Comment submitted by A. Jansen, Golf Course Superintendent, Baraboo Country Club

While pentachloronitrobenzene (PCNB) might not be a "cure-all" in the battle against certain turfgrass diseases, I can assure you that it?s use in controlling Pink Snow Mold and Gray Snow Mold is effective, from both an efficacious and cost standpoint. I have been using PCNB as my only chemistry in treating areas of the golf course for 12 years, specifically 280,000 sq. ft. of greens, tees and the approaches to the greens with remarkable results. Nowhere has there been any snow mold of any type on these treatment areas nor has there been any phytotoxicity results or concerns. The Baraboo Country Club is considered to be a "Limited Resource Facility" by the Golf Course Superintendents Association of America due to it?s relatively small, annual maintenance operating budget ($215,000.). Of that, $12,000 is dedicated to controlling a variety of turfgrass pests including Pink and Gray Snow Mold. The EPA has made the following, incredible statements: "There are several alternatives that will result in similar or moderately higher costs than PCNB, and potentially provide more effective control and lower risk of turf damage due to phytotoxicity" "We anticipate that if PCNB were no longer available, golf courses that currently use PCNB would not experience substantial negative effects." First of all, I don?t base my pesticide applications on products or tank-mixes that offer "potentially more effective control," and given that the EPA themselves have admitted that they did not directly evaluate the impact of possible pesticide cost increases to the economic viability of golf courses, I find it hard to explain to my Board of Directors a change I must make in the chemistry I use to protect ?their? golf course against snow molds. With no turf damage due to phytotoxicity to report to them and trying to explain the EPA?s concern of the environmental fate characteristics of PCNB when I cannot see any adverse environmental effects using it, either on the application site or around any adjacent property, I am put in a precarious position. Then there?s the cost differentiation I must explain. If PCNB were not available to me, I would use a tank-mix of propiconazole and chlorothalonil at 3 ounces/1000 sq. ft. and 5.5 ounces/1000 sq. ft., respectively, to treat 280,000 sq. ft. Here?s the math: I?m paying $2.18/oz. for propiconazole and $ .59/oz. for chlorothalonil. If applied to my 280,000 sq. ft. of greens, tees and approaches to prevent Pink and Gray Snow Mold, my cost would be $2,739.80. I now use the lowest recommended label rate of PCNB (12 oz./1000 sq. ft.), pay $ .22/oz. and achieve excellent results at a total cost of a mere $739.20, a difference of $2,000! So, with virtually no toxicological effects and no environmental damage using PCNB currently, I must explain to my Board that I now have to spend an additional $2,000 because the EPA is concerned about the human health and environmental risks associated with its use. In conclusion, there certainly might be concerns when using PCNB products on Cotton, Potatoes, Green Beans and Cole crops, but the continued successful use as a fungicide to treat Pink and Gray Snow Mold on golf courses should be maintained, after all, no one I?ve seen has ever eaten or consumed the turfgrass that I treat with fungicides! Thank you for considering this statement, Al Jansen, Golf Course Superintendent, Certified Commercial Pesticide Applicator, The Baraboo Country Club - 1010 Lake Street/PO Box 383 - Baraboo, WI 53913 - 608-356-0488 - aljansen@baraboo.com