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2006-387M-Minutes for Meeting December 20,2005 Recorded 4/7/2006L~
COURSE SUPERN ENQENiS`k5Soc.
Environmental Stewardship Guidelines
Best Management Practices
Integrated Pest Management
Water Quality Monitoring
Wildlife Habitat Enhancement
November 2000
Exhibit
Page 1 of 11 _
s:. OGCSA
Environmental Monitoring Guidelines
TABLE OF CONTENTS
ENVIRONMENTAL STEWARDSHIP GUIDELINES .......................................................................................1
Introduction 1
Objectives 1
Use of Guidelines 1
Overview of Guidelines 2
BEST MANAGEMENT PRACTICES ...............................................................................................................3
INTEGRATED PEST MANAGEMENT ...........................................................................................................11
Introduction 11
IPM Objective 11
Developing an IPM Plan 12
INTEGRATED PEST MANAGEMENT PLAN OUTLINE ..............................................................................13
INTEGRATED PEST MANAGEMENT PLAN EXAMPLE .............................................................................17
WATER QUALITY MONITORING ..................................................................................................................35
Why Develop a Water Quality Monitoring Plan? 35
Objective of Water Quality Monitoring 35
Water Quality Monitoring Guidance 35
OGCSA Opinion 35
WATER QUALITY MONITORING PROGRAM OUTLINE ............................................................................37
WATER QUALITY MONITORING PROGRAM EXAMPLE ..........................................................................41
WILDLIFE HABITAT ENHANCEMENT .........................................................................................................47
Introduction 47
Why Enhance Habitat? 47
Opportunities for Habitat Enhancement 47
Terrestrial Areas 48
Wetlands 48
Aquatic Areas 49
Wildlife Habitat Enhancement Resources 50
Exhibit___/!~k
Page c- of 11
Oregon Golf Course Superintendents Association
ENVIRONMENTAL STEWARDSHIP GUIDELINES
Introduction
The role of the golf course superintendent has evolved into a multi-task occupation in which a
broad range of complex issues influences golf course management practice. One area of
responsibility that has become increasingly influential is that of environmental stewardship. The
OGCSA recognizes the importance of environmental stewardship and sustainability, and its
membership is committed to optimizing golf course management practices to protect the
environment within, and those areas surrounding golf courses. In an effort to assist
superintendents in their efforts to address environmental issues, the OGCSA has undertaken an
extensive review of relevant regulatory and public concerns with the goal of developing
Environmental Stewardship Guidelines.
Objectives
The objectives of these Guidelines are to:
• Provide guidance to superintendents to assist them in the development of golf
course specific management plans.
• Provide meaningful and useful feedback to the superintendent regarding his or her
practice.
• Provide an efficient and effective means of documenting management practices
that will address a broad array of environmental issues.
• Contribute to the development of uniformity of practices within the industry.
Use of Guidelines
The OGCSA does not consider these Guidelines to be mandatory, compulsory, or obligatory.
Rather, the intent of the Guidelines is to provide general guidance for individual superintendents
in their efforts to establish a comprehensive, documented environmental stewardship plan. Also,
it should be noted that while a major objective of the Guidelines is to provide a means of
adequately addressing regulatory issues of concern to the golf industry, the possibility always
exists that expectations specific for local or regional locations may differ from the suggestions
provided in this document. As a result, federal, state, and local regulations should always be
reviewed and used as the final basis for the development of individual environmental stewardship
programs.
November 2000,
Exhibit N_
Page 3 of
OGCSA
Environmental Stewardship Guidelines
Overview of Guidelines
The Guidelines consist of four separate, yet interrelated sections that include:
Best Management Practices
This section contains an outline of Best Management Practices (BMPs), which can be defined as
general policies and procedures that are uniformly applicable to the golf course management
industry. The outline was derived from a variety of relevant industry sources including the Golf
Course Superintendents Association of America, the United States Golf Association Green
Section, and the Northwest Turfgrass Association.
Integrated Pest Management
Integrated Pest Management can be viewed as the incorporation of the general policies and
procedures of Best Management Practices into an operational document that defines specific golf
course management practice tailored for an individual golf course. Included in this section are a
suggested Integrated Pest Management document outline and a fully developed Integrated Pest
Management plan that demonstrates the appropriate level of detail for the respective outline
headings. The Integrated Pest Management outline has been derived and synthesized from a
variety of sources, which include Best Management Practices for Golf Course Development and
Operation (King County Environmental Division, 1993), the Portland Parks and Recreation Pest
Management Policy, and the Audubon Cooperative Sanctuary System.
Water Quality Monitoring
The Water Quality Monitoring section describes the basic features of a comprehensive system for
the implementation and documentation of a water quality monitoring program. A general
description of the individual features of a water quality monitoring program is provided, and a
complete water quality monitoring plan is included as an example. The water quality monitoring
plan is structured based on the Waterways Management Policy contained within the Portland
Parks and Recreation Pest Management Policy.
Wildlife Habitat Enhancement
Wildlife habitat enhancement practices are typically developed based on the unique environment
of individual golf courses. This section provides general suggestions for wildlife habitat
enhancement, and a number of resources that can be utilized to tailor specific golf course wildlife
habitat enhancement programs.
2'
November 2000,
Exhibit
~f
BEST MANAGEMENT PRACTICES
The Best Management Practices (BMPs) outlined below are general policies and procedures that
are uniformly applicable to the golf course management industry. However, circumstances may
be unique for an individual golf course. If questions exist regarding specifics of the following
guidelines, they should be addressed by cross-referencing appropriate guidance from relevant
resources whenever possible. Examples of available resources include the Environmental
Protection Agency, the Oregon Department of Environmental Quality, Oregon Department of
Fish and Wildlife, Oregon OSHA, the fire marshal, the universal building code, and the universal
fire code.
L Cultural Practice
A. Location
1. Develop location specific cultural practices (i.e., greens, tees, fairways and rough).
B. Hygiene
1. Remove clippings.
2. Optimize air circulation.
3. Minimize shade for turf areas. Whenever possible, retain shade over waterways to
preserve habitat.
4. Remove leaves, fallen limbs, and other debris from turf areas. Whenever possible,
do not disturb this material in waterways to preserve habitat.
C. Soil Moisture
1. Maintain proper soil moisture levels.
2. Avoid over-application of water to turf.
D. Mowing
1. Set mowing height appropriately for location.
2. Adjust mowing height to relieve turf stress when necessary.
E. Aeration
1. Adjust aeration frequency appropriate for turf location and conditions.
F. Topdressing
1. Use topdressing sand that meets USGA specifications for particle size distribution
when available to maintain consistent rootzone content.
2. Apply topdressing following aerification when appropriate.
3. Apply "light" topdressing following verticutting.
4. Apply "light" topdressing when appropriate.
November 2001)
Exhibit M
Page _ 2 of ( 1
OGCSA
Environmental Stewardship Guidelines BMPS
G. Overseeding
1. Select seed type best suited for the growing environment.
2. When available, use disease resistance cultivars.
ll. Fertilization
A. Soil Nutrient Testing
1. Perform soil nutrient testing at regular intervals (typically every 1 - 3 years).
2. Maintain accurate records of soil sample locations, date of sampling, and soil
conditions.
B. Nitrogen
1. Use slow release nitrogen when possible.
2. Regulate nitrogen application to optimize turf vigor and prevent disease
development.
C. Phosphorus
1. Using soil test information, avoid over-application.
D. Potassium
1. Using soil test information to develop target levels, apply as required.
E. Micronutrients
1. Apply as required.
F. pH
1. Maintain soil pH appropriate for turfgrass type.
2. Adjust soil pH to optimize turf vigor.
G. Buffer Zones
1. Establish buffer zones near waterways where appropriate. Consistent with the
remainder of this document, a 25 foot buffer zone is suggested.
2. Do not apply fertilizer to turf located in defined buffer zones.
H. Documentation
1. Record location, date, and type of fertilizer applied.
2. Record rate of application.
3. Record method of application.
4. Maintain current inventory of fertilizer on hand.
1. Storage
1. Maintain fertilizer inventory in a dedicated, enclosed area.
2. Keep fertilizer in a dry, well-ventilated environment.
■
.4
November 2000
Exhibit
Page (o of 1 l
OGCSA
Environmental Stewardship Guidelines BMPs
N. irrigation
A. Water Quality
Determine that water quality of irrigation source is suitable for application to turf.
B. Conservation
Optimize irrigation program to conserve water.
C. Reclaimed Water
When possible, use reclaimed water for irrigation.
D. Weather Data
When available, use weather station and evapotranspiration information to fine tune
irrigation regimen.
IV. Pest Management
A. Integrated Pest Management
1. Develop an Integrated Pest Management document (refer to the Integrated Pest
Management section of the Guidelines).
2. Use the Integrated Pest Management document as an operational reference for all
golf course operations.
3. Educate staff on the contents and utility of the Integrated Pest Management
document.
4. Revise the Integrated Pest Management document over time so that it remains a
contemporary document reflecting the state of the art of golf course management.
B. Weeds
1. Define threshold levels.
2. Monitor turf regularly for presence of weeds.
3. Optimize turf vigor by proper application of fertilizer to prevent weed colonization
and establishment.
4. When possible, use mechanical means (i.e., hand pulling) to remove.
5. Use selective herbicides only when thresholds have been exceeded, and when
possible, limit applications to spot treatments.
C. Fungal Disease
1. Define threshold tolerance levels.
2. Understand disease symptoms and disease life cycle.
3. Monitor turf regularly for disease symptoms.
4. Monitor conditions (temperature, humidity, moisture etc.) that favor disease
development.
5. Use fungicides with optimal efficacy and specificity.
6. When possible, use targeted, spot applications of fungicides.
7. Rotate chemical family of fungicides applied to prevent the development of fungal
resistance.
5
November-2000
Exhibit M
Page r7 of _L l A
OGCSA
Environmental Stewardship Guidelines BMPs
8. Document problem areas, disease identification, and disease treatment.
D. Insects
1. Define threshold tolerance levels.
2. Understand relevant insect life cycles and symptoms of infestation.
3. Monitor turf regularly for symptoms of infestation.
4. If infestation is detected, correctly identify the insect.
5. Use target specific insecticides.
E. Rodents
1. Define threshold tolerance levels.
2. Use mechanical traps when possible.
3. Study the habits of the target rodent to enhance trap efficiency.
4. Use rodenticides as a last resort.
F. Aquatic
1. Define threshold tolerance levels
2. Keep ponds/lakes as deep as practical to minimize aquatic plant growth.
3. Where possible, use mechanical means to remove undesirable aquatic plants.
4. Use non-toxic blue dye to block sunlight from growing plants.
5. Use beneficial aquatic plants to out-compete undesirable plants and/or to remove
nitrate from the water.
6. Use aerators to agitate water; this practice reduces the growth of bacteria and algae.
V. Environmental
A. Regulations
1. Become familiar with federal, state, and local regulations that apply to golf course
operations including those related to habitat, surface water, groundwater, and storm
water runoff.
2. Implement policies and procedures to achieve compliance with relevant regulations.
B. Habitat
1. Develop golf course operations to optimize preservation and enhancement of
wildlife habitat (refer to the "Wildlife Habitat Enhancement" section of the
Guidelines).
2. Where available, obtain advice from organizations such as the Audubon Cooperative
Sanctuary, Fish and Wildlife, etc. to assist in habitat enhancement.
C. Monitoring
1. Monitor and document habitat improvements and related wildlife response (e.g.,
installation of bird boxes leading to increased bird population).
2. Monitor and document water quality of relevant surface waters to assess impact of
golf course management practice (refer to the "Water Quality Monitoring" section
of the Guidelines).
6
November 2000
Exhibit M~
Page $ of q
OGCSA
Environmental Stewardship Guidelines BNPs
3. If monitoring information reveals a potential problem, implement and document
corrective action.
D. Corrective Action
1. In the event that monitoring information identifies a potential problem, design and
implement action to correct the situation.
2. Document any corrective action taken.
E. Spill Response
1. Maintain appropriate spill response equipment.
2. Train staff on proper use of spill response equipment.
W Pesticides
A. Selection
1. Confirm identity of pest requiring pesticide treatment.
2. Select pesticide based on efficacy, target specificity, and environmental
compatibility.
3. Rotate chemical family of pesticide used for a specific pest to prevent the
development of pest resistance.
B. Application
1. Read and understand pesticide labeling before use.
2. Use pesticides for labeled use only.
3. Mix pesticides for target pests at rates recommended by the manufacturer.
4. Mix pesticides in a dedicated area.
5. Wear appropriate personal protective equipment during pesticide mixing and
application.
6. Properly calibrate sprayer or spreader before use.
7. Apply pesticides to target areas only. Do not apply pesticides in buffer zones.
8. Minimize pesticide drift by applying when winds are 5 mph or less, or use hooded
booms.
9. Use curative applications only when threshold levels have been reached.
10. Use preventative applications only when conditions favoring outbreaks occur (e.g.,
summer stress favoring anthracnose, winter conditions favoring fusarium).
11. Use check plots to determine pesticide effectiveness (i.e. 2 x 2 foot square of
plywood laid on turf to block application and serve as an untreated control area.)
C. Storage
1. Store pesticides in a restricted access, dedicated room or cabinet.
2. Ensure that the pesticide storage area meets OSHA requirements (i.e., dry,
ventilated, temperature control, etc.)
D. Disposal
1. Triple rinse containers prior to disposal. Apply rinsate to turf.
7
November 2000
Exhibit rr
Page __9 of
oGCSA
Environmental Stewardship Guidelines BMPs
2. Inspect rinsed container to confirm that all visible residues have been removed prior
to disposal.
3. Contact local pesticide distributor for container recycling instructions.
E. Documentation
1. Follow state regulations for proper documentation procedures
2. Record target of pesticide application.
3. Record location, date, and type of pesticide applied.
4. Record weather conditions.
5. Record rate of application.
6. Record method of application.
7. Maintain current inventory of pesticides on hand.
V11. Petroleum Products
A. Fuel Storage
1. Store fuel in certified, double walled, self-contained concrete or steel tanks.
2. Keep gas cans in a separate metal cabinet.
3. Label fuel storage containers clearly and accurately.
B. Disposal
1. Store used fluids in separate containers appropriate for specific fluid type.
2. Maintain used fluid containers in an easy access, safe area that is out of the weather.
3. Store used fluid containers on a non-corrosive secondary containment deck.
4. Label used fluid containers clearly with fluid contents.
5. Contact local petroleum company to arrange pick up of containers for disposal.
Vlll. Waste Management
A. Compost
Compost as much biomass as possible and reuse on golf course.
B. Wash Water
Pre-wash all mowing equipment in a designated area in rough or use a leaf blower or
pressurized air to dry to remove material prior to rinsing. Rotate this location daily or
weekly. Perform final rinse at wash pad. When possible, recycle rinse water. Ideally,
rinse water should be discharged into a sanitary sewer. If this is not possible, the
Oregon Department of Environmental Quality should be contacted to determine if
permits are required.
C. Hazardous Waste
Contact the Oregon Department of Environmental Quality to perform a hazardous
waste audit through the agency's Waste Reduction Assistance Program.
D. Recycling
Implement recycling program (cardboard, plastic, pop cans, etc.).
8
November 2000,
Exhibit
OGCSA
Environmental Stewardship Guidelines amps
IX. Safety Program
A. Safety Meetings
1. Establish a regular meeting time (i.e., first Monday of the month).
2. Keep accurate records of meeting discussions.
3. Create safety committee consisting of maintenance crew members.
B. Safety Training
1.
CPR and first aid.
2.
Eye protection.
3.
Noise exposure and protection.
4.
Hard hat use and head protection.
5.
Personal protection equipment.
6.
Respirators
7.
Gloves
8.
Rubber boots
9.
Rain suit
10
. Chemical suit
11
. Safety glasses
C. Equipment training
1. Tool and accessory training.
2. Lightning safety and protection.
3. Emergency procedures.
4. Bomb threat.
5. Signage.
6. Highlight all fire extinguisher locations
7. Display signage appropriate for location or situation
8. Request free safety training videos from OSHA.
9. Understand how to interpret a Material Safety Data Sheet (MSDS). Place MSDS
documents in a file and store in a location accessible to all staff.
D. Safety Audits
1. Have fire marshal perform an audit of fire safety.
2. Have OSHA perform a "consultative" general safety audit.
3. Contact insurance company to determine if they will perform a safety audit.
■
SI
November 2000 .
Exhibit (v
Page it of
INTEGRATED PEST MANAGEMENT
Introduction
Integrated Pest Management (IPM) has become an increasingly important aspect of golf course
management and environmental stewardship programs. IPM plans are intended to function as
internal use documents that reflect the contemporary management practice of the golf course.
Accordingly, the plan should be tailored for the specific environment of the individual golf course,
and should be used as an operational reference that describes and directs golf course management
practice. The IPM plan should be viewed as a functional, working document that will evolve and
undergo revisions over time to reflect industry developments that will bolster and optimize the
effectiveness of the plan.
IPM Objective
The broad objective of Integrated Pest Management is to maximize the health of the plant as a
means of minimizing the susceptibility of the plant to pests. This is accomplished by the use
optimized, disciplined, and documented golf course management practices. Pest control
strategies should be developed and implemented following the consideration of safety, scientific,
economic, environmental, and feasibility issues. Although there are numerous definitions of
Integrated Pest Management, the OGCSA recognizes the definition provided in the Oregon
Revised Statute 634.650:
"Integrated pest management" means a coordinated decision-making and action process
that uses the most appropriate pest control methods and strategy in an environmentally
and economically sound manner to meet agency pest management objectives. The
elements of integrated pest management include:
• Preventing pest' problems
• Monitoring for the presence of pests and pest damage
• Establishing the density of the pest population, which may be set at zero, that can be
tolerated or correlated with a damage level sufficient to warrant treatment of the
problem based on health, public safety, economic or aesthetic thresholds.
• Treating pest problems to reduce populations below those levels established by
damage thresholds using strategies that may include biological, cultural, mechanical
and chemical control methods and that shall consider human health, ecological impact,
feasibility and cost effectiveness.
• Evaluating the effects and efficacy of pest treatments.
'Pest means any vertebrate or invertebrate animal, pathogen, parasitic plant, weed or similar or allied organism
which can cause disease or damage to crops, trees, shrubs, grasses or other plants, humans, animals or property.
71
koim ber 2000_
Exhibit IM
Page J-2- of I I
OGCSA
Environmental Stewardship Guidelines IPM Plan
Developing an IPM Plan
The IPM plan is a working document that potentially will be reviewed by a wide variety of readers
ranging from golf course owners to golf course maintenance staff. The plan should be thorough
and contain sufficient detail to allow the reader to understand all aspects of the plan. The plan
should also be written in such a way that readers with a variety of comprehension levels can easily
and quickly identify specifics of the plan. Ideally, the plan should be written based on an outline
form that has short, clear descriptions under each outline heading. In certain instances, the use of
tables is recommended to provide a concise presentation of certain aspects of the plan.
92
Nov-em r 2000
Exhibit NA
Page 5 of l l4
INTEGRATED PEST MANAGEMENT PLAN OUTLINE
1. Introduction
ll. Integrated Pest Management Definition
N. IPM Objectives
IV. IPM Structure
V. Area Definition
A. Turfgrass Areas
Golf Course Area Definition and Maintenance Requirements
Area
% Total
Areaa
Fertilizer
Re uirementb
Irrigation
Re uirementb
Mowing
Freuenc b
Cultural
Re uirementb
Greens
Green
Surrounds
Tee Surface
Tee Surrounds
Fairway
Rough
Ornamental
a = percent total turf area
b = expressed as high, medium, low, or NIA (not applicable)
B. Non-turfgrass Areas
1. Bunkers
2. Ornamental Plantings
3. Environmentally Sensitive Areas
4. Aquatic Areas
(a) Streams
(b) Lakes
(c) Buffer Zones
13
November 2000
Exhibit M
Page 14 of 114
OGCSA
Environmental Stewardship Guidelines IPM Plan Outline
A Pest Population Definition
Pest Definition and Distribution
Category
Pest'
Turf rasa
Ornamentals
A uatic
Fungal Disease
Weeds
Insects
a = list all pests by name under each category
b = check mark denotes that the specific pest affects this area of the golf course
WI. Pest Threshold Levels
Action Threshold Limits for Specific Pests
Pest' Tees Fairways Rough Greens Ornamentals-
Fungal Disease
Weeds`
Insects `
a = list all pests under each category
b = threshold = % of area affected
= threshold expressed as number per 1000 ft2
WII. Pest Monitoring
A. Fungal Disease
B. Broadleaf Weeds
C. Insects
D. Aquatic
IX. Pest Control
A. Fungal Disease
B. Weeds
C. Insects
D. Aquatic
14
November 2000,
Exhibit
Page l5 of HA
OGCSA
Environmental Stewardship Guidelines IPM Plan Oudine
X. Turfgrass Maintenance Practice
A. Cultural Practice
1. Mowing
2. Aeration
3. Thatch Management
4. Topdressing
5. Overseeding
B. Fertilization
1. Turfgrass Nutrient Requirements
(a) Nitrogen
(b) Phosphorus
(c) Potassium
(d) Additional Requirements
(e) pH
2. Fertilizer Treatment Areas
Fertilizer Application Areas and Typical Application Frequencies
Area % Total Areaa Fertilizer Treatments per Year
Greens
Green Surrounds
Tee Surface
Tee Surrounds
Fairway
Rough.
Ornamental
a = percent total turf area
3. Soil Nutrient Testing
4. Fertilizer Storage
5. Fertilizer Documentation
6. Buffer Zones
C. Irrigation
1. Water Source
2. Irrigation System
3. Irrigation Water Quality
4. Water Conservation
Xl. Pesticides
A. Pesticide Definition
B. Pesticide Use Determination
1 t~
November 2000
Exhibit
OGCSA
Environmental Stewardship Guidelines IPM Plan Outline
C. Current Practice
Pesticide Application Areas and Typical Application Frequencies
Area
% Total Area"
Pesticide Treatments
per Year
Pesticide Category
Greens
Green Surrounds
Tee Surface
Tee Surrounds
Fairway
Rough
Omamental
11 = percent total turf area
Pesticide Selection for Potential Application
Pesticide Chemical Namee
Pesticide Category
Fungicide
Herbicide
Insecticide
Nematicide
11 = list each pesticide in each category that has the potential to be used on the golf course
D. Pesticide Storage
E. Formulation
F. Application
G. Clean Up and Disposal
H. Pesticide Documentation
Xll. Facilities Description
A. Maintenance Building
1. Mechanical Shop
2. Equipment Storage
3. Fertilizer Storage
4. Pesticide Storage
5. Staff Quarters
B. Fluids Storage
C. Fuel Depot
D. Equipment Wash Area
E. Pesticide Formulation Area
Xlll. References
r
1!i
November 2000
Exhibit M
Page ((7 of 114
INTEGRATED PEST MANAGEMENT PLAN EXAMPLE
Bushwood Country Club
1. Introduction
Bushwood Country Club recognizes the importance of sound environmental stewardship,
and is committed to optimizing its golf course management practice to protect the
environment within, and surrounding the golf course. The following document defines an
Integrated Pest Management plan that describes detailed and specific practice at Bushwood
Country Club, and serves as an operational reference that directs golf course management
practice. Bushwood Country Club is dedicated to the philosophy and the practicality of
Integrated Pest Management, and remains vigilant to incorporate emerging and useful golf
course management practices into the Integrated Pest Management plan. Accordingly, this
document is viewed to be a functional document that will evolve over time, and one that
will be revised to incorporate industry developments that will bolster and optimize the
effectiveness of the plan.
11. Integrated Pest Management Definition
Although there are numerous definitions of Integrated Pest Management, the Bushwood
Country Club recognizes the definition provided in the Oregon Revised Statute 634.650:
"Integrated pest management" means a coordinated decision-making and action process
that uses the most appropriate pest control methods and strategy in an environmentally
and economically sound manner to meet agency pest management objectives. The
elements of integrated pest management include:
• Preventing pest' problems
• Monitoring for the presence of pests and pest damage
• Establishing the density of the pest population, which may be set at zero, that can be
tolerated or correlated with a damage level sufficient to warrant treatment of the
problem based on health, public safety, economic or aesthetic thresholds.
• Treating pest problems to reduce populations below those levels established by
damage thresholds using strategies that may include biological, cultural, mechanical
and chemical control methods and that shall consider human health, ecological
impact, feasibility and cost effectiveness.
• Evaluating the effects and efficacy of pest treatments.
Simply stated, the broad objective of Bushwood Country Club Integrated Pest Management
plan is to maximize the use of natural methods to control pests through optimized,
'Pest means any vertebrate or invertebrate animal, pathogen, parasitic plant, weed or similar or allied organism
which can cause disease or damage to crops, trees, shrubs, grasses or other plants, humans, animals or property.
17'
November 2000,
Exhibit M.
Page 19 of l4
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
disciplined, and documented golf course management practice. To meet this objective, the
Bushwood Country Club Integrated Pest Management plan defines turfgrass, non-turfgrass,
and aquatic management areas; pests of concern within these areas; methods to monitor
pest populations; pest threshold levels that when exceeded require action; and the proper
action to be taken once threshold levels have been reached.
Several examples of natural methods to control pests include optimizing turf health through
maintenance practices to enhance natural plant resistance to pest infestation, optimizing
habitats for beneficial species, and minimizing turf damage resulting from routine golf
course operations. However, in spite of the use of natural methods, in certain instances the
use of chemicals such as pesticides to control some pests is unavoidable. An essential
component of the Integrated Pest Management plan is the coordination of the ongoing use
of natural methods with the selective use of these agents as a means of minimizing pesticide
application.
N. IPM Objectives
• Minimize potential hazards to human health and the environment
• Optimize playing conditions of the golf course
• Utilize effective monitoring to enable selective control of pest populations
• Minimize pesticide use through targeted application while optimizing pesticide efficacy
• Improve turf grass quality
• Lower operating costs
IV. IPM Structure
The structure of the Integrated Pest Management plan is based on the selective targeting of
plant pathogens, weeds, and insects that threaten the agronomic health of the golf course.
In addition, the Integrated Pest Management plan includes provisions to optimize the
quality of aquatic areas of the golf course. The strategy of the Integrate Pest Management
plan is as follows:
• Define areas requiring management and the relative maintenance intensity associated
with each area
• Identify pests likely to be encountered
• Establish threshold levels for each pest which when exceeded, trigger corrective action
• Scout and monitor for the presence of pests
• Maintain vigorous turf health through maintenance practices to optimize pest tolerance
• Implement sequential corrective action when threshold levels have been exceeded
➢ Adjust maintenance practices
➢ Utilize biological controls when appropriate
➢ Apply minimum amounts of selective chemical agents in a highly targeted fashion.
Chemical agents will be selected based on minimal toxicity and optimal efficacy.
• Document all scouting and monitoring observations, treatments, and treatment results
181
November 2000
Exhibit P~
Page o of
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
V. Area Definition
Bushwood Country Club is an 18 hole, privately owned golf course located on 175 acres in
Tansy, Oregon (Malheur County). Property surrounding the golf course includes
commercial, residential, and city owned property. The golf course was built in 1931 with
native materials being used for all aspects of the initial construction. The managed areas of
the golf course include turfgrass areas, non-turfgrass areas, and aquatic areas. A
description of each specific area is provided below:
A. Turfgrass Areas
The turfgrass areas of the golf course are dominated by Poa annua, with small amounts
of ryegrass and bent grass being present at select locations on tee boxes. All grass types
are well suited and adapted for the climate of the location. The turfgrass and
ornamental areas and their respective management requirements are defined in Table 1.
Table 1. Bushwood Country Club Area Definition and Maintenance Requirements
Area
% Total
Area
Fertilizer
Requirement
Irrigation
Requirement
Mowing
Frequency
Cultural
Frequency
Greens
1.7
medium
medium to low
high
high
Green Surrounds
2.0
medium to low
medium to low
medium
medium
Tee Surface
1.7
medium to low
medium to low
medium
medium
Tee Surrounds
1.3
medium to low
medium to low
medium
medium
Fairway
16.0
medium to low
medium to low
medium
medium
Rough
77.0
medium to low
medium to low
low
low
Ornamental
0.3
medium to low
medium to low
N/A
low
* = percent total turf area
B. Non-Turfgrass Areas
Non-turfgrass areas consist of bunkers, ornamental plantings, wetlands and natural
areas, and aquatic areas.
1. Bunkers
Fairway and green-side bunkers are located throughout the golf course. Bunker
management is confined to routine maintenance including raking and smoothing of
sand contained within the bunkers.
2. Ornamental Plantings
Ornamental plantings are limited to areas in the immediate vicinity of the Bushwood
Country Club clubhouse.
3. Environmentally Sensitive Areas
To date, no areas of the golf course are officially designated as wetlands or
environmentally sensitive areas. However, Bushwood Country Club considers any
19
November 2000
Exhibit hA
Page 2d of ( l
OGCSA
Environmental Stewardship Guidelines 1PM Plan Example
area of the golf course that potentially serves as wildlife habitat to be by definition
environmentally sensitive. These areas include aquatic, native vegetation, and
forested areas.
4. Aquatic Areas
(a) Streams
A single, year-round stream (Bogey Creek) traverses the southwestern quadrant
of the golf course. The stream enters the golf course from the western
boundary, flowing across the 7th and 8th fairways, and finally exits the golf
course property behind the 12th green.
(b) Lakes
The golf course contains a single, spring-fed lake in the southern half of the golf
course that is located near the 4th green of the golf course.
(c) Buffer Zones
Buffer zones are defined as a corridor of land that is 25 feet in width on the
sides of a stream or other body of water. In specific areas, buffer zones may be
smaller than 25 feet and shall never be less than 10 feet.
Buffer zones at Bushwood Country Club will be 25 feet with the exception of
turf located on the 4th hole of the golf course. For three, limited areas adjacent
to the lake bordering the 4th hole (tee box, fairway peninsula, and green
surround), the buffer zone will be 10 feet.
W. Pest Population Definition
A summary of the total pest population at Bushwood Country Club is shown in Table 2.
Table 2. Pest Definition and Distribution at Bushwood Country Club
Category
Pest
Turfgrass
Ornamentals
F
l Di
Anthracnose
3
unga
sease
Pink Snow Mold
3
Broadleaf Weeds
Clovers
3
3
Mouse-ear Chickweed
3
3
Insects
Cutworms
3
European Cranefly
3
20
November 2000
Exhibit fA
Page 21 of U
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
Wll. Pest Threshold Levels
The action threshold levels for specific pest types are shown in Table 3. Action threshold
level is defined as the number of pests detected within a specified area that leads to
corrective action to reduce the density of the specific pest below the threshold level.
Table 3. Action Threshold Limits for Specific Pest Categories
Pest
Tees
Fairways
Rough
Greens
Ornamentals
Fungal Disease
10%a b c
N/A
N/A
0.20/,a b°°
NhA,
Broadleaf Weeds
1-5/1000 ft2
5-10/1000 f
20/1000 ft2
1/1000 ft2
20/1000 fit
Insects
Cutworms
2/ft2
N/A
N/A
10/1000 ft2
N/A
European Cranefly
2540/ft
25-40/ft
N/A
15-251ft
N/.A
a=% of area affected
b = when conditions dictate, preventative measures will be used
= spot treatments are used when conditions dictate
Wit. Pest Monitoring
All golf course maintenance staff will be trained to routinely scout the golf course and
monitor for evidence of pest infestation appropriate for their individual job descriptions.
The intensity and frequency of monitoring will be adjusted based on the likelihood of pest
infestation (i.e., seasonal) or in situation/site specific instances. All monitoring observations
of potential pest infestation will be reported directly to the superintendent on the same day
of the observation, and will be documented in a monitoring log book. Recorded
observations will include the area observed and a description of the pest(s). No action will
be taken until the threshold for a specific pest has been exceeded. If the threshold for a
given pest is exceeded, the resulting corrective action and the corresponding results will
also be recorded in the log book.
A. Fungal Disease
Fungal disease represents a serious threat to turf health and is of concern primarily on
tees and greens. Tees and greens will be inspected regularly for symptoms of fungal
disease. The primary means of identifying fungal disease will be diagnosis by the
superintendent. However, in some instances symptoms consistent with fungal disease
may have alternative causes (nutrient deficiency, insects, etc.). When uncertainty
regarding potential fungal disease is encountered, samples will be sent to a plant
pathology lab for confirmation of the presence of fungal pathogens. Heightened
monitoring of greens and tees will occur when conditions known to favor the
29
November 2000,
Exhibit
Page
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
development of these pathogens occur. Conditions favoring each specific disease are as
follows:
1. Anthracnose (Colletotrichum graminicola)
Anthracnose appears in the summer when temperatures exceed >78°F and soil
moisture conditions are high. Disease development is promoted by compaction,
excess thatch, and low nitrogen conditions. Symptoms of Anthracnose include
yellow to brown irregular shaped areas on turf with grass leaves having yellow
lesions with black centers.
2. Fusarium Patch (A icrodochium nivale)
Fusarium Patch appears in the autumn, winter, and spring and is very common in
Western Oregon during the winter. Conditions favoring disease development
include cool temperatures (35° - 65°C) and lush turf growth in which turf contains
high nitrogen and low potassium. Symptoms of Fusarium Patch include light
reddish to brown patches ranging from one to eight inches in diameter
B. Weeds
All turfgrass and ornamental areas will be monitored regularly for the presence of
broadleaf and grass weeds.
C. Insects
Monitoring for insects will consist of visual inspection of susceptible areas on a daily
basis. Conditions favoring the development of specific insects are as follows:
Cutworms (Noctuidae family)
The adult cutworm is a moth that lays eggs on grass leaves at night. The resultant
larvae are thick-bodied caterpillars approximately 1.5 to 2 inches in length that may
be greenish gray, brown, or black, and often have spots or stripes. The larvae reside
in the thatch layer during the day and emerge to the surface to feed on the grass
blades at night. Cutworm infestation results in small brown circular patches on the
turf. Also, an indication of cutworm infestation is the presence of birds attempting
to feed on cutworms by digging at the thatch layer during the day.
2. European Cranefly (Tiyula paludosa)
The European Cranefly is a flying insect that resembles a large mosquito. Adults lay
eggs on the turf in late summer, which hatch in late fall. The resulting larvae are
approximately one inch long and are brownish gray in appearance. The larvae feed
on the turf during the fall, overwinter, and then become active in the early spring.
The larvae reside under the surface of the turf and feed on the turf root system,
becoming especially active after soil temperatures exceed 50°F in the early spring.
Evidence of infestation is the presence of irregular brownish patches on the turf
surface and general turf thinning.
22'
November 2000,
Exhibit
Page _6
of
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
D. Aquatic
Monitoring of the streams and ponds on the golf course will consist of visual inspection
of these areas on a daily basis. The optimal condition is to have zero aquatic pests. As
a result, early detection of aquatic pests is very important, and corrective action will be
engaged as soon as evidence of these pests is recognized.
lX. Pest Control
The pest control strategy is sequential and consists of using maintenance practices as the
first line of defense, followed by biological/chemical control where appropriate. Pest
control strategy will be developed on a case by case basis with all potential control options
given consideration. The decision to implement appropriate pest control measures beyond
maintenance practices will be based on the review of relevant safety, scientific, economic,
environmental, and feasibility information.
Specific pest control strategies are defined below.
A. Fungal Disease
Within the overall spectrum of pest management, fungal disease represents the most
serious and consistent threat to turfgrass health at Bushwood Country Club. An
essential aspect of preventing the development fungal disease is the optimization of turf
vigor through routine management practice. In addition, fungal disease control is
dependent on the correct identification of the disease, understanding the disease cycle
and conditions that promote disease development, and the selective use of the
appropriate fungicide agents. Certain, specific maintenance practices can be employed
to minimize the potential for fungal disease, which are described below. In general, if
these measures fail and symptoms of fungal infestation are observed, the next tactic is
the selective application of fungicides.
Anthracnose
(a) Cultural Control
Nitrogen will be applied at the rate of 1/2 lb N/1000 ft2/4 weeks or less. Light-
weight mowing equipment will be used when practical to minimize compaction
of turf and the thatch layer will be monitored and managed in an effort to
restrict the thatch layer to 1/4" or less. Shade will be minimized to improve air
circulation for enhanced drying of turf, and irrigation of tees and greens will be
avoided in the late afternoon and evening prior to midnight. Disease resistant
cultivars will be used during overseeding.
(b) Fungicide Control
In the event that conditions favoring Anthracnose growth develop, select
turfgrass areas will receive preventative treatment with Azoxystrobin. If actual
Anthracnose infestation is diagnosed, affected areas will be treated with
Thiophanate Methyl, Chlorothalonil, or Iprodione.
23
November 2000
Exhibit tP
Page gA of
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
2. Fusarium Patch
(a) Cultural Control
Moderate rates of nitrogen will be applied at the rate of 1/2 lb N/1000 ft2/month
or less during late summer and fall. Moderate to high levels of potassium and
phosphorus will be maintained. Shade will be minimized to improve air
circulation for enhanced drying of turf and drainage will be optimized.
Irrigation of tees and greens will be avoided in the late afternoon and evening
prior to midnight, and soil moisture will be monitored to avoid drought stress.
(b) Fungicide Control
In the event that Fusarium Patch infestation is diagnosed, affected areas will be
treated with Thiophanate Methyl, Chlorothalonil, Iprodione,
Pentachloronitrobenzene, or Azoxystrobin.
B. Weeds
1. Turfgrass
The standard means of controlling broadleaf infestation will be to optimize turf
health through standard maintenance practices. Selection of well-adapted turfgrass
cultivars in combination with proper cultural practice, fertilization, irrigation, insect
and disease control produces a dense vigorous turf that optimizes resistance to
colonization by broadleaf weeds. If maintenance practices are not completely
effective, the first approach to broadleaf control at Bushwood Country Club will be
mechanical removal (i.e., hand pulling).
Clover is the primary broadleaf weed pest that occasionally requires management
outside of management practice and mechanical removal. When threshold levels of
clover have been exceeded, clover containing areas will be selectively treated with
applications of Triclopyr + Clorpyralid.
Mouse-ear chickweed is detected occasionally on greens, and when encountered,
will be removed by hand pulling.
At this time grass weeds are not a threat nor are any control measures warranted.
Scouting and monitoring for undesirable grass weeds will continue.
2. Ornamentals
Broadleaf and grass weeds in ornamental areas will be controlled primarily by
mechanical means (hand pulling). In addition, mulches such as bark dust will be
used to control weed populations. On occasion, the herbicide Glyphosate will be
used for weed control.
C. Insects
General turfgrass maintenance practices leading to optimal turf vigor aid in minimizing
the impact of insect infestation. However, when threshold levels of a specific insect
have been exceeded, the selective use of biological agents and/or insecticides will be
employed.
24
November 2000
Exhibit M
Page P,S of
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
Cutworms
(a) Cultural Control
Optimize turf vigor through standard maintenance practices.
(b) Biological Control
Several biological agents including azadirachtin (Turplex, Margosan-O) and
Bacillus thuringensis (Bactimos, Dipel, M-One, M-Peril, MVP, Teknar,
Thuricide, etc.) have been shown to be effective agents against cutworms.
These agents will be considered for use following a cost/efficacy analysis.
(c) Insecticide Control
The insecticide used to control cutworm infestations exceeding threshold levels
will be Chlorpyrifos.
fly
2. European Crane
(a) Cultural Control
Optimize turf vigor through standard maintenance practices.
(b) Biological Control
Steineraema cwpocapse (Turfco Vector) is a commercially available nematode
shown to be effective at treating European Cranefly infestation. This agent will
be considered for use following a cost/efficacy analysis.
(c) Insecticide Control
The insecticide currently used to control European Cranefly infestations that
exceed threshold levels will be Chlorpyrifos.
D. Aquatic
Management of aquatic areas at Bushwood Country Club is primarily restricted to the
mechanical removal of weeds. To date, no acute or chronic aquatic pests have required
management (including pesticide application) in aquatic areas.
X. Turtgrass Maintenance Practices
Turfgrass area maintenance is the most labor intensive element of the Integrated Pest
Management program, requiring greater than 95% of resource allocation. As stated
repeatedly throughout this document, the primary intent of the Integrated Pest Management
program is to optimize turfgrass vigor utilizing sound maintenance practices as a means of
preventing and/or minimizing pest infestation. The three basic components of turfgrass
maintenance practices at Bushwood Country Club include cultural practice, fertilization,
and irrigation.
A. Cultural Practice
Cultural practice includes the routine use of mechanical controls such as mowing,
aeration, topdressing, thatch removal, and overseeding to promote a healthy turf
environment.
25
November 2000
Exhibit rA
Page a-le of I l
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
Mowing
Mowing will be performed on an as-needed basis and mowing frequency is area
dependent. Mowing of Greens occurs daily, mowing of tees and fairways occurs
three to four times per week, and mowing of the rough occurs on an average of one
to two times per week.
Lightweight mowing equipment is used as often as practical to minimize turf
compaction and mowing heights are adjusted for individual areas. Mowing heights
include 0.115 to 0.200 inches for greens, 0.35 to 0.5 inches for tees, 0.5 to 0.75
inches for fairways, and 1.5 to 2.5 inches for rough.
2. Aeration
Aeration is the practice of removing soil cores from turf and is performed to
minimize turf compaction. This practice enhances the movement of air, water and
nutrients in the soil and is a useful technique to manage thatch layers.
Aeration frequency is greatest for greens and tees and to a lesser extent for fairways.
Aeration is typically performed during periods of active turf growth in the early
spring, early summer and fall; although selective aeration may occur at the discretion
of the superintendent. In the case of greens, topdressing sand is applied to fill the
cores resulting from the aeration treatment.
3. Thatch Management
Thatch is a layer of organic debris and the roots, crowns, and stems of grass that
exists between the soil and the turf canopy. In the absence of cultural management,
this layer becomes thicker over time, resulting in suboptimal turf growth.
Management of thatch is particularly important on greens and consists primarily of
aeration and topdressing practices. The thatch layer on greens will be maintained at
a depth of 0.5 inches or less.
4. Topdressing
The practice of topdressing consists of the application of a layer of sand to greens
and is used to assist in thatch layer management and to provide a smooth and firm
playing surface. Topdressing applications typically follow the aeration or
verticutting of greens, and are also made in the absence of aeration ("light"
topdressing). Following the application of sand, the sand is lightly brushed into the
turf surface.
5. Overseedinu
Overseeding is the selective application of turfgrass seed to improve areas of turf
depletion and to bolster turf density. Overseeding is performed in the late fall, early
spring, or early summer.
26
November 2000
Exhibit I,,
Page __a~ of
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
B. Fertilization
The application of fertilizers is essential for development of turf vigor. Management of
turf fertility involves the understanding of soil composition, fertility management
history, and the use of soil test information. The objective of the fertilizer program is to
provide maximum nutrient availability to turf while simultaneously avoiding the
application of excess nutrients to avoid weed infestation, disease development, and
nutrient runoff
1. Soil Nutrient Testing
Soil testing for nutrient composition provides valuable information that allows for
the development of strategic fertilizer plan development and also provides insight
into the affect of preceding management practice. Soil testing will be performed on
areas of the golf course selected by the superintendent to generate information that
will provide technical support during the development of the fertilizer program.
2. Turfgrass Nutrient Requirements
The major nutrients required for turfgrass health are nitrogen, phosphorus,
potassium, calcium, sulfur and iron. "Minor" nutrients, also referred to as
micronutrients, include boron, copper, manganese, magnesium, and zinc. The
availability of nutrients to turfgrass is influenced markedly by the pH of the soil.
Consequently, maintenance of the appropriate pH is an important component of the
fertilizer program.
(a) Nitrogen
The management of nitrogen levels is critical owing to the high turf demand for
this nutrient and the potential for excess nitrogen to enter into surface water and
groundwater. As a result, the amount of nitrogen delivered to turfgrass will be
the minimum amount necessary to promote turf vigor. In general, nitrogen will
be applied based on known rates to be effective for Western Oregon. In certain
instances when turf and/or climate conditions dictate, rates of application will be
adjusted (either higher or lower) at the discretion of the superintendent.
Nitrogen formulations consist of water insoluble (slow release) and water
soluble (quick release) types. Slow release nitrogen sources include methylene
urea, sulfur-coated urea, IBDU, polymer coated fertilizers, and organic
preparations such as activated sewage sludge. Examples of quick release
nitrogen sources include ammonium sulfate, ammonium nitrate, potassium
nitrate, and urea. To maximize plant uptake and minimize nitrogen runoff (e.g.,
nitrate), slow release nitrogen sources and/or light applications of soluble
nitrogen ("spoonfeeding") will be used whenever possible.
Determination of the appropriate nitrogen source will be at the discretion of the
superintendent and will be based on the season and relative growth rate of the
turf at the time of application.
27
November 2000,
Exhibit P&
A
Page a2rof HA
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
(b) Phosphorus
Turf requirements for phosphorus are relatively low and phosphorus does not
leach from soil quickly. As a result, application rates tend to be corresponding
low, which minimizes the possibility of storm water runoff carrying residual
phosphorus into water systems.
(c) Potassium
Turf requirements for potassium are intermediate to high in relation to nitrogen
and phosphorus levels. In general, potassium rates are dictated by the NPK
formulation chosen for application. Although applied to maximize efficiency of
uptake, potassium does not pose the extent of environmental risk that excess
nitrogen and phosphorus levels represent.
(d) Additional Nutrients
In general, turfgrass requirements for sulfur, calcium, iron, and micronutrients
are lower than for nitrogen, phosphorus and potassium. These nutrients are
available in a variety of formulations and application of these nutrients will be at
the discretion of the superintendent.
(e) pH
Maintenance of the proper soil pH is essential in optimizing the availability of
nutrients, and also is important in minimizing overall turfgrass stress. When the
soil pH requires adjustment to a more alkaline pH, lime will be added until the
targeted pH is obtained. When soil requires adjustment to a more acidic pH,
ammonium sulfate will be added until the targeted pH is obtained.
3. Fertilizer Treatment Areas
The rate and frequency of fertilizer application is area and situation dependent. A
typical fertilizer application frequency is shown in Table 4. Fertilizer application is
most frequent on the greens with less frequent applications being made to tees and
fairways, and the least frequent application being made to the rough.
Table 4. Bushwood Country Club:
Fertilizer Application Areas and Typical Application Frequencies
Area
% Total Areaa
Fertilizer Treatments per Year
Greens
3.5
12b
Green Surrounds
5.5
3
Tee Surface
3
8
Tee Surrounds
1.5
3
Fairway
38
1-3
Rough
48
0-1
Ornamental
0.5
2
a = percent total turf area
b = light rates applied frequently to minimize growth and potential leaching
28
November 2000
Exhibit
Page
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
4. Fertilizer Storage
All fertilizers will be maintained in a dedicated moisture free, well-ventilated storage
area.
5. Fertilizer Documentation
Records of all fertilizer purchases will be maintained in a fertilizer log book. All
fertilizer applications will be documented on a fertilizer application form.
Information recorded will include date of application, location of application, type of
fertilizer(s) applied, rate of application, irrigation following application, and the
identity of the applicator(s).
6. Buffer Zones
No fertilizer will be applied to turf located in designated buffer zones.
C. Irrigation
1. Water Source
Bushwood Country Club irrigates with water taken from a spring-fed lake located
on the fourth hole.
2. Irrigation System
The irrigation system is currently an automated satellite control system that is
computer controlled. Areas of localized dryness are treated by hand watering.
3. Irrigation Water Quality
Historically, no turfgrass problems have been correlated with problems in irrigation
water quality. Accordingly, testing of irrigation water quality is not performed. In
the event that turfgrass symptoms indicate potential contaminants in irrigation
water, water samples will be acquired from all irrigation water sources and
submitted for irrigation suitability testing by a qualified analytical laboratory.
4. Water Conservation
Irrigation is limited to prevent over-application of water as a means of optimizing
turf vigor and conserving water. The areas requiring the most frequent irrigation are
tees, fairways, and greens. Because it represents a substantial percentage of the
overall turfgrass area, the rough is irrigated as sparingly as possible to conserve
water.
The primary means of determining turfgrass irrigation requirements is the daily
observations of the superintendent and staff. Additionally, the computer controlled
irrigation system has a water budgeting feature, which relies upon
evapotranspiration data acquired from a weather monitoring station located on the
golf course.
29
November 2000,
Exhibit
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
Xi. Pesticides
A. Pesticide Definition
A pesticide is any substance that is used to control pests including insects (insecticides),
weeds (herbicides), and fungi (fungicides). The mechanism of action of most pesticides
is to eliminate the pest by suppressing, weakening or eradicating the target pest.
B. Pesticide Use Determination
The ideal pesticide is highly potent (requires minimal application), is target-specific (is
safe for non-targeted species), and is compatible with the environment. While these
properties are ideal and pursued by pesticide manufacturers, the degree of cross-toxicity
and environmental compatibility in pesticides approved for use by the Environmental
Protection Agency can vary considerably. As a result, if avoidable, pesticides will not
be used. In the event that pesticide application is necessary, pesticides will be applied
according to label.
The primary strategy for pest management as defined in this Integrated Pest
Management plan is to optimize turf vigor through maintenance practices to optimize
turf resistance to, or tolerance of pests. In the event that maintenance practices do not
maintain pest populations below damage thresholds, biological/chemical controls will be
considered when necessary. Pesticides applied to control pests will be selected by the
superintendent based on their safety, efficacy, economic impact, toxicology and
environmental compatibility. In addition, the superintendent will monitor developments
in pesticide research and development; and he/she will incorporate the use of newly
developed, tested and improved pesticides approved by EPA where appropriate.
C. Current Practice
In certain instances the use of pesticides for pest management is unavoidable. The
locations of pesticide use and the typical frequency of the application of these agents is
shown in Table 5.
Table 5. Bushwood Country Club:
Pesticide Application Areas and Typical Application Frequencies
Area
% Total Areaa
Pesticide Treatments per Year
Greens
3.5
6-12
Green Surrounds
5.5
0-1
Tee Surface
3
0-4
Tee Surrounds
1.5
0-1
Fairway
38
0-1
Rough
48
0-1
Ornamental
0.5
0
a = percent total turf area
30
November 2000
Exhibit I'`^
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
On occasion, the herbicide Glyphosate will be applied to limited areas surrounding trees
and along fence lines.
The pesticides that have potential for use at Bushwood Country Club include eleven
fungicides, nine herbicides, one insecticide, and one nematicide (Table 6). To minimize
the development of disease resistance, pesticides with different mechanisms of action
will be rotated as frequently as practical and necessary. In addition, if pest resistance to
these agents does develop, or if unanticipated circumstances arise, the superintendent
may use alternative EPA approved pesticides as required.
Table 6. Pesticide Selection for Potential Application at
Bushwood Country Club
Pesticide Chemical Name
Pesticide Category
Azoxystrobin
Fungicide
Chloroneb
Fungicide
Chlorothalonil
Fungicide
I rodione
F cide
Mancozeb
Fungicide
Metal 1
Fungicide
Propiconazole
Fungicide
Thio hanate Methyl
Fungicide
Triadimefon
Fungicide
Pentachloronitrobenzene
Fungicide
Copper Sulfate
Herbicide
Dichlobenil
Herbicide
Halosulfuron-meth 1
Herbicide
Gl hosate
Herbicide
Pelar onic Acid
Herbicide
O zalin
Herbicide
Triclopyr
Herbicide
Triclopyr + Clo d
Herbicide
Chlo fos
Insecticide
Phenami hos
Nematicide
D. Pesticide Storage
All pesticides will be maintained in a dedicated, dry, well-ventilated area that has
restricted access.
E. Formulation
Prior to pesticide formulation, the superintendent will determine that local weather
conditions are suitable for pesticide application. All pesticides will be formulated
according to manufacturer's labeling instructions by properly trained personnel.
311
November 2000
Exhibit
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
Personnel will wear personal protective equipment appropriate for the pesticide being
formulated during the entire mixing process. All formulations will be prepared in a
dedicated pesticide mixing area.
F. Application
All pesticides will be applied by personnel properly trained in the safe application of
these agents. Applicators will wear appropriate personal protective equipment
appropriate for the pesticide being applied. All pesticide application equipment will be
properly calibrated prior to the addition of the pesticide formulation to the equipment
and application to the golf course. Mobil spill response equipment and safety equipment
will accompany applicators during the application process.
The areas of the golf course requiring pesticide application will be specifically defined
by the superintendent. Whenever, possible, applications will be selective and limited to
localized, targeted areas to minimize the amount of pesticide being applied.
Pesticide delivery in buffer zones will be carried out by hand with directed, low volume,
single wand sprayers, or drop spreaders. No pesticide spray applications will occur if
wind speed is above S miles per hour or if wind direction or activity will carry pesticides
toward, or deposit them upon open water. No broadleaf herbicides will be applied to
turf located in designated buffer zones.
G. Clean Up and Disposal
Pesticide containers, mixing tanks, and equipment will be rinsed in accordance with
recommended procedures and rinse water will be distributed onto the golf course.
H. Pesticide Documentation
All pesticide purchases and usage will be documented in a pesticide log book as a means
of monitoring inventory control. Pesticide application information recorded will include
date of application, location of application, type of pesticide applied, rate of application,
weather conditions, and the identity of the applicator(s). In addition, current pesticide
labels and MSDS sheets will be compiled and maintained in a location accessible to all
employees. All pesticide documentation will be in accordance with federal and state
regulations.
Xll. Facilities Description
A. Maintenance Building
The maintenance facility at Bushwood Country Club consists of a single building
containing approximately 10,000 square feet of floor space. The building is segregated
into five main areas which are described below.
1. Mechanical Shop
This area is dedicated area of the maintenance building where all equipment
maintenance and repair work is performed. All fluids and solvents required for
32
November 2000
Exhibit
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
maintenance and repair are maintained within this area and used fluids and solvents
are disposed of according to federal, state, and local guidelines.
2. Equipment Storage
This area contains all equipment used in golf course maintenance operations
including mowers, tractors, and fertilizer and pesticide application equipment.
3. Fertilizer Storage
All fertilizer is stored in a dedicated storage room within the maintenance building.
The storage room is completely isolated and allows for the maintenance of fertilizer
in a dry, well-ventilated environment.
4. Pesticide Storage
All pesticides are stored in a dedicated storage room that has restricted access. The
storage room includes dedicated ventilation and temperature control systems. Spill
response equipment is also contained within this room. Liquid pesticides will be
stored below dry pesticides in the storage rack areas.
Staff Qgarters
This area consists of the superintendent's office, the staff lunchroom, staff locker
room and staff rest room.
B. Petroleum Fluid Storage and Disposal
1. All oils, solvents, lubricants, and antifreeze are stored in a dedicated storage room
adjacent to the mechanical shop.
2. Used fluids are stored in separate containers appropriate for the fluid type.
3. Used fluid containers are labeled with the identity of the used fluid.
4. Used fluids are disposed of according to state and federal regulations.
C. Fuel Depot
The fuel depot is located approximately 100 feet from the maintenance building and
consists of a gravity feed gasoline tank and a gravity feed diesel tank.
D. Equipment Wash Area
All washing of equipment will occur at a dedicated equipment wash bay located on the
south end of the maintenance building. The wash bay consists of a curbed, concrete pad
with a centrally located drain. Drain water from the pad will be processed through a
dedicated series of filters to remove grease, oil, and solvent residues.
E. Pesticide Mixing Area
All pesticide mixing occurs at a dedicated mixing area located at the south end of the
maintenance building. The mixing bay consists of a curbed, concrete pad with a
centrally located drain. Drain water from the pad will be processed through a dedicated
series of filters to remove pesticide residues.
33
November 2000
Exhibit
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
Xlll. References
A Guide to Integrated Control of Turfgrass Diseases. Volume I. Cool Season Turfgrasses.
1993. L.L. Burpee (ed.). GCSAA Press. Lawrence, KS.
2. Best Management Practices for Golf Course Development and Operation. 1993. King
County Environmental Division. Seattle, WA.
3. Color Atlas of Turfgrass Diseases. 1997. J. Beard (ed.). Ann Arbor Press, Inc. Chelsea, MI.
4. Fundamentals of Turfgrass Management. 1998. N. Christians (ed.). Ann Arbor Press, Inc.
Chelsea, MI.
5. IPMHandbook for Golf Courses. 1998. G. Schumann, P. Vittum, M. Elliott, and P. Cobb
(eds.). Ann Arbor Press, Inc. Chelsea, MI.
6. Oregon Pesticide Applicator Manual. A Guide to the Safe Use and Handling of Pesticides.
1998. Oregon State University Extension Service. Corvallis, Oregon.
7. Pacific Northwest Plant Disease Control Handbook. 1998. J. Psheidt and C. Ocamb (eds.).
Extension Services of Oregon State University, Washington State University, and the
University of Idaho.
8. Pacific Northwest Insect Control Handbook. 1998. G Fisher, J. DeAngelis, C. Baird, R.
Stoltz, L. Sandvol, A. Antonelli, and E. Beers (eds.). Extension Services of Oregon State
University, Washington State University, and the University of Idaho.
9. Pacific Northwest Weed Control Handbook. 1998. R. William, D. Ball, T. Miller, R. Parker,
J. Yensih, T. Miller, C. Eberlein, G. Lee, and D. Morishita (eds.). Extension Services of
Oregon State University, Washington State University, and the University of Idaho.
10. Pest Management Policy. 1997. Portland Parks and Recreation. Portland, Oregon.
11. The Standard Pesticide User's Guide. 1997. B. Bohmont (ed.). Prentice-Hall, Inc. Upper
Saddle River, NJ.
12. Turf Management for Golf Courses. 1982. J. Beard (ed.). Prentice-Hall, Inc. Upper Saddle
River, NJ.
13. Turfgrass Culture in the Pacific Northwest. 2000. T. Cook. Oregon State University.
Corvallis, OR.
34
November 2000
Exhibit
WATER QUALITY MONITORING
Why Develop a Water Quality Monitoring Plan?
A golf course specific water quality monitoring program provides the superintendent with direct
and informative feedback regarding the impact of golf course management practice on water
quality. In addition, a water quality monitoring program assists in addressing a wide variety of
local, state, and federal regulations that govern the protection of surface water and groundwater.
Objective of Water Quality Monitoring
The primary objective of a water quality monitoring program is to establish accountability for
management practice as it pertains to water quality. Although regulatory expectations can vary,
the two basic issues that should drive the development of a water quality monitoring program
include eutrophication (nutrient loading) and toxicity. The chemicals used in golf course
management practice that are of primary concern with respect to these issues are nitrogen,
phosphorus, and pesticides.
Water Quality Monitoring Guidance
Historically, the development of a formal golf course specific water quality monitoring program
has been hampered by the lack of a suitable monitoring model (i.e., testing frequency, etc.).
However, the National Marine Fisheries Service (NMFS) has published a significant document in
the Federal Register on January 3, 2000 (vol 65, No. 1) entitled "Endangered and Threatened
Species: Proposed Rule Governing Take of Seven Threatened Evolutionarily Significant Units
(ESUs); Proposed Rule." This document "represents the regulations NMFS believes necessary
and advisable to conserve the seven listed threatened salmonid ESUs and defines programs that
NMFS concludes will lead to the conservation of the listed endangered species." One of these
programs is the Portland Parks and Recreation (PPR) Pest Management Policy, which includes a
description of golf course management practice. Comment on the PPR Pest Management Policy
by NMFS represents a stringent review of management practice (including golf courses) as it
affects a highly sensitive aquatic environment
OGCSA Opinion
At the outset of the development of Environmental Stewardship Guidelines, OGCSA determined
that the top priority for the Guidelines was to establish the highest quality of standards possible.
With this objective in mind, OGCSA believes that the favorable comment on the PPR pest
management policy by NMFS represents an independent, thorough, and highly qualified scientific
review of relevant, highly sensitive environmental and water quality issues. In addition, OGCSA
has determined that technical elements defined in the PPR policy provide clear and concise
guidance that can be used in the formulation of golf course specific water quality monitoring
345
November 2000
Exhibit I(V\
OGCSA
Environmental Stewardship Guidelines IPM Plan Example
guidelines. Accordingly, technical guidance within the PPR pest management policy has been
used to develop the following OGCSA recommended water quality monitoring guidelines.
36
November 2000
Exhibit
WATER QUALITY MONITORING PROGRAM OUTLINE
1. Introduction
The water quality monitoring program outline shown below consists of four sections which
include application restrictions, monitoring plan design, sample collection and testing, and
proper methods for documenting monitoring activity.
Il. Application Restrictions
Maintenance of buffer zones and minimizing pesticide drift are preventative, operational
measures (i.e., not monitoring functions), and typically are described in IPM documents.
These restrictions have been included in this section in an effort to create a single document
that is as faithful to the Portland Parks and Recreation (PPR) Pest Management Policy as
possible.
A. Buffer Zones
Buffer zones are defined as a corridor of land 25 feet on the sides of a stream or other
body of water, but may be as little as 10 feet in specified areas. No fertilizer or
broadleaf herbicides should be applied to turf in designated buffer zones.
B. Pesticide Drift
No application of pesticides is to occur if wind exceeds 5 mph or if wind direction will
carry pesticides toward open water.
N. Monitoring Plan Design
A rugged water quality monitoring program is dependent on a number of individual features
that collectively contribute to a system of monitoring golf course management practice that
is comprehensive, thorough, and meaningful. The strength of the information generated is
directly dependent on each of the individual components, listed below, functioning properly.
A. Water Quality Testing Parameters
Water should be tested two times per year for the presence of fertilizer runoff indicators
(nitrate and phosphorus) and for any pesticides that have been applied to the golf course
during the preceding 6 months.
B. Timing of Water Testing
Water samples should be collected in the late spring at the same time each year. A 7-
day sample collection window is advised. A second set of samples should be collected
in the fall during a 7-day window six months from the spring sample collection event.
37
November 2000
Exhibit M,
Page -1>27 of
OGCSA
Environmental Stewardship Guidelines WQ Monitoring Plan
C. Sample Locations
The sample locations will vary from golf course to golf course. The ideal monitoring
plan design should include samples taken from all locations where surface water enters
the golf course ("water on") and at each location where surface water exits the golf
course ("water off'). Testing of samples taken from entry points serves to establish a
baseline to determine the influence of golf course management practice on water quality
by comparison of testing results for these locations with those obtained for water exiting
the golf course. Test results obtained for these locations also allows for the evaluation
of influences of upstream locations on the quality of water entering the golf course.
In the event that resource limitations restrict testing from entry and exit points, sampling
from all exit points should be viewed as the minimum in order to develop meaningful
monitoring information.
IV. Sample Collection and Testing
A. Sample Labeling
After determining the sampling locations, assign a unique sample identifier or code, to
each sampling location. Try to use simple identifiers and restrict the sample code to five
characters or less. An example would be assignment of the "Avery Country Club north
exit point" sample with the sample identifier of "ACCNX." The use of short, unique
sample identifiers streamlines the testing laboratory documentation process, reduces the
possibility of sample mix-up, and minimizes the documentation demands for the
superintendent.
B. Sample Collection Methods
Proper sample collection methods are also important in developing optimal testing
information value. The basic principles of proper sample collection are as follows.
1. Develop a written description of the sample collection procedure so that a single,
uniform method can be referred to by various staff members that may be responsible
for sample collection.
2. The most critical aspect of sample collection is to be consistent in obtaining samples
from the exact same location during each sample collection event. A map that
clearly defines the sampling location(s) will assist in this process.
Use appropriate sample collection vessels.
(a) Water for nitrate and phosphorus testing should be collected in new, clean
plastic bottles.
(b) Collection bottles must contain the appropriate preservative (e.g., sulfuric acid
for phosphorus testing).
(c) Water for pesticide testing should be collected in new, clean, brown glass
bottles which should be sealed with a clean, teflon-lined lid.
341
November 2000
Exhibit rA
Page of
OGCSA
Environmental Stewardship Guidelines WQ Monitoring Plan
4. Sample volume
(a) Collect approximately 250 milliliters (one cup) for nitrate and phosphorus
testing.
(b) Collect a minimum of one liter (one quart) for pesticide testing.
5. Label each sample collection bottle with the appropriate sample identifier (code), the
date and time of collection, and the type of testing to be performed.
C. Sample Handling and Transport
Following collection, maintain samples in a refrigerated condition until delivery to the
testing laboratory. This can be accomplished by placing samples into a simple cooler
containing ice or cold packs. Samples requiring nitrate testing need to be received by
the testing laboratory within 48 hours from the time of sample collection. Samples
collected for pesticide testing need to be received by the testing laboratory within 7
calendar days of sample collection.
D. Test Methods
Samples should be tested using methods approved by the Environmental Protection
Agency (EPA). Confirm that the testing laboratory uses EPA test methods before
delivering samples to the laboratory for testing.
E. Testing Laboratories
The data generated from the testing of samples is the foundation of the water quality
monitoring plan. Accordingly, it is essential that the testing laboratory is reputable and
has demonstrated proficiency in water quality testing expertise to relevant, independent
certification agencies. When considering a testing laboratory, ask the laboratory for a
copy of their credentials. Ideally, the laboratory should be a certified drinking water
testing laboratory. Additionally, certain laboratories have certification credentials from
other state agencies. It is also important to know if the laboratory you will be working
with actually performs the testing on site. Many laboratories sub-contract out this type
of testing. If possible, work directly with the laboratory that performs the actual testing.
V. Monitoring Documentation
Monitoring documentation includes chain of custody, laboratory reports, interpretations of
laboratory test data, and corrective action (if taken). It is advisable to maintain this
documentation in a single, three ring binder so that all relevant information if available from
a single source. Maintenance of documentation in this fashion provides a highly efficient
means of displaying the specifics, as well as the history of the program to all interested
parties (staff, management, regulatory, etc.).
A. Chain of Custody
Chain of custody is a formal means of documenting the location of a sample or samples
from the time of sample collection until the time of sample delivery to the testing
laboratory. Included in this documentation should be a description of the sample
■
39
November 2000
Exhibit M.
Page AO of i 1a
OGCSA
Environmental Stewardship Guidelines WQ Monitoring Plan
storage conditions. The intention of chain of custody is to establish a clear "trail" that
defines who was responsible for the possession and maintenance of the sample(s) from
the start (sample collection) to the end (sample delivery to the laboratory) of the
process.
Generally, chain of custody is documented on a single sheet of paper that includes
sections for signatures, and the date and time of sample transfer from one individual to
another. Often times, testing laboratories provide blank chain of custody documents for
their customers.
B. Laboratory Reports
Laboratory reports containing the "raw" test data should be maintained in a separate
section of the water quality monitoring program notebook in chronological order.
C. Test Result Interpretation
It is important to have written interpretation of the test results to support the "raw" test
data. In general, most testing laboratories do not provide this type of interpretation, so
it may become necessary for the superintendent to generate this document. The
interpretation should be made by making "water on/water off' comparisons, comparison
of testing results to relevant regulations, and commenting on the relative significance of
the testing results with respect to golf course management practice.
D. Corrective Action
In the event that testing results indicate that management practice may potentially
threaten to degrade water quality, it is very important to document the best way to
change practice to correct the situation. A good example would be if test results
showed a golf-course management related elevation in nitrate levels. A review of
fertilizer records identified that nitrogen had been applied two days preceding water
sample collection, and that heavy rains had followed application for the two days
preceding sample collection. Documentation of corrective action would include the
findings of the review of fertilizer applications records, and the corrective action
statement that in the future greater attention will be paid to weather forecasts and that if
heavy rain is imminent, application will be delayed until drier conditions exist.
It is very important that if corrective action is taken, it is taken as quickly as possible:
upon receipt of the test results and that it is documented in a clear, concise fashion.
44
November 2000
Exhibit M
Page .4 1 of i 1
WATER QUALITY MONITORING PROGRAM EXAMPLE
Introduction
A golf course water quality monitoring program provides the superintendent with direct and
informative feedback regarding the impact of golf course management practice on water
quality. In addition, a water quality monitoring program assists in addressing a wide variety
of local, state, and federal regulations that govern the protection of surface water and
groundwater.
The primary objective of a water quality monitoring program is to establish accountability
for management practice as it pertains to water quality. The two basic issues of concern
regarding the impact of golf course management practice on water quality include
eutrophication (nutrient loading) and toxicity. The chemicals used in golf course
management practice that have potential to cause eutrophication and/or toxicity are
nitrogen, phosphorus, and pesticides.
Consistent with its Integrated Pest Management Policy, Bushwood Country Club
recognizes the importance of sound environmental stewardship, and is committed to
optimizing its golf course management practice to protect the environment within, and
surrounding the golf course. The following document describes a program specific for
Bushwood Country Club that is designed to monitor the quality of water obtained from
specific locations of the golf course at specific time points during the year. Using EPA
methods, water samples will be tested semi-annually for the presence of the nutrient
indicators phosphorus and nitrate, and for all pesticides applied to the golf course during the
six months preceding the sample collection event.
Structure
Historically, the development of a formal golf course specific water quality monitoring
program has been hampered by the lack of a suitable monitoring model (i.e., testing
frequency, etc.). However, the National Marine Fisheries Service (NMFS) has published a
significant document [(4d) rule] entitled Endangered and Threatened Species: Proposed
Rule Governing Take of Seven Threatened Evolutionarily Significant Units (ESUs) '
Proposed Rule. This document "represents the regulations NMFS believes necessary and
advisable to conserve the seven listed threatened salmonid ESUs and defines programs that
NMFS concludes will lead to the conservation of the listed endangered species." One of
these programs is the Portland Parks and Recreation (PPR) Pest Management Policy,
which includes a description of golf course management practice.
Comment on the PPR Pest Management Policy by NMFS represents an independent,
thorough, and highly qualified scientific review of relevant, highly sensitive environmental
4;1
November 2004)
Exhibit M,
Page X12 of LA
OGCSA
Environmental Stewardship Guidelines WO Monitoring Plan Example
and water quality issues. The favorable comment on the PPR Pest Management Policy by
NMFS provides clear and concise guidance that can be used in the formulation of golf
course specific water quality monitoring programs. Accordingly, the structure of the
Bushwood Country Club water quality monitoring program is designed to be consistent
with guidelines established within the PPR Pest Management Policy, and is specific for the
environment of Bushwood Country Club.
The Waterways Pest Management Policy of the PPR Pest Management Policy states that
for golf course waterways testing "Waters adjacent to treated areas within the golf course
shall be tested on a regular basis for fertilizer and pesticide levels. Frequency of the testing
will depend upon the scheduling of applications, but shall occur no less than twice per
year." As a result, a semi-annual testing frequency is a central feature of the Bushwood
Country Club water quality monitoring program.
In addition, the water quality monitoring program is configured to incorporate Best
Management Practices, and technical recommendations provided in relevant Environmental
Protection Agency and Department of Environmental Quality guidance documents which
include:
A. Volunteer Stream Monitoring: A Methods Manual (EPA 84I-B-97-003)
B. Monitoring Guidelines to Evaluate Effects of Forestry Activities on Streams in the
Pacific Northwest and Alaska (EPA/910/9-91-001)
C. Oregon Department of Environmental Quality Laboratory Field Sampling Reference
Guide, Revision 4.0
ill. Sample Locations and Sample Collection Methods
For nutrient testing, water samples will be collected from three separate locations for each
sampling time point. For pesticide testing, water samples will be collected from two of the
three nutrient sampling locations for each sampling time point. Each sample location will be
assigned a unique sample identifier, and the same sample identifiers will be used to label
respective samples throughout the course of the monitoring program. Samples with the
same identifier but collected at different time points will be distinguished from one another
by date of sample collection. Sample identifiers and the corresponding sample locations are
as follows:
BCCBE (Bushwood Country Club - Bogey Creek Entry): This sample will be collected
from the western border of the golf course where Bogey Creek enters the golf course on the,
7th hole. A sample will be collected for nitrate testing from the center of the stream at a
depth of approximately six inches in a clean, plastic bottle and will be sealed with a clean
plastic lid. A sample will be collected for phosphorus testing from the center of the stream
at a depth of approximately six inches in a separate clean, plastic bottle containing a sulfuric
acid preservative and will be sealed with a clean plastic lid. A sample for pesticide testing
will be collected from the center of the stream at a depth of approximately six inches in a
clean, amber, one liter glass bottle, and will be sealed with a clean, teflon-lined lid.
42
November 2000
Exhibit
Page A3 of 114
OGCSA
Environmental Stewardship Guidelines WQ Monitoring Plan Example
BCCBX (Bushwood Country Club - Bogey Creek Exit): This sample will be collected at a
location where Bogey Creek exits the southern border of the golf course behind the 12th
green. A sample will be collected for nitrate testing from the center of the stream at a depth
of approximately six inches in a clean, plastic bottle and will be sealed with a clean plastic
lid. A sample will be collected for phosphorus testing from the center of the stream at a
depth of approximately six inches in a separate clean, plastic bottle containing a sulfuric acid
preservative and will be sealed with a clean plastic lid. A sample for pesticide testing will be
collected from the center of the stream at a depth of approximately six inches in a clean,
amber, one liter glass bottle, and will be sealed with a clean, teflon-lined lid.
BCC4G (Bushwood Country Club - 4 Green): This sample will be collected from the edge
of the lake located adjacent to the 4th green of the golf course. A sample will be collected
for nitrate testing from the center of the stream at a depth of approximately six inches in a
clean, plastic bottle and will be sealed with a clean plastic lid. A sample will be collected for
phosphorus testing from the center of the stream at a depth of approximately six inches in a
separate clean, plastic bottle containing a sulfuric acid preservative and will be sealed with a
clean plastic lid.
1V. Sample Collection Frequency
Samples will be collected semi-annually from each sampling location during the weeks of
April 7h- April 14'hand October 7th- October 140'.
V. Sample Collection
Samples will be collected between the hours of 7:00 a.m. and 11:00 a.m. by the Bushwood
Country Club Superintendent or by and individual designated by the Superintendent who
has received proper training in sample collection. Water samples will be acquired for
testing based on methodology defined in Volunteer Stream Monitoring, A Methods Manual
(EPA 841-B-97-003) and the DEQ Laboratory Field Sampling Reference Guide, Revision
4.0.
VI. Chain-of-Custody
Chain-of-custody will be documented for all samples from the point of sample collection to
the point of sample receipt by the testing laboratory.
VII. Sample Maintenance and Transport
After collection, samples will be stored at 4°C (-39°F) in the dark. Samples will be
maintained at 40C during transport to the testing laboratory and will be delivered to the
testing laboratory no later than twenty-four hours following sample collection.
43►
November 2000
Exhibit M
Page A of
I I
OGCSA
Environmental Stewardship Guidelines WQ Monitoring Plan Example
Vill. Sample resting
Water samples will be tested for the presence of nitrate and phosphorus using EPA
methods.
Water samples will be tested for the presence of all pesticides used on Bushwood Country
Club during the six months preceding the sampling event. Samples will be tested for the
presence of specific pesticides using appropriate EPA methods.
All laboratory test results will be linked by the laboratory sample identification number and
the Bushwood Country Club sample identifier assigned at the time of sample collection.
lX. Interpretation of Results
All testing results will be reviewed and compared to relevant federal and state water quality
standards.
X. Corrective Action
A. Nutrients
In the event that either nitrate levels or phosphorus levels in water samples are
determined to exceed water quality standards, the following corrective action will be
taken.
1. Records will be reviewed to determine if a direct cause and effect relationship
between fertilizer application events and nutrient levels can be established. If such a
relationship is identified, adjustments in fertilizer application rates and/or methods
will be implemented to reduce the load of the compound(s) entering waterways.
2. The Integrated Pest Management plan will be reviewed to identify and implement
alternative management practices that will mitigate the situation.
3. Following adjustments in practice, additional samples will be acquired for re-testing
to assess the effectiveness of revised management practice.
B. Pesticides
The inherent assumption is that when applied properly and in accordance with the
Bushwood Country Club Integrated Pest Management plan, no pesticides applied to the
golf course should be entering golf course waterways. However, in the event that a
pesticide(s) applied to the golf course in the six months preceding the sampling event is
detected in water samples, the following corrective action will be taken.
1. Testing results will be reviewed to determine if the pesticide(s) detected are entering
the golf course from an upstream location (i.e., are present in the BCCBE sample).
441
November 2000
Exhibit V\
Page _A5 of I I
OGCSA
Environmental Stewardship Guidelines WO Monitoring Plan Example
2. Records will be reviewed to determine if a direct cause and effect relationship
between pesticide application events and pesticide(s) detected in water samples can
be established. If such a relationship is identified, adjustments in pesticide
application rates and/or methods will be implemented to reduce the load of the
compound(s) entering waterways.
3. Based on the best information available, levels of the pesticide detected will be
compared to the allowable levels to determine if there is an immediate hazardous
threat. In the event that a hazardous situation is identified, the appropriate agencies
will be contacted.
4. The Integrated Pest Management plan will be reviewed to identify and implement
alternative management practices that will mitigate the situation.
5. Following adjustments in practice, additional samples will be acquired for re-testing
to assess the effectiveness of revised management practice.
Xl. Documentation
All activities associated with the Bushwood Country Club Water Quality Monitoring Plan
will be documented including sample collection, chain-of-custody, test results, interpretation
of results, and summary reports. All original documents will be maintained on site at
Bushwood Country Club.
X11. Reporting
Water quality monitoring results will be summarized and documented following each round
of testing (i.e., twice per year) and a summary of the Water Quality Monitoring Plan will be
prepared annually.
Xlll. References
1. Endangered and Threatened Species; Proposed Rule Governing Take of Seven Threatened
Evolutionarily Significant Units (ESVs); Proposed Rule. Department of Commerce. National
Oceanic and Atmospheric Administration. Federal Register. January 3, 2000.
2. Endangered and Threatened Species; Salmon and Steelhead; Final Rules. Department of
Commerce. National Oceanic and Atmospheric Administration. Federal Register. July 10,
2000.
3. Golf Course Management and Construction Environmental Issues. 1992. J.C. Balogh and
W.J. Walker (ed). Lewis Publishers Boca Raton, FL.
4. Guidelines and Specifications for Preparing Quality Assurance Project Plans. 1991.
Washington State Department of Ecology publication 91-16. Manchester, WA.
46)
November 2000
Exhibit CA
Page to of 1 1 4.
OGCSA
Environmental Stewardship Guidelines WQ Monitoring Plan Example
5. Technical Guidance for Assessing the Quality of Aquatic Environments. 1994. Washington
State Department of Ecology publication 91-78. Olympia, WA.
6. Monitoring Guidelines to Evaluate Effect of Forestry Activities on Streams in the Pacific
Northwest and Alaskan. 1991. Environmental Protection Agency publication EPA/910/9-91-
001. Region 10. Seattle, WA.
7. Pest Management Policy. 1999. Portland Parks and Recreation. Portland, OR.
8. Volunteer Stream Monitoring: A Methods Manual. 1997. Environmental Protection Agency
publication EPA 841-B97-003. Office of Water.
9. Methods for Chemical Analysis of Water and Wastes. 1983. Environmental Protection
Agency publication EPA-800/4-79-029. Cincinnati, OH.
10. DEQ Laboratory Field Sampling Reference Guide, Revision 4.0. 1996. Oregon Department
of Environmental Quality. Portland, OR.
11. Results from the USGA Environmental Research Program. 1995. USGA Green Section
Record. January/February.
12. GCSAA's Golf Course Water Quality Study. 1997. Golf Course Management. November.
46,
November 20061
Exhibit 11/1_
Page _A of L b
WILDLIFE HABITAT ENHANCEMENT
Introduction
Golf courses are diverse ecosystems and by definition, high intensity turf management involves the
management of complex habitat. Factors including nutrient availability, moisture, and
geotechnical properties are routinely monitored and adjusted to enhance turf health, minimize
disease, and optimize the microbial ecology of the turf rootzone. Sound turf management
practice promotes the compatibility of the golf course with wildlife, and as such, wildlife habitat
management is a natural extension of the turf management process. Wildlife habitat enhancement
involves the implementation of additional, specific measures that are designed to recruit and
sustain desirable species as a means of bolstering the unique ecology of individual golf courses.
Why Enhance Habitat?
The advantages of enhancing wildlife habitat are numerous. Recruitment and sustaining wildlife
creates a heightened playing experience for the golfer, and represents an excellent opportunity to
educate the public on the value of integrated management systems and the ecology of the
location. Habitat enhancement not only aids in sustaining existing wildlife, but also strengthens
the ecosytem by increasing habitat and species diversity. Finally, implementation of habitat
enhancement measures can lead to significant reductions in the allocation of golf course
resources.
Opportunities for Habitat Enhancement
The limited availability of property often drives golf course design to utilize the maximum amount
of space available for playing areas. However, in many instances, non-play areas and areas
designated as hazards offer the opportunity to develop wildlife habitat while maintaining the
desirable playing characteristics of the golf course. Locations on the golf course that are potential
candidates for wildlife habitat enhancement include terrestrial, wetland, and aquatic areas.
The Best Management Practices, Integrated Pest Management, and Water Quality Monitoring
components of these Guidelines collectively define a comprehensive management system designed
to optimize overall habitat management and protection. Habitat enhancement measures may
involve the implementation of additional practices specifically tailored for the individual golf
course. When considering any habitat enhancement project, it is always advisable to consult
resources with relevant expertise to obtain detailed input prior to the implementation of habitat
enhancement measures.
4T
November 2000
Exhibit r~
Page _A_9L of _LL
OGCSA
Environmental Stewardship Guidelines Wildlife Habitat Enhancement
Terrestrial Areas
Maintaining and enhancing non-play areas, buffer zones, unmowed areas, woodlots, "edges", or
rough areas contributes to wildlife habitat enhancement. In addition to providing cover, nesting
areas, and food sources, these practices also assist with storm water runoff control. The
following suggested practices are designed to enhance habitat located in terrestrial areas.
1. Mowing
Minimize mowing in non-play areas to create dense habitat that provides a rich food source
and excellent cover for a variety of species. These areas can be compatible with playing
areas by the selective maintenance of growth heights. For example, vegetation along or
across fairways (streams and ditches) can be allowed to grow from one to three feet in
height, without disturbing playing conditions. A variety of approaches can be used to
achieve this result while retaining sight distance, playing areas, hazards, and rough. These
areas can be "sculpted" to create a naturally appearing continuation of playing areas into
non-play areas, and this practice can actually lead to reduced mowing times, fertilizer and
pesticide applications, tree care, irrigation, and irrigation system maintenance.
II. Cover
Promote the growth of natural vegetation in appropriate areas to develop food sources and
provide cover for wildlife. Maintain understory vegetation, including brush piles where
possible, to provide additional cover and nesting areas. Whenever practical and if no safety
hazard exists, retain dead trees and snags to provide beneficial shelter and nesting habitat.
Also, insects inhabiting these structures serve as an important food source.
III. Wildflowers
Plant wild flowers in non-play areas to improve plant diversity and create a visual
enhancement of the golf course. The diversity of plant species recruits a variety of insects,
which in turn serve as a valuable food source for birds and mammals.
IV. Nesting Boxes
Place nesting boxes in appropriate areas to recruit and sustain wildlife. Access to a water
source and territorial boundaries for a given species are important strategic factors to
consider prior to the placement of nesting boxes.
Wetlands
Wetlands, which can be seasonal in nature, are areas typically located in depressions or at the
lowest point of landscapes. These areas are integral components of ecosystems and are important
habitat for a variety of wildlife. Wetland identification and specific mitigation measures for new
golf course construction and re-modeling projects are typically addressed on a case-by-case basis
through permit processes. Detailed management practices designed to protect and enhance
48
November 2000
Exhibit rA
Page _5 0 of l l A
OGCSA
Environmental Stewardship Guidelines Wildlife Habitat Enhancement
wetlands on existing golf courses should be developed based on input from the appropriate
regulatory agencies (e.g., Division of State Lands). The following are general suggestions for the
management of wetland areas on existing golf courses.
1. Inventory
If wetland areas are present on an existing golf course, they should be thoroughly mapped and
documented to develop a wetlands inventory. Also, a description of the management of these
areas should be included in the Integrated Pest Management Plan.
11. Water Quality
Protection of wetland water quality is very important, and includes protecting these areas from the
potential impact of stormwater runoff. Implementation of the practices described in the Best
Management Practices, Integrated Pest Management, and Water Quality Monitoring sections of
this document should optimize the protection of wetland water quality.
III, Vegetation
The growth of native wetland vegetation should be nurtured while discouraging the growth or
invasion of non-native plants. The Oregon Department of Agriculture can provide assistance in
the identification of non-native species and proper methods for control.
IV. Restricted Access
Entry of golfers into wetland areas, or any other areas of the golf course designated as
environmentally sensitive, should be discouraged. These locations should be identified with
signage such as "environmentally sensitive area: do not enter." In addition, information on the
score card that defines proper procedure if a golf ball enters an environmentally sensitive area aids
in educating golfers, while minimizing the tendency of golfers to enter these areas.
Aquatic Areas
Aquatic areas, consisting of lakes, ponds, and streams, represent excellent opportunities for
wildlife enhancement. The recent Endangered Species Act legislation for salmon and steelhead
heightens the importance of protecting and enhancing waterways that support any phase of
salmonid development and survival. In many instances, the same type of habitat enhancement
measures can be applied to lakes, ponds, and streams. Examples include the promotion of native
vegetation growth along shorelines and the positioning of nesting boxes.
Habitat enhancement for streams can be a relatively delicate process that requires design input
from experts to achieve the desired result. Examples of stream modification include stream
channel alteration, the addition of large woody debris, development of pools and alcoves, and
instream boulder placement. Before beginning any stream habitat enhancement process, it is
491
November 20061
Exhibit 1kj\
Page S I of I I A~
OGCSA
Environmental Stewardship Guidelines Wildlife Habitat Enhancement
important to consult resources such as the Oregon Department of State Lands and the Oregon
Department of Fish and Wildlife for advice on proper stream habitat enhancement methods.
Wildlife Habitat Enhancement Resources
Agencies and Organizations
City and County Planning Departments, Watershed Councils
Army Corp of Engineers Oregon Department of Agriculture
(503) 808-4376 (503) 986-4621
Audubon Cooperative Sanctuary
(518) 767-9051
Metro Regional Services
(503) 797-1510
National Marine Fisheries Service
(503) 231-2005
Documents
Oregon Department of Fish and Wildlife
(503) 878-5252
Oregon Division of State Lands
(503) 378-3805
Portland Audubon Society
(503) 292-6855
1. Oregon Aquatic Habitat Restoration and Enhancement Interim Guide -1998. The Oregon
Plan for Salmon and Watersheds.
2. A Practical Guide to Ecological Management of the Golf Course. 1995. R. S. Taylor (ed.).
The British and International Golf Greenkeepers Association and The Sports Turf Research
Institute.
3. Managing Wildlife Habitat on Golf Courses. 2000. R.G. Dodson (ed.). Sleeping Bear Press,
Chelsea, MI.
November 2000
Exhibit rA
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Case Studies AUDUBON/
INTERNATIONAL
SIGNATURE PROGRAMS
The Name Says it All
The Sanctuary balances development and environmental protection
BY NANCY RICHARDSON
Charlotte, North Carolina, is a bustling university town and center for
the arts, upscale shopping, and dining. It is also one of the 10 fastest
growing metropolitan areas in the nation, with associated traffic con-
gestion and loss of rural natural areas to show for it. Among 15 cities in the
U.S. studied in a growth analysis of preservation of rural land, Charlotte
ranked last at limiting the loss of rural land and open space in the 1990s
(Northwest Environment Watch, 2004). Between 1984 and 2001, Mecklenburg
County (which includes Charlotte) saw a 127-percent increase in areas cov-
ered by impervious surfaces.
The challenge for developers and city planners alike is how to balance Char-
lotte's growth and demand for new housing with the need to protect the en-
vironment and preserve what makes it an attractive community in the first
place. Just a few minutes and a short trip east of the city, a new residential
development named The Sanctuary is one place where developers are striking
that balance. The Sanctuary, developed by Crescent Resources LLC, recently
achieved status as the first Certified Gold Audubon Signature Sanctuary in
the state of North Carolina.
The Sanctuary is located along seven miles of quiet northern shoreline of Lake
Wylie, the largest and oldest of four lakes on the Catawba River, which sup-
plies much of the drinking water to the more than 700,000 residents of
Mecklenburg County. Because of the project's proximity to such a large and
regionally important water body, maintaining water quality by controlling
development impacts was critical to Audubon International's work with
Crescent Resources LLC.
Siting and Design
Fostering more environmentally-sensitive, planned growth begins with a well
thought out design.. The Sanctuary's primary distinction is its low-density ap-
proach. Crescent Resources limited homesites to 189 on the 1,348-acre
property, while leaving 80% of the land undisturbed. The vast majority of
the project site will remain wooded, with 215 acres preserved as common
open space and 20 miles of nature trails for residents to enjoy.
The site's topography is typical of the Piedmont area of North Carolina,
with obvious ridges and valleys sloping toward Lake Wylie. To protect water
quality, Crescent Resources LLC designated a 200-foot-wide conservation
corridor, or lakefront setback, along the entire lake front. The setback is
www.auduboninternational.org 0 2004 1
Exhibit ~A
Page (PZ of I1
Protecting Lake Wylie was of
central importance in the
project's design.
four times the distance required by Mecklenburg County. The conservation
corridor and 100-foot no-clear buffers along stream channels provide a filtering
mechanism for stormwater runoff, while at the same time helping to conserve
the habitat value of the land
Audubon International and Crescent Resources studied and mapped the natu-
ral characteristics of the land and customized a "development envelope" for
each house lot, designating areas for the main house, as well as any accessory
structures, such as a detached guest house, swimming pool, or other smaller
buildings. The lots are billed as privatepreserves, with no clearing and minimal
pruning allowed outside the development envelope. Rock outcroppings, flow-
ing or ephemeral streams, lake edges, unusual or noteworthy native plants, ma-
ture or specimen trees, bird nesting sites, wetlands, and views are among the
features that give each preserve its own character.
Audubon International also worked with Crescent Resources LLC to create an
interconnected network of habitat preserves to maintain the overall biodiversity
of the property. Preserves wind throughout The Sanctuary and also link with
other habitat patches in the surrounding area to facilitate wildlife movement.
Model home demonstrates green features
Arcadia Homes, Inc. of Charlotte constructed a model home at The Sanctuary to
demonstrate how "green living" features can be incorporated without sacrific-
ing convenience or luxury. The model is presently used as a sales center where
potential buyers can check out both interior and exterior environmental fea-
tures. Energy-efficient kitchen appliances include Energy Starproducts, such as
a Viking range, refrigerator, and dishwasher. Water is conserved by dual flush
toilets. A hot water circulating system supplies "on demand" hot water. A
high-efficiency air handling system allows air to be filtered and returned to the
home using less energy and contributing to a cleaner environment.
Outside, the building design and landscaping also promote environmental sensi-
tivity. In place of a manicured lawn, a grove of mature trees complements sur-
rounding woods. The trees shade the building in summer, keeping it cooler and
reducing energy demands for air conditioning. The structure also blends into
the surroundings through the use of stone, wood, and trim in earth tone colors.
In the case of The Sanctuary, good environmental design and Gold Signature
status is an attractive selling point for Crescent Resources LLC. Lower mainte-
nance costs and a beautiful, environmentally progressive setting are drawing
homeowners.
"In nearly every respect The Sanctuary sets a needed standard for developers in
the Charlotte area," says Ron Dodson, President and CEO of Audubon Inter-
national. "The Crescent Resources team, the home builders, and the various
consulting firms involved have all embraced our Principles for Sustainable Re-
source Management. Now that the private preserves and homes are being pur-
chased, we are confirming what we believed in the beginning-that customers
are also looking for environmentally friendly lifestyles. The Sanctuary is a real
winner on all fronts."
www.auduboninternational.org © 2004 2
Exhibit hk
Page 4a of 1 l~
Environmentally desirable materials and
construction are the hallmark of The
Sanctuary's model home:
• Recycled cork used in flooring and recycled
material used in sub-flooring
• Truss-joist floor joints consist of recycled
materials
• Oriented strand board (OSB) used for exte-
rior and roof sheathing as an alternative to
plywood
• Wall insulation made from recycled paper
(cellulose), which provides great insulation
value compared to fiberglass and comes
from recycled material
• Carpets made from recycled soda bottles
• Low VOC (Volatile Organic Compounds)
paints both inside and out reduce greatly
the amount of ozone depleting VOCs re-
leased into the atmosphere.
• Limited turf for home landscaping, drought
tolerant plants, and plants of similar low
maintenance requirements are used to mini-
mize the amount of irrigation needed.
• Pervious pavement used in driveway con-
struction allows water to drain through the
slab, rather than runoff. Pervious concrete
eliminates the erosion and stormwater run-
off problems often associated with impervi-
ous surfaces.
• A rain garden in the center of the cul de sac
of the driveway helps filter stormwater.
• Rain water diffusers added to downspouts
cut down on erosion and help water infil-
trate into the ground.
The sales center and model home show-
case numerous environmentally-friendly
features. Homes in The Sanctuary are
subject to design guidelines enforced by
a design review board.
www.auduboninternational.org © 2004 3
Exhibit ~n
Page 4 of II
Signature Programs
AU.DUBON
INTERNATIONAL
Saving Money, Saving Resources
"The objective of Sand Ridge Golf
Club is to provide a premium golf
facility while protecting the natural
en vironmen tally sensitive
surroundings. The guidelines of the
Signature Program enable us to
create this type of situation to
benefit the club as well as the
environment. With thispartnership
in place, we will continue to
enhance the game of golf while
protecting the environment. "
Bill Conway
Founder & Chairman of Sand Ridge
"Environmental commitment is the
foundation of Bonita Bay's
approach to managing its
properties. The natural partnership
with Audubon International
exemplifies the productive
relationship between conserving
the environmental beauty of the
property and obtaining the
economic benefits of reduced
maintenance costs "
B ecommg a certified Audubon Signature Sanctuary provides
tangible recognition that a property has been developed and is
being managed according to Audubon International's Ptincdples
for Swtainable &3ource Management. Owners and managers of Certified
Audubon Signature Sanctuaries gain local, national, and international
recognition for leadership in environmental stewardship. In addition,
members find that achieving certification leads to snore cost-effective
ways to develop and manage their properties-saving money as well as
natural resources.
Cost Effective Strategies
Sand Ridge Golf Club in Ohio transformed approximately 22 acres
of fairway that received little to no golf play into native plant/open
field roughs that are now seasonally mowed. The cost savings of this
restoration in terms of labor, equipment, and eliminated chemicals are
estimated to be $22,000 per year. Likewise, an additional 25 acres of
previously mowed and maintained primary rough were converted to
open field meadow zones. Ground crew labor costs over the past
three years were reduced by an estimated 15%, or about $5,000 per
year, not including the reduction in energy and equipment
maintenance costs.
Bonita Bay East in Florida, through the Audubon Signature
Program, reduced 82,442 square feet of turfgrass on the Sabal Course
and 4,905 square feet of turfgrass on the Cypress Course resulting in
the estimated savings of $56,000 annually relating to reduced
maintenance labor, irrigation, fertilizers, and pesticides. One thousand
three hundred carp were released in their lakes, saving approximately
$10,000 from the decrease in labor and pesticides needed to maintaui
the lakes. Bonita Bay East saved 1,837,500 gallons of water a year due
to replacing turf areas with native plantings and eliminating thirty
sprinkler heads. In addition, seven sprinklers were disabled on both
golf courses for a savings of 428,750 gallons of water a year, for a total
of 2,266,250 gallons of water saved in a year. By removing 86,400
square feet of turf, Bonita Bay East saved an estimated $12,000
annually in maintenance labor, irrigation, fertilizers, and pesticides.
Jim Schilling, CGCS
Director of Golf Course Operations
Bonita Bay Golf Club East
www.auduboninternational.org © 2005
Exhibit M
Page _5 of
Sand Ridge Golf Club
Chardon, OH
Bonita Bay Golf Club
Naples, FL
Cateechee Golf Club in Georgia, by implementing its specific
Audubon Signature Program Natural Resource Management Plan,
saved 20% in electric costs and 30% in overall operating costs
compared to traditionally built and managed golf courses. Likewise, it
handles more than 639 million gallons of effluent water annually,
allowing the City of Hartwell to abandon its practice of discharging
effluent water into a local stream.
The Audubon Signature Program has
developed a higher degree of
excellence throughout mystaff. They
understand nature better, the habitat
better. They understandwhatgolfers
really want, which is not homes lined
up and down the fairways, but rather
a fox or deer peeking out from
behind a tree in the woods Our
desire is that Cateechee gives the
golfer an experience he is not
expecting. The Audubon connection
has been a step in making the golf
course unique.
Lee Barton, Owner
Cateechee Golf Club
For more information about
the Signature Programs,
please contact:
Nancy E. Richardson
Director, Signature Programs
Audubon International
230 Second Street, Ste. 311
Henderson, KY 42420
Phone: (270) 869-9419
Fax: (270) 869-9956
E-mail: nrichardson
@auduboninternational.org
PGA Golf Club in Florida saved 25°'o in overall operating costs
because of the state of the art equipment and practices promoted by
the Signature Program, and, as a part of the program, conserves 100
million gallons of Florida's water supply by collecting runoff in 80
acres of ponds created for water storage and wildlife habitat.
Value of Program Participation Survey
Audubon International recently conducted a survey of Audubon
Signature Programs members on the business value of program
participation, with these results:
• 90% of respondents reported that they believed annual operation
and maintenance costs for their facility were either "lower than" or
the "same as" the costs of an equivalent, non-Signature Programs
golf course.
• 96% view their participation in the Signature Programs as "a good
business decision"
• 63% of respondents stated that participation in the Signature
Programs, including upfront monetary and staff investment, has or
will save money, as compared to a course designed, constructed,
and managed without Audubon International assistance.
• Finally, 90% stated that they believed the Certified Audubon
Signature Sanctuary status earned through following the program
guidelines has or will have value in marketing and promotional
efforts.
"Combining wildlife preservation and
development is not only the right thing to do,
but it makesgood business sense. Long-term
operating costs can be significantly reduced
while providing valuable environmental
benefits to the community. A healthy, well-
maintained golf course can be cost efficient by
reducing pesticides and conserving water and
in the process becomes vital habitat for plants,
wildlife, and people. It is a business-
environmental partnership thatserves
everyone. "
Jim L. Awtrey, Chief Executive Officer, PGA of
America, Palm Beach Gardens, FL
www.auduboninternational.org © 2005 2
Exhibit___~l\
Page b !P of I 1 A,
Cateechee Golf Club
Hartwell, GA
PGA Golf Club
Port St. Lucie, FL
r. L
Atli l)UB0N
1NTFI \T AT ONAN?1. ~ t
The Gold
Signature Pro gram
Cascais, Portugal
Exhibit (V\
Page & rl of
Quinta da Marinha Oitavos Golfe
THE GOLD SIGNATURE PROGRAM
Description
The Gold Signature Program is Audubon International's highest level Signature Program and is not
only ideal for new single-land-use developments, but particularly intended for landowners or
developers whose project may include mu4k new land uses (residential homes, recreational areas, golf
courses, etc.). It is aimed at developers who are interested in Audubon International's involvement in
the planning and design of the project, so that the developer has access to Audubon International's
Environmental Planning Department expertise at the inception of the project. The Gold Signature
Program provides more extensive education and training sessions through additional site visits and
over a longer period of time, to ensure a broader conunitment by all those involved in the project
Goals
The primary goal of the Gold Signature Program is to develop communities that integrate an
ecosystem approach to siting, design, construction, and management; and provide environmental
education for those who live, work, and recreate in the community. The Gold Signature Program
focuses on six separate areas including. 1) Site Design, 2) Landscape, 3) Wildlife, 4) Water, 5) Green
Building, and 6) Education. The specific goals within each of those areas comprise the integrated and
comprehensive approach that helps to define the Gold Signature Program.
1. Site Design and Planning
•
Incorporate Audubon International conceptual site review recommendations
in the site plan
•
Properly base siting on regional and site-specific elements (contextual design)
•
Meet both human and wildlife habitat needs (eco-centric design)
•
Minimize land clearing
•
Maximize preserves and open space
2. Landscape
•
Meet native planting requirements (indigenous, social, and entry zones)
•
Minimize turf areas
Minimize water and chemical use
•
Identify habitat enhancement / restoration projects
•
Implement an integrated pest management (IPM) program based on sound
science
3. Wildlife
•
Identify and protect core habitat areas
•
Protect and develop corridors and connections
•
Identify habitat enhancement / restoration projects
•
Monitor changes in biodiversity
4. Water
•
Implement conservation measures
•
Protect water quality with recommended drainage best management practices
•
Proper irrigation design, installation, and use
•
Routine water quality monitoring (ground and surface waters)
Exhibit 1v\
Page _ of I 1 A
5. Green Building
• Use existing programs that have a track record in achieving environmentally
friendly buildings (i.e., Florida Green Building Coalition, LEEDS program).
• Develop an Audubon International upgrade package
6. Education
• Promote corporate environmental stewardship and educate staff
• Develop resident and guest education programs
• Develop contractor education programs (landscape, construction,
homebuilding)
• Involve and educate the general public
Eligibility
The project must be registered as a member of the Gold Signature Program prior to completion of the
design of the project Audubon International then prepares the Environmental Master Plan for the
project, which is based on ecological considerations of the property and presents a common vision for
the property.
The Environmental Master Plan
The Audubon International Environmental Master Plan is the environmental "framework" from
which siting, design, and management decisions relative to environmental impact are made. In other
words, Audubon International will apply its "Principles for Sustainable Resource Management
"Principles for Ecological Restoration," and "Principles for Natural Landscaping" to the site.
Audubon International will work with the project team to ensure that all aspects of the project are
consistent with the common vision and with the Environmental Master Plan.
The Environmental Master Plan is implemented
Construction; and 3) Management and Education.
important aspects of the program
in three phases: 1) Planning and Permitting; 2)
These phases are described below along with other
Phase 1: Planning and Permitting
The goal of Phase 1 is to successfully design and obtain permits for the development based
upon ecological characteristics of the property and surrounding landscapes. As we begin the
design process, Audubon International provides specific Sustainable Resource Management
Guidelines for the project. These guidelines describe the development in the context of our
"Principles for Sustainable Resource Management" Audubon International then produces
the Ecological Design, which is Audubon International's resource-protective design for the
property, based upon ecologically significant regional and site characteristics, including water
and wildlife habitat At this phase of the process, we also work with the development team to
identify appropriate `green building' components of the development
We use the Ecological Design for two purposes: first, to apply Audubon International's
environmental stewardship principles to the specific site and region to develop site-specific
requirements for certification; second, to cooperatively establish a common vision for the
Exhibit N\
Page of (IA
property - a vision that includes overall economic goals and the ecological attributes of the
property. This vision provides guidance for project planning, and we work closely with the
project team to help implement this vision on the land plan. Once we agree on the vision for
the property, and the land plan reflects this vision, the land plan will be designated as an
Audubon International Approved Land Plan. The Audubon International Ecological Design
and the Audubon International Approved Land Plan will serve as the basis for permitting
efforts.
Phase 2: Construction Planning and Practice
The goal of Phase 2 is to successfully develop and implement environmentally sound
construction planning and practices. Considerations identified in Phase 1, the Ecological
Design, as well as Phase 2, are implemented at the site in order to mininmize site disturbance and
promote ecological sensitivity. As part of this phase, Audubon International's Environmental
Planning Department staff attend pre-bid meetings and contractor reviews, provide contractor
environmental education, and carry out on-site review during the construction process. The
following components of a construction management program are important parts of Phase 2 of
the Gold Signature Program 1) prevention practices, 2) management practices, and
3) monitoring.
Phase 3: Management and Education
The goal of Phase 3 is to successfully integrate environmental management and education into
the project. Audubon International prepares a Natural Resource Management Plan that
integrates natural resource protection and human use of the property. Audubon International
also prepares Community Education and Information Guidelines that provide the blueprint
for creating and nurturing an environmental ethic among those who live, work, or recreate at an
Audubon Gold Signature project. These plans serve as the long term management and
education tools for the project.
Other Important Aspects of the Program
Natural Resource Manager. A key component of the Gold Signature Program is the
position of the Natural Resource Manager. As part of the development team, this
professional is hired early in the process and will develop, lead, and implement
environmental and education programs for the property.
Facilitating the Process. Of equal importance to the production of technical
documents is education and outreach to the broader community. Audubon
International assists the developer by. 1) meeting with local citizens, environmental or
other non-government groups, and regulators to pro-actively promote the project as an
environmental demonstration model; and 2) providing training to the development
team and management staff during the development of the project and after the project
is completed
Exhibit rA
Page 7 of t L1~
Site Visits
The Gold Signature Program is a design and planning, resource management, and training and
education program The difference between the Gold Signature Program and Silver Signature
Program is the more intensive and earlier involvement by Audubon International in planning and
design and the emphasis on community outreach and education.
Through the Gold Signature Program, Audubon International is involved early in the design and
planning stages of the project, is actively involved throughout the construction and management of
the project, and provides guidance on the education and outreach requirements of the program The
number of site visits required from the beginning of the program to completion may vary from as
few as 12 to as many as 20, depending on the size and complexity of the project, and is determined
contractually. Every effort is made to distribute site visits evenly throughout the design, construction,
and implementation phases of the project to assist the landowner/developer to successfully achieve
program goals and objectives.
The planning phase includes site visits to:
1) identify and meet with key team members to determine the status of the project,
2) conduct an ecological assessment of the property and develop an ecological design
for the project,
3) identify wildlife and land use issues, assess water quality and use issues, and
ultimately develop a conceptual land plan for the entire project
4) verify pre-construction safeguards, oversee clearing, and begin final mapping and
wildlife and water assessments for the Natural Resource Management Plan.
During the construction phases attention is focused on:
1) oversight of on going construction to ensure compliance with and implementation
of all elements of the NRMP,
2) address issues related to shaping infrastructure, vertical construction, grow-in,
Integrated Pest Management, and turf,
3) training and education of construction and sales staff, and meeting with community
members as necessary,
4) Reviewing NRMP in regard to wildlife life and eco design implementation.
The Natural Resource Management Plan is usually completed towards the end of the construction
phase, and subsequent site visits are scheduled to walk the site, review implementation, and educate
employees. In addition, a site visit is scheduled to conduct a final environmental audit required of all
Signature Program members. If the Community Education and Information Plan is not completed at
the time of the actual project completion, it is reviewed during subsequent recertification site visits to
ensure compliance with the educational program requirements.
Exhibit
Page
ol7
Gold Signature Program Diamond Ratings
Within the Gold Signature Program, projects are rated in three categories. The first category focuses
broadly on planning, design, and management, taking into account performance in certain process
requirements, vegetation and landscape design and management, water conservation, green building
measures, waste management and recycling energy efficiency, and information and outreach. The
second and third categories focus on Audubon International's highest priority goals of protecting and
enhancing water quality and wildlife habitat. The water quality and wildlife habitat rating categories
also take into account the pre-existing condition of the site and its surroundings; raring standards are
more demanding for more pristine sites and less demanding for sites that are more degraded.
Depending on the performance ratings in each of these three areas, a project will be awarded one,
two, or three diamonds. The overall rating depends on the lowest rating in any one of the three categories.
"One Diamond" means the project met the minimum requirements for all Signature Programs
and at least the minimum requirements in each of the three rating categories of the Gold
Signature Program, but in at least one category did not substantially exceed the minimum
requirements.
"Two Diamond" means the project substantially surpassed the minimum requirements in all
three rating categories of the Gold Signature Program It may be rated exemplary in one or two
of those categories, but not all three.
`Three Diamond" means the project qualifies as exemplary in all three rating categories, far
surpassing minimum requirements consistently across the board.
Ratings on some of the factors considered in each rating category can change over time, depending
on changes that might occur in the project site and how it is managed. For that reason, a Gold
Signature Program project will be evaluated not only initially when considered for certification as a
Gold Audubon Signature Sanctuary, but also at the time of each annual recertification review.
Depending on the results of such a reevaluation, a project's diamond rating Wright increase or decrease in the f ffAn
Achieving & Maintaining Certification
To become certified as a Gold Audubon Signature Sanctuary, a project must comply with all the
generally applicable minimum requirements for all Signature projects. It must also meet whatever additional,
site-specific conditions and requirements are reasonable in light of its particular resources, features,
facilities, and other circumstances. These additional requirements are identified and established by
Audubon International in consultation with the property owner and manager during development of
the Ecological Design and the NRMP.
No property can become a Certified Gold Audubon Signature Sanctuary without passing a final on-Rk
audit. The audit by Audubon International staff provides an independent validation by this not-for-
profit environmental organization that the property has been developed and is being maintained in
accordance with all applicable requirements and the provisions of the NRMP. During the
certification process, the project will also be evaluated for its performance, in light of regional and site
resource characteristics, and rated from One to Three Diamonds.
Exhibit (V\
Page _2 of 4
In order to maintain membership status and certification, the project must submit any required
documentation (e.g., water quality testing results), an annual report, and annual membership fees on a
timely basis. It must also host an annual recertification site audit, which is designed to determine
whether the project continues to be operated and maintained in accordance with all applicable
requirements and the provisions of the NRMP and to review, and, if necessary, adjust, the project's
diamond rating based on its current performance.
Audubon Gold Signature Program Benefits
Audubon International's premier Gold Signature Program takes environmentally-responsible design
and development to the highest level, with a greatly expanded set of services from Audubon
International's Environmental Planning Department. This comprehensive environmental program,
covering planning design, construction, long-term management, and long-term education,
significantly enhances the economic and environmental value of the development. Our
Environmental Planning Department works in cooperation with your design, construction, and
operations teams to make your project an environmental model, while adding economic value to it.
Our Environmental Planning Department experts save you money and speed the process through:
Planning and design. Audubon International's Environmental Planning Department staff
develop an Ecological Design for the project, taking into account ecologically significant
regional and site resources and characteristics. They then work closely with your project
team to help develop an approved land plan, consistent with the Ecological Design, that
balances and optimizes environmental protection and enhancement and the economics of
your project. These steps, in turn, facilitate permitting.
Smoother, quicker permitting. Audubon International and its Gold Signature Program
have won wide recognition from government agencies in the U. S. and abroad, from the
national through local levels. Knowing a project will be developed and operated in
accordance with the principles for sustainability and good environmental stewardship
practices embodied in Audubon International's Gold Signature Program, with the guidance
and oversight of its staff, gives regulatory agencies confidence that helps move the project
more smoothly and quickly through the permitting processes and keep the project on track.
Our Environmental Planning Department also works directly with you and your project team
to provide information on the environmental protection benefits of the Gold Signature
Program for the property being developed, as well as the surrounding region, to assist in the
regulatory process.
Training. Audubon International's Environmental Planning Department provides gmat4
expanded training to your construction-and, later, operational-personnel on how to do
things the right way from the start, together with monitoring and advice that help protect
against costly mistakes that can harm the environment and require correction. That training,
together with Environmental Planning Department monitoring during construction and later
operation, not only saves you time and money, but also provides assurance that your project
will ultimately be able to achieve success and become a Certified Gold Audubon Signature
Sanctuary and maintain that status for the long term
Exhibit (V\
11A
23-of
Writing your long-term environmental management guide. Every Signature Program
project must have a specifically-tailored Natural Resource Management Plan (NRMP) to guide
and govern project construction and subsequent operations. Audubon International's
Environmental Planning Department experts will develop a detailed, comprehensive written
NRMP as the blueprint for development and long-term operation and management of your
property in accordance with the best environmental stewardship practices. They will also revise
it periodically to keep site managers up to date with changing conditions and the latest in
efficient, cost-saving environmental management principles and techniques for the future.
Community Education and Information Guidelines. Audubon International staff will
prepare Community Education and Information Guidelines for your project The Guidelines
provide a blueprint for the Natural Resource Manager to use to as the foundation for a specific,
detailed Community Education and Information Plan to involve residents, guests, and neighbors
in the environmental focus of your Certified Gold Audubon Signature Sanctuary property.
A land owner or developer will also realize these major benefits from participation and achievement of
certification in the Gold Signature Program:
"Green appeal" marketing edge. More and more people are looking for "green,"
environmentally-friendly developments where they can live and enjoy recreational activities. A
property certified as a Gold Audubon Signature Sanctuary provides the unparalleled appeal of a
unique sense of place, based on its "living with nature" environment, a living and lifestyles
educational program for residents and guests, and an on-site natural resource manager. These
features give a Certified Gold Audubon Signature Sanctuary an unmatched prestige and
marketing edge that leads to significantly increased sales prices and member fees, faster sales,
and lower marketing and holding costs.
Operation and maintenance cost savings. The sound environmental techniques and
practices embodied in the Gold Signature Program incorporate use of the right turf, as well as
low maintenance landscaping and natural areas, and reduce the amounts of managed turf, water,
fertilizers, chemicals, fuels and other energy, equipment, equipment maintenance, and labor
needed, all producing long-term savings in operation and maintenance costs. These life-cycle
cost savings provide substantial financial benefits to land owners for the long term and
command a premium on sale.
Reduced risk The best environmental practices incorporated in the Gold Signature Program
dramatically cut the use of hazardous materials on site and the possibility of migration to water
bodies or off-site properties, reducing risk of harm and potential liability to any residents,
members, visitors, neighbors, or employees. Those reduced risks in turn lower insurance and
workers' compensation costs, potential for adverse regulatory action and harmful publicity, and
lost worker time.
• Higher productivity. Managers and other employees working on certified Audubon Signature
Sanctuary properties feel better and more satisfied about their own work and relation to the
land. They also have less exposure to chemicals and hazardous conditions. As a result,
absenteeism, sick days, and workers compensation are reduced and employee productivity is
higher.
Exhibit
Page 74 of
Recognition for environmental leadership. Certification as a Gold Audubon Signature
Sanctuary recognizes that a property not only has been developed and is being managed in
accordance with Audubon International's Principles for Sustainable Resource Management,
but that it meets exceptional standards for protecting and enhancing wildlife and habitat,
water, and other resources for the long term Developers and land owners find that
certification in the program helps to forge a positive image and reputation and enhanced
good will in the community. Certified Audubon Signature Sanctuaries often win most
prestigious awards and recognition from other organizations and governmental bodies.
Environmental protection and enhancement. Owners and managers of certified Gold
Audubon Signature Sanctuary properties can take justifiable pride as exemplars in furthering
sustainable resource management and protecting and preserving the environment for this
and future generations. A Certified Gold Audubon Signature Sanctuary itself stands as a
model providing encouragement and superior example for other land owners and managers,
consultants, and the broader community to make future land management decisions based
on the environment as well as economic values, and to see that good environmental
stewardship and sound economic principles are both intertwined and fully compatible. The
more sustainable development and land management thus fostered in the community as a
whole then benefit the community in its entirety, which in turn adds greater value to your
own property.
Exhibit rA
t \A
Page R-5- Of
Costs
Costs are summarized below. Payments can be made in a variety of ways. The most common are
monthly or based on percent completion, with expenses reimbursed monthly. The actual schedule of
payment will be determined prior to signing the membership agreement
Program Fees for the Gold Signature Program
(Typical Fees shown are for a Golf-Course-Only Project)
Gold Signature Program
Fee
Registration Fee for the Signature Program:
$9,500
Cost for Site Visits and Technical Work:
-x$150,000
Includes 16 Site Visits by 1-2 Al Scientists
Does NOT include travel or reimbursable expenses
which are billed at no markup)
TOTAL PROGRAM COST
t$159,500 + travel expenses
Fees for Gold Signature Program after Initial Certification
Annual Review and Audit
2-3 days Q $800 per day
Number of days depends on the property and its loca-
+ travel expenses
tion.
Annual Member Fee:
$500
t Costs and expenses vary with size, location, and complexity of each project
Exhibit ri1\
Page 7 CP _ of 11
AUDI B0N
i,.\.rCRNArloti 1,
to)-
f-ISignature
Program
Snake River Sporting Club
Jackson Hole, WY
1~~
Exhibit IVY
Page '77 of'
The Silver Signature Program
Description
The Silver Signature Program is similar to the Bronze Signature Program, with three important
distinctions: 1) the project may include more than one neav type of land use; 2) it may be located outside the
continental United States and Canada; 3) Audubon International's Environmental Planning
Department prepares the Natural Resource Management Plan, which ensues full compliance aarith the
requirements and spirit of the Signature Pro
gram, and 4) the Environmental Planning Department provides
consultation, training, and education through additional site visits, to foster successful implementation of and
long-term commitment to the NRMP. The goal of the Silver Signature Program is to integrate an
ecosystem approach to construction and management and provide environmental education for those
who live, work, and recreate in the community. The development, upon successful completion of all
program requirements and subsequent to a final environmental audit, will receive the designation as a
Certified SilverAudubon Signature Sanctuary
Eligibility
The Silver Signature Program is open to any kind of development, in the United States and Canada or
beyond, and more than one land use change, such as development of a residential community with a
golf course or other amenities. Any project in the planning stage, including a major redevelopment,
may apply for membership in the program Audubon International prefers and recommends that a
project join the program before any construction work, including land clearing, begins and may reject
an application if clearing has begun. In any event, projects are no longer eligible to join the Silver
Signature Program after construction has moved from the clearing phase to installation of major
infrastructure, such as an irrigation system or sewerage.
The Natural Resource Management Plan
Every member of the Signature Programs must have a Natural Resource Management Plan. The
purpose of the Natural Resource Management Plan (NRMP) is to serve as the construction and
operations manual for the property. The Natural Resource Management Plan in the Silver Signature
Program is prepared by Audubon International's Environmental Planning Department and includes
chapters on: Site Characterization, Environmental Planning, Integrated Pest Management, Water
Conservation, Water Quality Management, Waste Management and Energy Conservation, Wildlife
Conservation and Habitat Enhancement, Natural Resource Management Center, and Outreach and
Education. It is written so that managers of the property have the best scientific and technical tools
available for making decisions during construction through completion and long term management
of the property and will be updated annually as needed. The Natural Resource Management Plan is
implemented in two phases, as described below.
Exhibit rA
Page_ Q of_ _L l
Phase 1- Construction Planning and Practices
The goal of Phase 1 is to successfully develop and implement environmentally sound
construction planning and practices. Construction guidelines are identified in the
document "Audubon InternationaPs Planning, Design, and Construction
Guidelines" presented at the initial site visit, and are implemented in order to
minimize site disturbance and promote ecological sensitivity. These plans and
practices include on-site reviews during the construction process. Prevention
practices, management practices, and monitoring are essential parts of Phase 1.
Phase 2 - Management and Education
The goal of Phase 2 is to successfully merge environmental management and
education into the project through the development and implementation of the
Natural Resource Management Plan which integrates natural resource protection
and human use of the property.
Site Visits
The Silver Signature Program is primarily a resource management and education program. The
number of site visits is dependent upon the status of the project at the time the landowner/developer
joins the Signature Program and the speed with which the project is progressing. Typically, site visits
are scheduled to target the major phases of construction. Usually, Audubon International staff
conducts five to six site visits and prepares the Natural Resource Management Plan, which defines
how the development will be constructed and managed so that natural resource protection and
human use of the property are integrated.
The site visits are an important tool to ensure developers are following Audubon International
construction guidelines and implementing the components of the Silver Signature Program. It is also
a valuable opportunity for the landowner/developer to have an on-going dialogue with Audubon
International staff and allows for an opportunity to educate the landowner/developer and project
staff, discuss any planning or construction issues, make recommendations, pose alternatives, and
answer questions that the staff or developer may have. In that regard, education is on going in the
Silver Signature Program. During each site visit, Audubon International staff assists members in
tasks such as creating a landscape palette, selecting plant species for out-of play areas, incorporating
native plants whenever possible, creating lake littoral zones, and helping to develop ideas for
continued education and outreach when construction is completed.
The site visits of the Silver Signature Program include the following.
1) The initial site visit usually occurs prior to construction and is an opportunity for
Audubon staff to meet with the development team, discuss the requirements of the
program, review plans and maps of the site and maintenance facility, and walk the
property.
2) The second site visit usually occurs during the preliminary stages of construction,
and is an opportunity to review issues such as turf selection, IPM, Best Management
Practices, and protection of wildlife and plant species, and drainage and water
quality.
Exhibit ---A
Page rte' 9 of_ 1 I A
3) The first draft of the Natural Resource Management Plan is usually completed prior
to the third site visit and is reviewed with the superintendent at that time. In
addition, Audubon International focuses primarily on turf issues including drainage,
irrigation, shaping, and grassing.
4) During the fourth visit, Audubon International staff reviews plans and ongoing
activities relative to clearing, shaping, and drainage, as well as makes a general
assessment of the project's progress. In addition, Audubon International staff
begins looking more closely at information regarding the fuel island, the wash pad,
and the maintenance facility.
5) The fifth site visit occurs near the end of construction and at that time, drainage,
wildlife connections, chemical and risk assessment, and the Natural Resource
Management Center are all reviewed to assess compliance with Audubon
International program requirements.
6) The final draft of the Natural Resource Management Plan is completed prior to the
sixth site visit, which is the environmental audit. At that time, it is determined
whether the member has satisfied all the requirements of the program and whether
the project will be designated as an Audubon Silver Signature Sanctuary.
Achieving & Maintaining Certification
To become certified as a Silver Audubon Signature Sanctuary, a project must comply with all the
generally applicable minimum requirements for all Signature projects. It must also meet whatever additional,
site-specific conditions and requirements are reasonable in light of its particular resources, features,
facilities, and other circumstances. These additional requirements are identified and established by
Audubon International in consultation with the property owner and manager during development of
the NRMP.
No property can become a Certified Silver Audubon Signature Sanctuary without passing a final on-site
audit. The audit by Audubon International staff provides an independent validation by this not-for-
profit environmental organization that the property has been developed and is being maintained in
accordance with all applicable requirements and the provisions of the NRMP.
In order to maintain membership status and certification, the project must submit any required
documentation (e.g., water quality testing results), an annual report, and annual membership fees on a
timely basis. It must also host an annual recertification site audit, which is designed to determine
whether the project continues to be operated and maintained in accordance with all applicable
requirements and the provisions of the NRMP.
Silver Signature Program Benefits
The Silver Signature Program greatly improves upon the Bronze Signature Program by providing
services from Audubon International's Environmental Planning Department to assist your team in
getting your project certified as a Silver Signature Sanctuary. You gain all the benefits of the Bronze
Signature Program, but more cost-effectively and expeditiously.
Exhibit M
q_
Page of
Our Environmental Planning Department experts save you money and speed the process through:
• Training. Audubon International Environmental Planning Department staff train your
construction personnel on how to do things the right way from the start and avoid costly
mistakes that can harm the environment and require correction, saving you time and money
and providing greater assurance that your project will ultimately be able to achieve success
and become a Certified Silver Signature Sanctuary.
Writing your project's 1' MP. Every Signature Program project must have a specifically-
tailored Natural Resource Management Plan (NRMP) to guide and govern project
construction and subsequent operations. Audubon International's own Environmental
Planning Department experts know the requirements for an NRMP inside and out, the way
no independent consultant can. As a result, they can prepare it more quickly and get it right
the first time, saving you the time and expense of multiple rounds of drafts, reviews,
comments, and redrafts typical with outside consultants necessary for you to hire in the
Bronze Signature Program. (In addition, because Audubon International also saves time and
effort by avoiding multiple review rounds, we pass our administrative cost savings on to you
in the form of a lower registration fee than for the Bronze Signature Program.)
A land owner or developer may look forward to these major benefits from participation and
achievement of certification in the Silver Signature Program.
Green appeal and marketing edge. More and more people are looking for "green"
environmentally-friendly developments where they can live and enjoy recreational activities.
The environmental and aesthetic appeal of properties that become certified in an Audubon
International Signature Program give a property a marketing edge that supports increased
sales prices and member fees, faster sales, and lower marketing and holding costs.
O&M cost savings. The sound environmental techniques and practices embodied in the
Silver Signature Program incorporate use of the right turf, as well as low maintenance
landscaping and natural areas, and reduce the amounts of managed turf, water, fertilizers,
chemicals, fuels and other energy, equipment, equipment maintenance, and labor needed, all
producing long-term savings in operation and maintenance costs. These life-cycle cost
savings provide substantial financial benefits to land owners for the long term and command
a premium on sale.
Reduced risk The best environmental management practices incorporated in the Silver
Signature Program dramatically cut the use of hazardous materials on site and the possibility
of migration to water bodies or off-site properties, reducing risk of harm and potential
liability to any residents, members, visitors, neighbors, or employees. Those reduced risks in
turn lower insurance and workers' compensation costs, potential for adverse regulatory
action and harmful publicity, and lost worker time.
Recognition for environmental leadership. Certification as a Silver Audubon Signature
Sanctuary recognizes that a property has been developed and is being managed in accordance
with Audubon International's Principles for Sustainable Resource Management, signifying
that it meets or exceeds our standards for protecting and enhancing wildlife and habitat,
water, and other resources for the long term. Developers and land owners find that
certification in the program helps to forge a positive image and reputation and enhanced
Exhibit V\
Page 8' I of
11 q
Certified Silver Audubon Signature Sanctuaries also often win prestigious awards and
recognition from other organizations and governmental bodies.
• Environment and resource conservation and enhancement. Perhaps most important,
owners and managers of certified Silver Audubon Signature Sanctuary properties can take
justifiable pride in doing their part to further sustainable resource management and protect
and preserve the environment for this and future generations.
• Employee satisfaction, retention, and productivity. Managers and other employees
working on certified Audubon Signature Sanctuary properties feel better and more satisfied
about their own work and relation to the land. They also have less exposure to chemicals
and hazardous conditions. As a result, absenteeism, sick days, and workers compensation are
reduced and employee productivity is higher.
Costs
Current costs for the program are summarized below. Payments can be made in a variety of ways.
The most common are monthly, or based on percentage completion, with expenses reimbursed
monthly. The actual schedule of payment will be determined prior to signing the membership
agreement.
Program Fees for the Silver Signature Program
(Typical Fees shown are for a Golf-Course-Onl Project
Silver Signature Program
Fee
Registration Fee for the Signature Program:
$9,500
Cost for Site Visits and Technical Work:
t$40,000
Includes 5-6 Site Visits by 1-2 AI Scientists
Does NOT include travel or reimbursable expenses
(which are billed at no markup)
TOTAL PROGRAM COST
t%9,500 + travel expenses
Fees for Silver Signature Program after Initial Certification
Annual Review and Audit
1 - 2 days @ $800 per day
Number of days depends on the property and its
+ travel expenses
location.
Annual Member Fee:
$500
t Costs and expenses vary with size, location, and complexity of each project
Exhibit M
Page $2 of Il4
AuDUBC)N -
INl'rRAATIONA1.
Tl)e Bronc>,p
Signature Pro
gram
a. b : ~ y
~ '1 "•i~.
it {'w.~
17
J l~+
.f
x
,r
Cateechee Golf Club
Hartwell, GA
Exhibit p(\
Page F~3 of U A
A
The Bronze Signature Program
Description
The Bronze Signature Program is an environmental education, review, and audit program created to help
landowners and managers follow sustainable resource management principles in a comprehensive
manner when developing and then managing properties. The Signature Program Office works primarily
with the golf course superintendent, resource advisory committee members, or other land or facility
managers for educational purposes.
The purpose of the program is to integrate wildlife conservation, habitat restoration and enhancement,
water conservation and water quality protection, and other areas of environmental protection and
improvement with the other objectives for the development. The Bronze Signature Program's long-term
goal is to foster a stewardship ethic that leads landowners and managers, consultants, and the community
to consider environmental benefits, as well as economic costs, in their decision making and to apply
these environmental values routinely in land management.
Eligibility
Although many Bronze Signature Program member properties are golf courses, the program is not just
for golf development. Any project in the planning stage, including a major redevelopment, may apply
for membership in the program. Among present non-golf members are a retail facility, a marina, a
private college preparatory school, a church, and an athletic field/sports complex. Membership,
however, is limited to projects involving only a single type of land use. The Bronze Signature Program is also
limited to projects located in the continental United States or Canada. (Projects are no longer eligible
for the Bronze Signature Program when installation of major infrastructure, such as an irrigation system
or sewerage, begins on the propeM)
The Natural Resource Management Plan (NRMP)
The Natural Resource Management Plan is the essence of the Signature Program The designation of
Cert~ted Bron.Ze Audubon Signature Sanctuary is contingent upon the quality and completeness of the NRMP
and its implementation. Components of the NRMP must be drafted and submitted to Audubon
International for review and comment prior to implementation of proposed plans in order to ensure that
all environmental concerns are addressed. The NRMP must be revised in response to Audubon
International's comments until it is satisfactory. Submission of an acceptable NRMP after plans, designs,
or projects have been implemented may jeopardize the designation as a Certified Audubon Signature
Sanctuary.
If the project is fully permitted at the time of the initial site visit, the first draft of the NRMP is due in the
Signature Program office four months from the time of the initial site visit. The first draft is then
reviewed by Audubon International staff and team of affiliated experts. The member revises the NRMP
in response to Audubon International comments and recommendations. The final draft is due in the
Signature Program office eight months after the initial site visit. At each recertification visit, the NRMP
is updated and revised based upon new, evolving information or best management practices and new
products and technologies that have become available.
Exhibit IV
Page $ of
Site Visits
The initial site visit occurs approximately six weeks after registration. The purpose is to view the
property and to meet with the development team, including those people designated to write sections of
the NRMP. During the initial visit, The Landscape Restoration Handbook and the Bronze Signature
Program Guide are provided, and the writing of the NRMP and other relevant topics are discussed.
Specific on-site construction and maintenance practices are identified. If construction has commenced,
the clearing is reviewed and an evaluation is made.
The second visit occurs mid-construction. At that time, Audubon International staff will review the
maintenance facility (Natural Resource Management Center), shaping and grassing, and the irrigation
system, depending on the construction progress made at the time of the site visit.
The third visit is the Final Environmental Audit to determine if the project will be certified. During this
audit, the entire project will be reviewed including, but not limited to, drainage, irrigation, and
management zones. Structures that will be reviewed include the pump house, entire maintenance facility,
clubhouse (pro-shop), and sales center.
Achieving & Maintaining Certification
To become certified as a Bronze Audubon Signature Sanctuary, a project must comply with all the
generally applicable minimum requirements for all Signature projects. It must also meet whatever additional,
site-specific conditions and requirements are reasonable in light of its particular resources, features,
facilities, and other circumstances. These additional requirements are identified and established by
Audubon International in consultation with the property owner and manager during development of the
NRMP.
No property can become a Certified Bronze Audubon Signature Sanctuary without passing a final on-site
audit. The audit by Audubon International staff provides an independent validation by this not-for-profit
environmental organization that the property has been developed and is being maintained in compliance
with all applicable requirements and the provisions of the NRMP.
In order to maintain membership status and certification, the project must submit any required
documentation (fg., water quality testing results), an annual report, and annual membership fees on a
timely basis. It must also host a recertification site audit every two years, which is designed to determine
whether the project continues to be operated and maintained in accordance with all applicable
requirements and the provisions of the NRMP.
Bronze Signature Program Benefits
A land owner or developer can look forward to substantial benefits from participation and achievement
of certification in the Bronze Signature Program:
"Green appeal" marketing edge. More and more people are looking for "green,"
environmentally-friendly developments where they can live and enjoy recreational activities. The
environmental and aesthetic appeal of properties that become certified in an Audubon International
Signature Program give a property a marketing edge that supports increased sales prices or member
fees, faster sales, and lower marketing and holding costs.
Exhibit 0
Page 2,5 of J
Operation and maintenance cost savings. The sound environmental techniques and practices
embodied in the Bronze Signature Program incorporate use of the right turf, as well as low
maintenance landscaping and natural areas, and reduce the amounts of managed turf, water,
fertilizers, chemicals, fuels and other energy, equipment, equipment maintenance, and labor needed,
all producing long-term savings in operation and maintenance costs. These life-cycle cost savings
provide substantial financial benefits to land owners for the long term and command a premium on
sale.
Reduced risk The environmental stewardship practices incorporated in the Bronze Signature
Program cut the use of hazardous materials on site and the possibility of migration to water bodies
or off-site properties, reducing risk of harm and potential liability to any residents, members, visitors,
neighbors, or employees. Those reduced risks in turn lower insurance and workers' compensation
costs, potential for adverse regulatory action and harmful publicity, and lost worker time.
Environment and resource conservation and enhancement. Owners and managers of certified
Bronze Audubon Signature Sanctuary properties can take pride in doing their part to further
sustainable resource management and protect and preserve the environment for this and future
generations.
Costs
The current registration fee for the Bronze Signature Program is $12,500 (US Dollars). That amount
includes the first year $500 annual membership fee, which continues for subsequent years and is billed
near the month of initial registration.
In addition to the registration and annual membership fee, a member pays travel and related costs for
site visits by Signature Program staff. There are three site visits required for the Bronze Signature
Program. Expenses for these visits are not covered in the registration or membership fee.
Each Bronze member must produce a Natural Resource Management Plan (NRMP) to guide
management of the project from construction through post-construction management. It is the
responsibility of the member to find people who are qualified to write the different sections of the
NRMP. The costs incurred in acquiring the services of these people varies according to their availability.
It has been our experience that the cost for outside consultants to write the NRMP usually ranges
between $60,000 and $100,000.
Recertification site reviews are scheduled every two years to ensure that the quality at which the project
was certified is still being maintained. The cost of the visit is currently $800 per day plus expenses. One
day is usually sufficient for a recertification site audit.
Exhibit,
Page $ ( of HA
Program Fees for the Bronze Signature Program
(Typical Fees shown are for a Golf-Course-Only Project
Bronze Signature Program
Fee
Registration Fee for the Signature Program:
$12,500*
Cost for Site Visits
Includes 3 Site Visits by Director of Signature Program
Does NOT include travel & related expenses for site visits
(which are billed at no markup)
* Note. In the Bmn.Ze Program, the member is responsible far writing the Natural
Resource Management Plan or hires outside consultants to write it. The usual costs
for writing an NRMP ranges between $60,000 and $100,000.
PROGRAM COST
$12,500 + travel expenses
Fees for Bronze Signature Program after Initial Certification
Bi-annual Review and Audit:
$800 + travel expenses
Annual Member Fee:
$500
Exhibit (A
Page K7 of 11 q
0
uring the late. 19900. con-
Laminated groundwater
was thought to he the cul-
r Iprit, and pesticide use ern
golf courses a root cause.
4 So When []he SouClh-
ampron planning board
received an application to
develop an exclusive pri-
vate gull club, residents
and town of icials were
extremclY wary.
According to joe RdN,nor,
project manager for what
WOUld ultinhateh, become
the Bridge Coll Club, an-
other golfCOUrsc in the area
had a histor' ul~ problems Lvith groundwater
1301lu6011, and that nhcant "militant Opposi-
rion" to Bridge Golf Cauh's initial application
in 199!i.
But groundwater quality' wasn't the
commu-nity's only- concern: do was loss of
open Space, the number one environmental
concern lacing the town, says.leff tN.•lurpftree,
AICP, planning and development adminis-
trator for the town's Deparunent, of Land
klanagemenr.
The Brid,~r. Goil Cluh wa15 linalh~ sap-
proved in 1999. But first, the town took an
unusual step. As a condition of approval, it
mandated that the golf club become certi-
fied through Audubon International's Sig-
nature Pro,,ram.
Breast
" er
ls.~and
of New
e---,ion
ERI
The ltttluhtnn approach
Audubon International, a nonprofit environ-
mental organization headquartered in upstate
New York was c tatted in 1987. It is a:n inde-
pendent societ'i• ( not affiliated with National
Audubon) that fOCU5C5 oth natural 1-e5Ouree
protection.
The organization's Signauurc Program is a
"design for environment" certification pro-
gram~that works with developers- to inregrare
environmenralh sound practices into sac plan-
ning, construction, and long-terns manigw-
ment of a project, Golf courses happen to
constitute. the Vast majority, of the program's
membership, making certificat ion uhmcthing
of, an industry standard for em, ronmentallV
sensitive developments. For the llrid;fie, th<
Exhibit N
Page $ of UA
program olTered xn additional laver of oyer-
sight, which, according to \4111-phree, is cs-
actly what the town was looking tier.
Raynor tells a slightly diff'Crent story. Lur-
ing the mid and late '90s, the Bridge Goll-
(:luh, the town, and Audubon Irltl•rll:iLional
c•rnercd into a three-way conversation. "\\1c
said to the town, dit makcsa difference, wc-'re
pleased to participate in jAndubon's) pro-
gram." explains Raynor.
father wav. tltc beet remains that the Bridge
w.rs obliged to participate in ncc Audubon
Signature Program. The golf course 01111631I
opened for play in 2001. Today, the 512-acre
site inclucfcs a 281-afire golf course, 70 anent
devoted to 20 single-family residential lots.
And I -Sacre. that were ceded to the town as
(Numb hi
the town 1,/
Sourhlnlltunct
worried that
1l7e lfrid,r
Wl,ghl degrade
lordd uvwr
glealily. 1 hc•
rhrb it b+rrllcyd
clove to
/'erouir HT,
'Ild rill
dyuiJc'l•. l11taA
tlppyom'd 0111)'
<</ierGeyrle
rertificd ds
r
r fiwwd!y 1n the
egl'nDin MI,
pumanently protected open space. Warer qual-
ity is monitored by an independent consult-
attu. The Bridge is expected toachievcAndtibon
certification some time this year.
Southampton ha: continued it) use the
Audubon Signaanre Program as in em'iron-
mental standard for new golfcout:ses, rcquir-
tr1 anotlicr proposed cont-se to become urti-
f ied as yvel1.
Open spac-c has also gotten a hotist. 'The
town not only acgnircd I53 acres from the
Bridge GolfOnt). btu it adopted a commu-
nity preservation fiend that collects a two
percent tau on the balance of all ruts esnttc
transactions over $250,000. Those nion.ies go
direcilyv towards the purchase of land and
dcvefopnlrrrt right,, aimed m preserving open
space. Since it began in mid-1999, the fund
has collected more than 51 W million, taking
in anywhere from $900.000 to $4.5 million
per month. Ill turn. the town has financed
over S 162 million yvorth ofrcal eSCnC aceluisi-
tions-1 in all--acquiring mare tli:ut 2,0:30
acres of open spaw.
Whl slundurtl
\/lany planning bodies across the counrry
don't fully understand what is involved in
I~uildingagolfcourse,"says Nancy Riihardsan.
director of thin Audubmi Signature Program.
"They know that there are environmental
issues. BW what are AMC issues? Mint should
deal with them?-lla sets them oWkx&kg Or
someone to help, and we uatttrally pc.p up.'
To date, 23gaventmenrentities, licnnstate
agencies to county= and focal s;crvernments.
Iwvc required applicants to abide by the Sig-
nanire Program in one Conn oranother, whether
rhr•ough ordinanccs, amendments to land cle-
yelopmcnt regulations, resolutions, or condi-
tions of approval fur particular projects. The
projects are scattered around ncc U.S. from
Florida to Wyoming. Hawaii to New York.
The idea ofa local government requiring a
developer to participate in a program opcr-
ated by a private organization raises many
thorny legal questions; including the ctbyic,uS
one: Arc they allowed to ilo that? \4ost goy-
ernmentsand planninghodicsharvcsidestcpped
die issue by careful wording that requires a
proposed golf course to pirticipanr in the
Audubon Signature Program or to meet equiva-
g rlie dovr
lent environmental stanclnrds, Icavint
open for other possible paths to ncc same
environmental end.
RusselI Township. Ohio, iscutexample.'T-he
19-scinarc-mile township (pop. 5,600). located
cast of Ocvcland, also relies tin the Audubon
program. "Wdw been very imantal in pro-
tectingour namr;iI resources." says Grq,,SELltlerl.
Russell Township trustee mid chairman of the
zoning, ci~rttmission. "We were concerned that
normal golfcourse operations posed a porch.
tiai threat to ground and surlace water yualit}~.
We got into the issue and decided chat we
needed a regulation."
Exhibit_I,/\
Page ?'9 of _114
Some 4.4111111111 Ili Iivs .11.4. Illo1' m-ekill r **vll fill t.11-y-
greell prog-raIlls. Hy l'eper 131-o.4 ci
2(. }'Luuun •1~.,};u~i'h•(~iu.. lugl 'I)w,
Itt,itlvIhesi_nniurt I'ro~►ont
Auduhon International works with planners, archi-
tects. and matragers to ensure that rnyironmentaf
quality is nrrintainetl alter construction is contliletc.
The progrun oflers a "beyond compliance".ilil,ronih,
starting where minintunt cnvironntental ctuTapliall
leaves oft.
Certified members earn one of three designa-
tions: hrona.c, silver, or gold. Generally, such t.les-
igna(ions depend onthe construction stage at which
a project enters the proguirn, the overall complex-
it), of the project, and the level of Atachihon filter-
national ineolv.nu nt in I)Ianning, design. and over-
sight.
All Ivogram rncmhers must develop a natural re-
srn.ute man.lgc•nIt'll t plan, which addre•sscs six compo-
nents: site assc.ssincnt, wildlife ha i icu en lallLcInall
.uld management, waste n1anagancnt, energy effi-
ciency, water ytIality and conset•valion, and integrated
best naan.lgen,ent.
In addition. Attdtlhon International staffnicinhcrs
conduct several site visits duringetmstnfuhm rind an
ern site environmental audit upon completion ufthc
project. Depending on the level of participation,
An duhon International also conducts education pro-
granis:md pt•ovides project monitoring. All merithers
must maintain certification with periodic status r•l
ports and animal site audits by Audubon Interna-
tional staff.
Fees filr the Autiuhon Signature Program range
frcnn $9,500 its M2.500, which includes a one-time
registration Ice and the No year's S5111 membership
Ire. Progi-mm mcmhers also pay travel expenses filr
Audubon International site visitors, as well as for any
,additional contracted services that may he provided
fly tluduhon International.
%Wlature 14%mm staff rncmhers odinatc that fin
a silver level member inside the LI S., plannkgan 18-
hole golf course will cost approximately $35.000 for
the natural resource ntariagernent plan and related
cdtwatiunA services, plus another SS,000 f1w tmvcl
and other expenses. There is no additional cost to
achicvc ctrl i lk.t ital.
Initial expenses arc typically covered 1,v the project
developer mid later transferred to the long-terra prop-
erty owner or manager.
Readings. See "Greening Up tic Greens," August
19t)G P1,11ining. Snstahwble Gal/ C:uursr.~: A (;uid1• to
l itriraumertr,tl S'lrtr~rlr~/ship. by Ronald G. Dodson.
Wild onc. Another environmentally friendly golf resor[
is Rands ul I )unes, located on the Oregon eoa. t. -Fhe
resort's three courses arc built on rugged terrain, and golf
carts arc prohibired, Sec wwsv.handondune goH.com.
.Fhe progrttn. For enure on Audubon International,
see wititiv.auduhunitvcrna[icrnaLorg.
I'ht regulation, adopted as pan of a
1996 toning nm1frion, lays out a am.
prchensive set of cnvironmeutal gttidc-
lineshorrowcd from file standards (ifthe
Audubon Signamm Propaim And while
the regulation stops short of requiring
proposed golf courses rsi join dic• pro-
gram, it clots encourage developer, to
participate.
GulfcOlll'sc`J in Russell'I'ownship that
earn Audubon certification are not re-
quired to show the zonings htlard of NY
peals addirirnal Cvideliccof environmental
compliance. In contrast, golfcoutscs that
choose to Frocced independently must
provideextcnsivcd0cuInCl111,ion roshosv
Char thev are in comphancc Hit hoth
Au(iul)oii'scm-ironnieiital principics:utd
chi re; elation's other environmental to
gttimments, which address w=ildlifr and
habitat, water quality and conservation,
waste naanagetnc•nt, resourcc usc•, and
energy efficiency, among other f-.tctor:s.
bt fact, Russell Township had no golf
courses at the time it enacted the regula-
tion, and it still has none rod:w. [-.()cal
Icadcm have taken a proacuvc stance iii,
environmental issues in their conunu-
nity, however, and the township is pre-
pared should the issue cver arise.
114)tis ill, 10 IIu. ttlrt•ioll,
There are more than I 7,00O golf courses
in the U.S. today. I'lorida, with more
than 1.300, is home to mom golf courses
than all other stare. Sarasota (`minim,
on the (i 111C:oast, has 6S golfcourses in
a 620-square-mile area.
Such a profusion ul golfGOnr4eSWeighs
heavily on the minds of the county com-
missioners. "-Fhe)' arc concerned about
pesticide and water use and hahirat pro-
tcction," say. lint Die AK envommen-
tal specialist with doe county?:s Dqui-t-
mcnt of Re nIN Protection. Watcrquality
is a big, concern hccallse Florida's karst
landscape makes groundwater especially
vulnerable. More than 9t) pem nt of the
state's residents gcl rheir drinking water
bum one of several aquifers, including
the Floridian, Biscayne, and C:hokoloskec.
-We were putting numerous stipulations
on golf- courses It) address those issue...
Dierolfcalttin«es. " If we• were going to do
this every rime, why nor just have an nak
na icc that would contain A rhos. require-
nwim i hen weMould just saydwr you have
to he consistent with that ordinance."
Looking filr examples of a pwd golf'
course cnvironmemal program, CotinT of-
i icials discovered die Raptor Bay (MCIA)
in nc•arhy Lev County, the first rcsorf golf
course in the world certified by Audubon
International as a "gold signaturc sanau-
ary"--thc highest Ic•vc•I of compliance.
We felt that Audubotr International
crxu•scs rcallycpirrnnizcd the iypcofsaut-
dards that were appropriate for gulf
course's," says Dorothea lvsko, former
i ii; in:iger of:lvmnl rce p n n ctatot Ar Saraasot a
(Amnrv. - Fhat's when we decided to
Miele them as a nimmatc.'•
Sarasota C.:ount}'s ordinance passed in
October 2003, but not without contro-
versy. C:uunty commissioners tn'igirtally
warred to include existing golf courses.
Exhibit N
Page qo of
"it l?~rhtnr li,t)~ (';ol1'01ib iu ice, Counq, l'hnirhr, rhr littr~rnl ~hrlr~c~ lnunnd 11{~shnrc~~
/)1.11111) ?nl inta ll uwlel•qu'lligmid provide ttvldhf ,habitat,
Auu!j"an I'tnnoing A-,, I., I i,m
r.
r
'r
rctiluiriFig, ` grCen retrofits' through other Audubon
International programs. But that approach was
abandoned, and in the end, the ordinance ap-
plied only to nev golf course developments.
Likc Ohio's Russell Township, Sarasot-.l County
stopped shy of requiring certification by the
Audubon Signature Program. It die[. however,
require that golf courses be designett and man-
aged according to rile Audubon International
program or a similar certification program.
The Venctian Golf and River Caul,, owned
by WC1 Communities, Inc- (which ilko owns
Raptor Bay), is :a Sarasom County golf-course
that joined the Audubon Signature. Program
well before the c:ounrv ordinance. was enacted.
"W11a1 was once state of the are becomes rcgu..
l:nory. We're trying to do something that's
carting edge above and beyond what regula-
tions mandate, but %ve're all goint, for the Same
thing: to raise water quality standards and
make the golf course a more environmentally
friendly habitat," says Terrence Dolan, cnvi-
ronmentai director for WC.I ('onumuhitic~S.
I)tl or flit.
In Teton County, WN'Onting, economic suc-
cess depends on the quality of the natural
environment. Roug11107 percent ofthecounty's
4,008 square miles is public land, including
Grand `l'oon National Park, halfofYellowstone
National Park, the National L"Ik Refuge, much
(.it Bt idger-'Peron National Forest, :and several
%vilderness areas. Those immense natural anhcni-
tics drive as robust tourism economy.
Although Teron County has a permanent
population of just 18,000, summer tourism
attracts more than four million people. Win-
ter ski season logs over 400,000 skier days.
Randy Bosch, the county's interim pLut-
ning director, saes ncC county recognizes the
need to protect its tourism assets while also
preserving traditional ranches. He calls the
traclcolis ":t quid pro9uo conservation ethic,"
Recognizing that development and eco-
nomic pressures were driving lone;-term land-
owners off the land, 'I eton County began ui
use conservation easements and land trusts to
create continuous open space.
lit 1ggj,theSn:akcRiver Sporune, Club filed
:m application to build aft 18-hole golf course-
expectcd to open in 2006. G,ilf course supcrin-
tcndcnt Bill Shrum dcscrihcs this cnvironmen-
tallysc•nsitivcland,located 17milesfroinJac.son,
as "the last developable piece ofpropcrty bck,re
the Snakc Riverstarrs rumbling into white water
clown the canyou." The property and its inhnae-
diate surroundings are home to an elk migration
corridor, deer and moose habitat, and nesting
sites for four pairs of bald eagles.
With previous experience at. other Audubon
Signature courses, Shrum-who has been su-
perintendcnt since thebel'innin-0fthept'(-)ieCL-
proposcd to the county that his firm help to
write golf course regulations. Those regular
tions would he based on rile natural resource.
management plan camplcrcxl as part of any
Audubon Signature gtdfawrsc development.
"it ended up stalling it,,, for about it vcar
while the county wrote the regulations sae
suggested. So we kind ofshot ourselves in rile
foot," Shrum explains. "But do I regret it' No.
['d do it again..'
Shrum's commitment to the environment
ultimately appcitsed a broad spectrum of ini-
tial opponents, including the GreaterYellow-
stonc Coalition, Jackson Hole Conservation
Alliance, fishermen. river raf .crs, and the U.S.
Forest Service. "We all wanted the hest for the
land of this area " he notes.
With Audubon eer11ficali0n, the nets golf
course will d ifli: r faun tgpical golf-courses in it
number of ways. It will have more acres of-
protected wildlife habitat, use Icss warcr and
pesticides. and tC:uure an outreach progr: in
to cducatc Staffand club members. It will also
have Audubon oversight.
'flit, t•i-hi avail in -ti?
Should municipalities require devclopers to
loin rile Audubon Signature Program' Most
people s:n• no. "It is a voluntary program. and I
would like to see it remain that Nva\ " Say°s
Audubon's Nancy Richardson. "Instead, I would
like to sec senile rype of* irna•nrivcs from the
pL mting body liter projects that participate...
Sarasota C:ountv"s Dierolf .adds: "We al-
ways look fir inccilrives as opposed to retruia.
lii.nt. But occasionally, (developers arel either
nor going there fast enough, or there's im
environmental concern. so regu1ati0nsare writ=
ten to meet rhat goal.
\Vherher those regulations should. include
a private organization's tnvironntenctl cerri-
fication program or 1101 is it elutstion being
answered on a case-by-case hasis, but it's an
option more and more Iocales are cxplori ng as
a means to protect the local cnvir0riment in
the lace ofdevcluptnent pressures.
Shrum !rout Snake River sums it tip bcsr:
"Ifdcvelopnaent is goint, to happen. let's make
Sure it's done right."
Pet •r lin,nslti is a tieelance writer and the coordinator
of Audubrai Imernatic,nal's Susmiriable Communities
Prot;mm_
Exhibit /A
Page of -~L-
Naricla; Ulrl Collier (;u1((lub AJi) beneliud bl srrevrrrtlirrrrl r nnirr nnrenta/ rrrluirrnu rrtr adapted br Collier C;maity, lu Teton Counr}•, 11%laruting, theSnake 16ver•
Sportinrr ( .711b roiU upm a ;merle "Sadl rurvv nrar ),rar (ri rhrl, lair, e ,rtarrrhr, o f irpe-n spare 11,11•,• berry msrmed as nri nrltian rnrtidnrs fur elk, deer, and nlnnre.
V/
Q
iT
..".-O-regon
John A. Ki+zhaber, AD., Governor
CERT=D'1 A1L: Z 700 336 298
Department of Environmental Quality
Eastern Region Bend Office
2146 NE 4'h, Suite 104
Bend, OR 97701
(541).-,88-6146
FAX (541) 388-82283
April 2, 2001
Cline Butte Utility Company
P.O. Box 1215
Redmond, OR 97756
Re: NO VICE C>F i`l0r1CO'M;?LIA'CE
WQ-ERB-2001-6713
Tl.e Ridge at Eagle Crest - Eaale Crest H
WQ - Deschutes County
On March 24, 2001, there was a discharge of sewage to the ground surface in drainfield cell No.
1 in the Eagle Crest II system. We received notification of the spill from a resident that lives
near the drainf eld area and from the perinittee. A written report on the incident was received on
March 28, 2001.
Oregon Administrative Rule (OAR) 340-71-130(3) states that "discharge ofuntreated or partially
treated sewage or septic tar1k effluent directly or 'indirectly onto the ground surface or into public
water constitutes a public health hazard and is prohibited." The discharge of sewage onto the
around surface is also prohibited in Schedule A, Condition l.c., of your Water Pollution Control
Facilities Permit, No. 107204. It is very important to prevent the exposure of people to sewage
due to the risk of transmitting water borne diseases. Children are likely to be exposed to sewage
on the ground surface in a residential area because they are omen playing on the ground and may
be unaware of the danger.
Accordin; to the incident report a couple of small roc;cs became lodc'ed in the control valve for
cell No. 'I and kept it o+i, ciJSli+ wl "ch aiio led the ceii to becoine o'verioadGii. The surfacing
sewage problem was corrected within a couple of hours of notification by Cline Butt: Utility
Company. The problem with the centroi valve was fixed the next morning. We appreciate the
perrnittee's prompt response. v
We understand that the pressure sewer lines are flushed following construction to clear them of
debris. However there are still eccasicral incidents, such as the cre on March 24, 2001, where
debris in the pipe interferes ~x-ith control valve operation. Please review your procedures for
placing pressure sewer lines in service to see if there are any additional steps that could
reasonably be taken to assure that the lines are free of materials that could interfere with valve
operation.
(Over)
DEO•ucl
Exhibit M
Page _a2- of __I
too
The above violation is a Class U violation of your permit. Oregon Administrative Rule 340-12-
041(2)(c) provides that a pemlittee shall not receive more than three NONs for Class H violations of
the same permit within a thirty-sic (36) month period without being issued a more formal
enforcement action called a Notice of Permit Violation (NPV). The Department may, however,
issue a NPV prior to the third NON. The Department requests your cooperation in ensuring that this
violation does not recur.
Please contact Tom Hall in this of ce at 383-6146 ext. 233 if you have any questions regarding
this matter.
Sincerely,
Richard J. Nichols, Manager
Bend Water Quality Section
Eastern Region
RJN/tdli/mb
cc: Deschutes County Department of Environmental Health, Bend
Tom Walker, WS-,H Pacific, 920 SW Emkay, Suite C-100, Bend, OR 97702
~G3►
OEO-OCI
Exhibit N`i
Page 2 of 1 1
of,
F
Department of Environmental Quality
r
2146 NE 4th Street, Suite 104
Bend, OR 97,.701
John A. Kitzhaber, M.D., Governor
5 e (541) 388-6146
CERTIFIED MAIL #7000 0520 00121762 3264
April 6, 2001
Cline Butte Utility Company
P.O. Box 1215
Redmond, OR 97756
Eastern Region
Bend Office
RE: NOTICE OF NONCOMPLIANCE
ERB-01-6734
The Ridge at Eagle Crest - Eagle Crest II
WQ - Deschutes County
On April 5, 2001, about mid afternoon we observed evidence of a discharge of sewage to the
ground surface in one of the drainfield cells near Highway 126 in the Eagle Crest II system. The
soil was still saturated. It appeared that the incident had occurred within the last 24 hours prior
to our inspection.
Oregon Administrative Rule (OAR) 340-71-130(3) states that "discharge of untreated or partially
treated sewage or septic tank effluent directly or indirectly onto the ground surface or into public
water constitutes a public health hazard and is prohibited." The discharge of sewage onto the
ground surface is also prohibited in Schedule A, Condition I .c., of your Water Pollution Control
Facilities Permit, No. 107204. It is very important to prevent the exposure of people to sewage
due to the risk of transmitting water borne diseases. Children are likely to be exposed to sewage
on the ground surface in a residential area because they are often playing on the ground and may
be unaware of the danger.
We understand that all of the flow to the Eagle Crest H system had been diverted to the drainfield
cells near Highway 126 for several days prior to our visit to rest the drainfield cells near the
drainfield pump station. The additional load on that part of the system caused the failure. Even
so it appears that the current Eagle Crest II drainfield is being used near its maximum capacity
and this is with a significant portion of the Eagle Crest H flow being diverted to the Eagle Crest I
expansion drainfield.
Exhibit M
Page_9_~L of~~
Cline Butte Utility Company
April 6, 2001
Page 2
- a m
d
U
) T
Therefore by no later than April 27, 2001, please submit a plan and time schedule for reducing
the flow and/or implementing wastewater system improvements that will provide consistent
compliance with permit conditions. Also beginning by not later than April 14, 2001 please
provide weekend inspections of the drainfield areas to insure proper operation.
This is your second NON for a Class II violation of your permit. Oregon Administrative Rule 340-
12-041(2)(c) provides that a permittee shall not receive more than three NONs for Class II
violations of the same permit within a thirty-six (36) month period without being issued a Notice of
Permit Violation (NPV). If additional Class II violations occur, we will be referring these
violations to the Department's Enforcement Section for the issuance of an NPV. The NPV is a
formal enforcement action that requires you to submit one of the following, within five working
days of its receipt: (1) a certification of full compliance with all permit conditions; or (2) a detailed
plan and time schedule demonstrating what steps will be taken to gain compliance, together with
interim measures taken to reduce the impact of the violations, and a statement that the permittee has
reviewed all of the conditions and limitations of the permit and is in compliance with all other
provisions.
Please contact Tom Hall in this office at 388-6146 ext. 233 if you have any questions regarding
this matter.
Sincerely,
RicharcVJ. Nichols, Manager
Bend Water Quality Section
Eastern Region
cc: Robin Bennett, 486 Nutcracker Drive, Redmond, OR 97756
Deschutes County Department of Environmental Health, Bend
Tom Walker, W&H pacific, 920 SW Emkay, Suite C-100, Bend, OR 97702
Exhibit IVN
Page q S of A
..spry
re on
g
John A. Ki¢haber. M.D.. Govemor
CERTIFIED MAIL Z 700 336 303
May 17, 2001
Cline Butte Utility Company
P.O. Box 1215
Redmond, OR 97756
Dep_, cment of Environmental Quality
Eastern Region Bend Office
2146 NE 4", Suite 104
Bend, OR 97701
(541)388-6146
FAX (541) 388-8283
Re: NOTICE OF NONCOMPLIANCE
WQ-ERB-2001-7059
The Ridge at Eagle Crest - Eagle Crest H
Deschutes County
On the evening of May 10, 2001, there was a discharge of sewage to the ground surface from a
drainfield system serving the Eagle Crest II development. The failure was limited to single
drainfield cell in the drainfield located adjacent to Highway 126. At the time I inspected the
drainfield (about 6:45 AM, Friday, May 11, 2001), all liquid had seeped or evaporated away
leaving only damp soil to indicate the failure. There was at least one hole in the soil over the cell
where effluent had discharged on to the ground from the system.
Oregon Administrative Rule (OAR) 340-71-130(3) states that "discharge of untreated or partially
treated sewage or septic tank effluent directly or indirectly onto the ground surface or into public
water constitutes a public hedlth hazard and is prohibited." The discharge of sewage onto the.
ground surface is also prohibited in Schedule A, Condition l.c., of your Water Pollution Control
Facilities Permit, No. 107204. It is very important to prevent the exposure of people to sewage
due to the risk of transmitting water borne diseases. Children are likely to be exposed to sewage
on the ground surface in a residential area because they are often playing on the ground and may
be unaware of the danger.
According to a phone conversation with Mr. Ric Kuss on Friday, May 11, 2001, your Utility
thoroughly examined the system and could find no apparent reason for the failure. All valves
were taken apart, examined and found to be in working condition. Screens had been installed to
prevent rocks from blocking the closure of the valves so past problems with valves being
obstructed with rocks was not a potential cause.
The above violation is a Class II violation of your permit and this is the third NON to be issued to
you this year.
(Over)
DECZCI
Exhibit M
Page 9 ~P of
1 ,
The Department has your written submittal of April 27, 2001, outlining the steps you propose to
prevent failing drainfields. We also have your request to enter into a Mutual Agreement and
Order (MAO) which was included with the April 27, 2001, submittal. I have asked staff to begin
drafting this MAO and should be able to discuss its provisions within a week or so, perhaps
sooner. An MAO, as you know, would be a bilateral agreement between your Utility and our
Agency that documents a course of action to resolve compliance issues. The MAO would
include stipulated penalties should you violate conditions of the MAO.
This NON has been issued in accordance with an established enforcement process established in
administrative rule. Its issuance, however, should not be construed to mean that Eagle Crest and
your Utility have been uncooperative or resistant to addressing these sewage issues. You have
done a lot of work as identified in a status report submitted to me today. We also recognize that
some of the problems defy a logical cause. And we note that there may some reason to believe
that vandalism may be a factor in some of the problems.
Please contact Tom Hall in this office at 388-6146 ext. 233 if you have any questions regarding
this matter.
Sincerely,
Richard
,Y.Nichols, Manager
Bend Water Quality Section
Eastern Region
RJN/mb
cc: Deschutes County Department of Environmental Health, Bend
Tom Walker, W&H Pacific, 920 SW Emkay, Suite C-100, Bend, OR 97702
Greg Lynch
Joni Hammond - ER Administrator
40s~I
?Z.4
OErLX-I
Exhibit M
Page q rJ of IA--
...'D
■
M oNd
o
CITY OF REDMOND
z Public Works Department
Wastewater Division
4000 NW Pershall Way
PO Box 726
Redmond, OR 97756-0100
(541) 504-5075
Fax: (541) 923-4059
info@ci.redmond.or.us
Wastewater Pretreatment Survey
Please have a qualified representative from your facility complete this survey and return it
to the below address by January 2, 2006. If you need help completing the survey contact
Chris Miccolis, City of Redmond Pretreatment Specialist at 541-504-5076.
Wastewater Division
Attn: Chris Miccolis
PO Box 726
Redmond, OR 97756
1. 2.
(Company Name)
3.
(Redmond Business License Number)
(Facility Name)
4.
(Facility Address, Street)
- (City) (State) (Zip Code)
5.
(Mailing Address, Street/PO Box)
(City) (State) (Zip Code)
6. Provide the name of the person to contact regarding information contained in this
questionnaire:
(Naisie)
(Title)
(Phone)
(e-mail)
Page 1 of 8
(Fax)
Exhibit NI
Page of~~
7. Is this facility a categorical industry as defined under federal regulation 40 CFR Part 403?
Check the list below for categorical industries or look at DEQ's pretreatment website
http://www.dN.state.or.us/wq/pretreatment for help making this determination.
Yes [ ] No [ ] Unknown [ ]
If yes, check all categories that describe the business activities conducted at your facility from the
list below
DAIRY PRODUCTS PROCESSING
[ ] GRAIN MILLS
[ ] CANNED AND PRESERVED
FRUITS AND VEGETABLES
PROCESSING
[ ] CANNED AND PRESERVED
SEAFOOD PROCESSING
[ ] SUGAR PROCESSING
[ ] TEXTILE MILLS
[ ] CEMENT MANUFACTURING
CONCENTRATED ANIMAL
FEEDING OPERATIONS (CAFO)
[ ] ELECTROPLATING
[ ] ORGANIC CHEMICALS,
PLASTICS, AND SYNTHETIC
FIBERS MANUFACTURING
[ ] INORGANIC CHEMICALS
MANUFACTURING
[ ] SOAP AND DETERGENT
MANUFACTURING
[ ] FERTILIZER MANUFACTURING
[ ] PETROLEUM REFINING
[ ] IRON AND STEEL
MANUFACTURING
[ ] NONFERROUS METALS
MANUFACTURING
[ ] PHOSPHATE MANUFACTURING
[ ] STEAM ELECTRIC POWER
GENERATING
[ ] FERROALLOY
MANUFACTURING
[ ] LEATHER TANNING AND
FINISHING
[ ] GLASS MANUFACTURING
[ ] ASBESTOS MANUFACTURING
[ ] RUBBER MANUFACTURING
[ ] TIMBER PRODUCTS
PROCESSING
[ ] THE PULP, PAPER, AND
PAPERBOARD
[ ] MEAT AND POULTRY
PRODUCTS
[ ] METAL FINISHING
[ ] COAL MINING
[ ] OIL AND GAS EXTRACTION
[ ] MINERAL MINING AND
PROCESSING
[ ] THE CENTRALIZED WASTE
TREATMENT
[ ] METAL PRODUCTS AND
MACHINERY
[ ] PHARMACEUTICAL
MANUFACTURING
[ ] ORE MINING AND DRESSING
[ ] TRANSPORTATION EQUIPMENT
CLEANING
] PAVING AND ROOFING
MATERIALS (TARS AND
ASPHALT)
[ ] WASTE COMBUSTORS
[ ] LANDFILLS
[ ] PAINT FORMULATING
[ ] INK FORMULATING
8. If you answered "yes" or "unknown" question 7, does your categorical industry discharge to
City of Redmond sewer?
Yes [ ] No [ ] Unknown [ ]
Page 2 of 8
Exhibit 1'A
Page 9 of ~ N
9. a) Enter applicable facility SIC (Standard Industrial Classification) code(s):
Or
NAICS (North American Industry Classification System) code(s):
See http://www.ceiisus.gov/epcd/www/naics.fitml to find these codes for your facility.
b) Enter the number of shifts operating at the facility daily:
Enter total number of employees working at facility:
Enter total number of manufacturing units produced monthly
c) Circle the days of operation:
d) Enter hours of ;operation:
Sun Mon Tue Wed Thu Fri Sat
e) Provide a brief description of the activities that occur at this facility. Include all
manufacturing, products and/or services provided.
10. Is this facility connected to the City of Redmond's sanitary sewer system?
Yes [ ] No [ ] Unknown [ ]
a) If No, how is the wastewater disposed of?
11. Does this facility receive water or sewer billing statements from the City of Redmond?
Yes[] No[]
a) If Yes, list the facility's account number(s). If there are more than three, list the three
with the highest volume of water usage.
I.Acct#: 2.Acct# 3.Acct.#
b) If No, list the water source for this facility and the average monthly usage, in gallons
per month.
Water source:
Volume:
c) Is/was there a water well on site for potable or irrigation? Yes [ ] No [ ] Unknown [ ]
If Yes, what type: Potable [ ] Irrigation [ ]
If Yes, is the well: active [ ] inactive [ ] decommissioned [ ]
Page 3 of 8
Exhibit M
Page /dO of , I t A
12. Do you use EPA Toxics Release Inventory (TRI) reportable chemicals in reportable
quantities? See the EPA website at http://www.epa. rod v/tri/ for more information.
Yes [ ] No [ ] Unknown [ ]
Please list those chemicals.
13. Are you required to fill out an Oregon State Fire Marshal report for any hazardous materials
used at your facility? See the State Fire Marshal website for more information at
littp://e *o~ v.ore on.gov/OOHS/SFM/
Yes [ ] No [ ] Unknown [ ]
Please list materials reported and their use at your site.
14. Does your facility generate any industrial (non-domestic) wastewater streams? Yes [ ] No [ ]
a) If Yes, please describe this wastewater. [ ] boiler blowdown
[ ] noncontact cooling water [ ] process water [ ] remediation water
[ ] cooling tower blowdown [ ] wash water (vehicle, equipment, etc.)
[ ] other (please describe)
b) Is the wastewater described in 14(a) discharged to the Redmond sewer system?
Yes [ ] No [ ] Unknown [ ]
Volume Estimate for each (monthly gallons):
Page 4 of 8
Exhibit
Page /o/ of _ 1 I /A
15. Do you store any materials or products outdoors (i.e., chemicals, equipment, tanks, drums,
barrels, etc)? Yes [ ] No [ ]
If Yes, briefly describe the products and related activities:
16. Indicate where the following systems drain:
System
Sanitary
Storm sewer
URC-
N/A
Other (Where does this
Unknown
sewer
(drywell)
system discharge?)
drill hole)
Interior floor
drains
Parking lot
runoff
Roof drains
Outdoor
storage area(s)
Fueling
areas
Washing
area s
Maintenance
area(s
Transfer
area(s)
17. Do you service any vehicles or equipment at this facility? Yes [ ] No [ ]
If Yes: a.) Is this performed indoors or outdoors?
b) Where does the service area and service waste drain?:
Redmond sanitary sewer [ ] Dry well [ ] Storm sewer [ ]
100% Recycled [ ] Collected for off-site disposal [ ]
Other (specify):
18. Do you wash or clean any vehicles or equipment at this facility?
Yes [ ] No [ ]
a) Please describe the equipment and vehicles being washed and any cleaning chemicals
used.
b) Does the wash water from 18(a) water drain to:
Redmond sanitary sewer [ ] Dry well [ ] Storm sewer [ ]
100% Recycled [ ] Collected for off-site disposal [ ]
Other (specify):
Page 5 of 8
Exhibit
Page /OZ of 11k
19. Does this facility have an oil/water separator or a grease trap on the wastewater discharge
line?
Yes[] No[]
a) If Yes, does the oil/water separator or grease trap discharge to:
Redmond sanitary sewer [ ] Storm sewer [ ] Don't know [ ]
How often is this grease trap/separator serviced and/or cleaned out?
What company do you contract with for this service?
Please attach records from (2004- present) for this service.
20. Does the facility have a garbage disposal or grinder which discharges material into the
sanitary sewer?
Yes[] No[]
If Yes, please list the number of garbage disposals and describe the material disposed
with this grinder.
21. Do you generate Hazardous Waste as defined by Oregon DEQ and federal regulations
(RCRA)? See .http://www.deg.state.or.us/winc/hw/.tactslieets/11owDetermineHazWaste.pdf for
help. If you answer yes please fill out the hazardous waste questionnaire attached for all
generated waste streams
Yes[] No[]
22. Has your facility claimed the sanitary sewer discharge exemption under RCRA (40 CFR 240-
299 ) federal regulations? See http://www.epa.gov/rcraonline/ for help.
Yes[] No[]
a) If yes, when did your facility first file for this exemption?
Describe the wastewater streams that are exempt.
Page 6 of 8
Exhibit
Page /03 of I I
23. Certification Statement
This statement must be signed by the executive facility official knowledgeable of the
survey contents.
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to ensure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons directly responsible for gathering the information, the information submitted is, to the
best of my knowledge and belief, true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations. X40 CFR 403.6(a)(2)(ii)J
(Pri
name here{ (Title)
ii-
-1(gignatur0
(Date)
(Phone)
We thank you in advance for your cooperation and participation in this DEQ mandated
pretreatment survey. Photocopy the completed survey form for your records and return
the original survey to:
City of Redmond
Wastewater Division
Attn: Chris Miccolis
P.O. Box 726
Redmond, OR 97756
Page 7 of 8
Exhibit M
Page 1 O S of 11 4
HAZARDOUS WASTE INFORMATION QUESTIONNAIRE
(Please use additional sheets if necessary)
1. What is your current generator status?
[ ] Small Quantity Generator [ ] Large Quantity Generator
[ ] Conditionally Exempt Generator [ ] Don't know
2. What is your EPA/DEQ Generator ID number?:
Fill in the table below for each regulated waste stream generated by your facility or attach a copy
of your 2004 DEQ Hazardous Waste report
Table 1: Hazardous Waste Streams Generated
Wasic
stream
Description
of,Wa'ste
1-Tazardous
Waste
Code
Is this waste
treated on
site?,
Describe ?
treatment.
' How
much
waste was
generated
in 2004?
How is this
waste
disposed?
Is waste
discharged-
in batch or `
continuous
manlier?
1
2
3
4
For each waste stream listed in Table 1 please fill out the hazardous constituent infonnation in
Table 2.
Table 2: Hazardous Constituent Information:
Waste
stream #
(from
,,=Tab1e 1
Name of
Constituent
Largest total mass
waste generated
during «month in
20041
Total mass
waste '
generated in
2004
Projected."
mass
generated
ini 2005
Average'
concentration in
waste stream w,
2004
Page 8 of 8
Exhibit DA
Page _ / 04 of I l
DEPT. OF ENVIRONMENTAL QUALITY-340-055
OREGON S'LCHE(AIRY 01• SW E
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HOME
MARCH
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Page 1 of 9
The Oregon Administrative Rules contain OARS filed through November 15, 2005
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION 55
REGULATIONS PERTAINING TO THE USE OF RECLAIMED WATER (TREATED
EFFLUENT) FROM
SEWAGE TREATMENT PLANTS
340-055-0005
Purpose
The purpose of these rules is to protect the environment and public health in Oregon by prescribing the
methods, procedures and restrictions required for the use for beneficial purposes of reclaimed waters.
Stat. Auth.: ORS 468.020, ORS 468.705 & ORS 468.710
Stats. Implemented: ORS 46813.015 & ORS 46813.020
Hist.: DEQ 32-1990, f. & cert. ef. 8-15-90
340-055-0007
Policy
It is the policy of the Environmental Quality Commission to encourage the use of reclaimed waters for
beneficial purposes using methods that assure that the health of Oregonians and the environment of the
state are protected. Proper use of reclaimed waters for beneficial purposes enhances water quality by
reducing discharges of treated effluents to surface waters and by conserving stream flows through
reduced demand for withdrawals for out-of-stream use.
Stat. Auth.: ORS 468.020, ORS 468.705 & ORS 468.710
Stats. Implemented: ORS 46813.015
http://arcweb.sos.state.or.us/rules/OARs 300/OAR 340/340_055.htm1 12/19/2005
Exhibit N\
Page l0(0 of i lA
DEPT. OF ENVIRONMENTAL QUALITY-340-055 Page 2 of 9
I-Est.: DEQ 32-1990, f. & cert. ef. 8-15-90
340-055-0010
Definitions
(1) "Sewage" means water-carried human wastes, including kitchen, bath and laundry waste from
residences, buildings, industrial and commercial establishments, or other places, together with such
groundwater infiltration, surface waters, or industrial wastewater as may be present.
(2) "Industrial Wastewater" means any liquid, gaseous, radioactive, or solid waste substance or a
combination thereof resulting from any process of industry, manufacturing, trade, or business, or from
the development or recovery of any natural resources.
(3) "Sewage Treatment System" means any facility or equipment used to alter the quality of sewage by
physical, chemical or biological means or a combination thereof such that the tendency of said
wastewater to cause any degradation in water quality or other environmental conditions is reduced.
(4) "Sewage Treatment System Owner" is any person who owns a sewage treatment system that
provides reclaimed water for use.
(5) "Person" means the United States and agencies thereof, any state, any individual, public or private
corporation, political subdivision, governmental agency, municipality, copartnership, association, firm,
trust estate, or any other legal entity whatever.
(6) "NPDES Permit" means a waste discharge permit as defined in Oregon Administrative Rules
Chapter 340, Division 45.
(7) "WPCF Permit" means a Water Pollution Control Facilities permit as defined in OAR Chapter 340,
Division 45.
(8) "Reclaimed Water" means treated effluent from a sewage treatment system which, as a result of
treatment, is suitable for a direct beneficial purpose or a controlled use that could not otherwise occur.
(9) "User" means any person who uses reclaimed water.
(10) "Oxidized Wastewater" means treated sewage in which the organic matter has been stabilized, is
nonputrescible, and contains dissolved oxygen.
(11) "Biological Treatment" means methods of sewage treatment in which bacterial or biochemical
action is promoted as a means of producing an oxidized wastewater.
(12) "Clarification" means the removal by gravity of settleable solids remaining in the effluent after the
biological treatment or after flocculation as part of the coagulation process.
(13) "Coagulation" means a treatment process applied to oxidized wastewater in which colloidal and
finely divided suspended matter have been destabilized and agglomerated by the addition of suitable
floc-forming chemicals or by an equally effective method.
http://arcweb. sos. state. or. us/rules/OARs-3 00/OAR340/34005 5.html 12/19/2005
Exhibit Iv\
Page t a `7 of I l
DEPT. OF ENVIRONMENTAL QUALITY-340-055 Page 3 of 9
(14) "Filtration" means a treatment process applied to oxidized, coagulated, clarified wastewater which
has been passed through natural undisturbed soils or filter media, such as sand or diatomaceous earth, so
that the turbidity as determined by an approved laboratory method does not exceed an average operating
turbidity of 2 turbidity units and does not exceed 5 turbidity units more than 5 percent of the time during
any 24-hour period.
(15) "Disinfection" means a treatment process in which the pathogenic organisms have been destroyed
or reduced to very low levels by chemical, physical or biological means. Disinfection is deemed to have
occurred when total coliform and (where appropriate) turbidity limitations have been continuously met
for the specific uses cited in Table 1.
(16) "Beneficial Purposes" means a purpose where the resource values of the reclaimed waters, such as
but not limited to its nutrient or moisture value, are utilized for enhanced productivity or water
conservation by the user.
(17) "Restricted Impoundment" means a body of reclaimed water in which recreation is limited to
fishing, boating, and other non-body-contact water recreation activities. Restricted impoundments
constructed and operated pursuant to these rules shall be considered part of a sewage treatment system
and not waters of the state for water quality purposes.
(18) "Nonrestricted Impoundment" means a body of reclaimed water in which no limitations are
imposed on body-contact water recreation activities. Nonrestricted impoundments constructed and
operated pursuant to these rules shall be considered part of a sewage treatment system and not waters of
the state for water quality purposes.
(19) "Landscape Impoundment" is a body of reclaimed water which is used for aesthetic enjoyment or
which otherwise serves a function not intended to include public contact through such activities as
boating, fishing, or body-contact recreation. Landscape impoundments constructed and operated
pursuant to these rules shall be considered part of a sewage treatment system and not waters of the state
for water quality purposes.
(20) "Potable Water Supply System" means a water supply system used to provide water for human
consumption.
(21) "Controlled Use" means a use of reclaimed water for which the sewage treatment plant owner,
either directly or through a written contract, has reasonable knowledge of the use and fate of the
reclaimed water and is able to discontinue the use of the reclaimed water if it is determined that the
requirements of the rules and the permit authorizing use of reclaimed water are not being met.
(22) "Processed Food Crops" means those crops which undergo thermoprocessing sufficient to kill
spores of Clostridium botulinum. Washing, pickling, fermenting, milling or chemical treatments are not
sufficient.
[ED. NOTE: The Table(s) referenced in this rule is not printed in the OAR Compilation. Copies are
available from the agency.]
Stat. Auth.: ORS 468.020, ORS 468.705 & ORS 468.710
Stats. Implemented: ORS 468B.005, ORS 468B.030 & ORS 468B.050
Hist.: DEQ 32-1990, f & cert. ef. 8-15-90
http://arcweb.sos.state.or.us/rules/OARs 300/OAR 340/340 055.html 12/19/2005
Exhibit fv~
Page 10 9 of
DEPT. OF ENVIRONMENTAL QUALITY-340-055 Page 4 of 9
340-055-0013
Exemptions
Reclaimed water used at the treatment plant site where it is generated shall be exempt from these rules
provided:
(1) The reclaimed water that is used is disinfected, oxidized wastewater, and
(2) Reclaimed water that is used for landscape irrigation shall be confined to the treatment plant site. No
spray or drill shall be allowed off the treatment plant site. The treatment plant site shall not include
property that is not contiguous to the parcel of land upon which the treatment plant is located.
Stat. Auth.: ORS 468.020, ORS 468.705 & CRS 468.710
Stats. Implemented: ORS 468B.050
Hist.: DEQ 32-1990, f. & cert. ef. 8-15-90
340-055-0015
General Requirements for Use of Reclaimed Water
(1) No sewage treatment system owner shall release any reclaimed water for use unless so authorized by
a WPCF or NPDES permit issued by the Department. Any application for a WPCF or NPDES permit
that proposes to use reclaimed water shall provide sufficient information as necessary to evaluate and
determine compliance with this Division.
(2) Except for use of reclaimed water already authorized by permit by the Department, no sewage
treatment system owner shall release any reclaimed water for use until a reclaimed water use plan
meeting the requirements of OAR 340-055-0025 has been approved in writing by the Department.
Before approving any plan, the Department shall submit the proposed plan to the Health Division for
comment. For uses of reclaimed water already permitted, but for which no reclaimed water use plan has
been approved, the sewage treatment system owner shall submit a reclaimed water use plan to the
Department when requested in writing by the Department.
(3) Where the rules of this Division require limitations and conditions that are different or more stringent
than conditions in existing permits, the existing permit limitations and conditions shall control until such
time as the Department chooses to change the permit limitations and conditions through permit
modification or renewal. When the Department does choose to change existing permit limitations and
conditions to conform to these rules, the permittee shall be given a reasonable compliance schedule for
achieving more stringent requirements. The compliance schedule shall be inserted in the permit at the
time the permit is renewed or modified.
(4) Reclaimed water from sewage treatment systems used for agricultural and nonagricultural uses listed
in Table 1 of this Division shall comply with the associated effluent quality limitations and the
treatment, monitoring and other requirements for that use that are stated in Table 1:
http://arcweb.sos.state.or.us/rules/OARs 300/OAR-340/340-055.html 12/19/2005
Exhibit-_Yy\
Page 109of
DEPT. OF ENVIRONMENTAL QUALITY-340-055 Page 5 of 9
(a) Where Table 1, for specified uses, requires that reclaimed water receive biological, coagulation,
clarification, filtration treatment plus disinfection, the Department will consider treatment processes that
do not utilize coagulation provided that equivalent effluent quality to that achieved with coagulation can
be demonstrated. The Department shall consult with the Oregon Health Division when considering
alternative treatment processes allowed for under this section;
(b) The Department may include additional permit effluent limitations and/or other permit conditions
other than those required by Table 1 if it determines or has reason to believe that the reclaimed water
may contain physical or chemical contaminants that would impose potential hazards to public health or
the environment or cause detrimental effects on an allowed use;
(c) In cases where chlorine or chlorine compounds are used as the disinfecting agent, the Department
may specify in the permit a minimum chlorine residual concentration to be met after a minimum contact
time. In cases where other disinfecting agents are used, the Department may require other additional
monitoring requirements that will assure adequate disinfection. The Department may consult with the
Health Division before allowing disinfection agents other than chlorine or chlorine compounds;
(d)(A) The Department may reduce the buffer distances required in Table 1 if it determines that
alternative controls as specified in the permit will adequately protect public health and the environment.
Alternative controls may be, but are not limited to, valves that are activated by wind speed or direction,
low trajectory sprinklers or remoteness of the site to incompatible uses;
(B) Buffers for uses in Table 1 for Level I effluent shall be specified in the permit and shall be based on
a determination that aerosols will be adequately controlled so as to protect public health;
(C) The Department may consult with the Health Division before establishing buffer distances other
than those specifically cited in Table 1.
(5) Reclaimed water from sewage treatment systems shall be considered adequately treated and
disinfected if, at the end of the treatment process, the bacterial and turbidity limitations for the use of
reclaimed water as specified in Table 1 are met. The sampling point for monitoring compliance with
water quality limitations shall be specified in the permit.
(6) By permit, reclaimed water for a use not specified in Table 1 may be authorized. In considering such
authorization, the Department may request information and shall impose such effluent limitations as
deemed necessary to assure protection of public health and the environment. Before the Department
shall authorize uses of reclaimed water under this section of the rule, written concurrence from the
Oregon Health Division shall be obtained.
(7) A person using reclaimed water from a sewage treatment system may provide additional treatment
for a more restrictive reuse as allowed under Table 1 of this Division. Under such conditions, the
sewage treatment system owner providing the additional treatment is subject to the same requirements as
other sewage treatment system owners releasing wastewater for reuse and its owner shall have a WPCF
or NPDES permit issued by the Department.
(8) The Department may consider the effects of blending reclaimed water with other waters if proposed
by the owner of a sewage treatment system. In cases where blending of reclaimed water is provided, the
sewage treatment system owner shall submit to the Department, at a minimum, a plan of operation, a
description of any additional treatment process, blending volumes, and a range of final quality at the
point of use. Reclaimed water receiving less than secondary treatment and disinfection shall not be
http://arcweb.sos.state.or.us/rules/OARs 300/OAR 340/340 055.html 12/19/2005
Exhibit M
Page I 1 O of J AZ
DEPT. OF ENVIRONMENTAL- QUALITY-340-055 Page 6 of 9
blended for uses requiring a higher level of treatment and disinfection.
(9) The sewage treatment system owner shall be solely responsible and liable to the Department for
meeting the requirements of these rules and the sewage treatment system owner's permit for any and all
water that passes through the owner's treatment plant. Any reclaimed water released for use on property
not under the direct control of the sewage treatment system owner shall be allowed only if there is a
legally enforceable contract between the treatment plant owner and the user. The contract shall set forth
as a minimum:
(a) The quality and maximum quantity of wastewater to be released for use by the sewage treatment
system;
(b) The specific use(s) for which the reclaimed water will be used by the user;
(c) The maximum quantity of reclaimed water that shall be used on an annual basis;
(d) A condition that the direct release of any reclaimed water to surface waters of the State of Oregon
shall be prohibited;
(e) A statement specifying the parties in the contract responsible for compliance with these rules and -the
sewage treatment system permit;
(f) A provision allowing the sewage treatment system owner to cease providing reclaimed water if the
Department or the owner determine that the requirements of this Division are not being met;
(g) A condition that requires the user of reclaimed water to report to the sewage treatment plant owner
any and all violations of the terms of these rules or the contract.
(10) In cases where reclaimed water is transferred from one user to another, each succession of
ownership of the reclaimed water shall be governed by a legally enforceable contract on file with the
owner of the sewage treatment system and which notifies the succeeding reclaimed water user of the
requirements of this Division and the permit for the sewage treatment system. The contract shall also
require the succeeding user to so contract with any additional succeeding reclaimed water users.
(11) The use of reclaimed water from a sewage treatment system for direct human consumption,
regardless of the level of treatment, is prohibited unless, after public hearing and with the written
concurrence of the Oregon Health Division, it is so authorized by the Environmental Quality
Commission.
(12) The monitoring requirements specified in any permit that authorizes use of reclaimed water shall(, at
a minimum, meet the requirements listed in Table 1 of this Division. Effluent and other data required by
a permit authorizing use of reclaimed water from sewage treatment plants shall be submitted to the
Department each month.
(13) A permit authorizing use of reclaimed water from sewage treatment plants shall require reporting of
noncompliance with this Division and the sewage treatment system owner's permit within 24 hours of
when the permittee becomes aware of an incident of noncompliance. If the permittee becomes aware of
the incident of noncompliance when the Department is not open, the incident shall be reported to
Oregon Emergency Response System (Telephone Number 1-800-452-3011).
http://arcweb.sos.state.or.us/rules/OARs 300/OAR 340/340 055.html 12/19/2.005
Exhibit hA
Page I I I of
DEPT. OF ENVIRONMENTAL QUALITY-340-055
Page 7 of 9
[ED. NOTE: The Table(s) referenced in this rule is not printed in the OAR Compilation. Copies are
available from the agency.]
Stat. Auth.: OR q 469.020, nR q 469.705 & nR q 469.710
Stats. Implemented: ORS 468B.030 & ORS 468B.050
Est.: DEQ 32-1990, f. & cert. ef. 8-15-90
340-055-0020
Groundwater Protection Requirements
No reclaimed water shall be authorized for use unless all requirements for groundwater protection
established in OAR Chapter 340, Division 40 are satisfied. OAR Chapter 340, Division 40 shall be
considered satisfied by the Department if the sewage treatment system owner demonstrates that
reclaimed water will not be used in a manner or applied at rates that cause contaminants to be leached
into the groundwater in quantities that will adversely affect groundwater quality.
Stat. Auth.: ORS 468.020, ORS 468.705 & ORS 468.710
Stats. Implemented: ORS 468B.150 - ORS 468B.190
Est.: DEQ 32-1990, f. & cert. ef. 8-15-90
340-055-0025
Reclaimed Water Use Plan
Reclaimed water use plans shall demonstrate how the sewage treatment system owner will comply with
these rules and shall meet the following minimum requirements:
(1) The plan shall contain a description of the design of the proposed reclamation system and shall
clearly indicate the means for compliance with these regulations.
(2) No reclaimed water use plan submittal shall be deemed complete for review by the Department
unless the submittal includes three complete copies of the proposed plan.
Stat. Auth.: ORS 468.020, ORS 468.705 & ORS 468.710
Stats. Implemented: ORS 468B.030 & ORS 4688.050
Hist.: DEQ 32-1990, f. & cert. ef. 8-15-90
340-055-0030
Other Requirements for Use of Reclaimed Water
(1) No bypassing shall be allowed of untreated or inad-equately treated water from the sewage treatment
system or from any intermediate unit processes to the point of use.
http://arcweb.sos.state.or.us/rules/OARs 300/OAR 340/340 055.html 12/19/2005
Exhibit M
Page 112 of II
DEPT. OF ENVIRONMENTAL QUALITY 340_055 Page 8 of 9
(2) Alarm devices shall be provided as necessary to provide warning of loss of power and/or failure of
process equipment essential to the proper operation of the sewage treatment system and to compliance
with this Division.
(3) Unless otherwise approved in writing by the Department, sewage treatment systems providing
reclaimed water for use shall have standby power facilities of sufficient capacity to fully operate all
essential treatment processes. The Department may grant an exception to this section only if the sewage
treatment system owner demonstrates that power failure will not result in inadequately treated water
being released for use and will not result in any violation of an NPDES or WPCF permit limit or
condition or Oregon Administrative Rule.
(4) Sewage treatment systems that provide reclaimed water for use shall contain sufficient level of
redundant treatment facilities and monitoring equipment to effectively prevent inadequately treated
water from being used or discharged to public waters.
(5) Unless otherwise approved in writing by the Department, all piping, valves, and other portions of the
reclaimed water use system shall be constructed and marked in a manner to prevent cross-connection
with potable water systems. Unless otherwise approved in writing by the Department, construction and
marking shall be consistent with sections (2), (3), (4), and (5) of the Final Draft of the "Guidelines Iror
Distribution of Nonpotable Water" of the California-Nevada Section of the American Water
Works Association, as revised September 14, 1983. The Department may allow exceptions for existing
systems in rural areas where it can be demonstrated that both private and public domestic water systems
are more than 100 feet from any component of the system using reclaimed water.
(6) There shall be no connection between any potable water supply system and the distribution system
carrying reclaimed water unless the connection is through either an unrestricted air gap at least twice as
wide as the diameter of the potable water discharge, or a reduced pressure principle back flow preventor
(RPP) which is tested and serviced professionally at least once per year.
(7) Every NPDES or WPCF permit that authorizes use of reclaimed water shall include a requirement:
that the sewage treatment system operator submit at least an annual report to the Department describing
the effectiveness of the system to comply with the approved reclaimed water use plan, the rules of this
Division, and permit limits and conditions.
(8) No reclaimed water shall be made available to a person proposing to use reclaimed water unless that
person certifies in writing that they have read and understand the provisions in these rules. This written
certification shall be kept on file by the sewage treatment system owner and be made available to the
Department for inspection upon request.
(9) Compliance with these rules shall not create a water right under ORS Chapters 536, 537, 539 or 540.
[Publications: The publication(s) referred to or incorporated by reference in this rule are available from
the agency.]
Stat. Auth.: nR q 469.020, nR.q 469.705 & nR.q 469.710
Stats. Implemented: ORS 46913.030 & ORq 46913.050
Hist.: DEQ 32-1990, f. & cert. ef. 8-15-90
The official copy of an Oregon Administrative Rule is contained in the Administrative Order filed at the Archives Division,
800 Summer St. NE, Salem, Oregon 97310. Any discrepancies with the published version are satisfied in favor of the
Administrative Order. The Oregon Administrative Rules and the Oregon Bulletin are copyrighted by the Oregon Secretary of
http://arcweb.sos.state.or.us/rules/OARS 300/OAR 340/340 055.html . 12/19/2005
Exhibit to
Page 113 of I I A
DEPT. OF ENVIRONMENTAL QUALITY-340-055
State. ,
- - - Index by Agency Name
- - Index by OAR Chapter Number
the Text of the OARS
- - about Administrative Rules?
. to the Oregon Revised Statutes (ORS)
to Oregon State Archives Home Page
http://arcweb.sos.state.or.us/rules/OARS 300/OAR 340/340 055.html
Page 9 of 9
12/19/!005
Exhibit 1'\
Page 111A of 04,
