Comment submitted by T. R. Alex

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 the Director of Golf Course Maintenance at Grand Cypress Resort in Orlando, FL. 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 as superintendent, I am responsible for providing healthy turf that has minimal weed issues at my golf course. This is necessary in order to meet the demands of my customers (golfers) as my facility is located in a very competitive golf market. MSMA products are an important part of my weed control program because of their effectiveness and affordability. For 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. 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 be cost prohibitive to my facility and would provide an ineffective means of dealing with tough annual weed growth in turf. Current use restrictions of proposed alternatives are quite problematic. One suggestion of an alternative control measure is the use of pre-emergence herbicides. Being located in an area of the country that has extremely high counts of about 5 different types of nematodes, additional pre-emergence applications cannot occur without significant risk of turf injury. The nematode pressure on the existing turf is so extreme, pre-emergence herbicides can actually destroy existing turf because of the lack of an adequate root structure. With the removal of Nemacur (Fenimaphos) in 2006, the nematode pressures will be even worse. Our turfgrasses will no longer be able to handle a steady diet of pre emergence herbicdes Like most of my fellow superintendents, our applications of MSMA have always been done in spot treatments. We have over 350 acres of maintained turf on our 48 holes of golf. We never use more than 10 gallons of a typical 6.6lb of MSMA for a single treatment. We will spot treat the courses no more than 4 times per year. Spreading 40 gallons of this product over a 350 acre site has to be little or no risk for ground water contamination. As the Director of Golf Course Maintenance here at Grand Cypress, 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 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 my 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, Thomas R. Alex