Developing a sound approach to environmental management often begins with a look at the environmental, health and safety risks that may arise from many typical club operations. From the siting, layout and construction of golf courses and maintenance facilities to the wide-ranging club operations, many considerations are factored in how to manage risk. Some, but not all of the areas a club must consider, include course maintenance and water supply, wastewater management, stream/ponds/wetlands management, air emissions (e.g., open burning), indoor air quality, solid and hazardous waste management (including recycling), wildlife management, fuel supply and storage, chemical storage and applications; cart maintenance; swimming pool chemicals; and energy supply and conservation. For many clubs, a “best practice” to manage these environmental, health and safety risks is the adoption of a formal Environmental Health and Safety Compliance Plan.
A successful environmental plan is one that includes input from the various club stakeholders—especially staff from each of the various club departments, directors and members, and in some cases, the surrounding community. A plan involves a comprehensive analysis of the environmental and safety issues. Far too often, the environmental and safety aspects of club operations are afterthoughts, uncoordinated among the various departments.
Developing an Environmental, Health and Safety Compliance Plan
An effective environmental, health and safety compliance program demands club commitment of time and resources. The primary responsibility for compliance with federal, state and local requirements lies with the club’s board of directors and club management. Boards, through their legal committee (or risk management or other designated committee) should periodically conduct reviews of club operations to ensure proper compliance with pertinent and applicable standards.
Club officials need to establish policies and procedures for handling chemicals and wastes. These should derive from a policy statement that embodies the club’s commitment to comply with all applicable regulations and to identify, evaluate and manage liabilities and risks whenever feasible. Implementing an environmental, health and safety statement can:
- Improve regulatory compliance;
- Reduce costs for pollution control and waste disposal;
- Improve employee safety; and
- Potentially reduce liability.
Just as a strategic plan and forward vision statements are best practices for those clubs that project where they will be, the environmental plan serves as a blueprint and benchmark to help with budgets, plans and the execution of capital and maintenance steps. For those clubs located within major metropolitan areas where there are numerous clubs in the geographic vicinity, the clubs might consider benchmarking with clubs of similar size and stature. For example, a club might partner with other clubs within a local CMAA chapter or local golf organization in the development of an overall policy statement.
An environmental, health and safety compliance program reflects the commitment of the board of directors and club officers and key employees to include health, safety and environmental considerations in all facets of club operations. Without one, environmental, health and safety issues may be forgotten, or given short consideration. With a written commitment to environmental planning and compliance, the board states affirmatively that environmental compliance is a priority for the club.
Adoption of the Plan
The adoption of an environmental plan allows the club to minimize its footprint or impact on the environment and the community. It fosters an attitude of being a good neighbor and respecting the limited resources of the community. Clubs committed to a successful and sustainable program require support from their boards of directors. Key steps for the program include:
- Developing and circulating a written policy on environmental compliance;
- Setting goals for reducing or recycling waste and preventing pollution;
- Designating program coordinators with responsibility—those who have “ownership”;
- Establishing clear lines of responsibility;
- Publicizing and rewarding successes; and
- Providing training and making compliance a part of the evaluation process.
Adopting an environmental plan leads to a re-examination of the assumptions on areas and types of golf course management that seemed to perpetuate themselves because no one ever asked whether things could or should be done differently—i.e., reduce the areas of maintenance (and the associated costs), change the frequency and types of fertilization and watering. Far too often, a golf course superintendent will cut the same acreage “because that is the way we always have.” Or water every night “because that is what we have done for 40 years.” The same can be said about chemical use. But a plan allows the club to ask questions about the underlying assumptions and practices.
The new USGA president, Jim Hyler, was recently quoted as saying in his acceptance speech, “I believe that our definition of playability should include concepts of firm, fast, and yes, even brown, and allow the running game to flourish. We need to understand how brown can become the new green. A more natural game that is sustainable can be promoted as a more responsible philosophy for maintaining golf courses everywhere.”
A special report from the National Golf Course Owners Association, entitled Troubled Waters: Golf’s Future in a Thirsty World, noted that water is the “bloodstream” of any golf course “and the water issue will be ongoing and will only rise in importance.” Citing the May 2008 issue of Golf Digest, the special report states that “Golf in America will face a crisis over water…There simply won’t be enough to go around for golf courses to continue doing what they have been doing.”
The Club as a Good Steward
Members of the club and of the surrounding community will often judge a club by its environmental compliance plan. With continuing growth in awareness of how operations affect the environment and leave a footprint for others to manage, the environmental plan shows the club’s concern for sustainable options and responsible stewardship.
While environmental compliance issues constitute serious business matters for private clubs, other environmental concerns such as providing an environmental sanctuary and habitat to numerous plant and animal species may be equally important to a club’s members. As people become more focused on “going green,” clubs should learn what measures members want, rather than focusing only on environmental compliance.
An environmental, health and safety plan serves as a way to organize thoughts on assigning responsibilities, training employees and members, and holding every one accountable for their responsibilities. But it does no good, and in fact can be counterproductive and can create liability, if the plan is written but not enforced at the board level. Actions speak louder than words. It is a good idea to develop an environmental management plan if and only if its elements become a way of life in club activities.
Available Resources
There is a long list of issues that arise from golf course impacts on surface and groundwater. They include: water use and conservation; installation and extraction permits for groundwater use; the application of nutrients to the golf course; surface water runoff of pesticides and fertilizers; erosion control; permitting requirements to work in stream beds and lake bottoms; storm water discharge; spill reporting; salt from snow removal operations; and equipment washings and grass clippings discharged to streams. To deal with these matters proactively, the Golf Course Superintendents Association has sponsored research on best practices and procedures. When developing an environmental plan, a club would profit from utilizing this information. See www.eifg.org. In addition, Audubon International has published best practices on a wide range of topics, including water conservation and turf care. These can be accessed at the following Web site: http://acspgolf.auduboninternational.org.
Michael L. Hardy is a partner at Thompson Hine LLP, where his primary focus is on environmental law. Hardy is also vice chairman of NCA.