Comment submitted by P. Jett

The EPA's decision to ban the re-registration of Organic Arsenicals, most notibly MSMA, is one that needs further consideration. These products have long been a trusted part of southern turf managers weed control program. They serve a purpose that will not easily be overcome by products that are less effective and in many cases not effective. The loss of MSMA would effectively end all Dallisgrass control without significant loss/damage to bermudagrass. This would be unacceptable to the management of our club and for the customers that play our course. The list of alternative control products does not address the ability to control Dallisgrass and will be less effective and cause more product to be applied to get the same level of control that MSMA would provide. The cost increases also make this option not only undesirable, but in most cases simply out of the question. Golf course superintendents are licensed applicators. We are required to maintain our licenses through continuing education. Restrictions on who can use these products and where they can be used is the solution as compared to an all out cancellation of the entire group of products. Thank you for your consideration of this issue and we trust that a workable solution for all parties will be the outcome. Paul Jett,CGCS