|
Attachment One: Public Comment
Responses to National Park Service Comment Letter
August 23, 2002
Water Quality
1st bullet
In response to the NPS suggestion, one additional stormwater sampling
location will be incorporated into the monitoring program.
2nd bullet
The CA Department of Health Services was sent a copy of the EA at the
beginning of the public comment period, and did not respond with any comments.
3rd bullet
All testing of water samples will be done in accordance with EPA-approved
standards. Appendix A has been revised to indicate laboratory capability
to detect each pesticide listed in the Program at acceptable detection
levels.
4th bullet
One of the stated objectives of the IPM Program is to minimize risks to
the human health, wildlife and the environment. As explained in detail
in the IPM Program and EA, heavy emphasis on the use of non-chemical measures,
monitoring, and other preventative actions reduces and minimizes the need
for chemical applications. In the event that chemical applications are
deemed necessary, the Best Management Practices outlined in Chapter 12
of the IPM Program would be implemented to keep pesticides from adversely
or significantly impacting water quality. Further, section E-9 of the
Environmental Assessment, along with the following paragraph, discuss
how the pesticide selection process eliminated pesticides from the Program
that have a high potential to leach to groundwater. Three of the four
documents referenced by the NPS were reviewed and considered in the preparation
of the IPM Program and EA. The NPS does not specify the source of the
purported conflict amongst these documents and the EA, and the Trust disagrees
that these documents contradict one another.
The USGS National Water Quality Assessment Program's 1998 document entitled
Pesticides Used on and Detected in Groundwater Beneath Golf Courses,
compiled by Jack Barbash includes a list of 115 pesticides and pesticide
degradetes that have been used on a wide-range of golf courses. Of those
115, the document shows that twenty-three have been documented in groundwater
beneath at least one golf course. None of those twenty-three chemicals
that have been documented in groundwater beneath golf courses is included
in the PGC IPM Program. Thus, the statement in the EA that "all pesticides
that have been documented as having been found in groundwater beneath
golf courses (Barbash 1998) were removed from the IPM Program" is
accurate. This issue was previously discussed with NPS natural resources
representatives at a meeting on the PGC IPM Program on April 17, 2002.
5th bullet
The NPS's recommendation that Heritage be removed from the IPM Program
is noted, and this fungicide has been retained. The following is a summary
of the scientific sources that were considered in including both Heritage
(with the active ingredient azoxystrobin) and Turflon (with the active
ingredient triclopyr) in the PGC IPM Program.
- The US EPA pesticide fact sheet for azoxystrobin (available at http://www.pmac.net/azoxy.htm)
indicated it to be relatively immobile and non-persistent in actual
use. It states "laboratory studies show that Azoxystrobin is moderately
persistent in soil in the absence of light and potentially moderately
mobile in coarse textured soils (e.g., sand and loamy sand soils)."
(I.e. comparable to PCG soils.) Upgradable, supplemental field dissipation
studies indicate that Azoxystrobin was moderately immobile and relatively
non-persistent under actual use conditions."
- The USDA pesticide fact sheet on triclopyr (available at http://infoventures.com/e-hlth/pestcide/triclopy.html)
states: " The potential for leaching depends on the soil type,
acidity and rainfall conditions. Triclopyr should not be a leaching
problem under normal conditions since it binds to clay and organic matter
in soil. …. [soil] microorganisms degrade triclopyr rapidly."
Triclopyr use would be permissible along fairways or because these areas
have a high soil organic matter content to impede mobility.
- The PGC IPM Program requires measures and management practices which
are listed in the IPM Handbook for Golf Courses (Schumann et
al., 1998), to decrease the risk of leaching: only apply pesticides
to areas with vegetative cover (never to bare soil), irrigation guidelines
to prevent overwatering, and a ban on applying a pesticide during or
within twenty-four hours before an expected rain.
It should be noted that both compounds have been approved for use on
PGC by the NPS Presidio IPM Coordinator in the years 2000, 2001, and 2002.
In addition, the IPM Program requires that a Relative Aquifer Vulnerability
Evaluation (RAVE) be conducted for each potential pesticide application.
The RAVE takes into account many factors including persistence, soil texture,
distance to groundwater, and distance to surface water. Through this review
process, which was recommended for use by the NPS, any application that
poses a moderate or greater risk to groundwater would be prohibited.
6th bullet
The NPS's recommendation is addressed in the PGC IPM Program. As stated
in Section 3.3 of the IPM Program, the course is to be irrigated in a
"cycle and soak" manner during individual irrigation events
in which water is not continually applied. In this way, the water would
be periodically turned off to allow the water to move into the soil profile
before more water is added, preventing the occurrence of runoff. Please
note that the section of the PCG IPM Program cited by the NPS where soil
is allowed to dry out between irrigation events applies to a broader set
of circumstances. Rather than replenishing the soil each night with the
amount of water that was lost due to evapotransipration, the soil is allowed
to dry out so that the subsequent irrigation can be longer and deeper,
which encourages the growth of deeper roots without causing runoff.
Relative Aquifer Vulnerability Evaluation (RAVE) Factors Scoring Procedure
1st bullet
The NPS questions the usefulness of the RAVE model, but the criticism
is unsupported. The Trust disagrees, and believes that the use of the
RAVE model, in conjunction with the protective and non-chemical measures
established in the IPM Program provide a sound and scientifically based
approach to management of the PGC.
The RAVE model is the best available evaluation tool that to systematically
assess risk to groundwater in the field. Throughout the IPM Program development
process, NPS and other experts in the field have offered no better evaluation
tool. It is well documented that the factors included in the RAVE: depth
to groundwater, soil texture, percent organic matter, topographic position,
distance to surface water, annual precipitation, pesticide application
frequency, pesticide application method, and pesticide leachability, are
good predictors for risk of groundwater impacts. Soil texture and percent
organic matter were surveyed on the course in the summer of 2000, and
are well outlined in the IPM Program. Topographic condition and distance
to surface water are easily determined by a topographic map, which is
included in the IPM Program. Annual precipitation is known for the course,
and is included in the document. Pesticide application frequency and method
will be known by the course superintendent and Pest Control Advisor for
any given proposed application. Pesticide leachability is documented by
various sources, including US EPA and university pesticide assessments,
and the leachability of each pesticide approved for use is listed in the
PGC IPM Program. Depth to groundwater is based on well borings taken near
Mountain Lake (directly adjacent to the course) and near the golf course
clubhouse. This data is used in conjunction with known elevation and topographical
information to provide a good estimation of depth to groundwater anywhere
on the course.
In addition, the RAVE model has been used by the NPS in IPM Plans for
other National Parks, including the Fort Vancouver Invasive Exotic Plant
Management Plan. Further, the Users Guide for the Vegetation Management
Risk Assessment for Herbicide Use in Forest Service Regions 1,2,3,4 and
10 and on Bonneville Power Administration Sites (December 1992) in
which RAVE is used to assess risk to groundwater, was presented by the
NPS Presidio IPM Coordinator at the Sept 13, 2001 San Francisco IPM Technical
Advisory Committee Meeting as a cutting edge guide for pesticide risk
assessment.
2nd bullet
A RAVE score will be calculated for each individual (i.e. site-specific)
area where a pesticide application is proposed. For instance, if it is
proposed that a pesticide be applied to five fairways, a RAVE will be
done for each of the five fairways.
3rd & 4th bullets
The citation of page 122 in the PGC IPM Program was a mis-print; it should
have read "i.e. RAVE scores of 45 or greater." It has been corrected
in the Final Program. By relying up on control protocols that pose no
greater than a moderate risk to groundwater, the risks of groundwater
contamination have been minimized to the grestest extent feasible while
still achieving the need for an effective and practicable program.
5th bullet
Since adjuvants that would increase the leachability of a pesticide would
not be used under the program, the effects of adjuvants on pesticide leachibility
would not be necessary as part of the RAVE assessment for the PGC. Please
refer to section 12.9 of the PGC IPM Program. However, if an adjuvant
were proposed for use, that adjuvant will be included as part of the RAVE
assessment, and the Program has been edited to clarify this.
Wildlife
The IPM Program addresses potential impacts and corresponding mitigation
for the protection of wildlife. The protection of wildlife, as well as
human health and the environment, are stated objectives of the project.
Pesticides classified by the pesticide label, MSDS, Extoxnet, and/or USDA
Pesticide Factsheet as moderately to highly toxic to birds, mammals or
the most commonly tested non-target insect (bees) were specifically excluded
to minimize potential impacts to wildlife. In addition, the Program requires
that use of these low-toxicity compounds be allowed only if non-chemical
and other preventative maintenance actions have proved ineffective. The
Program establishes a series of Best Management Practices (BMPs) and other
protective measures to ensure that any application is done a manner which
is protective of wildlife. Please refer to Chapter 12 for additional discussion
of this issue.
Application of Pesticides
The pesticide labels and MSDS, as presented in Volume II of the IPM Program,
identify application procedures and restrictions. In some instances, the
IPM Program establishes additional application restrictions and spot-treatment
requirements. For instance, in order to use Roundup on broadleaf weeds,
the Program states "Apply as spot treatment with sponge applicator,
hand-held sprayer or backpack sprayer." Please refer to the individual
pest management option tables in Chapter 11 for additional detail.
Monitoring
1st bullet
The IPM Program outlines the limitations of TurfSite, namely that it is
not widely used on the West Coast. However, it is the only service of
its kind available at this time, and it is a service that was recommended
for this Program by Carol DeSalvo, the NPS Washington Regional IPM Coordinator.
Due to the TurfSite limitations, the Program does not allow any pesticide
applications based solely on TurfSite forecasts to occur. TurfSite data
is always used in conjunction with site-specific action thresholds.
2nd bullet
The inspection times established in the IPM Program are based on the Trust's
working knowledge of the Presidio Golf Course operations. Based on this
experience, this schedule has proven to be more than adequate for monitoring
and effective management. Using the prescribed monitoring schedule, no
pest problem has taken the APGM or Trust by surprise. Further, the Trust
and APGM have been able to treat many of these pests non-chemically, by
early detection and through the subsequent application of cultural management
techniques. In addition, the minimum inspection times established in the
PGC IPM Program are comparable to other courses practicing IPM such as
Crystal Springs Golf Course. The Trust believes the inspection and monitoring
frequency is fully adequate, and more frequent monitoring would offer
no measurable benefit.
Cumulative Impacts
The pest management activities set forth in the IPM Program were specifically
designed to incorporate protective measures for adjacent natural and forested
areas. The Program establishes a "Natural Area Zone" at the
course, which includes forested areas, where the use of pesticides is
prohibited. In addition, the Program requires implementation of a variety
of protective measures such as spray weather restrictions and buffer zones
to prevent effects on non-target sites. The IPM protocols have been defined
in such a way as to be self-contained and therefore not contribute to
effects outside the project boundaries. Please refer to Sections E-22
through E-25 in the EA, and Chapter 13 in the PGC IPM Program for additional
discussion of these issues.
Coordination with NPS
The NPS/Trust MOA Regarding Natural Resources Management at the Presidio
of San Francisco (PT-2002-MA-01) provides guidelines for coordination
between the Trust and NPS on IPM Program and related matters. The Trust
intends to coordinate with the NPS on proposals to add or change the PGC
IPM Program.
SUGGESTED CHANGES TABLE
All text corrections suggested by the NPS were made except the following,
for the reasons stated below.
Section 13.4.1 Wash Pad. The IPM Program is not the appropriate
document to prescribe wash pad filtration system monitoring. Currently
the wash pad is serviced every month in the summer, and every three months
through the rest of the year. During service visits, the service technician
verifies that the filtration system is operating properly.
Section 14.4 Reporting: The NPS's suggestion that multiple copies
of all lab analyses be provided to the Trust is noted. The Trust believes
that the reporting requirements established in the IPM Program fully adequate
and no change was made.
|