Comment submitted by E. J. Wygant, Shannopin Country Club

Eric J. Wygant, CGCS Certified Golf Course Superintendent. The EPA should reconsider their decision to cancel registration of PCNB in the turfgrass market. It can not be argued that there are alternative fungicide combination that are effective on gray and pink snow. In certain areas of the country these combinations are very good and could be an adequate substitute. However, in the northern part of the country it also can not be argued that PCNB is the only chemical that will adquately protect the turfgrass from gray snow mold. In areas where the ground could be snow covered for months at a time, PCNB is the only chemical with the longevity to continue working. Any combination will start to break down after 60 days and the protection will fail and there is no way to reapply with a snow cover. Those a little farther south have the ability to make a mid winter application to ensure the protection of the turfgrass until spring, so therefore the list of combinations they can use will work. My club does $3 million of business every year, most of which is either directly or indirectly derived from the golf course. If the golf course gets severely hit snow mold than the revnue and the taxes we pay on that revenue takes a hit as well. So not only are we losing money, but we are paying more for the combinations we are forced to spray, and paying an additional expense on seed, fertilizer, and labor to repair the damage caused by a disease that could have been prevented by spraying PCNB. For those who are far enough south, now they are forced to spray a second application of chemistries that are already being restricted on their annual use, ie. Chlorothalonil. PCNB has always been a once a year application, so therefore the amount of chemical being appied each year is minimal. The little hazard caused by that one application is well over shadowed by multiple application of a combined chemistries, the loss in revenue should the combined chemistries fail, the higher cost of the combined chemistry, and the extra cost to repair the damage caused by the snow mold after the combined chemistry fails. Please reconsider registering PCNB for use on turfgrass. The problems brought on by not having it, heavily out weigh those of using it.