The Environmental Protection Agency (EPA) put out a voluntary information collection request (ICR) to evaluate and designate organizations as EPA Qualified Conservation Programs (QCPs) or EPA Qualified External Parties (QEPs). This effort supports implementation of pesticide mitigation requirements under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and aligns with EPA’s 2025 Herbicide and Insecticide Strategies to protect listed species.

On April 6, GCSAA submitted comments to the EPA in relation to the ICR. GCSAA staff weighed in on behalf of superintendents and the wider golf industry.

As stated in the ICR, the EPA is considering expanding the process to qualify conservation programs and external parties that support non-agricultural (e.g., turf, nursery/ornamentals, forestry, rights of way) uses. Additionally, the EPA intends to develop a mitigation menu for non-agricultural uses. However, this menu has not yet been developed. In this ICR, the EPA is asking: 1) Are there conservation programs that cover non-agricultural use sites that could want to be qualified? 2) Would there be value to qualify external parties for non-agricultural use sites? 3) And if yes to either of these questions, would the applications in their current form be relevant for these programs or parties seeking qualification?

GCSAA wishes to work with the EPA to determine how its national best management practices (BMP) program can qualify as a non-agricultural conservation program under agency standards. With our BMP program officially recognized by the EPA, implementation of select course management practices would potentially satisfy forthcoming federal regulations for pesticide use and management.

As the agency is currently implementing the Endangered Species Act (ESA) Workplan and Strategies, which will affect future use of pesticides by the golf industry, it is important GCSAA works together with regulators to ensure the new compliance effort protects species and fits into the industry’s current environmental efforts.

GCSAA has been talking to the agency about golf specific mitigations that support ESA compliance. Staff are using the current BMP program to model the EPA mitigation list for non-ag pesticide applications, ensuring the framework is tailored to cover the various and unique conservation strategies of the golf industry. Members can see a list of agriculture specific mitigations on the EPA Online Mitigation menu for a point of reference at: https://www.epa.gov/pesticides/mitigation-menu.

Please contact Chava McKeel at cmckeel@gcsaa.org to learn more.