Comment submitted by R. J. Tillema,

October 4, 2006 Lance Wormell Special Review and Reregistration Division (7508P) Office of Pesticide Programs Environmental Protection Agency 1200 Pennsylvania Ave., NW. Washington, DC 20460-0001 wormell.lance@epa.gov RE: Docket ID number EPA-HQ-OPP-2006-0201 I am a retired certified golf course superintendent after 27 years service, however, I still work in the golf course industry at the Valley Oaks Golf Course in Visalia, CA. I am requesting that the EPA reconsider its recent decision to cancel registration of the organic arsenical herbicides (MSMA, DSMA, and CMA) in the turfgrass market. In my role now as a golf course greenskeeper, I have the task for providing healthy turf that has minimal weed issues at the Valley Oaks Golf Course. This is necessary in order to meet the demands of the golfers, as the Valley Oaks Golf Course is a city owned golf course, located in a very competitive golf market. MSMA products are an important part of our weed control program because of their effectiveness and affordability. The Fairways and Tee boxes at Valley Oaks G.C. are bermudagrass, no comparable substitute for the organic arsenical herbicides is available. No control alternatives exist for a number of weeds. Lack of suitable control is especially true for dallisgrass, which is one of the weeds we have to control at Valley Oaks G.C. EPA acknowledges there is no direct replacement for the MSMA selective control of broadleaf and grass weeds in golf course turf. However, the agency has developed a proposed list of alternative herbicide treatments using two to three herbicides. EPA has pointed out these proposed alternatives may be cost prohibitive and I wholeheartedly concur with this statement. MSMA is a very affordable and low cost herbicide. The proposed list of alternatives will have an adverse effect on the Valley Oaks G.C. maintenance budget and would provide an ineffective means of dealing with tough annual weed growth in turf. Current use restrictions of proposed alternatives are quite problematic. Valley Oaks Golf Course Superintendent and I give high priority to maintenance practices that do not have a negative impact on the environment. Meeting or exceeding the expectations of our golfing public, while ensuring golf's compatibility with the natural environment, is fundamental for the financial success of our facility and a high priority for me personally. I respectfully suggest that EPA consider restricting the use of organic arsenical herbicides on soil types with the greatest potential for organic arsenical leaching, but not ban them from those soils with little or no leaching potential. I ask that the EPA take into consideration my comments as a user of this product when making your final assessment. Removal of MSMA from the market will have a significant financial impact on the golf industry and our facility specifically. Thank you for allowing me to express my concerns with this decision and I highly encourage this re-registration decision to be reconsidered. Sincerely, Robert J. Tillema, CGCS