PCNB update from Dave Green
Many of you asked me for an update in the PCNB process when I had the chance to visit with you last week at the GLTE. Most know the review period did finally end January 8th after three extensions. The final tally looks like this:
Garlic Growers 1 response to retain use
Potato Growers 8 responses to retain use
Ornamental Growers 1 response to retain use
Turf 156 responses to retain use, 3 to drop turf
In addition to these largely grass roots responses, Amvac submitted on the last day a 200 plus page document that appears to be an outline of a legal brief to be filed on the Environmental Protection Agency. This is a crap shoot in our view. It could force the EPA to back off or it goes the other way on them and us. Our experience playing hardball with the EPA has not been good but we have seen others have success. The EPA is not required to reply to these comments within any time frame but our registration people expect a response between 30 and 60 days of January 8 so we are looking at February or March for a final decision, we think, but again no guarantee.
What we can guarantee is the EPA was impressed with the number of grass roots supporters of turf usage for PCNB. I can also guarantee this response would not have been delivered without your support, your hard work and your persistence in the face of those who said it could not be done. As you make the rounds this winter, please make sure your customers know how much we appreciate their individual efforts in this cause.
Speaking on behalf of everyone at Chemtura Corporation, I want to say to each of you a very sincere Thank You! I can't guarantee we'll win, but together we mounted a good fight. You are to be congratulated. My best in the New Year!
Dave Green
Specialty Chemicals Field Sales
Chemtura Corporation
14807 Blues Creek Road
Marysville, OH 43040
800-763-6049
FAX 937-642-4023
Dr. Joe Vargas PCNB support letter
September 7, 2006
Public Information and Records Integrity Branch
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460-0001
Attention: Docket ID No. OPP-2004-0202
A. Identity of Commenter
J. M. Vargas Jr. PhD, Professor of Plant Pathology, submits these comments in response to the Benefits and Cost Analysis of PCNB and Alternatives for Use on Golf Course Turf (Greens, Tees, and Fairways).
I have been a member of the faculty at Michigan State University for the past 37 years. I have conducted snow mold fungicide trials every year since I first arrived in November of 1968. I have published the most widely used turfgrass disease text in titled “Management of Turfgrass Diseases Third Edition”.
B. Comments
Snow mold is a combination of two diseases, Typhula blight (cause by Typhula incarnata and Typhula ishikariensis) and Microdochium patch (caused by Microdochium nivale). The percentage of each fungus contributes to a snow mold outbreak varies from year to year. The only cost effective control for snow mold on golf course fairways in areas where permanent snow covers the ground for 3 or more months is PCNB.
Table 1 is based on studies conducted by Dr. Schmann in Massachusetts where snow cover and thawing occurs throughout the winter period. These data are not really relevant for regions that have permanent snow cover for 3 or more months The other most cited reference in the report is from Kentucky where severe snow mold outbreaks do not occur. Some of those cost effective combination alternatives may work well in Kentucky or Massachusetts, but they will not work in Northern Michigan or similar regions where snow covers the ground for three or more months.
In Table 3 of the report cost comparisons of fungicide combinations with and without PCNB are valid, but these combinations are used almost exclusively on greens and occasionally tees. They are not used on fairway because of the costs involved, or in some cases lack of snow mold control. I know of no golf course in Northern Michigan that uses anything other than PCNB for the control of snow mold on fairways.
Another problem with the suggested alternatives is the EPA-imposed restrictions on the total poundage of certain fungicides that can be applied in any one season, or the limited number of applications that can be made in a given season. In the sighted study, 12 of the 26 combination products contain chlorothalonil and 8 of the 18 combinations without PCNB contain chlorothalonil. Also, in my snow mold studies conducted in Northern Michigan chlorothalonil is an important partner in any fungicide combinations especially when PCNB is not included.
Chlorothalonil has an annual poundage restriction for greens, tees, and fairways which is normally reach before it is time for snow mold fungicide application to be made. One of the reasons for chlorothalonil usage during the growing season is fungicide resistance management. Most of the resistance problems on golf courses have occurred to the dollar spot organism. Chlorothalonil is an important rotational partner in delaying resistance and, once resistance has occurred, it becomes the most economical way of managing dollar spot. It doesn’t take long to use up the allotted amount of chlorothalonil way before snow mold fungicide applications are to be made.
PCNB is the most economical means of controlling snow mold on golf course fairways. If it is removed from the market place, most golf courses will not be able to afford to apply the three way combinations necessary to obtain adequate disease control in climates like Northern Michigan. It will be especially devastating to golf courses that have predominately creeping bentgrass fairways where the primary disease is dollar spot during the summer. If the snow mold kills the creeping bentgrass, it will be replaced by annual bluegrass which will then require multiple fungicide applications of various fungicides for not only dollar spot but anthracnose and summer patch as well.
Memo from Dave Green of Chemtura
I hope I am safe in assuming all of you in Turfgrass, Inc. are very familiar with the attached letter issued a few weeks ago.
My purpose in writing again is to remind you that this window of opportunity to respond to the RED issued by the EPA on PCNB will close October 2, 2006. If the RED as issued August 2, 2006 is allowed to stand we can expect to hear from the EPA on when manufacturing of PCNB will actually end.
We are optimistic this will not happen. PCNB has been a significant player in the turf market for a long, long time. The problem is snow mold is not a national problem and for a good number of members in the GCSAA they are not concerned. For many supertendents in the middle part of the country that are only treating greens and tees so a cost increase would not be all that significant.
For those customers in the northern part of your sales territory it is a different story. These are the courses that are now spending 45 to 50% of their total fungicide budget for snow mold prevention. An increase of even a small percentage makes a tremendous difference in their operations. These are the same folks that already have a short season. Cost containment for these accounts is critical to their operations. They have to show a profit to survive and remain Turfgrass, Inc. customers.
Between now and October 2nd, please make available the PDF open letter below and encourage your customers to write directly to the EPA concerning this issue. The future of PCNB is in large part in your customers hands. We will respect their decision.
Dave Green
Specialty Chemicals Field Sales
Chemtura Corporation
14807 Blues Creek Road
Marysville , OH 43040
Phone 800-763-6049
FAX 937-642-4023