Comment submitted by R. Hertzing, Valencia Country Club

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