The Club Managers Association of America and the Golf Course Superintendents Association of America have joined forces with over 30 other national organizations to form a group designed to present a collective voice that will raise concerns about the proposed “Waters of the U.S.” regulation that they fear would hand federal agencies too much power and lead to costly new permitting and regulatory requirements designed.
The Club Managers Association of America (CMAA) and the Golf Course Superintendents Association of America (GCSAA) are among the more than 35 national organizations that have joined forces to form the Waters Advocacy Coalition (WAC), which will raise concerns to state and federal policy-makers over the proposed ‘Waters of the U.S.’ (WOTUS) regulation.
WOTUS, proposed by the Environmental Protection Agency (EPA) and U.S. Army Corps of Engineers in April 2014, would substantially expand jurisdiction of the federal Clean Water Act (CWA).
If enacted, the organizations that have formed WAC contend, the changes brought about through WOTUS would allow a significant increase in the level of federal control over land and water resources in the U.S., triggering additional permitting and regulatory requirements at a substantial added cost to businesses, including clubs and golf course operations. The WAC is interested in overturning the WOTUS rule as it is currently proposed.
If adopted, the CMAA and GCSAA contend through their participation in WAC, WOTUS could come to include all drainage ditches, stormwater ditches and water storage or treatment ponds on golf courses. The effect would likely be to keep golf course managers from tending to routine erosion control and utilizing best management practices for environmental stewardship—which those groups note would be the exact opposite of what is intended. Generally, WAC contends, WOTUS could also lead to an increase in the cost of goods and services in the economy.
“The Club Managers Association of America supports HR 5078, the Waters of the US Regulatory Overreach Protection Act of 2014, and all efforts to prevent the enactment of the EPA’s proposed regulation,” says the CMAA’s current Vice President, Tony D’Errico, who is also General Manager of Westwood Country Club in St. Louis, Mo. (http://clubandresortbusiness.com/2014/07/16/singular-purpose/)
“The definitional changes contained in the rule constitute an overreach of statutory authority, broadening federal control of land and water resources in the U.S. and triggering punitive regulatory requirements for our industry and others,” D’Errico adds. “We firmly believe that federal agencies should consult with state and local officials to identify which waters should be federally regulated and which should be left to the states.”
The GCSAA’s Associate Director of Government Relations, Chava McKeel, notes that the golf industry has been a consistent and prominent leader for initiatives promoting water quality and environmental stewardship. “This proposed rule hinders the industry’s ability to move forward toward even stronger best management practices,” McKeel adds.
As part of its ongoing outreach, WAC will draft additional legal and economic analyses before the comment period on the proposed regulation closes at the end of October. Golf industry groups will also submit comments to the federal docket.
Other participating organizations in WAC represent industry voices for agriculture, construction, energy, forestry and wildlife conservation, all of which could be affected by the proposed WOTUS regulation. Other prominent members of WAC include: American Farm Bureau Federation, American Forest & Paper Association, American Gas Association, Associated General Contractors of America, International Council of Shopping Centers, National Association of Home Builders, National Association of State Departments of Agriculture and National Mining Association.