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 Implementation Branch III (RMIB III) 

Pesticide Re-Evaluation Division 

U.S. Environmental Protection Agency 

One Potomac Yard 

2777 S. Crystal Drive 

Arlington, VA 22202 

Re: Fenamiphos Stocks- Supplemental to August 5, 2014 Request for Continued Golf Course 

Use Until October 6, 2017 

Dear Tracy: 

I write on behalf of the members of the Golf Course Superintendents Association of America 

(GCSAA) regarding the continued use of existing stocks offenamiphos on golf courses. We 

appreciate EPA carefully reviewing GCSAA's request for the extension of use offenamiphos 

stocks past the October 6, 2014 deadline and wanted to offer some additional information to the 

agency as it comes to a final decision on this imp011ant request. 

As noted in our previous letter, golf courses were not aware of the October 6, 2014 deadline 

whereby stocks must be used up. If EPA allows continued use of fenamiphos stocks past the 

October 6, 2014 deadline, GCSAA is committed to making sure that all U.S. golf facilities and 

all GCSAA members are made aware of any new compliance deadline. Listed below are 

numerous ways GCSAA would be able to accomplish this task: 

• Publish the compliance deadline in Golf Course Management magazine, which goes to 

all golf courses in the 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 Chief Executive Officer Rhett Evans to entire 

GCSAA membership 

• Include the compliance deadline on GCSAA.org in a prominent location 

• Utilize our 9 regional Field Staff Representatives on the ground in the states to spread 

the message 

GCSAA is dedicated to serving its members, advancing their profession, and enhancing the enjoyment grmvth and vitality of the game o( golf 
• Work with our government relations counterpmts from the PGA of America, United 

States Golf Association, Club Managers Association of America, National Club 

Association and National Golf Course Owners Association of America to publish the 

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 golf facilities. In any message sent to golf facilities, 

we would emphasize that golf facilities must use up remaining stocks by the new existing stocks 

deadline. 

Lastly, it has come to our attention the agency may have some questions about the 

efficaciousness of remaining fenarniphos products. Mark M. Mahady, President of Mark M. 

Mahady & Associates, Inc. who is referenced in our August 5 letter, says that undoubtedly 

Nemacur is still very efficacious for suppression/control of Anguina pacificae. It has been used 

sparingly, perhaps only once per year during severe outbreaks, as an effective component of an 

!PM program with azadirachtin based products. Dr. Billy Crow, University of Florida, 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 or via e-mail at wtcr@ufl.edu. 

Thank you again for your consideration of this important and time sensitive request from 

GCSAA on behalf of U.S. golffacilities. Please do not hesitate to contact me if you have any 

questions or need additional information. 

We look fmwm·d to hem·ing from you shmtly. 

Sincerely, 

Chava E. McKeel 

Director, Government Relations 

Golf Course Superintendents Association of America 

cc: Mark Mahady, President, Mark M. Mahady & Associates, Inc. 

William (Billy) Crow, Professor of Nematology, University of Florida 

Rhett Evans, GCSAA Chief Executive Otncer