On behalf of the Virginia Golf Course Superintendents Association (VGCSA), I write to provide feedback related to 9VAC25-920, proposed regulations to create a new general permit to promote the use of the surficial aquifer in any Groundwater Management Area.

The VGCSA is dedicated to leading the golf industry by serving its members and advancing the profession and the game of golf. Our members professionally maintain green spaces across the Commonwealth, ensuring environmental stewardship of natural resources and employing environmental best management practices that help preserve and enrich Virginia’s waterways. Golf course superintendents have partnered with Virginia Tech scientists to develop and document best management practices (BMPs) for golf course management. These BMPs help golf course superintendents protect our state’s surface and groundwater resources, provide habitats for wildlife, reduce pesticide usage, and conserve energy.

Our members are expertly trained to conserve water and efficiently manage their courses. The ideal playing surface for golf is “firm and fast”, with maintenance requiring limited water usage. Turfgrass breeding also continues to progress, with newer varieties needing less water to flourish.

We appreciate Virginia’s Department of Environmental Quality (DEQ) including a golf course superintendent on the regulatory advisory panel involved in the development of these proposed regulations, as this issue is critically important to golf courses. To properly maintain playing surfaces, having the appropriate quality of water is vital. Saltwater intrusion is a big concern, and with the low height at which turfgrass is maintained on a golf course, water that is too rich in salt content is detrimental to the turf. In short, if the groundwater is not of the appropriate quality, it will have a negative impact on golf course quality and financial sustainability. Quantity is unimportant if the quality is not right.

Due to the authorizing legislation (Senate Bill 673 (Mason) from 2020) containing an expedited review process for golf courses seeking a determination from DEQ that either the quantity or quality of the ground water in a surficial aquifer is not adequate to meet a proposed beneficial use, it is important to have appropriate criteria for making that determination. We greatly appreciate the inclusion of reasonable quality standards based on current science that addresses the levels of bicarbonate, chloride, sodium, manganese, iron, and electric conductivity that could cause surficial aquifer water quality to not be sufficient for nonagricultural irrigation, such as a use on a golf course.

Furthermore, having a process that is more streamlined – and less expensive - for golf courses where the water quality is sufficient to utilize the surficial aquifer is very helpful. We also believe it is important that these regulations not affect golf courses that have already invested in deep aquifer wells and are pleased that as proposed, they would only apply to newly drilled wells.  

Drilling wells is an expensive endeavor for any golf course. The deeper the well, the higher the cost involved. Golf course superintendents will not seek to drill any deeper than necessary to obtain the needed quality of water. VGCSA members have a strong track record of reducing environmental impacts through their water management and water quality monitoring practices, and we will continue to work with the Commonwealth of Virginia to promote water conservation and improved water quality.