+----------------------------+-----------------------------------------+
| > **\"Chava McKeel\"       | +---+---------------------------------+ |
| > \<cmmckeel@gcsaa.org\>** | | T | > Nathan Mottl/DC/USEPA/US@EPA  | |
| >                          | | o |                                 | |
| > 06/29/2007 03:52 PM      | +---+---------------------------------+ |
|                            | | c |                                 | |
|                            | | c |                                 | |
|                            | +---+---------------------------------+ |
|                            | | S | > GCSAA comments re: Docket ID  | |
|                            | | u | > No. EPA-HQ-OPP-2006-0109      | |
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|                            | | j |                                 | |
|                            | | e |                                 | |
|                            | | c |                                 | |
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|                            |   ----- ------------------------------  |
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+----------------------------+-----------------------------------------+

Dear Mr. Mottl:

Please find below comments from the Golf Course Superintendents
Association of America in response to the notice of the opening of the
Registration Review docket for the plant growth regulator paclobutrazol
published in the March 28, 2007 *Federal Register*. We understand that
we missed the June 26 comment deadline but hope that you will include
them in the registration review docket. Thank you, and please let me
know if you have any questions.

Sincerely,

Chava

**Chava McKeel**

Senior Manager, Government Relations

Golf Course Superintendents Association of America

1421 Research Park Drive

Lawrence, Kan. 66049-3859

\(800\) 472-7878, ext. 3619

\(785\) 832-3619

[[cmmckeel@gcsaa.org]{.underline}](mailto:cmmckeel@gcsaa.org_)

[[http://www.gcsaa.org]{.underline}](http://www.gcsaa.org/_)

 

June 29, 2007

Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P)

Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, DC 20460-0001

**Attention: Docket ID No. EPA-HQ-OPP-2006-0109**

**A. Identity of Commenter**

The Golf Course Superintendents Association of America (GCSAA) submits
these comments in response to the notice of the opening of the
Registration Review docket for the plant growth regulator paclobutrazol
published in the March 28, 2007 *Federal Register*.

GCSAA is a leading golf organization, which has as its focus golf course
management. Since 1926, GCSAA has been the top professional association
for the men and women who manage golf courses in the United States and
worldwide. From its headquarters in Lawrence, Kan., the association
provides education, information and representation to more than 20,000
members in more than 72 countries. GCSAA's mission is to serve its
members, advance their profession and enhance the enjoyment, growth and
vitality of the game of golf. The association\'s philanthropic
organization, The Environmental Institute for Golf, works to strengthen
the compatibility of golf with the natural environment through research
grants, support for education programs and outreach efforts.

**B. GCSAA Comments**

Paclobutrazol is a plant growth regulator used by golf course
superintendents to reduce the population of annual bluegrass (*Poa
annua*) in greens, tees, and fairways where creeping bentgrass is the
desired turf species. Annual bluegrass is considered by some
superintendents to be a desired turf species and by other
superintendents to be a troublesome, difficult to control weed.
Superintendents who consider annual bluegrass a weed do so because it
has poor tolerance to heat, drought and cold stresses, and dies during
these stress periods resulting in thin stands of turf or bare soil. In
addition, it is susceptible to many common turf diseases causing
superintendents to rely on frequent fungicide applications to keep the
annual bluegrass alive so it can provide an acceptable playing surface.

Implementing sound management practices can reduce annual bluegrass
populations, but management practices alone will not reduce annual
bluegrass populations to acceptable levels. Paclobutrazol is an
important tool to reduce annual bluegrass populations when used in
conjunction with appropriate cultural practices. By reducing the annual
bluegrass population in creeping bentgrass greens, tees, and fairways,
superintendents are able to provide better playing surfaces while
reducing the amount of resources needed to maintain turf stands that
only have small populations of annual bluegrass.

Superintendents have few effective chemical control options to reduce
annual bluegrass populations to acceptable levels in creeping bentgrass
turf stands. It is important that paclobutrazol remain available to
superintendents so they have several options to choose from when
developing annual bluegrass control strategies.

In 2002, GCSAA conducted the Performance Measurement Survey to determine
fertilizer and pesticide use on golf courses in the United States. Four
hundred and seventy six golf course superintendents responded which was
an 11% return rate. The data indicated 67 of 476 respondents used
paclobutrazol to reduce populations of annual bluegrass in creeping
bentgrass turf. Respondents indicated 301 applications were made.

Golf course superintendents give high priority to management practices
that do not have a negative impact on the environment. Meeting or
exceeding the expectations of their customers (golfers), while ensuring
golf\'s compatibility with the natural environment, is fundamental for
the financial success of golf facilities.

GCSAA supports the continued use of paclobutrazol on golf courses.
Paclobutrazol has unique characteristics, it is a plant growth regulator
and it slows down the growth of annual bluegrass, which makes it
important for superintendents to retain access to paclobutrazol. While
GCSAA understands that the volume of use of this product might not be
high *the importance of the product* to GCSAA members remains high.

Thank you for the opportunity to submit these comments. Please forward
any questions or comments to me by phone at (406) 656-1986, or by email
at [[cthrossell@gcsaa.org]{.underline}](mailto:cthrossell@gcsaa.org_),
or direct mail at GCSAA, 1421 Research Park Drive, Lawrence, KS, 66049.

Sincerely,

Clark Throssell, Ph.D.

Director of Research

GCSAA