Recent announcements expedite the need for a well written drought emergency plan

The California State Water Resources Control Board recently issued letters to thousands of junior water rights holders on the American, Feather, Sacramento, San Joaquin and Yuba rivers, as well as numerous small streams, to cease pumping water from those sources.  

This curtailment notice for junior right holders is rare, hasn’t occurred since 1977 and will have a negative effect on golf courses throughout the greater Sacramento area and Central Valley.  Courses will have to rely on backup sources of water and reduce their use in nearly all cases. To date, the state has issued over 4,200 water diversion notices throughout that particular area.  

While this curtailment notice has been expected for months, it reinforces the need for golf courses to have an effective drought emergency plan in place to deal with future water right curtailments (possibly including senior and riparian rights holders by June 25) and mandated cutbacks (25-50 percent in some areas) from other water sources.  

As a superintendent, you may be asking yourself, “Where do I begin?”  The answer is - you don’t have to reinvent the wheel. There are numerous sources and materials available that will help put your plan into place fast and effectively.  

While I have numerous plans from GCSAA chapters, superintendents and other reliable resources, I often cite the work done by Pat Gross, director of the Southwest Region of the USGA Green Section.  Pat has assembled a step-by-step guide to determine in advance precisely how much water needs to be reduced to satisfy a 10, 20, 30, or >40 percent mandate and develop a strategy to accomplish these goals. 

Below are the five steps that Pat recommends in his emergency drought plan:

1. Secure an accurate map of the property
2. Determine the size of turf and landscape areas
3. Determine how much water is used annually to irrigate the golf course 
4. Develop a prioritized list for irrigation scheduling
5. Determine how much water must be reduced for each drought emergency level and where the reductions will be applied

The entire plan, including information on communicating it to key stakeholders, is available online at http://www.gcsanc.com/education/water-issues/gross-developing-7-12-131/.  If you have any problems accessing the file online or would like to view other drought emergency plans throughout the country, please contact me at jjensen@gcsaa.org and I will forward you PDFs of the appropriate materials. Also, make sure to check out the USGA's new water website at www.usga.org/water. The site went live on June 13 and contains some great information and resources for superintendents. 

As the hot and dry summer wears on, many of you may be required to have these plans in place by your local or regional water district/municipality and they are a great tool when working with water regulators.    

GCSAA seeking extension on EPA’s Waters of the United States new proposed rule

The Environmental Protection Agency (EPA) and Army Corps of Engineers have proposed a new Waters of the United States (WOTUS) rule that would bring nearly every river, stream, creek, wetland, pond, ditch and ephemeral (land that looks like a small stream during heavy rain but isn’t wet most of the time) in the U.S. under the jurisdiction of the Clean Water Act (CWA). 

For more than 40 years, the issue of what waters fell under federal scrutiny turned on whether they were “navigable,” or near an adjacent wetland; however, the new proposed rule goes much further. For every new body of water to be included under the CWA there has to be a significant nexus between it and the bodies of waters traditionally regulated under the CWA. The connection must be so that the water impacts the “chemical, physical or biological integrity” of the traditionally regulated water.  If allowed to stand, this would include almost every water body in the U.S., except those that are geographically isolated.  If finalized without significant change, the rule will subject more activities on golf courses to additional permitting requirements, environmental impact analyses, costly mitigation and citizen lawsuits. 

A couple of areas of the CWA that could have a significant impact on golf courses include sections 402 and 404. 

Section 402 establishes the National Pollutant Discharge Elimination (NPDES) permitting program, in which the EPA or states (with EPA oversight) can issue permits for discharges of pollutants into WOTUS. If almost all water bodies on a golf course are deemed WOTUS, many routine golf course management activities (such as fertilizer and pesticide applications) will be deemed to result in a “discharge” to those so-called WOTUS. Activities that result in a “discharge” cannot legally go forward without a required permit.  

Section 404 allows the Corps to issue permits for discharges of “dredge and fill” material into WOTUS. This includes discharges that would result from moving soil, such as planting trees, installing drainage, dredging ponds/wetlands, and fixing stream alignments or banks below the ordinary high water mark including rip rap for erosion protection. Under federal authority, proposed golf course construction or renovation projects within jurisdictional areas may require an individual, regional or nationwide permit.

GCSAA does not support the EPA or the Army Corps of Engineers expanding the jurisdictional reach of the federal CWA. This would be an unprecedented expansion of the regulatory authority of the federal government. Expanded federal jurisdiction would pre-empt state and local government authority over land and water use decisions.

GCSAA is currently seeking an extension on the 90-day comment period (to 180 days) regarding this issue, and support from GCSAA members is needed. An extension request letter is available at http://cqrcengage.com/gcsaa/take-action, as well as additional information on the proposed rule.  The extension will give us the needed time to fight the implementation of this rule.