Cosmetic Business Proposal Template Letter re B C pesticide consultation from golf by pjx11396


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									Letter re B.C. pesticide consultation from golf course staff member



Cindy Bertram
C. Rankin and Associates
P.O. Box 28159
Westshore RPO
Victoria, B. C.
V9B 6K8

Via e-mail:

Re: BC Government Cosmetic Pesticide Use Consultation Process

Dear Ms. Bertram:

I am writing as the <owner, general manager, superintendent, golf professional> of <golf course
name> in response to the current consultation process being conducted by the Government of British
Columbia to assess the views of the public with respect to the cosmetic use of pest control products.

The golf industry in Canada has worked for well over a decade to educate itself on the judicious use of
pesticides in the management of turfgrass. In fact, Canada was the first country to introduce Environmental
Guidelines for Golf Courses and has been referenced in the Environmental Principles for Golf Courses in
the United States and An Environmental Strategy for Golf in Europe. The Canadian guidelines were
developed in 1993 by the Royal Canadian Golf Association in consultation with the Canadian Golf
Superintendents Association (CGSA). They were revised in 2007.

In 2001, the CGSA developed the Environmental Management Resource Manual for golf. This guideline
was distributed to all of its members and was recognized by both the Golf Course Superintendents
Association of America and the British International Golf Greenkeepers Association as a key resource in
the area of golf course management. In addition, since 1997 all superintendent and assistant superintendent
members of the CGSA have been required to be licensed through their respective provincial government
authority in the proper use of approved pest control products.

The motivation for these and many other initiatives is both economic and environmental. Besides the fact
that pesticides require a significant expenditure, the current patchwork of municipal by-laws restricting the
use of pesticides creates a situation that has the potential to be confusing for the superintendents, the golf
industry and the public. It could also serve to drive golfers out of one community to an adjacent
municipality to find the playing conditions they seek. As such, the British Columbia golf industry
welcomes the Provincial Government’s proposal to introduce pesticide legislation that will level the
business playing field from the uneven situation currently being created by the enactment of municipal by-
laws. From the perspective of the environment, stewardship has always been at the forefront of the
profession of golf course management and the golf industry in Canada. As such, the value of the golf
course as a “green” enterprise within the community has never been more important than it is today. This
value is further enhanced by the current industry focus on issues such as the reduction of water and nutrient
use, carbon reduction, habitat protection and the need to maintain green space corridors within urban

Given the above factors, I would recommend the following inclusions in the Province’s legislative package:
       That if the government determines that the regulation of the cosmetic use of pesticides is
        necessary, that golf facilities be deemed to not be engaged in cosmetic pesticide use ;

       That if conditions are to be imposed on the continued use of pesticides by golf, that any such
        changes not restrict product availability and be phased in over a minimum period of three years,

       That a provision be included in the legislation that restricts municipalities from passing legislation
        related to pesticide use and overrules any existing bylaws.

I would also submit the following points to support my recommendations:

       turf on the golf course is NOT cosmetic or non-essential. The greens, tees and fairways are
        playing surfaces that are necessary to the game and to the business of golf. Since the business of
        golf depends on the quality of the playing surface, the negative economic impact of unsuitable or
        unplayable turf conditions would be economically devastating to a golf facility. As such, turf is
        essential to the business of golf and pesticides are vital to the proper health and care of turf;

       British Columbia accounts for approximately 13.5% of Canadian golfers or about 812,000 out of
        an estimated 6 million golfers. It contributes 1.58 billion to British Columbia’s GDP and 4.0
        billion in total production (direct, indirect and induced), over 46,600 jobs, almost 1.088 billion in
        household income, 161 million in property and other indirect taxes and 257 million in income

       the majority of golf course superintendents have a minimum of a two-year post-secondary diploma
        in turfgrass management (CGSA Compensation and Benefits Survey, 2008). They are trained and
        licensed to use, store and properly dispose of pesticides. They receive continuing education
        through a variety of sources (including national and regional conferences, regional seminars, web
        casts, university courses and online education) on new cultural practices, products and turf species,
        all focused on using all of the necessary inputs to provide suitable playing surfaces;

       the pest control products used are expense items and are used only when needed. Golf is a
        business and the economics of the business require superintendents to operate within the limits of
        annual budget estimates. However, when IPM protocols indicate that pesticides are needed, there
        really are no other viable options. There are fungal organisms that can destroy large areas of turf
        overnight that must be pre-treated when the climate conditions for disease development are

       the golf industry is committed to finding plant species and management practices that are
        complimentary to the objectives of integrated pest management (IPM). The golf industry funds
        research at Canadian universities through the Canadian Turfgrass Research Foundation (CTRF)
        and several other turfgrass research organizations at the provincial level, including the Western
        Canada Turfgrass Association (WCTA);

       most golf courses have controlled access. All golf courses are required to post signs in advance of
        using pest control products. Also, in most cases, entry to the property is through controlled access
        points where a fee is required to be paid, further limiting the possibility of uninformed access to
        the property;

       the turf used on golf courses is made up of very different species than turf found on a residential
        lawn or parkland. For example, creeping bentgrass is specifically used because of its ability to
        withstand low mowing heights to create a quality playing surface;

       the golf course industry has pro-actively developed an IPM Accreditation program offered by the
        IPM/PHC Council of Canada. It provides a way for golf course managers to understand the
        opportunities that IPM provides and a set of protocols for superintendents to follow to implement
        IPM. The protocols included are methodologies that are being practiced and implemented by a
        large majority of CGSA members. Besides being required to have a pesticide applicators license
        as a condition of membership, 98.3% of CGSA members indicated in a 2009 survey of
        environmental practices that they were familiar or very familiar with IPM practices. Seventy
        percent of members currently maintain IPM related records and on a scale on 1 – 5, CGSA
        members ranked on average a 3.95 in eight different IPM related skill areas, with the minimum
        average score for any of the skill areas being 3.57. Through ongoing professional development
        opportunities, CGSA members continue to implement IPM practices not as a regulatory
        requirement but as something that makes good business sense and that is also an environmentally
        sound approach to golf course management.

Thank you for your consideration of my submission.

Yours truly,

<golf course>

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