Virginia Pollutant Discharge Elimination System (VPDES) General Permit Regulation for Discharges Resulting from the Application of Pesticides to Surface Waters
[9 VAC 25 ‑ 800]
Commenter:
Matt Boyce, Virginia Golf Course Superintendents Association
Pesticides and surface water
My name is Matt Boyce and I'm the Golf Course Superintendent at Princess Anne Country Club in Virginia Beach. I am also the President of the Virginia Golf Course Superintendent's Association representing it's five chapters. We appreciate the opportunity to comment on the VPDES General Permit for Discharges Resulting from the Application of Pesticides to Surface Waters. We feel that the Virginia Department of Environmental Quality were very responsible in working with businesses on it's advisory panel and listening to the concerns on how this would effect small business. We believe that what could be done within the parameters set by the EPA was given full consideration to have a working solution. That said, we feel strongly that this Permit is redundant to what is already covered in FIFRA and an undo burden to small business. In challenging times for all, putting additional costs to any business for reasons that already have regulatory guidance and requirements would seam inappropriate.