Thank you for the opportunity to be involved in the protection of our environment. You have my overall concerns from the public hearing I attended in Fredericksburg, following are some concerns regarding the specific guidelines.

Pg91 Recommended season for N applications - does not take into consideration unusual weather like this past spring where we had several 60+ degree weeks in January and February. Some foliar feeding was done as the turf plant was actively growing.

 Warm season N applications end one month prior to first fall killing frost date - refer to above comment. Dr. Goatley of Va. Tech has research data on the value of late season N applications on bermudagrass.

Pg92 Do not apply more than one pound on N within 30 days, no differentiation between cool or warm season turf and established verses establishing turf or the fact that some do light frequent applications of foliar nutrients several times a month to put nutrients in the plant not on the soil.

Pg94 Recommendations for Established Turf - what is the defination of a " good stand of grass"?  Does not take into consideration vegatative propagation, ie.sprigging, of warm season grasses.       

Nitrogen Timing - 30 day N application interval,  again often use low frequent applications to control availability. Warm season grasses require higher rates to establish more frequently.

pg95 Recommendations for Golf Courses: Fairways should be 3-5 pounds and Roughs 1-3 pounds due to intense maintenance and constant mowing and the need for growth and recovery potential. Does not consider adverse weather, warm vs. cool season, established vs. grow-in situations.

Pg96 N Management on Athletic Fields -  What is considered "heavy use"? Does not differentiate between warm and cool season species or grow-in vs maintenance.

Please consult with Virginia Tech, the Virginia Turfgrass Council, Golf Course Superintendents Association of America and Virginia, National and Virginia Sports Turf Managers Association, United States Golf Association - Green Section, Virgina Nursery and Landscape Association and Virginia Green Industry Council for information and assistance in updating the guidelines to todays standards and practices.