On page 95 of this proposed text, the list of Annual N fertility rates for Golf Course fairways and roughs does not distinguish between cool season grasses (Bluegrass, Ryegrass) and Warm Season Grasses(Bermuda and Zoyia).

In our divided state of cool season grasses mainly in Northen Va and Warm Season grasses in the South and Tidewater region their needs to be an adjustment to the text to take into account the different N levels for both types of grasses for fairways and Roughs.  For example, Bermuda growin on fairways and roughs in Richmond would prefer to be fertilized with N rates in the 3-5Lb range not 1-3 as stated in the text.

Please look to Va Tech and other Turf Professional  Managers within the state for reccomendations on changing this part of the text.    Thank you 

 

  

The proposed nutrient guidelines will hopefully help to reduce nutrient loading into the Chesapeake Bay and its tributaries.  I have many friends and family that enjoy both the economic and recreational benefits of the Chesapeake Bay and I hope that it is alive and healthy for future generations to enjoy.  For the most part, the proposed regulations represent what most of us in the turfgrass industry have been doing already.  However, I believe the proposals could use some adjustments.

In section VI on page 95, the recommendation for golf course fairways is 1-3 lbs. of Nitrogen / 1000ft2 per year and the recommendation for golf course roughs is 1 lb. N. / 1000ft per year.  It has been well documented in standard industry publications such as "Turf Management for Golf Courses" by James Beard PhD. and "Turfgrass Soil Fertility and Chemical Problems - Assesment and Management" by Drs. Carrow, Waddington, and Rieke that nitrogen rates for bermudgrass should range anywhere from .25  - 1.5 lbs. Nitrogen / 1000ft2 per growing month.  In the Tidewater region of Virginia, these recommendations would equate to ranges between 1.75 to 10.5 lbs. of annual Nitorgen per 1000ft2.  The proposed regulations only allow for 1 lb. (for roughs) and 3 lbs.(for fairways) per 1000ft2 per year. These authors of the above publications are some of the most experienced and well-respected turfgrass researchers in the country. 

Virginia has very diverse climatic regions.  Some golf courses are growing warm-season turf while others are growing cool-season turf.  Even within the bermudgrass family, there are more than 20 different varieties that require different levels of nutrition to maintian quality turf.  Also, some courses may also be in the "grow-in" phase of development where even more nitrogen may be temporarily required to speed establishment.  The proposed limits on nitrogen application rates are too low and would severely limit our ability to maintain quality playing conditions for our customers. 

Please seek input from organizations such as the Virginia Turfgrass Council, Virginia Golf Course Superintendent's Association, the current turfgrass extension staff at Virginia Tech, as well as other turfgrass practitioners in the state so that we can come to a compromise that will help to both protect the environment and allow turfgrass managers to grow quality turf.

We are all concerned about the environment and what our generation is doing to protect it for future generations.  It is always necessary that nutrient management recommendations for turfgrass systems be based on strategies that protect our soil and water.  Nutrient management has some similarities to human diets.  Too much or too little food for a human has negative consequences.  Likewise, nutrient management recommendations that are so restrictive can negatively impact turfgrass density and health.  Restricting adaquate nutrient levels for turf is much like aggressive dieting for humans.  In many cases restricting food will create a weak plant that is not able to withstand environmental stress. If we under fertilize for too long of period, it will likely cause even greater environmental concerns due to factors such as higher soil erosion potential and less retention and filtration of sediments and/or chemicals.

 

Here are some selected points to consider regarding the proposed regulations: 

 

1)      The maintenance of a dense, healthy turf has both environmental and economical implications and must continue to be emphasized.

a.       There is less potential for soil erosion and such turf provides a highly effective filtration system for dust, nutrients, chemicals, and sediments.  This “functionality” of turf applies to all situations where soil stabilization is desired, but is of particular importance in the establishment and maintenance of turf for slopes and highway rights-of-way.

b.       A healthy, thick turf is desirable for both aesthetics and playability in terms of golf and sports turf management.  In a culture where so much emphasis is placed on sport for enjoyment, exercise, and recreation, it is important to maintain an actively growing turf that can withstand the rigors of managed turf use and deliver safe, desirable playing surfaces.

c.       Lawns are usually a major landscape component surrounding homes and businesses.  In addition to the functional uses of turf presented above, turf serves as a major source of heat and noise abatement, as well as provides beauty and economic value to the property.

2)      The diversity in Virginia’s grasses, climate, soils, and the end use of the turf is conducive to site-specific nutrient management planning rather than broad scale criteria that try to address all situations at once. 

a.       For instance, in the current recommendations specific N level recommendations for certain components of golf turf management (fairways and roughs, page 95, Section VI) are very restrictive and do not address management systems that distinguish between cool-season turfgrasses (ryegrasses, bluegrasses, fescues, or bentgrasses) from warm-season grasses (primarily Bermuda grass and Zoysia grass).   Annual N fertility levels of 1-3 lbs. N/1000 sq ft for fairways and 0-1 lb. N/1000 sq. ft. for roughs are extremely conservative and are inadequate to meet the nutritional and/or playability needs of grasses at many facilities.  In particular, it is inconceivable that golf turf fairways that are likely mowed a minimum of 2-5 times per week at 0.5 to 1 inch cutting heights could have more restrictions placed on their N use levels than those currently recommended for home lawn turf management in Virginia.  However, this is the case when you review the N levels recommended in the DCR-VCE-Chesapeake Bay Program informational tri-fold bulletin entitled “Tips on Keeping Your Lawn Green and the Chesapeake Bay Clean”.  Again, there needs to be a certain level of flexibility and site-specific recommendations in future nutrient management programs because of the inherent differences in nutritional requirements between (and within) cool and warm-season turfgrasses.

 There are many unbiased sources of information that address the nutrient needs of all types of turfgrass.  I would encourage those involved to look to organizations such as Rise

www.pestfacts.org and the various universities for more info.

I have not read the entire act, but from what I have read it seems to me that the people who would oversee this endeavour are mostly from the agriculture side and have little if any at all knowledge of what it takes to run a golf course. As a municipal course with a small budget I would be spending funds for this program that would be sorely needed elsewhere.  Golf  course superintendents are taught to be good stewards of our enviornment, and we hold ourselves to a higher standard than is mandated. It seems to me that this program, if passed, will punish those who are already doing their best to protect our resources. Before I could fully support such a program I would have to see firm data that supported what is proposed

As a former Va Tech Extension Agent, past President of the Virginia Seedman's Assoc, former Director of the Virginia Turfgrass Council, and with 30 years experience in turfgrass management I disagree with this proposal. Mr. Whitmere has presented a valid and compelling case. While the recommendations may look good on paper, the recommendations ignore validated research. The implementaion of said recommendations would be a great hindrance to turfgrass managers resulting in a negative impact on the environment.

I support your efforts to protect our environment, and this is a driving policy of my company as well. I am concerned with one aspect of the proposed changes of your nutrient management training and certification regulations. My company treats cool season grass lawns of residential and comercial properties. One of our main sources of fertilizer is "Stabilized Nitrogen" (brand name UMAXX).This is urea (100% watersoluable) combined with N-(n-butyl) thiophosphoric triamide, (NBPT), a urease inhibitor, and dicyandiamide, a nitrification inhibitor. The NBPT stops nitrogen volatization and dicyandiamide stops microbial conversion of ammonium to nitrate. This product makes for more efficient utilization of our nitrogen applications while protecting our water from leaching. While the effect is equivalent to a slow-release nitrogen source, it technically is not because all of the nitrogen is water soluable. I am concerned that our use of this environmentally friendly product might be restricted because of a technicality. This product saves us money both in material costs and time savings. Restricting its use to 3.5 pounds per 1000 ft. per year would be detrimental to our lawn care program. Can wording be added that will allow for use of this type of product at rates adequate for proper turf nutrition?  

I am very much in favor of  protecting the Chesapeake Bay. However, the proposed nutrent levels for golf course fairways and roughs are too low to produce a  thick healthy turf. A more workable number for nitrogen levels would be 3-5 lbs. n/1000 sq. ft. for fairways and up to 3 lbs n/1000 sq. ft. for roughs. Please contact the Agronomy Department at Virginia Tech and The Virginia Golf Course Superintendents Association for more information before making an final decisions.

I strongly encourage more research and study before we change any regulations or limitations on agriculture - including the Turf Grass Industry.  We must make sure our regulations are no more restrictive than other areas of the country so we maintain an economically competitive environment.

I question how we can expect waterways to be clean with double digit residential growth in most areas.  Human waste is nutrient rich just like livestock waste.  The majority of those nutrients directly enter surface water through wastewater treatment facilities.  At least most nutrients from livestock waste are recycled and land applied as fertilizer.

Nutrient loading in watersheds is a problem we all have to deal with.  From my perspective, this and most proposals shift an unfair amount of the corrective action to agriculture.  I also question how much of the proposed change is based on sound, objective research.

 

The proposed changes to the Nutrient Management Training and Certification Regulations place an unreasonable burden on farmers within Virginia.  Farmers throughout the state face many challenges each growing season ranging from weather factors to market fluctuations.  These challenges have forced many farmers to abandon their farm operations and sell their land.  Often times the land is sold to developers.  In the last half-century, technology and scientific research have greatly decreased the use rates of nitrogen, phosphorus, and many other inputs used on farms.  While farming is not a perfect science, it is one of the most effective BMP's available.  It is much easier for pollution to reach Virginia's surface waters if it runs across a parking lot than if it must flow across a field.  Help Virginia's farmers remain profitable so that we can continue to do our part in conserving and protecting our environment while producing safe and cheap food by canceling these proposed regulation changes.

Love of the outdoors and the ability to work "in" nature and not gaze at it through a pane of glass is the primary reason I and many of my peers are in the green industry.  So I have no problem with, and in fact agree with many of the concerns addressed in this document.  Nutrient loading of waterways is not a new topic to our profession, but rather something that has been at the forefront for years.  That is why the industry has been proactive in developing slow-release fertilizers, encouraging buffer zones, and developing best management practices.

My concern with governmental regulation is that it typically is painted with a broad brush.  Rarely are all the factors calculated.  Specifics like: type of turfgrass (warm season vs. cool season); type of fertilizer (quick release vs. slow release); new establishment or maintenance of turf; different soil types; sports turf (where constant growth and recovery are essential) or low maintenance turf; etc.  Such is the case with the proposed regulations, specifically page 95, section VI.

Good, sound science based information is available from Virginia Tech, the Virginia Turfgrass Council, the United States Golf Association Green Section, and the Golf Course Superintendents Association of America addressing nutrient issues.  I would hope that these organizations would be consulted and this information given proper consideration.

 

 

 

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.

Having read the Economic Impact Analysis of proposed changes to 4 VAC 5-15 I must comment.  The words "economic" and "analysis" imply that a situation is studied using facts and definitive numbers.  This document does not do that.  It is lacking in real information about the cost of these regulations to Virginia farmers.  Lacking the information and wishing to promote the changes anyway, the report turns to a string of assurances that "the impact is not likely to be large."

The first sentence of the Economic Costs section reads "The proposed phosphorous and nitrogen management criteria are likely to impose additional costs...."  Further on there is the statement "While the overall impact on poultry farmers is hard to determine with any degree of certainty, DCR expects that...."  And, "Due to the uncertainty surrounding the number of poultry farmers likely to benefit and lose out due to the proposed change, an estimate of the cost savings is not possible at this time."  The classic line is "Thus, given the many large uncertainties, it is not possible at this time to make a sound determination of the net economic impact of the proposed change.  However, both the costs and benefits are likely to be large and the net economic impact, whether positive or negative, is not likely to be very large."  It seems that the agency does not know the economic impact and is determined to charge ahead anyway.

Many poultry farmers have just felt the impact of the current phosphorous standard in the last two years.  They are buying commercial nitrogen to supplement.  The are hauling greater distances.  They are renting more land.  They are often giving away what once was an income producer.  Based on concerns expressed by many of our contract growers the proposed phosphorous application rates appear to be burdensome.  Without a clear understanding of these costs on a small but important group, it is not appropriate to hasten on with reductions in allowed phosphorous application rates.

I would recommend that the rates be no more restrictive than "crop removal."  That is already moving manure over greater areas and encouraging responsible application.  The 50% saturated criteria for 2010 must have only an arbitrary basis.  I have not previously heard of any arguement for this criteria.  The perception is that it is an arbitrary number that will continue the increasing restriction of phosphorous application.  The 50% criteria should be removed.

The use of the P Index is good science and is a good addition to the regulation.  The use of conservation BMPs is good for the environment, localizes nutrients and should be encouraged.  The P Index does encourage the use of BMPs by recognizing the benefits.  With good BMPs one can safely apply more than "crop removal," decreasing the need for inorganic nitrogen application.

The current revisions to the regulations and nutrient criteria address new and revised components, in particular phosphorus management, timing considerations, and heightened attention to the Green Industry segment of agriculture.  These revisions should seek as their foundation the best available science, and be crafted to achieve the maximum environmental protection with due consideration of the economically achievable outcomes for the citizens of the Commonwealth.

 

Key Points 

1. Soil Test Threshold versus P Index.  P enrichment (biosolids, manures, etc.) does not harm the environment and certainly presents no direct threat to life.  Only when significant amounts of unbound P move from agroecosystems to surface waters with naturally low P concentrations are these aquatic systems adversely affected.  The consensus of the scientific community on this issue is that assessment of potential P impact shall (not should) consider not only the “source” component (soil reserves and added P-containing materials), but the “transport” (runoff, erosion, and leaching) component as well.  This should be the underlying scientific principal of P-based nutrient management plans.  The use of a soil-testing based threshold alone, as proposed by this regulation, addresses only the source component, and is thus runs contrary to the best available science. 

 

If transport is minimized through variety of BMPs promoted by DCR, and actual P loss is truly minimized, a soil test threshold based system (such as the 65% and 50% saturation limits) erroneously continues to “predict” high P losses, and imposes the same restrictions as those imposed on a site with no management of transport losses.  Losses are grossly over predicted.  In the second type, a producer below the 35% saturation could choose to use this “assessment method”, and still make P additions.  If he fails to manage transport losses (runoff and erosion) the site could still lose excessive amounts of P.   Losses are grossly underestimated.

 

The use of the P-Index method attempts to deal with source and transport factors and should not be abandoned simply for the convenience of a rapid soil test threshold method.  

 

2.  Crop Phosphorus requirements are not always correctly predicted by soil test levels alone.  There are instances in which a crop requires and responds economically to small additions of starter P even though the soil test values are high.  This may results from extremely slow root growth in cold soils, from slow diffusion rates of P, or from a lack of moisture.  To deny these applications will place these growers at a significant economic disadvantage.

 

3) The Green industry/urban/non-agricultural nutrient management requirements are currently covered in essentially by TWO sentences. These sentences clearly do not reveal expectations and criteria for planners who are to prepare nutrient management plans for turf, roadside vegetation, and horticultural crops.  This document must define this process for those agencies, voluntary planners, and for future mandated programs.  

 

Agency Comments and Economic Impact

 

1)  In 62.1-44.17.1.1 “Poultry waste management program”, Section C2c. states that DCR, in consultation with DEQ .....“ Has such a review been completed and in what manner has DCR made the summary of this study public?  Available documents contain only the DCR response to part ii of their charge.  How can the affected citizens of the Commonwealth access the extremely important scientific documentation which forms the basis for the proposed regulatory changes?    

 

2) DCR has lobbied heavily and effectively to require all state agencies to develop nutrient management plans for lands under their control.  While we agree with this goal, several sections of the economic impact analysis totally ignore these additional implementation costs to the state agencies, and even fail to include these agencies as affected parties.

 

3) The economic impacts attributed to these changes are in large measure ignored as either attributed to other regulations, or dismissed on the basis of voluntary participation in the program.   The fact remains that new costs will accrue to both the citizens and to affected state agencies directly as a result of the changes proposed.  DCR is fully aware that these regulatory changes will indeed be mandated for a variety of users (CAFOs, poultry producers, fellow state agencies) and it seems very likely that they may again lobby for additional non-voluntary programs in the near future.  In all fairness to the citizens of the commonwealth, DCR should make a good-faith attempt to address the true costs of implementation which will be required by the changes under the known existing mandates.

 

 

 

 

In regards to the proposed amount of nutrients that can be applied to golf course turf, it is apparent that more research is necessary.  As stated in previous comments, healthy turf is as good a filter as the bay can get as far as preventing run-off into the waters that all of us in this region use and enjoy.  Most golf course managers have received extensive training in the field and use nutrients in a manner already consistent with best management practicies.  To limit the amount of nitrogen that can be applied to turf so that it is helathy is a mistake.  Please take the time to consult with turf managers and University experts before enacting legislation that could prevent us from growing the grass that WILL filter the nutrients before they reach the bay.  As someone who lives in Tidewater and whose family enjoys the waters around us, I do everything in my power to prevent run-off and pollution, but not being able to grow strong turf will cause larger areas of uncovered soil,  leading to pollution and leaching of nutrients into the waters we are trying to protect.

I believe that it is of the utmost importance to protect and improve this beautiful and unique environment in which we all live.  I also believe that many of your efforts to do this have been very beneficial, and I agree with many of the regulations you have implemented in the past in order to do this.  Upon saying that, I would like to state that this document is not one of them.  It contains no sound, science-based information and the entire report is full of assumptions.  Much of the statistical information it does contain is five and ten years old.  Not having the assured information required, this report turns to using phrases such as “likely”, “DCR expects”, and “not possible to make a sound determination at this time.”

 

Due to the already stringent regulations farmers have been confronted with, as well as the increased cost of supplies and resources, farming has become more and more difficult to maintain as a viable occupation.  Throughout the report, however, these costs have not been quantified.  It appears as though the economic analysis was rushed through and many critical pieces were forgotten or just ignored altogether.    

 

The use of the P-Index is a very good method, and when used in association with other BMP’s, will accomplish our goal of protecting our environment much more efficiently.  Using crop removal as the application rate is already restrictive enough and encourages organic nutrients to be moved to fields with a higher need.  There is no scientific basis for the 50% saturation limit, and I recommend that it be removed from the regulation altogether. 

I urge you to take the time to consult organizations and institutions, such as Virginia Tech, that have a sound background in dealing with the research of these nutrient issues before you move forward with this regulation.  If not, devastating outcomes could result to not only Virginia farmers, but to Virginia’s economy as a whole.

We must approve these regulations in order to have any hope of controlling what so called nutrients are placed on our farm land.   I am afraid for our soils, our animals and birds, our people, and our aqualife.  Please take this very small step toward helpiong to protect us all.

I am writing to wholeheartedly support DCR’s proposed regulation 4 VAC5-15. 

 

As a businessperson and professional whose livelihood is directly impacted by the health of the Shenandoah River, I have watched for more than two decades as the water quality of this and nearly all rivers in the Commonwealth has deteriorated.

 

Our current and economically devastating river-wide fish kill has is being attributed to the poor water quality caused by nitrates and phosphates derived primarily from agricultural runoff.  There are few golf courses and urban runoff areas in this rural area of the South Fork of the Shenandoah River.  The culmination of the failure of voluntary practices to curtail pollution is visible with this fish kill.  4 VAC5-15 promises to begin to correct these failures.

 

After decades of failed voluntary efforts – recall the “Nutrient Reduction Strategy 2000” program – it is time to regulate.  Decades of failure require a stronger approach to achieve the needed long and short-term improvement in water quality.

 

On the South Fork of the Shenandoah River voluntary Best Management Practices (BMP’s) has not solved nutrient loading, bank degradation and other ill effects caused by  lack of regulation and enforcement on the agriculture community that dominates the Shenandoah’s watershed.   It is time for all – especially our friends in the agriculture community – to take the long view to stop pollution. All interest groups view change and regulation through the lens of their singular perspective, which is often myopic and now driven.  Having healthy water is good business and good for business.

 

As a businessperson in a highly priced, competitive and non-subsidized market where price increases may spell ruin, I fully understand the intrusive nature and additional cost this regulation might engender; interest groups always call it burden.  I prefer to call it investment.

 

One of the underlying assumptions in economics is that participants make rational decisions based not on the past but on current viable information. Additionally, in our system, those who cannot compete either become more efficient or fail. All businesses have hardships.  All businesses under American Capitalism are constantly faced with increasing costs. Typically, these costs are passed on to consumers. It is simply the price of doing business. I do not believe I have ever heard any major retailer whining about the cost of doing business. The prices simply go up.  Increasing costs (gasoline is an example we can all relate to) is a business constant.    

 

This regulation is a good starting point.  In order to protect our river and the ability of agriculture, golf courses and other rural based businesses to continue to succeed in the long term, I am willing to invest in the future by passing on to my customer base the additional burden that Regulation 4 VAC5-15 might create.  This will allow everyone to invest in the future. It is the American Way!

 

Regards,

Trace Noel

My Name is Jeff Yarborough. I am a Certified Golf Course Superintendent with the National association GCSAA and curently the Vice President of the Virginia Golf Course Superintendents Association. I am an avid fisherman and enjoy all the recreational opportunities that the Chesapeake Bay and many of its tributaries has to offer. My golf course is located on the Nansemond River. I practice intigrated pest management and make no pesticide applications or fertilizer applications unless they are critical to plant survival and health.

Having said this I feel as though some important information is not included in your proposed reccomendations. It would be in the best interest of all parties involved to have Va Tech Staff, members from the Virginia Turf Council, and the Virginia Golf Course Superintendents Association come together to put together quidelines that meet the needs of our environment and agri business of Virginia. Comments from some of our members are posted and address some of the specific issues that need to be addressed. I look forward to the opportunity to work with the State on creating a real and needed set of attainable guidlines. Keeping Virginia Green thank you for the opportunity to comment.