September 22, 2014 Golf Course Superintendents Association of America 1421 Research Park Drive • Lawrence, KS 66049-3859 • 800.472.7878

VIA E-MAIL and U.S. MAIL Ms. Tracy Perry Team Leader Risk Management and ImplementationBranch III (RMIB III) Pesticide Re-Evaluation Division U.S. Environmental ProtectionAgency One Potomac Yard 2777 S. Crystal Drive Arlington, VA 22202 Re: Fenamiphos Stocks- Supplemental to August 5, 2014 Request for Continued GolfCourse Use Until October 6, 2017 DearTracy: I write onbehalfofthe members ofthe GolfCourse Superintendents Association ofAmerica (GCSAA) regarding the continued use ofexisting stocks offenamiphos on golfcourses. We appreciate EPA carefully reviewing GCSAA's request for the extension ofuse offenamiphos stocks past the October 6, 2014 deadline and wanted to offer some additional information to the agency as itcomes to a final decision on this imp011ant request. As noted in our previous letter, golfcourses were not aware ofthe October 6, 2014 deadline whereby stocks must be used up. IfEPA allows continued use offenamiphos stockspastthe October 6, 2014 deadline, GCSAA is committed to making sure that all U.S. golffacilities and all GCSAA members are made aware ofany new compliance deadline. Listed below are numerous ways GCSAA would be able to accomplish this task:

• Publishthe compliance deadline in Golf Course Management magazine, which goes to all golfcourses inthe United States • Publish the compliance deadline in GCSAA This Week, which membership e-newsletter goes to every GCSAA member • Publish the compliance deadline in Greens & Grassroots, GCSAA's government relations e-newsletter • Send a special e-blast from GCSAA's ChiefExecutive OfficerRhett Evans to entire GCSAA membership • Include the compliance deadline on GCSAA.org in a prominent location • Utilize our 9 regional Field StaffRepresentatives on the ground in the states to spread the message

GCSAA is dedicated to serving its members, advancing theirprofession, and enhancing the enjoyment grmvth andvitality of the game o(golf• Work with our government relations counterpmts from the PGA ofAmerica, United States GolfAssociation, Club Managers Association ofAmerica, National Club Association and National GolfCourse Owners Association ofAmerica to publishthe compliance deadline in their communications vehicles GCSAA is available to also working with the agency to generate additional ideas to ensure a new compliance deadline is made well known to golffacilities. In any message sent to golffacilities, we would emphasize that golffacilities must use up remaining stocks by the newexisting stocks deadline. Lastly, it has come to our attention the agency may have some questions about the efficaciousness ofremaining fenarniphos products. Mark M. Mahady, President ofMark M. Mahady & Associates, Inc. who is referenced in ourAugust 5 letter, says that undoubtedly Nemacur is still very efficacious for suppression/control ofAnguina pacificae. Ithas been used sparingly, perhaps only once per year during severe outbreaks, as an effective component ofan !PMprogram with azadirachtin based products. Dr. Billy Crow, University ofFlorida, and also referenced in our August 5 letter, reports that he is still using Nemacur as an industry standard in his trials and getting a positive response. For additional information on this topic, please feel free to reach out directly to either Mr. Mahady or Dr. Crow for additional insight. Mr. Mahady can be reached via cell phone at (831) 236-2929 or via e-mail at markmahady@aol.com and Dr. Crow at (352) 273-3941 orvia e-mail at wtcr@ufl.edu. Thank you again for your consideration ofthis important and time sensitive request from GCSAA on behalfofU.S. golffacilities. Please do not hesitate to contact me ifyou have any questions or need additional information. We look fmwm·d to hem·ing from you shmtly. Sincerely,

Chava E. McKeel Director, Government Relations GolfCourse Superintendents Association ofAmerica

cc: Mark Mahady, President, Mark M. Mahady & Associates, Inc. William (Billy) Crow, Professor ofNematology, University ofFlorida Rhett Evans, GCSAA ChiefExecutive Otncer