The U.S. EPA and Army Corps of Engineers opened a 45-day public comment period for their proposed rule updating the definition of "Waters of the United States" (WOTUS), which began Nov. 20, 2025, and closed on Jan. 5, 2026, following publication in the Federal Register (federalregister.gov). The proposal aims to implement the Supreme Court's Sackett v. EPA decision, narrowing federal jurisdiction by excluding groundwater and clarifying ditches, and comments were submitted via Regulations.gov or by mail. 

GCSAA took the lead in drafting the comments on behalf of the industry, and others joining GCSAA as signatories on the comments included: National Golf Course Owners Association; Club Management Association of America; Golf Course Builders Association of America; American Society of Golf Course Architects; and National Club Association.

The industry weighed in with comment on the EPA’s proposal to determine a “Water of the United States” via a two-part test: a landowner must (1) identify the wet season months; and (2) determine whether surface water is standing or continuously flowing for a period of time that is at least as long as the duration of the wet season. The industry supports the EPA and Corps of Engineers working with golf to determine the best set of tools to make those determinations.

Read the golf industry comments here.

For questions, please contact Bob Helland, GCSAA director of congressional and federal affairs.