12/4/2006
Jill Bloom
Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P)
Environmental Protection Agency
1200 Pennsylvania Ave., N.W.
Washington, DC 20460-0001
bloom.jill@epa.gov
RE: Docket ID number EPA-HQ-OPP-2004-0202
I am the golf course superintendent at the Valencia Country Club in Valencia,
California. I am requesting that the EPA reconsider its recent decision to cancel
registration of pentachloronitrobenzene (PCNB) in the turfgrass market. PCNB is a
critical tool for golf course professionals for the control of pink and gray snow mold
in addition to Brown Patch.
As golf course superintendent at Valencia Country Club, I am responsible for
providing quality turf conditions at my golf course that are free, or nearly free, from
disease. This is necessary to meet the demands of my customers (golfers) as my
facility is located in a very competitive golf market. Turf loss from snow mold or
other diseases is unacceptable.
As part of the PCNB re-registration decision, EPA has identified several fungicides
it believes are alternatives to PCNB for managing pink and gray snow molds on
tees, greens and fairways on golf courses. These alternatives are comprised of
tank mixes of two or three fungicides of different chemistry. EPA has also
determined several of these alternatives 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. Finally, EPA has concluded that if PCNB were
no longer available, golf courses that currently use PCNB would not experience
substantial negative effects.
I strongly disagree with these conclusions. PCNB is an important part of my
disease program to control snow mold because of its affordability and
effectiveness. Loss of this product would put a major strain on my facility's budget
and the profitability of my golf course. The alternatives are significantly more
expensive than a PCNB application without an improvement in snow mold control.
I acknowledge that other alternatives are available. However, these alternatives do
not provide the effectiveness or longitivity that PCNB does. In addition, these
products are signigificant more expensive. The increase in the cost of fuel has
significantly increased our maintenance expenditures of the past few years. The
removal of PCNB from the turfgrass market place would needless elevate our
maintenance cost even more.
PCNB can be an important part of fungicide tank mix programs, especially
considering that other fungicides, specifically chlorothalonil, are increasingly
limited to specific usage maximums per year. These alternative fungicides
suggested by EPA for snow mold control are important for controlling other
diseases through the growing season where PCNB is limited to use only prior to
winter for gray and pink snow molds.
As a trained golf course professional, I give high priority to maintenance practices
that do not have a negative impact on the environment. Meeting or exceeding the
expectations of my customers (golfers), while ensuring golf's compatibility with the
natural environment, is fundamental for the financial success of my facility and a
high priority for me personally.
I respectfully ask that the EPA take into consideration my comments as a user of
this product when making your final assessment. My facility, the golf industry,
and specifically the limited budget facilities in the Northern tier of the nation will
suffer a significant financial impact with removal of PCNB from the turfgrass
market. Thank you for allowing me to express my concerns with this decision and
I add my support in encouraging EPA to reconsider this re-registration decision.
Sincerely,
Robert Hertzing
Golf Course Superintendent
Valencia Country Club
Comment submitted by R. Hertzing, Valencia Country Club
This is comment on Notice
Pentachloronitrobenzene (PCNB) Reregistration Eligibility Decision; Third Extension of Comment Period
View Comment
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