GCSAA recently submitted comprehensive comments responding to the Trump Administration's proposed rule redefining what constitutes a Water of the United States (WOTUS) under the Clean Water Act. This is the culmination of years of advocacy efforts on behalf of golf, to ensure that superintendents will be able to clearly understand whether the waters on or near their facilities fall under the jurisdiction of the Clean Water Act. GCSAA was joined on these comments by the American Society of Golf Course Architects, Club Management Association of America, National Club Association, Golf Course Builders Association of America and the National Golf Course Owners Association.
The proposed rule is a positive step in providing clarity and predictability in defining those tributaries, wetlands, ditches and ponds falling under federal jurisdiction. It would eliminate, for example, the inclusion of ephemeral waters, i.e. those with only a limited flow of water during certain times of the year. It would also limit wetlands to those with a direct, surface connection to another water considered to be WOTUS. This is an improvement over the definitions within the 2015 Clean Water Rule, which the GCSAA opposes. It takes into account the critical role water plays on a golf course, whether for enhancing the golf experience, providing stormwater and flood management, or meeting irrigation needs. Finally, it appreciates the best management practices used when designing, building, reconstructing and managing a golf facility that ensures successful environmental protection, use of natural resources, healthy landscapes, and business operations.
The comments will be considered by the EPA and Army Corps of Engineers as part of the review process before a final rule is published, which is expected in the fall. In the interim, GCSAA will continue to advocate for a clearer definition of WOTUS on behalf of golf course management, including at National Golf Day. As of now, the 2015 Clean Water Rule WOTUS remains in effect in 22 states. Advocacy efforts will not stop until it is repealed nationwide.