black flies, and some chironomid species (Boisvert and Boisvert 2000), and is not known to be directly toxic to non-dipteran insects; there are no toxic inert ingredients included in Bti products (Extoxnet 1996). Bti produces protein endotoxins, activated in the alkaline mid-gut of target insect species that bind to protein specific receptors of dipteran larvae species, resulting in mortality. Bti must be ingested by the target insect to be effective and is most effective on larval salt marsh mosquito instar stages 1 and 2; it is considerably less effective against instar stages 3 and 4; and has no effect on pupae or adult mosquitoes. The preferred larvicide for use on the refuge is Bti. Methoprene is a contact insecticide that does not need to be ingested like Bti (Tomlin 1994); it ranks as a toxicity class IV, and is considered slightly to practically nontoxic by EPA. Methoprene compounds like Altosid Liquid Concentrate and Altosid Single-Brood Granule all mimic the action of an insect growth hormone and interfere with the normal mosquito maturation process, acting as an insect growth regulator preventing mosquito larvae from pupating and reaching the adult stage. Adulticides appear to effectively control adult mosquito populations and spread of mosquito-borne disease such as WNV (Carney et al. 2008), but only for a brief time, and are therefore only recommended during a disease event to break the disease transmission cycle. Adulticides kill only mosquitoes that contact insecticide droplets. The fog soon dissipates. Although the local mosquito population is reduced for a few days, fogging does not prevent mosquitoes from re-entering the sprayed area. Adulticides will be considered only in the case of a declared public health emergency. Focused timing and location of adulticide application to control mosquito disease vector source populations is essential for effectiveness. Short-term Impacts Naled has strong public health benefits of reducing mosquito borne diseases. By limiting aerial spraying to late evenings, the risk of exposure to humans is limited since there are 8-12 hours of chemical drying and degrading prior to human interaction. In addition, EPA has assumed a zero order dermal transfer rate which greatly exaggerates the calculated risk to humans. (Palmisano 2006). Palmisano concluded that USDA risk assessments have overestimated the risk from Naled, which were based on assumptions, models, and extrapolations and further concluded that Naled rapidly disseminates and degrades, making risk assessment conclusions not very credible. By applying an ultra-low volume by aircraft, and at the 0.75 oz/ acre, the active ingredient is not expected to drift to aquatic environments or establish on the surface of vegetation but to disseminate in the atmosphere prior to reaching the earth’s surface (personal communication Director of St. Tammany Mosquito control). Palmisano concluded that it is doubtful that residues of Naled or its metabolite can be detected on foliage or turf when Naled is applied according to label directions since Naled dissipates through volatilization and degradation rapidly (Palmisano 2006). Spray droplet sizes in an ultra-low volume application are near 20 microns. EPA concluded in their risk assessment that acute and chronic risks are not a concern for birds, animals, or fisheries and that human risks from aerial adulticide spraying of Naled at label rates are of no concern through dietary exposure or drinking water exposure. This product is highly toxic to bees, including alkali, alfalfa leafcutter bees, and honeybees, exposed to direct treatment on blooming crops or weeds. To minimize hazard to bees, product is not to be applied more than two hours after sunrise or two hours before sunset. Do not apply or allow drift to blooming crops or weeds while bees are visiting treatment area except when applications are made to prevent or control a threat to public and/or animal health. Naled contains the petroleum distillate naphthalene (<1 to 2%), which is hazardous to the aquatic environment. Naled is moderately to very highly toxic to freshwater fish on an acute basis. Fathead minnows, bluegill, and mosquito fish are particularly sensitive to. Do not apply over bodies of water except when necessary to target areas where adult mosquitoes are present and weather conditions will facilitate movement of applied material away from the water to minimize incidental deposition into the water body. Runoff from treated areas or disposition of spray droplets into water may be hazardous to fish and aquatic invertebrates (Naled 2015). Long-term Impacts No long-term impacts to wildlife would be expected since Naled has a half-life of 2 days. In aqueous media, Naled showed a half-life of 15 hours. In air, half-life is 1.8 hours. Although honeybees were highly

susceptible to exposures after 1-hour of an application rate of 16 oz/acre (16 times label rate), 1-day residues were practically non-toxic (Palmisano 2006). Applications would be applied at night when honeybees have returned to their hives and at significantly reduces application rates. Used according to label directions, exposures are considered to be hundreds and even thousands of times below the amount that might cause human health concerns, assuming human ingestion of soil and grass as well as dermal and inhalation exposure over weeks of spraying (Palmisano 2006). Chronic risk to fish is not expected. Chronic risks to invertebrates is expected based on studies reported in the safety data sheet for Naled and from studies on effects of spraying Naled on insects (Ecostat, Inc. 2005). The insecticide Naled kills invertebrates which provide food for wildlife. However, it has been decided that human health will take precedence, and insecticide treatment may be required to prevent mosquito-borne disease. A U. S Fish and Wildlife Ecological Services computer model was used to aid in their Section 7 consultation, which showed that pesticide treatments would "not likely adversely affect" the endangered red-cockaded woodpecker. Naled is a restricted use pesticide and is not approved for spraying over crops. The refuge has no share crop farmers. This active ingredient may only be authorized for use on Service lands and waters when a public health agency or their authorized, designated representative has documented a need to use this mosquito adulticide to protect public health. In 2005, a study was conducted by EcoStat, Inc. to determine whether aerial application of Naled for mosquito control would be likely to negatively impact the RCWs on Big Branch Marsh NWR. That study found the potential risk to RCWs to be negligible and potential risk to the bird’s prey to be insignificant (Ecostat, Inc. 2005). Cumulative Impacts No cumulative impacts would be anticipated with this use. Studies have shown that Naled does not bio accumulate when killifish were exposed over a 7 day period at 8 times the approved application rate (Palmisano 2006) . St. Tammany Mosquito Abatement has used Naled in the rest of the Parish since the 1970’s for the control of adult mosquitoes. No cumulative effects have been documented. Dr. Caillouet, (Director St. Tammany Mosquito Abatement) has observed predation on nestling birds by mosquitoes while conducting WNV transmission research. In a further effort to limit non-target effects only limited parts of the Refuge are treated. No cumulative impacts are anticipated with the use of Bacillus thuringiensis israelensis (Bti) or s-methoprene. For Bti, research performed by Timmerman and Becker (2017) indicated that there were no statistically significant differences in both non-target insect availability as well as feeding predator abundance in treated and untreated sites. For both Bti and s-methoprene, Russell et. al (2009) found no significant effects on non-mosquito arthropod assemblage within subtropical saltmarshes. PUBLIC REVIEW AND COMMENT: The public previously had the opportunity to comment on this use through the 2007 Environmental Assessment for the draft Comprehensive Conservation Plan (USFWS 2007). Public comments were analyzed at that time and a final Comprehensive Conservation Plan, including a final Mosquito CD, and Finding of No significant Impact was approved in the 2007 (USFWS 2007). The current public review and comment period builds upon the previous public involvement. Public notification and review on the CD revision will include a 15-day comment period from July 3, 2019 through July 18, 2019. Copies of the document will be displayed at the Southeast Louisiana National Wildlife Refuge Complex (Complex) Headquarters. The document will also be made available on the Complex website and distributed by news releases to the media outlets (including The Advocate Newspaper, The Daily Advertiser Newspaper, and The Times Picayune Newspaper). The Louisiana Department of Wildlife and Fisheries is in agreement and supports the efforts of refuge management in allowing chemical and larvicide treatments for public safety.

Letters will be sent to representatives of Tunica-Biloxi Indians of Louisiana, Alabama Coushatta Tribe of Texas [Louisiana]; Coushatta Tribe of Louisiana; Jena Band of Choctaws; Mississippi Band of Choctaws; Tunica-Biloxi Tribe of Louisiana, Chitimacha Tribe of Louisiana, and Choctaw Nation of Oklahoma, requesting issues they would like to see addressed in the Compatibility Determination with request for a 15 day comment period. The Service will consider all substantive comments received in the development of the final Compatibility Determination. Summary of Comments Received: DETERMINATION (CHECK ONE BELOW): ☐ USE IS NOT COMPATIBLE

☒ USE IS COMPATIBLE WITH FOLLOWING STIPULATIONS STIPULATIONS NECESSARY TO ENSURE COMPATIBILITY:

• Following best management practices, including spraying only after identified vector thresholds have bene reached and following the label directions, including only applying pesticides when wind speeds are at or below 10 MPH to minimize drift (generally during the evening hours), calibrate application equipment, conduct field scouting/monitoring before pesticide application, observe buffers around sensitive areas such as in red-cockaded clusters, and using the lowest effective rate on the label. Naled would only be applied after larvicides have no longer been effective in controlling outbreaks.

• Applications will be based on the annual Pesticide Use Proposal for the use of Naled (Dibrom),

including number of approved applications, and no more than the application rate listed on the pesticide label.

• Applications should be at least 7 days apart, unless mosquito borne disease activity indicates that such an interval is inadequate to protect public health. Application of adulticide should occur when wind speeds are less than 10 MPH and in the evening and morning hours. Treatments will occur on or adjacent to USFWS land during peak mosquito season (March-October). The mosquito district will perform as few treatments as required. The Mosquito abatement staff consider the following prior to spraying: presence of equine encephalitis or west Nile virus, success of hand treatments of bacterial agent, analysis of mosquito trap collections of 100-300 or more mosquitoes per night, and increase in number of vector species. The mosquito district inspects refuge forest interior ponds monthly to determine if spraying is required.

• Use is authorized only when incidence of disease is confirmed by public health officials (and/or their authorized representative within the mosquito control district) in sentinel organisms; by human health cases caused by mosquitoes that do occur on refuge and are capable of vectoring the disease; by confirmation that mosquitoes on refuge are capable of vectoring disease.

• Use of Naled must be approved by the Division of Environmental Contaminants in the Washington

Office (WO) of the U.S. Fish and Wildlife Service and any special conditions will be made a part of a Special Use Permit and Pesticide Use Permit.

• In accordance with Integrated Mosquito Management, the District will continue in its use of biological larvicides as a first line treatment; methoprene as a second line defense; and adulticiding, where appropriate and applicable, as a third line defense.

• The District will continue the use of ultra-low volume aerial applications.

• The District will continue to explore new spray technologies aimed at reducing rates or numbers of applications and implement such technologies when proven to be effective and reliable.

• The District will continue its monitoring efforts and provide such information to the Refuge.

• The District will notify the Refuge Manager prior to any adulticide application and provide monthly

reports of all treatments and monitoring records.

• The District will continue the use of GPS technology to target spray sites and reduce impacts to non-target marsh and other sites.

• The District will work cooperatively with the Refuge to educate the public on mosquito control efforts

on Refuge lands, and provide information to Refuge neighbors on the role they can play in reducing mosquito populations in their homes and communities.

JUSTIFICATION: Given the Refuge’s proximity to an urban area, the human health threat demonstrated in the District’s area of operation, and the dense mosquito populations of Southeast Louisiana, the Service recognizes the need for nuisance treatment of mosquito populations in Big Branch Marsh Refuge. The nuisance treatment is permitted in order to reduce the previously demonstrated occurrences of mosquito borne diseases in proximity to Big Branch Marsh Refuge. An environmental assessment was created in February, 2006 for ultra-low volume aerially applied Naled which was found to be the most effective adult mosquitocide currently available (Palmisano 2006). Other alternatives that were deemed not acceptable include electro-mechanical traps, biological, behavioral, biochemical and genetic. Naled is an organophosphate, which is commonly used globally to control mosquitoes and blackflies. It is used in food and feed crops, in greenhouses and in pet flea collars. The most common alternative to Naled is Malathion, which is more costly and rendered more ineffective (Palmisano 2006). The stipulations outlined above should minimize potential impacts relative to wildlife/human interactions. At the current and anticipated levels of visitation, the management of mosquito use does not conflict with the national policy to maintain the biological diversity, integrity, and environmental health of the refuge. Based on available science and best professional judgement, the Service has determined that the monitoring and management of mosquito use at Big Branch Marsh NWR, in accordance with the stipulations provided here, would not materially interfere with or detract from the National Wildlife Refuge System mission or the purposes of the refuge. Categorical exclusions are classes of actions which do not individually or cumulatively have a significant effect on the human environment. Monitoring and management of mosquitos can be categorically excluded from further NEPA analysis under 40 CFR §1508.4, and the following DOI and/or FWS Categorical Exclusions: DM 516 DM 8.5 (A)(1), Changes or amendments to an approved action when such changes have no or minor potential environmental impact; 516 DM 8.5 (B)(7), Minor changes in the amounts or types of public use or Service or State-managed lands, in accordance with existing regulations, management plans, and procedures; 516 DM 8.5 (B)(9), Minor changes in existing master plans, comprehensive conservation plans, or operations, when no or minor effects are anticipated. Examples could include minor changes in the type and location of compatible public use activities and land management practices;

516 DM 8.5 (C)(5). The issuance or reissuance or special use permits for the administration of specialized uses, including agricultural uses, or other economic uses for management purposes, when such uses are compatible, contribute to the purposes of the refuge system unit, and result in no or negligible environmental effects. Further, the actions do not trigger an extraordinary circumstance as outlined under 43 CFR §46.215. The monitoring and management of mosquito is consistent with the 2007 Comprehensive Conservation Plan, associated Environmental Assessment, and Finding of No Significant Impact (USFWS 2007a), for the refuge. Environmental conditions and mosquito monitoring and management have not changed substantially since that analysis. This compatibility determination updates and replaces the 2007 compatibility determination for monitoring and management of mosquito within the CCP. Conditions imposed in the required SUP will help ensure that these activities minimize impacts. Approved monitoring and management of mosquitos would not conflict with the national policy to maintain the biological diversity, integrity, and environmental health of refuges with the refuge nor would they materially interfere with or detract from the purposes of the refuges. NEPA COMPLIANCE FOR REFUGE USE DECISION: ___ Categorical Exclusion without Environmental Action Statement _X_ Categorical Exclusion and Environmental Action Statement ___ Environmental Assessment and Finding of No Significant Impact ___ Environmental Impact Statement and Record of Decision

REFERENCES CITED:

Boisvert, M. and J. Boisvert. 2000. Effects of Bacillus thuringiensis var. israelensis on target and nontarget organisms: a review of laboratory and field experiments. Biocontrol Science and Technology 10: 517-561. Carney, R.M., S. Husted, C. Jean, C. Glaser, and V. Kramer. 2008. Efficacy of Aerial Spraying of Mosquito Adulticide in Reducing Incidence of West Nile Virus, California, 2005. Emerging Infectious Diseases 14(5). Ecostat, Inc. 2005. Risk characterization: application of Naled to the Big Branch Marsh. Ecostat, Inc., Mebane,

North Carolina, USA.

Extension Toxicology Network (Extoxnet). 1996. Bacillus thuringiensis. Pesticide Information Profile. Extension Toxicology Network. Available at http://extoxnet.orst.edu/pips/bacillus.htm; accessed December, 2018.

Kanaski Richard, undated, unpublished. Unanticipated Site Discovery Plan (Archaeological and Historic Sites). U.S. Fish and Wildlife Service 1p.

Louisiana Arbovirus Surveillance Summary 2018 available at: http://ldh.la.gov/assets/oph/Center-PHCH/Center-CH/infectious-epi/Arboviral/arboweekly/2018/ARBO_1840.pdf 3pp.Naled 2014 & 2015. SDS, Dibrom Concentrate specimen label & SDS. AMVAC Chemical Corporation. Los Angeles, CA. 7 & 11 pp., respectively.

U.S. Fish and Wildlife Service. 2007. Comprehensive Conservation Plan. Big Branch Marsh National Wildlife Refuge. September 2007. U.S. Department of the Interior, Fish and Wildlife Service, Southeast Region. Atlanta, GA. 143 pp.

U.S. Fish and Wildlife Service. 2007a. Draft Comprehensive Conservation Plan and Environmental Assessment. Big Branch Marsh National Wildlife Refuge. April 2007. U.S. Department of the Interior, Fish and Wildlife Service, Southeast Region. Atlanta, GA. 181 pp.

U.S. Fish and Wildlife Service. 2011. Big Branch Marsh National Wildlife Refuge Visitor Services Plan. November 2011. U.S. Department of the Interior, Fish and Wildlife Service, Southeast Region. Atlanta, GA. 86 pp.

U. S. Fish and Wildlife Service. 2018. Handbook for Mosquito Management on National Wildlife Refuges. June, 2018. 44 pp.

Palmisano, R.P.E, Charles T. 1995. Environmental Assessment For the proposed Application of Bacillus thuringiensis israeliensis (B. t. i.) for the control of Mosquito Larvae in the Big Branch Marsh National Wildlife Refuge in Lacombe, Louisiana 10 pp.

Palmisano, R.P.E, Charles T. 2006, Environmental Assessment. Proposed Application of Aerially Applied Ultra Low Volume Naled for the Control of Adult Mosquitos within the Big Branch Marsh National Wildlife Refuge in Lacombe, LA 71pp.

Russell T.L., Kay B.H, Skilleter GA. 2009. Aquatic Biology. Environmental effects of mosquito insecticides on saltmarsh invertebrate fauna. Vol. 6: 77-90, doi: 10.3354/ab00156

Timmermann U., Becker N. 2017. Bulletin of Entomological Research. Impact of routine Bacillus thuringiensis israelensis (Bti) treatment on the availability of flying insects as prey for aerial feeding predators. Cambridge University Press 2017. DOI:10.1017/S0007485317000141

Tomlin, C. 1994. The Pesticide Manual. Farnham: British Crop Protection Council/Cambridge: Royal Society of Chemistry.

APPROVAL OF COMPATIBILITY DETERMINATION:

Refuge Manager Big Branch Marsh National Wildlife Refuge: ___________________________________

Project Leader: ______________________________________________________ Southeast Louisiana National Wildlife Refuges Complex

Review: Regional Compatibility Coordinator: ____________________________________ Review: Refuge Supervisor: _____________________________________________ Concurrence: Regional Chief: _______________________________________________________

MANDATORY 10-YEAR REEVALUATION DATE: