Arizona Golf Courses Water Compliance and Conservation Arizona Department of Water Resources 2009.

Arizona Golf Courses Arizona Golf Courses Water Compliance Water Compliance

and and Conservation Conservation

Arizona Department of Water ResourcesArizona Department of Water Resources

20092009

Discussion TopicsDiscussion Topics

1. Water Regulation in Arizona – Background

2. Phoenix AMA Golf Course Water Use

3. Conservation Allotment Calculations

New vs. Historic Courses

Temporary Additional Allotments

4. Turf-Facility Flexibility Accounts

Example Facility Violation

5. Enforcement Procedures

6. Future Golf Course Regulation in Arizona

Water Regulation in Arizona – BackgroundWater Regulation in Arizona – Background

• Arizona is an arid environment with limited water supplies

• Prior to 1980 groundwater law was addressed in a piecemeal fashion by the courts because there wasn’t a comprehensive body of law dealing with water

• This resulted in many confusing and contradictory decisions over the years

• Population growth and groundwater overdraft were increasing problems

Water Regulation in Arizona – BackgroundWater Regulation in Arizona – Background

• Most of the overdraft problem was in the population centers and agricultural areas of the state

• The Central Arizona Project was under construction but funding jeopardized unless Arizona controlled groundwater overdraft

• In the 1970s the state Legislature sought help from municipal providers, agricultural users and mining interests

• Result: AZ State Legislature passed a comprehensive Groundwater Management Act in 1980

Water Regulation in Arizona – BackgroundWater Regulation in Arizona – Background

• The Groundwater Management Act created Active Management Areas and Irrigation Non-expansion Areas in the population centers and agricultural areas of the state

• Active Management Areas (AMAs) are areas of the state that are “actively managed” through the creation of groundwater rights and limitations on the amount of groundwater that can be pumped, delivered and received

• Irrigation Non-Expansion Areas (INAs) are managed to prohibit agricultural expansion only

• The Groundwater Code generally does not regulate water use outside AMAs

AMAs and INAsAMAs and INAs• Established AMAs

– Phoenix (1980)– Pinal (1980)– Prescott (1980)– Tucson (1980)– Santa Cruz (1994) formerly part of Tucson AMA

• Established INAs– Douglas (1980)– Joseph City (1980)– Harquahala (1981)

Golf Courses Outside of AMAsGolf Courses Outside of AMAs

• No ADWR conservation requirements outside of AMAs

• Individual counties, cities or towns may regulate golf courses independent of ADWR

• ADWR Adequate Water Supply Program• If golf course is in a subdivision that requires a

demonstration of adequacy the golf course must demonstrate a 100 year adequate water supply

• May limit the amount of water for a golf course

Phoenix AMA Golf Course Water UsePhoenix AMA Golf Course Water Use

2007 STATISTICS• 3,569 Golf Holes or

198 18-Hole Courses• 16,175 turfed acres

3,325 LWU acres

1,114 surface water acres

• Approx. 3% - 4% of total AMA use

75

85

95

105

115

125

135

145

155

165

175

185

195

2005 2006 2007

Th

ou

san

ds

Acr

e-F

eet

2150

2200

2250

2300

2350

2400

2450

Golf Course

Phoenix AMA

Linear (GolfCourse)

Conservation Allotment CalculationsConservation Allotment Calculations • Acre-Foot Definition

• Amount of water needed to cover 1 acre 1 foot deep

• 1 acre-foot = 325,851 gallons• 1 acre-foot is enough water for 2 – 3 households

for a year

• Maximum application rates• Turf = 4.9 a-f/acre• Low water use landscape = 1.5 a-f/acre• Lake = 6.2 a-f/acre

Conservation Allotment CalculationsConservation Allotment CalculationsConservation requirements for new regulation 18 hole golf courses in Phoenix AMA

Constructed post 1984 and minimum of 6,200 yards in length

Example calculation for maximum annual allotment based on 18 holes:

LANDSCAPE TYPE MAX ACRES MAX ACRE-FEET

Turf Acres 5 acres/hole 441 af

Additional Turf And Low Water Use Acres: 5 a-f/hole 90 af

Lake Acres0.14 acres/hole

15.62 af

TOTAL ALLOTMENT 546.62 a-f/yr

Conservation Allotment CalculationsConservation Allotment CalculationsConservation requirements for historic regulation 18 hole golf courses in Phoenix AMA

Constructed pre 1985. May have historic turf, lake, and low water use acres > 90 acres.

If remodeling occurs ( > 2 holes) historic exemption is reduced to 90 a-f maximum for new courses.

Example calculation for annual allotment based on 18 holes:

LANDSCAPE TYPE MAX ACRES MAX ACRE-FEET

Turf Acres 5 acres/hole 441 af

Historic Turf Acres (above 5 acres/hole) 4 a-f/acre Unlimited

Historic Low Water Use Acres 1.5 a-f/acre Unlimited

Lake Acres .14 acres/hole Unlimited

TOTAL ALLOTMENT Variable

Temporary Additional AllotmentsTemporary Additional Allotments

The following temporary additional allotments all require approval from ADWR Director.

LANDSCAPE TYPE ADDITIONAL LIMITATIONS

Newly Turfed Area Establishment 1 a-f/acre 1 year only

Revegetation 1.5 a-f/acreUp to 3 years

Approved plant list

Lake (Initial fill and refill) Total Volume needed Year of fill/refill only

Leaching (TDS > 1,000 MG/LTR) Formula Based Until TDS < 1,000 MG/LTR or 4MP

Golf Course Conservation IncentivesGolf Course Conservation Incentives

• Turfed acre reduction usu. maintains conservation allotment unless significant remodeling (2 or more holes)

• Renewable supplies

Effluent = 40% credit (100 af = 60 af)

Surface Water

Turf-Facility Flexibility AccountsTurf-Facility Flexibility Accounts

A turf-facility flexibility account:• measures compliance status • was created to address annual weather variability• rolls over from year-to-year for TMP duration• is equal to 20% of a facility’s conservation

allotment • Debit – subtract overuse if use more than allotment

• May not exceeded >20% of conservation allotment

• Credit – add under use if use less than annual allotment

• Accrues to a maximum of 20% credit for using less water than conservation allotment.

Flexibility Account Violation: ExampleFlexibility Account Violation: Example

-100

0

100

200

300

400

500

600

700

2005 2006 2007 2008 2009

ConservationAllotment

Annual Water Use

Flex Account Balance

Flex AccountViolation

Additional Compliance ViolationsAdditional Compliance Violations

• Facility Conservation Plan on file

• Exceedance of Permitted Well Volume

• Exceedance of Groundwater Withdrawal Authority

Note: A facility’s legal entitlement to withdrawal groundwater (pursuant to Type 1 or 2 rights and GIU) may be greater than or less than the conservation allotment

Enforcement ProceduresEnforcement Procedures

• Advisory Letters

• Citations

• Notice of Non-Compliance

• Stipulation and Consent Orders (SCO)

Advisory LettersAdvisory Letters

• Issued for suspected minor violations of the Groundwater Code and/or Management Plan

• Explains basis of ADWR findings• Encourages regulated person to contact ADWR

for assistance and additional information• Not considered a formal enforcement action• If violations are repetitious further enforcement

action may apply

CitationsCitations

• Currently issued in every ADWR regulatory program (except Surface Water)

• Violations are ‘remedied’ by assessment of fines/civil penalties and possibly requires instructions/actions to be completed by violator

• Citations must be paid within 30 days and upon payment the case is closed

• ADWR usu. monitors violator for several years to ensure compliance in future

Notice of Non-ComplianceNotice of Non-Compliance

• May be first formal notification of violation• Can be sent in conjunction with Report of Audit,

Field Investigation Report or prior to SCO process

• Sent when ADWR has determined that violation has occurred

• Provides regulated person with opportunity to contact ADWR

Stipulation and Consent Order (SCO)Stipulation and Consent Order (SCO)

• Generally utilized for repetitious violations or those involving large quantities of water

• Sets conditions that Respondent must meet by a specific date, payment of associated civil penalties

• Civil penalties may be reduced and in return Respondent agrees to complete all conditions set forth in SCO

Stipulation and Consent Order (SCO)Stipulation and Consent Order (SCO)

• Usually includes a probationary period of several years

• Violation of SCO results in full payment of any waived/reduced civil penalties

• Can be a negotiated process between ADWR and Respondent

• Monitoring continues throughout probationary period and beyond

Future Golf Course Regulation in ArizonaFuture Golf Course Regulation in Arizona

• We recognize the considerable economic impact of the golf industry in Arizona

• We recognize that the golf industry has contributed to water conservation by:• Conducting research• Investing in new technologies• Developing innovative turf grass management

techniques• Being creative when designing golf courses to use

less water• Implementing the use of non-groundwater water

supplies, especially reclaimed water

Future Golf Course Regulation in ArizonaFuture Golf Course Regulation in Arizona

Primary regulatory tool for golf courses in the AMAs is the Management Plan• A new management plan is developed every 10

years until 2025• Management Plans are used to achieve each AMA’s

management goal• Phoenix, Tucson and Prescott management goal is

safe-yield by 2025• The Fourth Management Plan is in early stages of

development

Future Golf Course Regulation in ArizonaFuture Golf Course Regulation in Arizona

Are we expecting the golf course industry do more?• We will evaluate current golf course

allotments and requirements and analyze the potential for additional conservation as we do for all water use sectors

• We will seek participation and input by the golf industry as we have done for previous management plans

Questions?Questions?

Arizona Department of Water Resources

Phoenix Active Management Area3550 N. Central Avenue, 2nd Floor

Phoenix, Arizona 85012(602) 771-8585

www.azwater.gov

Andrew CraddockChair, ADWR Compliance Program

ajcraddock@azwater.gov

Macreena CressTeam Lead, Industrial Program, Phoenix AMA

mkcress@azwater.gov