Water Quality

• EPA, U.S. Army Move to Rescind 2015 WOTUS Rule
• A Sign Of Things To Come: After Just 39 Days In Office, The Trump Administration Indicates A “Review” of WOTUS
• What Are The Next Steps on WOTUS?
• WOTUS Rule Stopped Nationwide
• EPA Finalizes the Clean Water Act (WOTUS) Rule
• GCSAA Submits Official Comment on WOTUS Proposed Rule
• GCSAA Joins Waters Advocacy Coalition To Support Efforts to Overturn EPA WOTUS Rule as Currently Proposed

GCSAA supports water quality protection laws and regulations that are based on sound science and credible data and promote the benefits of turfgrass and professionally managed landscapes. Sound science includes the recognized/accepted science methodologies and practices for research that follow the high standards of the scientific method. These standards include important investigational attributes and practices such as the formulation of a readily testable hypothesis; the use of systematic and well-documented experimental or analytical methods; the application of appropriate data analysis tools (e.g., statistics and mathematical models) to the data; and the articulation of conclusions that address the hypothesis and are supported by the results. Sound science is also reproducible until there are no discrepancies between observations and theory.

GCSAA supports the use of reclaimed, effluent or other non-potable water for golf course irrigation when the water quality is suitable for plant growth and there are no public health implications. GCSAA does not support mandated use of reclaimed water when the water quality or water quantity is not adequate, when use is not cost effective or when the golf course superintendent does not play a key role in the decision-making process for the development of effluent water standards.

Properly maintained turfgrass provides many community benefits including: critical "greenspaces"; habitat for birds and other wildlife; temperature buffer, recreational opportunities; capture of run-off pollutants in stormwater, and carbon sequestration and oxygen production. In addition, many entities both public and private rely on healthy greenscapes such as golf courses as a key component in maintaining financial revenues.

GCSAA does not support Congress, EPA or the Army Corps of Engineers expanding the jurisdictional reach of the federal Clean Water Act. This would be an unprecedented expansion of the regulatory authority of the federal government. Expanded federal jurisdiction would pre-empt traditional state and local government authority over land and water use decisions and alter the balance of federal and state authority. Increased delays in securing permits will raise costs of and impede many economic activities.

Water quality is a critical issue for golf facilities for both surface water and groundwater. Golf courses serve as important water treatment systems. Healthy turfgrass is a filter that traps and holds pollutants in place; courses actually serve as catch basins for residential and industrial runoff; many courses are effective disposal sites for effluent wastewater and have agreements with local municipalities for this purpose. Modern turfgrass management practices greatly reduce the potential for leaching or runoff into water supplies. Independent university research supports the fact that well-managed golf courses do not pose significant risks to environmental quality, wildlife or human health.

Some areas of the U.S. require golf courses to use reclaimed, effluent or other nonpotable water sources for irrigation and it is important that there is access to water suitable for use on turfgrass. Many golf course superintendents monitor water quality of streams and groundwater. Golf courses can also have a significant impact on groundwater recharge, especially in suburban areas. The turfgrass system acts as a living filter for reclaimed wastewater as measured by the leachate that percolates below the rootzone. This leachate helps with the recharging of aquifers.

In April 2014, the U.S. EPA and the Army Corps of Engineers issued a proposed rule that would redefine “waters of the United States” under all Clean Water Act (CWA) programs. The proposed regulation broadens the scope of CWA jurisdiction beyond constitutional and statutory limits established by Congress and recognized by the Supreme Court. In addition to raising serious legal issues, the proposed rule fails to provide clarity or predictability, and raises practical concerns with regard to how the rule will be implemented. The proposed rule will result in duplicative and incongruent regulatory requirements that are inconsistent with the purpose and structure of the CWA and have not been adequately considered by the agencies. The EPA and Army Corps of Engineers made final the Clean Water Rule on Aug. 28, 2015. On Aug. 27, 2015, a federal district judge in North Dakota put a halt to the rule in 13 states. In 2015, over 31 states filed lawsuits against the EPA and Corps finalization of the rule. Congress also spent 2015 working on passing legislation to stop the rule.

The WOTUS rule has been put on hold nationwide and it has been decided the 6th Circuit Court of Appeals has jurisdiction over a case to decide the fate of the Clean Water Rule. Litigation will play out during 2017.

In 2006, GCSAA’s philanthropic organization, the Environmental Institute for Golf, and the USGA began funding a research project in 2006 to measure the impact of golf courses on surface and ground water. “A Critical Review of Water Quality Impacts by Golf Courses: Update and Trends," is a continuation of a previous national assessment published in the November 1997 issue of Golf Course Management and the Journal of Environmental Quality. The objective is to collect as much data as possible from golf facilities that are conducting surface and/or ground water monitoring projects and publish a critical review of the quality of surface and ground water as affected by golf courses.

In 2007, members of GCSAA’s water task groups completed development of a Water Fact Sheet to be distributed to recycled water suppliers to encourage them to take the necessary steps to ensure proper water quality for healthy turfgrass cultivation.

In July 2011, GCSAA submitted comments to EPA and the U.S. Army Corps of Engineers on their draft guidance for determining whether a waterway, water body, or wetland is protected by the Clean Water Act.

During 2014, GCSAA lobbied in opposition to the EPA and Army Corps of Engineers’ proposed Clean Water Rule that would make nearly every drop of water on a golf course property come under federal jurisdiction.

• GCSAA formed a golf industry stakeholder team including architects and builders to respond to the WOTUS rule.
• GCSAA conducted extensive direct lobbying and grassroots lobbying with a goal to have EPA withdraw the rule and work with stakeholders to develop a better proposal.
• GCSAA joined the Waters Advocacy Coalition along with six other leading golf organizations.
• In November 2014, the golf industry submitted formal comments on the WOTUS rule.
• GCSAA supported passage of H.R. 5078, which the House passed on Sept. 9, 2014.

During 2015, GCSAA lobbied in opposition to the Clean Water Rule including:

• GCSAA supported passage of H.R. 1732 (Regulatory Integrity Protection Act of 2015) and S. 1140 (Federal Water Quality Protection Act).
• GCSAA hosted a Clean Water Rule webinar on July 28 with WAC attorney Deidre Duncan.
• GCSAA participated on the WAC’s WOTUS implementation subgroup.
• GCSAA met with EPA to discuss the impact of the WOTUS rule on golf properties.

CWA Definition of "Waters of the U.S." comments filed with the U.S. EPA on July 31, 2011.

Comments on file with the EPA related to Total Maximum Daily Loads and National Pollution Discharge

Elimination System permitting requirements.

Filed comments on Nov.14, 2014 with EPA on the proposed “Waters of the United States” rule.