SPM Advisory Committee Meeting - June 15, 2026

Dear Sir:



I have a few comments:

Salaried public advisors would have no real time experiences.  Many chemicals don't work as the labels say and only by personal experience does the PCA find out.  Even if these salaried public advisors are very experie...↓nced PCA's, if they aren't in the field every season working in different crops, they quickly fall behind in current technology.  Chemicals work differently in every crop; how can some salaried public advisors cover the diversity of crops in California?  PCA's already specialize in the crops that they advise.  The scenario gets even more complicated with biologicals.  Where will you get salaried public advisors that can be knowledgeable in multiple crops using multiple species of natural enemies.  The Entomological field is so large, that we have thousands of experts in academia and they can only cover a small percentage of the knowledge needed.  Working with biologicals and natural enemies of insects is extremely complex.  Failures can happen even working with knowledgable experts.

This is an extremely ambitious project. Success or failure will depend on careful planning.

Sincerely,

Cliff Kitayama, Ph.D.

Entomologist, Biological Control Specialist

California licensed PCA 73506 45 years

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I appreciate the immense effort and thought that the SPM Advisory Committee has put into the Roadmap. It's clear that the focus is shifting from killing pests to building a system. You also addressed the challenge of streamlining the registration o...↓f safer alternatives which helps spur public and private investment in AgTech and it was also clear that the team spent a lot time bringing divergent stakeholders into the conversation. Thank You.

After reading the Roadmap and listening to the presentation, I have the following questions/observations:
1) Since most of the new hires are focusing on accelerating the registration of biologics, are we creating a "biological treadmill" to replace the "pesticide treadmill"? Are we implying that all synthetic pesticides are bad rather than using them more judiciously and integrating them into a more comprehensive program?
2) A 2050 timeline is incredibly optimistic. Shifting an entire agricultural economy away from a century of chemical-dependent practices in just a few decades presents massive logistical and biological hurdles.
3) Can you adjust the transition time for different crops? Fast Adopters with short-cycle crops, row crops, and industries with strong organic market premiums are more likely to hit the 2050 benchmarks. But the timeline is strained for permanent specialty crops like almonds, walnuts, and citrus. Because a tree crop represents a 25-to-30-year financial investment, growers cannot easily "rotate" crops or survive a failed trial of an unproven biological tool. For these sectors, 2050 will represent a tight, high-stakes deadline
4) The SPM advisory committee has not addressed the core bottleneck of IPM adoption/lack of adoption which is labor and preventative overhead costs associated with monitoring and sanitation. I understand that education and training and regulatory incentives might stimulate interest but adoption historically has been poor because of cost and lack of real-time tools. If SPM is to be a system-wide ecologically-based prevention platform, then why not mandate sanitation and monitoring? Both are pillars of IPM and included in every IPM publication regardless of what the practice was called (Re: Insect Pest Management, Insect Control, Integrated Pest Control).
5) Pest monitoring (other than rodents) is not included as a topic of interest in DPR SPM grants, yet would be critical for the effective use of biologics. The FDA requires a companion diagnostic for every biologic drug registered because biologics work differently than small molecule drugs. Biologic pesticides are more challenging to use effectively so why not mandate a tool to ensure that it's used correctly.
6) The proposal to encourage and retrain independent PCAs is good; however, it ignores the reason why only a small percentage of the PCAs are independent which is financial support while they build a business. Perhaps SPM grants, vouchers, or other forms of reimbursement can fund or provide support for these professionals while they train while the state figures out how to fund it? (Note: this might be a policy goal rather than a reality?)
7) It appears that the state is considering providing all the funding for salaried public advisors to break the reliance on retail advice but the this defeats the purpose of independent PCAs. The state-salaried employees will have "no skin in the game" and historically cannot endorse or make recommendations so this would seem to be a conflict of interest.
8) You mentioned that this Department would be "stand-alone" and would not necessarily interact with other agencies even though there is significant overlap in many areas. I think that the other agencies would benefit and contribute to the program's success.
9) Maybe a clearer explanation of SPM is needed since a couple of the Advisors and myself didn't understand the difference? IPM was always a community approach-that's why the early inundative releases of beneficials worked and how we eradicated boll weevil and pink bollworm.

I acknowledge that my comments may be biased as I studied under Drs. Hal Reynolds, Vern Stern, and Roy Fukuto who were my major and minor professors during my Ph.D. research at UC Riverside. My degree is in Economic Entomology and Pesticide Toxicology and I have 40+ years in ag and animal health. I am currently leading a UCR spinout with real-time pest monitoring technology which has been commercialized and used in several crops. My concern is that we are still focusing on only a couple of pieces of IPM, the biologics and education, and excluding other foundational elements which would ensure success.



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Thank you for your introductory SPM advisory meeting. As a representative for urban stakeholders, I appreciated listening in.

Comment #1: Recommend separate partner and incentive program lists for urban stakeholders

Partners and incentive progra...↓ms for urban stakeholders look very different than agriculture, be it industrial/commercial (such as facility managers) or residential (point-of-purchase outreach). Consider developing a parallel but separate partner list and grant/incentive program list. Partners could include the Structural Pest Review Board, as suggested by Andrew Sutherland. Other key stakeholders could include those that provide CE units to key stakeholders, such as state and local veterinary associations. Incentive programs could include Dr. Farrar's examples of IPM inclusion in LEED building certification and Green Shield for IPM practitioners. I also liked his idea of a co-benefit for energy upgrade tax incentives (in which a new door sweep is both energy efficient and keeps pests out).

Comment #2: Add DTSC, particularly their Safer Consumer Products (SCP) Program, to your list of external state partners

Biocides (antimicrobials) are commonly added into consumer products, often to protect people using the products from the unwanted growth of viruses, fungi, bacteria, or other microorganisms. Examples include preservatives in eye drops, cosmetics and other personal care products. Because many biocide-containing products do not make a pesticidal claim on the label, they are not regulated by DPR. Meanwhile, DTSC's SCP Program already includes many of these biocides on their Candidate Chemical List (such as quaternary ammonium compounds, QACs). Therefore, BACWA recommends that DPR include DTSC and their SCP Program in your state partner list.

Comment #3: Add Cal-OSHA to your list of external state partners

Agricultural workers face occupational pesticide exposure, as do urban workers such as janitors and hospital staff exposed to biocides or veterinarians and dog groomers exposed to on-pet flea treatments. Therefore, BACWA recommends that DPR include Cal-OSHA in your state partner list to build SPM knowledge, enhance data collection (with respect to human health risks), and coordinate state-level leadership.

Comment #4: Add the Water Board to your list of external state partners

The State Water Board issues discharge permits to agencies managing urban stormwater and wastewater treatment facilities, both of which are conduits of upstream urban pesticide use. These discharge permits (known as NPDES permits) may include IPM and SPM activities. Therefore, BACWA recommends that DPR include the Water Board in your state partner list to build SPM knowledge, enhance data collection (with respect to aquatic toxicity risks), and coordinate state-level leadership.

Comment #5: Possible urban SPM success story

Committee members commented that urban examples would help ease the pressure (and fear) from the agricultural community regarding SPM. We might have one regarding flea/tick treatments. Fipronil and imidacloprid are observed in treated wastewater discharged to water bodies, often at concentrations greater than aquatic life benchmarks. Scientists (including those at DPR's SWPP) have tied that to on-pet flea treatments. As a pilot project, the City of Palo Alto reached out to the contractor operating their city animal shelter to ask them to (1) replace fipronil for on-pet flea control and (2) include educational flyers in adoption baggies. While it took some time, this was successful. Palo Alto has since shared their outreach materials with other municipalities interested in coordinating with their municipal animal shelters. Reach out if you would like us to prepare a more detailed success story (with links) to share.


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June 30, 2026
Sapna E. Thottathil, Ph.D.
Deputy Director for Sustainable Pest Management
California Department of Pesticide Regulation
DPR Staff and Members of the Sustainable Pest Management Advisory Committee
California Department of Pesticide Reg...↓ulation

Re: California Pest Management Association's Comments on the June 15, 2026 Sustainable Pest Management Advisory Committee Meeting
Submitted via Smart Comment

Dear Deputy Director Thottathil, DPR Staff, and Members of the Sustainable Pest Management Advisory Committee:

The California Pest Management Association (CAPMA) appreciates the opportunity to provide comments following the first meeting of the Sustainable Pest Management Advisory Committee. DPR's meeting materials state that the Committee will advise DPR on goals, tactics, policies, and partnerships supporting statewide implementation of Sustainable Pest Management, track statewide progress, and review public comments submitted during the 15-day comment period. DPR also made clear that the Committee does not hold decision-making authority.

CAPMA appreciates that DPR is exploring the concept of Sustainable Pest Management and how it may be applied across California. As DPR evaluates this concept, CAPMA urges the Department and the Committee to proceed carefully, practically, and with full consideration of the public health, property protection, housing, and economic realities of professional structural pest management.

CAPMA's primary recommendation is straightforward: DPR should appoint a CAPMA member and structural pest management expert to the SPM Advisory Committee before the next meeting. CAPMA strongly recommends Blair Smith, BCE, or Dr. Sydney Crawley.


1. The Committee needs structural pest management expertise and a CAPMA member.
DPR's own meeting materials recognize that pest management is necessary to protect public health. That is especially true in the structural pest management industry, where professionals protect homes, schools, childcare facilities, hospitals, senior care facilities, multifamily housing, restaurants, food processing facilities, grocery stores, hotels, warehouses, public buildings, and commercial properties.

Structural pest management is not interchangeable with agricultural pest management. It involves pests hidden inside walls, attics, crawlspaces, roofs, equipment voids, kitchens, drains, food-handling areas, hospitals, schools, apartment buildings, and other sensitive sites. It also involves real estate transactions, tenant habitability, public health complaints, food safety requirements, customer tolerance, reinspection requirements, regulatory compliance, and liability.

A theoretical alternative can look viable in a meeting room but fail in practice because the infestation cannot be located, the pest is inaccessible, the structure cannot tolerate the treatment, the customer cannot tolerate repeated failures, the site requires immediate correction, or the law requires a higher standard of certainty. The Committee needs someone who understands these realities before recommendations are formed.

2. CAPMA strongly recommends Blair Smith, BCE, or Dr. Sydney Crawley.
Blair Smith, BCE, would bring California-specific structural and urban pest management expertise that is directly relevant to the Committee's work. Her application states that she has more than eight years of experience in structural, urban, and institutional pest management programs throughout California, with a focus on developing, implementing, and auditing IPM programs that reduce pesticide risk while maintaining effective pest control outcomes. As Director of Technical and Quality Assurance for Clark Pest Control, she oversees statewide IPM standards, technician training, regulatory compliance, and quality assurance across residential, commercial, food-handling, healthcare, educational, and municipal settings.

Ms. Smith's CV also shows that she develops technical protocols for approximately 800 technicians, has trained more than 400 technicians for Branch 2 and Branch 3 licensing, performs WDO inspection quality assurance, develops service protocols and SOPs, and participates in UC Riverside Pest Management Alliance work involving field trials on low-impact service techniques. Her application further states that she works at the intersection of regulation, science, and field application, and can contribute expertise in pesticide regulatory compliance, urban and structural pest management, resistance management, stakeholder communication, and translating applied research into practical guidance.

Dr. Sydney Crawley would also bring exceptional expertise in urban and medical entomology. Her CV lists a Ph.D. in Entomology, current service as Principal Vector Scientist at Rentokil Terminix, prior service as Assistant Professor and Extension Specialist in Urban Entomology at North Carolina State University, and prior service as a Public Health Entomologist responsible for public health pest product portfolios, research, product development, technician training, and academic and industry partnerships. Her publications and professional work include bed bugs, ticks, mosquitoes, cockroaches, public health pests, traps, pest monitoring, structural pest inspection, and urban pest management training.

Either candidate would add practical, science-based structural pest management expertise that the Committee needs.

3. Professional pest control protects public health, housing, and property.
Structural pest control professionals manage pests that affect health, sanitation, habitability, and property value. Rodents, cockroaches, mosquitoes, flies, bed bugs, ants, termites, stored product pests, and wood-destroying organisms are not merely nuisances. The Pest Prevention by Design guidelines explain that pests compete with people for resources, can carry disease, create unsafe conditions, and may be associated with sanitation and building maintenance problems.

The same guidelines emphasize that effective structural pest prevention requires an understanding of local pest pressures, pest biology, building conditions, entry points, harborage, food, and water. They also note that pest tolerance varies by setting: an occasional ant trail in a home may be a nuisance, but even a single ant in a surgical ward can have serious consequences.

That is why access to effective pest management tools matters. If California policy limits necessary tools before equally effective and practical alternatives exist, the consequences will not be theoretical. Californians could face more pest pressure, more retreatments, more property damage, higher service costs, greater inequity, and increased public health risks.

4. Sulfuryl fluoride remains essential because there is no comparable whole-structure replacement.
DPR's own sulfuryl fluoride alternatives materials, based on the independent CCST review, state that many chemical and nonchemical localized treatments are effective and widely used in California, but that few viable alternatives exist for whole-structure fumigation. The same materials state that sulfuryl fluoride has been an effective structural fumigant for approximately 30 years and became the only federally approved fumigant for homes, garages, barns, storage units, and commercial warehouses after methyl bromide was phased out.

That distinction is critical. Localized treatments have a role, but localized treatment is not the same as whole-structure fumigation. Whole-structure fumigation is designed to address all wood in a structure at the same time. Localized treatment depends on locating the infestation. DPR's sulfuryl fluoride materials explain that localized treatments are highly reliant on the ability of pest management professionals to locate the exact site of infested boards and termite tunnel systems, and that existing detection devices cannot reliably identify the presence and location of drywood termites in structures.

The same materials explain that some situations remain legally and practically dependent on sulfuryl fluoride, particularly when termite infestations extend into areas inaccessible to professionals and structures are not amenable to whole-structure heat treatment. They further note that heat treatment, while a whole-structure alternative in some cases, costs approximately twice as much as fumigation, cannot be used on all structures, and can damage heat-sensitive materials such as vinyl, Formica cabinets, and newly installed wood flooring.

A list of possible alternatives should not be confused with a viable replacement for sulfuryl fluoride. The standard should be whether an alternative is effective, available, affordable, legally workable, and capable of protecting public health and property under real structural conditions.

5. The economic stakes are substantial.
A 2024 peer-reviewed article by Dr. David Zilberman and Dr. Vernard Lewis of UC Berkeley in the Journal of Economic Entomology modeled the economic effects of restricting sulfuryl fluoride for drywood termite control in California. They estimated that annual drywood termite damage and home equity loss in California would be $4.5 billion to $16.8 billion without treatment. They further estimated that current practice, using fumigation for a portion of homes and localized treatments for others, results in a combined social cost of roughly $1 billion to $2 billion annually, while a localized-treatment-only scenario would cost $3.2 billion to $4.9 billion annually. Their analysis estimated that severe restriction or banning of sulfuryl fluoride would increase annual social costs by $1.43 billion to $4.31 billion.

Zilberman and Lewis also explain that when localized treatment is ineffective and sulfuryl fluoride cannot be used, drywood termite colonies may be inaccessible or undetected, creating significant damage risk. They further note that drywood termites can attack structures in hidden and concealed locations, with multiple colonies attacking simultaneously, and that local treatments are highly dependent on finding active infestation sites.

California's housing affordability challenges make these risks even more serious. Policies that reduce access to effective termite control can translate into higher repair costs, reduced home equity, increased transaction costs, and disproportionate impacts on lower-income property owners and renters.

6. Greenhouse gas discussions should use full social-cost analysis.
Sulfuryl fluoride has been discussed in the context of greenhouse gases. That issue should be evaluated proportionately and in the full context of public health, housing, property protection, treatment efficacy, and economic cost.

Zilberman and Lewis estimate that each sulfuryl fluoride fumigation in California uses approximately 6 kilograms of sulfuryl fluoride on average, and they use an estimated global warming effect of 4,800 kilograms of CO₂-equivalent per kilogram of sulfuryl fluoride. Their analysis estimates total GHG costs for 100,000 fumigated structures annually and concludes that, even accounting for GHG costs, current practice produces large social gains compared with no treatment or localized-treatment-only scenarios.

For context, CARB's 2025 greenhouse gas inventory report states that California's 2023 statewide emissions were 360.4 MMTCO₂e and that direct transportation-sector emissions accounted for 37.1% of statewide emissions. CARB also notes that sulfuryl fluoride is tracked separately from the AB 32 inventory's seven greenhouse gases. Using Zilberman and Lewis's estimate of roughly 2.9 MMTCO₂e for annual California sulfuryl fluoride structural fumigation emissions, that is approximately three days of total statewide emissions or roughly eight days of direct transportation-sector emissions.

That comparison does not eliminate climate concerns, but it does show why single-factor analysis is inappropriate. Zilberman and Lewis estimate that the implied cost of eliminating sulfuryl fluoride emissions through severe restriction or a ban would be $624 to $1,465 per ton of CO₂ eliminated, while also increasing social costs by billions of dollars and creating equity and property impacts.

7. Prevention and IPM are important, but they do not replace necessary remedial tools.
CAPMA members already use inspection, monitoring, exclusion, sanitation, habitat modification, mechanical controls, customer education, targeted applications, and other IPM practices. These tools are essential. They can prevent infestations, reduce pest pressure, improve sanitation, and help ensure that pesticides are used appropriately.

But prevention cannot fully replace remedial treatment when an active infestation already exists. California has millions of existing structures, many of them older, wood-framed, and vulnerable to termites and other structural pests. Building design, exclusion, and maintenance can help reduce future pest pressure, but they cannot substitute for effective professional tools needed to control existing infestations in real buildings.

The Pest Prevention by Design guidelines themselves recognize the importance of building design and retrofit, but also note that many pest control activities are "predominantly in the realm of pest control professionals," not builders. That is exactly why DPR needs structural pest management expertise and a CAPMA member on the Committee.

8. CAPMA's recommendations.
CAPMA respectfully recommends that DPR:

Appoint a structural pest management expert and CAPMA member to the SPM Advisory Committee before the next meeting, specifically Blair Smith, BCE, or Dr. Sydney Crawley.

Preserve access to essential structural pest management tools, including sulfuryl fluoride, unless and until alternatives are proven to provide comparable efficacy, affordability, availability, legal workability, and protection of public health and property.

Evaluate alternatives using real-world criteria, including whether they work in inaccessible infestations, whether they increase retreatments, whether they are affordable, whether they are legally defensible, whether they protect sensitive sites, and whether they can be implemented by licensed professionals in actual structures.

Consider the full social cost of any restriction, including public health risk, housing impacts, termite damage, home equity loss, repair costs, retreatment, consumer costs, and disproportionate impacts on renters and lower-income Californians.

Engage CAPMA, the Structural Pest Control Board, County Agricultural Commissioners, UC researchers, and licensed structural pest management professionals before forming recommendations that could affect structural pest management tools or practices.

Conclusion
CAPMA appreciates that DPR is exploring the SPM concept and seeking stakeholder input. As this process moves forward, the Committee must include the practical expertise needed to understand the built environment. Structural pest management protects public health, housing, food safety, schools, hospitals, businesses, and property.

DPR should not move forward without a structural pest management expert on the Committee. CAPMA strongly urges DPR to appoint Blair Smith, BCE, or Dr. Sydney Crawley so future discussions are informed by practical, science-based, field-tested expertise.

Respectfully submitted,

Jake Plevelich Travis Mickel, ACE
Government Affairs Committee, Chair President
California Pest Management Association California Pest Management Association

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SPM Advisory Comm comments:

Thanks to whoever let me into the meeting when the link was locked, not sure if due to my outdated software. Missed some of the intros, but looks like a diverse and engaged group. I was impressed by the liveliness of the...↓ comments and questions. Such a contrast from the PREC meetings.

I appreciated that Sapna succinctly described SPM as pest management to protect the food supply and public health in light of climate change and the new science on pesticides. That expands the definition beyond IPM.

I also appreciated the emphasis on cross agency collaboration, would have liked to have seen a whole list plus acronym expansions. What about collaboration and communication among the various committees within DPR that work on related issues? I found it notable that EJAC was not mentioned; indeed, I don't recall hearing the term environmental justice in the meeting, altho the "public" was mentioned a few times, mostly in regard to committee members' belief we're not understanding what growers are doing with respect to IPM. I recognize that the EJAC is not under SPM's umbrella, but its work is certainly related, as is the PREC. And with Sapna's description of the purpose of the SPARC committee, it's unclear to me how that committee's work will differ from that of the PREC.

With the recognition that tools and alternatives are key to SPM implementation, I noted that, while DPR is working on new regulation for drone delivery of pesticides, it didn't appear that anyone with specific expertise in the area of tech solutions as alternatives was on the committee. Yet several committee members have close ties to the pesticide industry, either as purveyors of products or as PCAs who may receive commissions from pesticide sellers.

The role of PCAs in communicating and and adopting changes needs more emphasis. As long as PCAs' incomes are dependent on kickbacks from the chemical industry, that's not going to happen. There will need to be some changes in their training and more accountability for their regulatory obligation to offer info on less toxic alternatives first.

The input from people who work in the urban sector was especially valuable. Great suggestion to have urban PURs, especially in light of the toxicity of some of the chemicals used in urban pest control. (E.g. sulfuryl fluoride, a potent greenhouse gas, used heavily in some California communities.) We need to address the risk of exposure for people in their home and indoor settings, from personal pesticide use, institutional use, and use by neighbors. The idea of organic certification for pest control in urban spaces is also a good one. I love the idea of the color-coded stoplight tiered pesticide system, based on the pest hazard as well as pesticide hazard. That could be especially useful in school settings and other public spaces.

I found the first formats of the SPM matrix much too text-based. There were only two versions that were highly visual, the sort-of-Venn diagram and the flow chart. I thought those had potential as models for effective communication, would need time to read the slides to see past my resistance to other presentation formats.

I agree that there needs to be more explanation of how SPM differs from IPM. That communication should go to concerned groups, both rural residents and growers, and discussion of the potential impacts of SPM should include all "stakeholders". Thus far, the main distinction I've heard is the focus on the economic viability of California's (large and diverse) agricultural system. Other elements worth emphasizing:
Developing collaborative regional- and crop-based solutions, with farmers sharing best practices for pest prevention and early intervention;
Positive response to public pressure both from ag communities and consumers, with their shared desire to reduce the toxicity of our food system;
Climate resilience, which necessarily includes reduced dependence on fossil fuels, from their use for fertilizers and ag chemicals to packaging and delivery of ag products to markets.

Yes, markets are key, and if SPM-engaged agencies plan to provide incentives, practices must be verifiable. Research, support, and training will be needed. Complicated issues will need to be rendered clear and accessible to action.

It was great to end (almost) with mention of an existing color-coded system for birds, ranking harms from pesticides. That's a model that could be adapted more broadly for pesticides, with columns for impacts on human health, soil, water, and wildlife, plus potential for climate harm: a useful task for some of your new, tech-savvy staff!

DPR has the capability to set targets for reduction of highly toxic pesticides, and to measure progress toward that goal. Several lists already exist; new science and community concerns should be taken into consideration. As someone schooled in Public Health, I recognized it's hard to measure the absence of a problem. But that's how healthy conditions are built: by removing harms and unnecessary barriers. 2050 is very likely to be beyond my lifetime. This committee has expertise and enthusiasm that can help DPR pick up the pace.
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Hi guys!! Please focus on education people, particularly home owners on the proper use and disposal of pesticides rather than focusing exclusively on the pest control industry. We need better technology to do whole house treatment for termites and be...↓etles, rather than just relying on fumigation, please invest funding in developing mor effective local termite control.↓

Please approve FireHawk Bioherbicide for use by CA farmers, landscapers, and residents so they have a good regenerative option. The approval process for herbicides that support regenerative farming and landcare practices takes too long, and the peopl...↓e of CA need non-conventional options, please! FireHawk Bioherbicide Super Concentrate (EPA Reg. No. 93740-7)
CalPEST ID PRO-2504066
Thank you.↓