The Evolution of the IPM Program

Two separate developments set the stage that eventually led to Boulder's IPM policy and land-management philosophy. During the same time period that Rachel Carson was writing Silent Spring and agricultural entomologists at UC Davis were developing the concept of IPM ( see What is IPM? ), a grassroots movement was unfolding in Boulder to protect the foothills from development.

Today's open space program exists because a group of young CU professors and their spouses resolved to stop development plans in the foothills during the 1950s, including plans to build a resort hotel on Enchanted Mesa. This small group organized on a shoestring budget and were successful at blocking foothills development in its tracks.

Their first step was a ballot initiative, the "Blue Line," that amended the city charter to prohibit piping city water above 5,750 feet, which impeded development at the elevation of the foothills. They gathered enough signatures to get the Blue Line on the ballot, which was passed with 76% of the vote. Their next move was a campaign to get voters to approve a bond to purchase Enchanted Mesa, which was also successful. They then went on to organize another ballot initiative in 1967 - the first open space tax in the nation - to purchase and maintain land surrounding the city. It passed with 57% of the vote.

Boulder's environmental history is filled with innovative and visionary ideas that are often the first of their kind in the nation - some led by residents and others initiated by city staff. The IPM program is considered one of the top in nation and it came about from concurrent and separate actions led by city residents and city staff.

There have been two major updates to the initial IPM policy. Each update was in response to concerns from city council and residents about the impacts from pesticides to people and the environment. This diagram provides an overview of updates after the  1993 IPM Policy , and recommendations from program reviews that were later incorporated in the  2002  and  2019  IPM policy updates. More details are provided in the sections below.

City council's 2000 environmental and sustainability goals are outlined in this  study session memo . Their objective was to "institute state of the art policies in prioritized areas for both the community and for internal organization" with the goal to "enact and enhance City policies that cause the Boulder community to become a nationwide environmental leader among communities, and for the City departments to a model of exemplary environmental practices" listing the following environmental priorities:

• Pesticide Reduction
• Waste Reduction
• Energy Efficiency
• Habitat Preservation
• Water Quality

To achieve the goal of pesticide reduction, council directed staff to explore the feasibility of a pesticide ban, and in 2001 a consultant was hired to conduct an  environmental audit  of the city's IPM and water conservation programs. Their recommendations addressed council's request for a pesticide ban, including a pesticide phaseout, stepwise elimination of pesticides by toxicity level categories, and an exemption process. There were also recommendations to improve the IPM program through accountability, consistency and reporting with multiple recommendations for city departments and IPM coordinator oversight and support.

The environmental audit set several steps in motion. City council passed a moratorium on pesticide use within 50 feet of creek corridors and the civic area in April of 2002. Staff began taking action to improve and strengthen the city's IPM program, including updating the IPM Policy ( city council memo ). The biggest changes to the  2002 IPM policy  were the new city IPM Coordinator role, and the requirement for each city department to develop an IPM plan with procedural guidelines for implementation of the policy. Two new sections (VII and IX) specified that all staff are required to follow the policy and that changes to the policy can only be made by the city manager.

City council created an IPM Task Force in October of 2002 to stregnthen the program and implement the environmental audit recommendations. The task force consisted of 15 external members and seven city staff. They were asked to provide recommendations to city council and the city manager about the feasibility of a pesticide ban.

The IPM Task Force met 18 times from 2002 to 2006. They were tasked with:

1. Reviewing the potential impacts of a pesticide ban on city lands.
2. Determining situations where pesticides would and would not be appropriate on city lands for plant disease, weed and insect pests.
3. Reviewing the Best Management Practices (BMPs) practiced by city staff; recommend changes to BMPs.

The task force created two tools for staff - the I PM Site Assessment Tool for Chemical Appropriateness , and the  IPM Decision Flow Chart . They modified city council's pesticide moratorium to ban pesticide use within 50 feet of Boulder Creek within city limits, ban pesticide use in the civic area with minor exceptions for trees, and pesticide use was also prohibited near pedestrian entrances to buildings, or within 50 feet around playgrounds with some exceptions. The Task Force consulted with an EPA toxicologist to review pesticides and developed the first Approved Pesticide List. City staff were not allowed to use any pesticide that was not included in this list. The task force also developed a process for updating the Approved Pesticide List.

After the IPM Task Force completed their work, the city began implementing task force recommendations, including the Approved Pesticide List, site assessment tool and IPM flow chart. The city's IPM Coordinator role was unfilled from 2007 to 2009. When a new IPM Coordinator was hired in 2009, staff requested new products for addition to the Approved Pesticide List. The process was used that was that developed by the task force, which seats a three-member "IPM Subcommittee" with representatives from the Environmental Advisory Board, Parks & Recreation Advisory Board, and Open Space Board of Trustees. The subcommittee had decision-making authority to approve or deny staff pesticide requests at a public meeting. The IPM Subcommittee met in 2010 under heavy scrutiny from the public and the press. They  voted 2 to 1 to approve staff requests  for new pesticide products, including two turf herbicides. This resulted in strong public opposition. Many people, including children, spoke at council, and picketed and protested outside the municipal building. The Earth Guardians organized a protest and press conference outside the court house.

In response to public concern, the city manager determined that no additions would be made to the Approved Pesticide list until the city hired consultant to review the program and the pesticide assessment and approval process ( memo ). An interim Approved Pesticide list was created for the following season (2011) until the review was completed. The list removed Round Up and other glyphosate formulations with surfactants, allowed biopesticides and encouraged use of minimum-risk (EPA 25(b)exempt) products ( memo ).

A team of consultants reviewed the city's pesticide program in 2011, held public meetings and made recommendations. Their  report  was published at the end of 2011. It concluded that the city's IPM program was a national leader in practices and pesticide reduction, but noted some of the same issues and challenges as the 2000 Environmental Audit. Their key recommendations were:

1. Develop a comprehensive checklist of IPM policy elements and a realistic timeline and prioritized action steps for improving consistency of IPM policy implementation across all city departments, properties, contractors and lessees.
2. Develop IPM plans for all departments or workgroups, beginning with one or two workgroups the first year and phasing in all others by 2014.
3. Revise the Approved Pesticide List process using well-defined, up-to-date, science-based criteria based on hazard tiers and exposure potential, similar to the process used by the City and County of San Francisco.

The city manager approved changes to the Approved Pesticide List, while staff researched options to address the consultant's recommendations. Several products of concern were removed from the list:

1. Round-Up (glyphosate with polyethoxethyleneamine); 2. Astro (permethrin); 3. Escort + 2,4-D (metsulfuron and 2,4-D); 4. Hard Ball (2,4-D); 5. Pathway (2,4-D and picloram); 6. Tordon (picloram); 7. Pendulum (pendimethalin); 8. Acclaim (fenoxaprop-p-ethyl); 9. Tartan (trifloxystrobin and triadimefon); 10. Contrac (bromadiolone); and 11. Zinc phosphide.

Staff presented several options for reducing pesticide use and updating the Approved Pesticide List to city council ( see memo ). Council directed staff to:

1. Implement a partial pesticide ban, which includes program areas such as managed turf, and designates specific municipal properties that will be free of synthetic cosmetic pesticides;
2. Revise the Approved Pesticide List process to include hazard tiers, using well-defined criteria for each category; and
3. Establish an IPM technical advisory committee, with the role of reviewing staff pesticide requests for the Approved Pesticide List and making recommendations to the city manager about pesticide use on municipal properties.

Staff began implementing this direction over the following years. A process was developed for rigorous review of pesticides, with hazard tier categories modeled after other local government processes including San Francisco and Thurston County, Washington.

City leadership strengthened the partial pesticide ban by banning glyphosate, and eliminating herbicide use in park non-turf managed areas, medians, and paths. One recommendation, common to every IPM review and that has never been implemented, was the requirement for each city department and/or division to develop their own IPM plan. Staff assessed a new approach - a citywide IPM Operations Manual to provide background, information and direction for all city IPM strategies and procedures and serve as a guide for IPM staff, contractors and lessees. Procedures for particular program areas could be added in a modular approach over time including urban forestry, natural lands, agriculture, etc.

The city manager and department directors approved the hazard tier pesticide assessment process in 2017. Harzard tiers include "Allowed," "Conditional," and "Special Use." Staff's request to develop an IPM Operations Manual to replace the requirement for individual department/division IPM plans was also approved.

The example below shows how pesticides are assessed using the hazard tier process and criteria.

Recommendations from the IPM Task Force, the 2010 IPM program review, and council and city manager direction were included in the  2019 IPM Policy  update ( see memo ).

The majority of the elements of the 1993 policy have been retained through the 2002 and 2019 policies. Each policy update included external reviews, consultation with subject matter experts, review by department staff and directors, advisory boards, public engagement, and ultimately city council direction and city manager approval.

The 2019 update included more revisions than 2002, because it incorporates the recommendations from two comprehensive program reviews - the 2006 IPM Task Force and the 2010 IPM review, as well as city council and city manager direction. Attachment A in this  city council memo  shows all track changes to the 2019 IPM Policy with comments explaining the reason for revisions. The table below provides an overview of the major changes.

It's now been over 30 years since the first IPM policy was adopted by the city. The core principles and the ecological foundation remain unchanged. The policy was strengthened in subsequent updates to reflect program reviews and direction to city staff. This story map series was created to share institutional knowledge about the history and rationale for the city's IPM program to ensure that staff at all levels share a knowledge base to understand what the IPM program requires of each of us. From this point of shared understanding, we have a yardstick to assess how the IPM program is functioning in practice, the challenges that the city and each workgroup are facing with limited resources, rapidly changing climatic conditions and current and emerging challenges.

Next: Part 4:  IPM Policy Roles & Responsibilities 

Part 1 -  Introduction to Boulder's Integrated Pest Management Program 

Part 2 -  What is IPM? The history of IPM and Boulder's first IPM Policy