Virginia Department of Conservation and Recreation
203 Governor Street, Suite 302
Richmond, VA 23219
RE: Proposed Revisions to Virginia Stormwater Management Program Permit Regulations
Dear Regulatory Coordinator:
Thank for the opportunity to submit our industry’s comments on the proposed regulations. The Virginia Golf Course Superintendents Association represents golf course superintendents and industry affiliates across the state. Our members professionally care for and maintain Virginia’s beautiful golf courses, which are so vital to our state’s economy and our environment, providing open space and healthful outdoor recreation.
Regarding the proposals, we have two main concerns and several recommendations. One concern is the potential for the proposed changes to significantly increase the cost of constructing or reconfiguring professionally managed turfgrass areas such as golf courses. While the cost to implement management practices may vary from project to project, there will likely be additional practices or design requirements which will likely increase the costs of construction for a facility. Additionally, we are concerned that the proposed regulations may require additional time to construct a new facility, through more consulting, engineering, architectural designs, and permitting processes. Each of these processes can add to the cost. The public is crying out for more access to outdoor activities and as such, we encourage you to work with our industry to identify measures that will not result in making such venues excessively difficult and costly to design and construct.
In order to address some specific concerns that our industry has raised regarding the proposed regulations, we support these recommendations, and respectfully ask DCR implement the following:
We strongly recommend that DCR include representation from the turfgrass industry on the Virginia SWM BMP Clearinghouse Committee.
We recommend that DCR consider development of a supplement to the stormwater management handbook that specifically addresses the management of runoff on sites with turf-intensive uses such as golf courses. Many of the practices and design approaches could be implemented in a more cost-effective and efficient manner.
We recommend that DCR consider development of an alternate list of management practices for turf-intensive uses, including providing credit for ongoing BMPs, nutrient management planning and implementation, integrated pest management planning, water efficient golf course development and other similar practices which could have a much more beneficial effect on water quality for these land use settings.
We recommend that DCR develop guidance to reduce permit overlap and clarify roles and responsibilities in instances where a VPA or VPDES discharge permit or other similar permit affecting golf course water and nutrient management has been developed and integrated into a golf course management plan. At present, we foresee the possibility for conflicts between these competing permit interests and the CGP/Post-construction stormwater unless some clear guidance is provided.
We recommend that DCR further consider guidance or refinement of the existing guidance on the application of open space versus turf crediting for turf-intensive uses such as golf courses. The many different cover and grass types (irrigated turf, roughs (first/second cuts), managed forest cover, and non-managed forest cover) on a golf course setting may cause some regulatory confusion without further specific guidance.
We recommend that DCR consider how runoff reuse practices (commonly employed on a large scale at golf courses) could be adapted to provide the appropriate crediting for golf course. In many instances, portions of courses receive intensive water harvesting through irrigation storage reservoirs and reuse for irrigation which results in significant decreases in total runoff volume and annual pollutant loads, consistent with the principles and practices embodied in the runoff reduction method. Golf courses or other large scale runoff harvesting efforts should be appropriately credited in a similar fashion to small scale runoff harvesting (cisterns, rain barrels, etc).
We recommend that DCR provide written clarification that stripping and replacing sod, and other golf course maintenance and upkeep practices which do not result in changes to the footprint of those land surfaces is considered maintenance (operation and maintenance of an existing facility) and are therefore exempt from the requirements of the Construction General Permit. In a recent meeting with DCR there was considerable discussion of this matter, and the "kickouts" that would mandate coverage if the bounds of "operation and maintenance" were exceeded. A guidance document would be very useful to the regulated public to reduce confusion for golf course managers and local governments ultimately implementing this program.
Finally, we commend DCR for developing the Turf and Landscape Nutrient Management Certification program. This program promises to be a tremendous benefit both to the environment and to the industry. We would like for the DCR to consider the application of nutrient reduction offsets to existing turf-intensive uses that provide for nutrient management plan implementation. This would be consistent with the agricultural offset guidance already produced and would provide an easier quantification method for urban programs that desire to implement more comprehensive approaches to overall nutrient reduction.
In this era of economic challenge, it is important to note that Virginia’s golf industry generates a $3.1 billion economic impact, and employs 40,000 Virginians. Thus it is important to carefully meld the regulations we need for stormwater management, with the reality of their potential impact on the welfare of our economy and citizens, who want reasonably priced recreational opportunities and protected open space.
Thank you again for this opportunity to provide comments on the proposed regulations. We look forward to continuing to work with the agency to identify mechanisms to address the concerns and recommendations outlined in our comments.
