The Turf Zone Podcast
Pennsylvania Turfgrass Council – Site-Specific Plans & PA Act 83 Compliance
PENNSYLVANIA TURFGRASS: Maxim J. Schlossberg, Ph.D.
Email responses I receive from PTC members are the most rewarding part of contributing to Pennsylvania Turfgrass Magazine. Which shouldn’t come as a surprise given the above-average mean aptitude of Pennsylvania Turfgrass magazine’s readership. Well above average. These enlightening interactions support and facilitate direction to my ongoing efforts (so please keep them coming).
Resultantly, I’ve prepared the following for Pennsylvania turfgrass managers seeking further interpretation of PA Fertilizer Law specifics and/or assistance developing their Site-specific Plan(s). Of course, the official guidance on all practical aspects of the Responsible Fertilizer Use act will be finalized by the Pennsylvania Department of Agriculture (PDA). The official guidelines are pending issue within the PDA website:
(https://www.agriculture.pa.gov/Plants_Land_Water/Fertilizer/Pages/default.aspx).
But in the meantime, having read the PA Responsible Fertilizer Use Law (Act 83 of 2022) several times, I offer my best-educated answers to recent questions from motivated pragmatists.
Must I develop a Site-specific Plan for my golf course or recreational / athletic facility?
Well, it depends. If at some point in the future you would like to lawfully make any single granular fertilizer application to turf at a rate supplying >0.7 lbs readily-available N per 1000 ft2, then the answer is yes. Likewise, if you imagine yourself legally treating mature turfgrass with a phosphorus fertilizer of your choice at a rate exceeding 0.25 lbs P (0.57 lbs P2O5) per 1000 ft2 per application, or cumulatively exceeding 0.5 lbs P (1.14 lbs P2O5) per 1000 ft2 annually; then yes, your development and maintenance of a Site-specific Plan is advised.
However, fertilizer N and P application rates applied to a turfgrass system described in a Site-specific Plan and exceeding the maximum(s) described above must still not exceed ‘recommendations by The Pennsylvania State University or other institution of higher education in this Commonwealth approved by the department.’ These recommendations are provided within informational components #2 and #3 of the following.
What information is required of a valid Site-specific Plan?
While subject to change, Site-specific plans pursuant to PA Act 83 currently require:
- Characterization of soil properties, plant species, climate, use, topography or other appropriate management factors; and,
- Soil test results from a sample collected from the specific turfgrass system site in accordance with procedures recommended by The Pennsylvania State University no more than 3 years previous; and,
- Nutrient delivery rates recommended by The Pennsylvania State University or other institution of higher education in this Commonwealth approved by the department.
Does possession of a valid Site-specific Plan exempt me from the 0.5 lbs total N per 1000 ft2 cumulative application limit between December 15 and March 1?
No, this maximum cumulative N application applies to all turfgrass in the Commonwealth. The dates and N rate limit is also subject to revision by the PDA, so affected parties should stay apprised.
Will a unique Site-specific Plan be required for each putting green or fairway of my golf course?
Based on my interpretation of Act 83, probably not. Particularly if all 20 putting greens reside on similarly constructed rootzones or topdressed native soils and feature common turfgrass species monostands or mixtures. The same will likely apply to multiple athletic fields maintained within a single recreational facility. A comprehensive Site-specific Plan for all putting green or athletic field acreage seems appropriate considering similar usage and the likelihood of similar fertilizer programs. However, starkly different underlying soil, turfgrass species, and/or usage across managed systems on the property may warrant development and maintenance of unique site-specific plans; e.g., golf course tees/approaches, fairway, and rough acreage. Let’s all stay tuned for PDA’s upcoming guidance issue.
Do I need a valid Site-specific Plan to foliarly apply low rates of soluble P2O5 to mature turfgrass systems?
Probably not under the following circumstance: the P fertilizer used qualifies as enhanced-efficiency, is natural organic or organic-based, or is labelled and applied for the purpose of repairing a turfgrass area. If none of the above; e.g., because the fertilizer is derived from a salt form of P or phosphoric acid, the committed method of making light and foliar applications (<0.05 lbs P2O5 per 1000 ft2) may be interpreted by the PDA as an efficiency-enhancement. But if the cumulative annual P fertilization exceeds 0.5 lbs, or 1.14 lbs P2O5, per 1000 ft2, a site-specific plan will be required regardless. Given the Commonwealth’s fertilizer grade standard, phosphite treatments will likely not have to be counted against the annual P maximum. But again, the PDA guidance issue will comprise the final word on these topics.
I run a private lawn care operation. Am I required to develop and maintain Site-specific Plans for every client property I fertilize?
This is a poignant question, for which I believe the answer is probably not. During our College’s deliberations over the PA SB 915 bill language in 2021, I emphasized the extent to which environmental and economic sustainability of professional turfgrass management relies on operational efficiency. Hence, pending regulations had to consider recent technological advances supporting extended nutrient availability and cost benefit realized by turfgrass professionals already using them to make sizable annual to semi-annual N applications.
I’ll refrain from rehashing specific justifications for, and consequences of not, utilizing the latest-generation, granular, controlled-release, N-fertilizers here. But google ‘Fertilizer Schlossberg’ for details articulated in open-access papers originating from our lab between 2018 and 2022.
Of greater importance is that the PA Responsible Fertilizer Use Law affords provisional exceedance of the stated N application rate limits for dependable controlled-release fertilizer technologies. However, such applications will require employ of pre-approved fertilizers at rates not exceeding pre-approved maximums.
A comprehensive list of these options will be published by PDA in its Bulletin, and this list will be updated annually. Lawful application of any other N fertilizer that supplies >0.7 lbs readily-available N per 1000 ft2 can only be made to a turfgrass system having a valid Site-specific Plan in place. Hopefully the PDA’s official issue will articulate whether two or more discrete, yet identically-fertilized, properties may be included in a single, valid, Site-specific Plan.
How should turfgrass managers go about developing their Site-specific Plans?
If your facility is in the US, then a great way to start is by exporting high-quality aerial photos from the USDA Web Soil Survey (WSS) at https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm. Zoom into your local region and select either your entire facility or a sector of it (Figure 1). This selection comprises the area of interest (AOI) and can be further enlarged to optimize inference. The user can then click on the ‘Soil Map’ tab to see the overlayed soil survey map units, descriptions, and respective percent occupancy of the AOI (Figure 2).
The AOI can then be divided into management units. For the AOI on the Penn State Golf Courses aerial shown, this would logically include putting greens, tees/collars, fairways, and rough management units. It is also recommended to identify the 15-foot-wide ‘No-fertilizer broadcast zone’ to be maintained around each of the two surface water features.
If GPS-referenced square footages of these areas within the AOI are known, then the aerial and soil map unit overlay can be exported, saved as a .jpg file, and pasted into a MS Excel Worksheet. Otherwise, you can clear the AOI and zoom in further to outline individual management units using the polygon selection tool. By including MS Excel on the split-screen, you can populate spreadsheet cells with Web Soil Survey generated square footages of each management unit (or its components), like for 15 Green on the Blue Course (Figure 3).
Regardless of the soil survey data provided by the Web Soil Survey, routine soil fertility data derived from laboratory analysis of recent composite samples must also be included in each Site-specific Plan. Specification of the turfgrass species predominating the management unit will be required for submission of soil samples.
Once results are received, they should be recorded in the appropriate worksheet. Likewise, the annual N and/or P fertilizer recommendations should be transcribed from the soil report into the Site-specific Plan worksheet, as these comprise each cumulative upper limit for seasonal fertilizer N or P application. Additional data from soil chemical or physical analysis of collected samples, by management unit(s), should also be included in your Site-specific Plan(s). Other management factors should be determined and reported; including topography, microclimate, pest incidence, significant cultural inputs, and usage.
Summary
Hopefully the good-faith information provided in this article answered one or more of your questions regarding compliance with the PA Responsible Fertilizer Use Act. Likewise, I hope it facilitates orderly initiation and development of your Site-specific Plans. As always, please do not hesitate to contact me with questions, comments, and/or topics for future articles at mjs38@psu.edu.
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