1. The safe and responsible use of pesticides has long been a top priority of
golf course superintendents and the golf industry. This has been well
demonstrated through the development and use of Best Management
Practices (BMPs), Integrated Plant/Pest Management Strategies (IPM) and
other voluntary environmental stewardship programs and initiatives.
2. It is critical that golf courses fall within the Level II or Level III Compliance
Matrix.
3. The terms “near” (referenced to throughout the Permit) and “adjacent” (page
5, line 2) should be eliminated and replaced with water’s edge. The
definition of “Water’s Edge” (page 11) should be defined at normal full pool
elevation. The golf industry requests that terrestrial pesticide applications on
golf courses in Texas not be subject to TCEQ’s draft NPDES PGP. We ask
that the TCEQ make the exemption for golf courses explicit in the permit to
provide regulatory certainty for this permit. We should only be dealing with
aquatic pesticide applications.
4. Page 11 – under definition of Water’s Edge. The use of the term
floodwaters or flooding throughout the permit should be eliminated.
Flooding is an uncontrollable act of nature, and should flooding occur,
runoff from other sources is unknown and uncontainable.
5. Page 9, under Point Source: What is the definition of “agriculture” and
would golf courses and commercial turf operations fall under that category?
6. Page 11, item (2) under Waters Edge: Where is the boundary of a
“conveyance to waters of the US”? The terms “runoff, irrigation waters and
floodwaters” are not included in Part I (Definitions) and without a clear
definition, such terms should be avoided. Many golf courses were purposely
constructed in the flood plains of communities and developments and
provide for storm water control and drainage of those surrounding areas.
Golf courses have proven to be excellent sources for pollutant filtration in
flood plains. Upstream runoff and floodwaters from storm events should not
even be relevant and again, should be eliminated.
7. Page 12, line 2-3 under Exceptions: The term “hydrologic surface
connection” is not included in Part I (Definitions). This term leaves too
much room for interpretation and should be eliminated.
8. The term “threshold” is quantified but how it is calculated is not included.
TCEQ calculations methods need to be explicit in the permit in its definition
– that only the actual surface area treated is included in the threshold limits.
9. Page 14 of the Matrix. Is there a difference between the Self Certification
Statement and the Self Certification Letter? Will these be available on the
website?
10.Page 18-2c: By definition on page 7, a “Pest Management Area” is a
contiguous are of land. Would the entire golf course be considered one pest
management area? Many golf courses wind through subdivisions and have
portions of the property that are dissected by streets. Would a street
constitute a break in a contiguous area of land and result in a separate PMA?
11.Are licensed contract applicators responsible for the applications and
recordkeeping, or is it the property owner?
12.Page 39 (a) reword to state “use the lowest application rate according to
label and target pest”. This may not be the lowest rate listed, but the
applicator will always be in compliance with the label and guidelines set by
FIFRA. Include a statement that the operator has the authority to use his
best professional judgment in making decisions on the appropriate label
rates for the control of the target pest.
13.It is critical the TCEQ provide training and information sessions to inform
and educate those affected by General Permit TXG870000.
14.In 2006, the total economic impact of the golf industry in Texas was $7.4
billion. Golf course superintendents are long-time industry leaders in their
commitment to continued education, research, and the use of current
technology.