WCTA Submission Regarding Proposed IPM Regulation Amendments

December 4, 2013

To: Bob Lucy, BC Ministry of Environment Pesticides License Officer, Integrated Pest Management Program
CC: Bruce Holms, Daphne Dolhaine, Cindy Bertram

Dear Mr. Lucy

On behalf of the Allied Golf Association-BC (AGA-BC) and the Western Canada Turfgrass Association (WCTA), I would like to thank you,  Mr. Holms and Ms. Dolhaine for providing  the opportunity to speak with you prior to new regulations pertaining to the application of pesticides in British Columbia are enacted.  

After the meeting, most of us went for dinner to discuss the proposed changes and I can report there was a very positive feeling around the table. At this point, as the Chair of the AGA-BC Environmental Advocacy Committee, I would like to clarify some of the key topics and ideas that came from this meeting so we can begin the process of updating our members.

1. All golf courses, whether on private land or public (BC crown not municipal) will need to have a Pesticide Use Licence, for a fee of $250/year. A Pesticide Service Licence is needed for anyone spraying pesticides for a fee for service based business. Is there a possibility to have this fee reduced? It could be seen as  a type of  ‘tax grab’ from  our government by our members.

2. All persons spraying pesticides will need to have a Pesticide Applicators Certificate or under the proposed regulations, an ‘assistant applicator’ certification.  While supportive of an entry level designation, our caveat is that a further distance of supervision should be allowed. In a golf course setting, 500 meters is not that far and in many cases, if close contact supervision is required then we would have our Certified Applicators apply.  Our suggestion is there should be no distance but applies to the entire property that holds the use license and must have some form of communication with certified applicator, i.e. radio or cell phone. Another suggestion was that this “assistant applicator” could be the first step for persons wishing to obtain the full Certificate.

3. We would very much like to see an addition to the current examination including a turfgrass specific section that would be required for all turfgrass professionals. We are very willing to assist with creating criteria for this and could have something ready by fall 2015.

4. Implementation dates were also discussed.  Our thoughts were that 2014 would be too soon for all golf facilities to comply since our 2014 education program has already been determined.  Summer 2015 would give us a chance to update and prepare our members appropriately for the changes.  We have already started discussing educational seminars for this topic for next summer’s regional education programs.

5. Finally we support the alternative for courses to have a service license contractor to apply products on courses who may not be able to hire certified applicators or maintain a use license. We feel that this will assist smaller operations to stay in compliance with these proposed changes. Again, thank you for allowing us this opportunity to speak with MOE staff.  I am sure we can all work to improve ourselves and the public’s image on how and who applies plant health products in BC.

Sincerely;

Keith Lyall
WCTA President and AGA-BC Environmental Advocacy Committee Chair