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HomeMy WebLinkAboutAgenda - 02-24-1997 - C3b ORANGE COUNTY BOARD OF COMMISSIONERS ACTION AGENDA ITEM ABSTRACT Meeting Date: February 24, 1997 Action Agenda Item 9-C 3b SUBJECT: Zoning Ordinance Text Amendments - Golf Course Standards Article 4.3 Permitted Use Table Article 6.16.10 Recreational Facilities(Profit/Non-profit) Article 6.23 Extra Requirements for Watershed Protection Overlay Districts Article 6.23.1 Land Use Restrictions Article 8.8 Regulations Governing Individual Special Uses Article 8.8.7 Golf Courses [new] Article 22 Definitions-Golf Course DEPARTMENT: Planning& Inspections PUBLIC HEARING: _X Yes No BUDGET AMENDMENT REQUIRED: Yes_X—No ATTACHMENT(S): INFORMATION CONTACT: Emily Cameron Golf CART Roster Extension 2580 Proposed Amendments Agency Comments TELEPHONE NUMBERS: Hillsborough - 732-8181 Durham - 688-7331 Mebane -227-2031 Chapel Hill - 967-9251 PURPOSE: To receive citizen comment on proposed amendments to the Zoning Ordinance to include standards for golf courses. BACKGROUND: (Please refer to pages 3-5 of the proposed amendment for complete background information. A summary follows.) On August 20, 1996,the Board of Commissioners adopted a charge and appointed members to the Golf Course Amendment Review Task Force (Golf CART). The Golf CART began meeting in September 1996 and continued its work through February of 1997. At the end of December, a draft was distributed to 27 agencies and individuals for review and comment, including the Institute of Government, state agencies 2 involved with water quality and pesticide regulation, the Recreation and Parks Advisory Council, the US Golf Association, the National Association of Counties, US Environmental Protection Agency, the Golf Course Superintendents Association of America, the American Society of Golf Course Architects, and the Center for Resource Management. Twelve (12) responses were received. Written comments are attached. Comments from the County Attorney reference adjustments to be made to other sections of the Zoning Ordinance if the proposed amendments are adopted. Specifically, Articles 11.6 and 8.7 should both be amended to refer to the proposed Section 8.8.7 with regard to enlargement or modification of existing golf courses. RECOMMENDATION: Article 20 of the Zoning Ordinance requires that the Zoning Officer's recommendation be presented to the Planning Board within 30 days of receipt of an application. However, Article 20.4 exempts any application for amendments to the Zoning Ordinance by either the public or the County from the provisions of Article 20.3. In either case,though,the public hearing is the time scheduled for presentation of the Zoning Officer's recommendation. Zoning Officer Recommendation ' Provided that the Planning Board and the Board of Commissioners find in the affirmative, the Zoning Officer recommends approval of the proposed text amendments. Administration Recommendation The Administration recommends that the proposed amendments be referred to the Planning Board for a recommendation to be returned no sooner than May S, 1997. i ORANGE COUNTY PLANNING AND INSPECTIONS DEPARTMENT GOLF COURSE AMENDMENT REVIEW TASK FORCE (GOLF CART) AUGUST 23,1996 NAME ADDRESS/PHONE REPRESENTING Karen Barrows 7311 Gates Road Orange County Planning Board, Hurdle Mills, NC 27705 Ordinance Review Committee 732-4491929-8282 Elizabeth Walters 7119 High Rock Road Orange County Planning Board, Efland, NC 27243 Ordinance Review Committee 563-3842 John Link P.O. Box 8181 Orange County Manager Hillsborough, NC 27278 732-8181, ext. 2300 Jim Ray 1500 Lawrence Road, Owner, Hillsborough, NC 27278 Occoneechee Golf Club 732-3435 Phil Arnold 920 Airport Road, Suite 210 Executive Vice President, Chapel Hill, NC 27514 Golf Course Builders 942-8922 Association of America Dan Jewell,ASLA 111 W. Main Street Coulter, Hart,Jewell, Thames, Durham, NC 27701 PA 682-0368 Rick Robbins,ASLA 100 Hardaway Court Designer, Mill Creek Golf Cary, NC 27513 Course,Mebane, NC 319-1004 Dr.Charles Peacock 4912 Liles Road NC State University Raleigh, NC 27606 851-5672 Dr. Miles(Bud)Smart P.O. Box 1226 Siena College-Audubon Cary, NC 27512 International Institute 380-8565 Allen Spalt 300 James Street Sierra Club, Orange County Carrboro, NC 27510 Chapter 967-3054 Audrey Booth 750 Weaver Dairy Road, #130 Triangle Land Conservancy Chapel Hill, NC 27514 918-3476 Don Cox 7010 Thunder Mountain Water Resources Committee Efland, NC 27243 563-8911 Craig Thompson 103 Lancaster Drive Golf Course Superintendent, Chapel Hill, NC 27514 Chapel Hill Country Club 932-2854 Bob Jones P.O. Box 8181 Director, Orange County Hillsborough, NC 27278 Recreation and Parks 732-8181,ext. 2661 {j ..t <� s r - �� rJ ?/11/97 Final Draft Page 1 DRAFT OUTLINE GOLF COURSE STANDARDS 8.8.7 Golf Courses 8.8.7.1 Intent and Applicability 8.8.7.2 Submittal Requirements a. Site Analysis b. Biological Inventory c. Environmental Assessment d. Grading and Erosion Control Plan e. Stormwater Management Plan f. Utilities Plan g. Landscape Plan h. Resources Management and Mitigation Plan i. Integrated Pest Management Program j. Hazardous Materials Management Plan 8.8.73 Standards for Golf Courses a. Siting Course Components b. Access, Circulation, and Parking C. Maintenance and Storage Areas d. Habitat Areas e. Landscaping and Buffers f. Stormwater Management g. Mitigation Plan 8.8.7.4 Construction a. DraAge b. Grading and Erosion Control C. Solid Waste Management 8.8.7.5 Operation And Maintenance a. Integrated Pest Management(IPM) b. Best Management Practices(BMP's) C. Irrigation d. Habitat Maintenance e. Maintenance of Improvements I; ih 2111197 Final Draft Page 2 f. Solid Waste Management 8.8.7.6 Pollutant Monitoring Program a. Baseline and Construction Monitoring b. Operations Monitoring c. Parameters for Sample Testing d. Reporting e. Management Response to Pollutant Monitoring i Y 2111197 Final Draft Page 3 PROPOSED ORDINANCE AMENDMENT ORDINANCE: Zoning Ordinance REFERENCE: Article 4.3 Permitted Use Table Article 6.16.10 Recreational Facilities(Profit/Non-profit) Article 6.23 Extra Requirements for Watershed Protection Overlay Districts Article 6.23.1 Land Use Restrictions Article 8.8 Regulations Governing Individual Special Uses Article 8.8.7 Golf Courses [new] Article 22 Definitions - Golf Course ORIGIN OF AMENDMENT: Staff Planning Board _�_BOCC Public —X—Other: Golf CART Expected Public Hearing Date: February 24, 1997 Purpose of Amendment: To provide standards for the location, planning, design, construction, operation,and maintenance of golf courses and associated uses. Background: During discussion of the Rural Character Strategies and the University Station Project, citizens and advisory board members expressed concern over the potential impacts of golf courses, particularly when allowed as a use of open space required with residential development. Currently, a golf course is a permitted use in most zoning districts; however, there are no specific standards in the ordinance to address impacts to the environment. In 1995 the Board of County Commissioners adopted Natural Resource Preservation as one of its Goals for FY 1995-26. One of the objectives included in the goal was development of standards and approval procedures for golf courses. This initiative was continued on May 14, 1996, as the Commissioners adopted Goals for FY 1996-97. On August 20, 1996, the Board of Commissioners adopted a charge and appointed members to the Golf Course Amendment Review Task Force (Golf CART). The Golf CART began meeting in September 1996 and continued its work through February of 1997. The work of the Golf CART was an attempt to address the design and environmental issues which are traditionally of greatest concern when a golf course is proposed. The most noticeable impact from a project the size of a golf course is usually a large area of disturbance (removal of vegetation r 2111197 Final Draft Page 4 and grading). Other impacts may include pollution of air, water, and soil from long-term use of fertilizers, pesticides, loss of habitat and displacement of wildlife, erosion and sedimentation, alteration of the microclimate, changes to the visual environment, and water supply demand for irrigation. These potential impacts are not associated with every golf course. Research completed to date is insufficient to identify widespread problems. The proposed ordinance amendments were not drafted to target a particular problem with existing golf courses in Orange County, but to prevent possible degradation of the environment from golf course developments proposed in the future. The text of the amendment reflects the focus of the task force which was to try to address adverse impacts and safety concerns while leaving aesthetics and style of play to the discretion of the golf course owner/developer. Similarly, the task force did not discuss to what extent a golf course could count as required open space in a subdivision or planned development. This issue is better resolved in the context of reviewing open space goals or policies,rarher than when developing standards for golf courses. As part of the proposed changes to the Zoning Ordinance, in Article 4.3, a golf course would be allowed as a Class A Special Use rather than a permitted use in AR and residential zoning districts. It would no longer be permitted in commercial or industrial districts. This approach is consistent with Article 4.2 of the Zoning Ordinance which contains statements of intent for each of the zoning districts or categories. Most of the residential districts (R-2 through R-13) specifically include recreational uses in the statement of intent as supporting the permitted residential uses. Purpose statements of the commercial and industrial districts include uses such as office, service, manufacturing,processing,etc.,but do not mention recreation. Revisions to Article 6 include deleting the four (4) current "standards" for golf courses (6.16.10), prohibiting new golf courses in critical areas of protected watersheds (6.23.1), and allowing trees to be cut in a stream buffer when they block the line of play (6.23.7). The definition of golf course in Article 22 is also revised to remove minimum acreage requirements. A new section of Article 8, Special Uses, is proposed to include standards for components of golf courses such as access, circulation, and parking; landscaping and buffers; habitat areas, maintenance and storage areas, etc. Provisions for activities such as construction, irrigation, stormwater manage&ent, maintenance, and pollutant monitoring are proposed as well. Minimum required acreages for courses with nine or eighteen holes were not included because the task force decided that other standards and dimensional requirements such as setbacks, buffers, and habitat protection would have more effect on the quality of site design than a minimum lot size for the use. Furthermore, different styles of course such as regulation, executive, championship, or youth courses have different acreage requirements based on variations in design. Points recommended for further discussion: In their deliberations, the Golf CART discussed (without reaching consensus) other sections of the Zoning Ordinance which may need reconsideration to effectively address golf courses and possibly other similar large scale land uses. Some task force members felt that the civil penalties established in Article 23 to remedy a violation 2111197 Final Draft Page 5 of the ordinance would not be large enough in proportion to the size of a golf course development project to elicit corrective action from a land owner once he or she had failed to respond to a written notification of violation. Other members suggested that a Stop Work Order (also in Article 23) would be more effective when a golf course developer is not in compliance with the terms of a Special Use Permit. Article 8.7 of the Zoning Ordinance contains provisions for changing a Special Use Permit after the original approval. Minor changes may be approved by the Zoning Officer, while modifications that do not meet the ten criteria for minor changes are subject to review at a public hearing before the Board which approved the original application. The task force was concerned that some of the criteria used to distinguish a Special Use Permit modification from a minor change would not be appropriate when applied to a project with the size and complexity of a golf course. For example, an increase in usable floor area or an increase in the size or number of approved signs constitutes a modification requiring a public hearing. Given that 1) floor area is not an appropriate measure of the intensity of a golf course as a land use, and 2) that a golf course typically includes numerous signs that are not visible from a public road, the current criteria listed in Article 8.7.1 could be re-evaluated so that changes which are small in proportion to the use are considered minor and eligible for administrative review. s K (,) ���_) r • 2/11/97 Final Draft Page 6 EXISTING ORDINANCE PROVISIONS: 4.3 Permitted Use Table [Refer to attachment 6a,page 4-17 of the Zoning Ordinance, specifically use S35, Recreational Facilities (Profit/Non-profit): Golf Club and Golf Countryclub] 6.16.10 Recreational Facilities (Profit/Non-Profit) The following restrictions shall be applied to profit or non-profit recreational facilities such as a golf course or country club with golf course: a) The minimum lot area shall be 50 acres. b) No building shall be closer than 20 feet to a property line or the minimum requirements of the district whichever is greater. C) No more than 2 identification signs,not to exceed 16 square feet each and not located closer than 1 foot to the right-of-way. d) No adverse impacts such as noise or glare shall extend beyond the lot boundaries. Article 22 Definitions Golf Course-A tract of land designed and laid out for the game of golf, including accessory uses and buildings. The minimum area for a nine hole course shall be fifty acres. The minimum area for an eighteen hole golf course shall be one hundred acres. 6.23 Extra Requirements for Watershed Protection Overlay Districts F. 6.23.1 Land Use Restrictions [See attachment 6b] 6.23.7 Stream Buffers C J2 2111197 Final Draft Page 7 c) Land Disturbance and Planting of Vegetation 1) Area within a stream buffer which is subject to serious erosion may be disturbed for the purpose of planting and maintaining erosion- resistant vegetative cover. 2) Existing forested areas or any other healthy vegetation cannot be removed from a stream buffer, except where replaced with vegetation resulting in comparable stormwater runoff velocity and quantity one year after planting. 3) New vegetation shall be planted to capture non-source pollutants before they reach the perennial stream,as per applicable Orange County Standards. PROPOSED ZONING ORDINANCE TEXT AMENDMENT: '[FINAL DRAFT 12/19/961 4.3 Permitted Use Table [Refer to the attachment of page 4-17 of the Zoning Ordinance, specifically, use S35, Recreational Facilities(Profit/Nonprofit): Golf Club and Golf Countryclub, proposed as a Class A Special Use instead of a permitted use.] Article 6.16.10 The fellewing rvswiefiem Tell be applied♦ r- l~e + r- e& e eat ,1 fftilities sueh as a if - e er. «+...,..l,.l....:+1 golf eoufse.i. � a \ ThS ffifikFAM 18t.,Ese SM11 be 50 .. MS. • Article 6.23 Extra Requirements for Watershed Protection Overlay Districts [Refer to attachment indicating proposed language added to the table in Article 6.23.1 to prohibit new golf courses in the critical areas of protected watersheds. Note that commercial uses are currently prohibited in critical areas; therefore, the V 5.j 2111197 Final Draft Page 8 effect of the change would be to prohibit public/non-profit courses. The task force determined that courses proposed as part of a residential development typically would be considered commercial uses currently prohibited in critical areas by 6.23.1 ] Article 6.23.7 Stream Buffers (Proposed text is underlined in this section only.) c) Land Disturbance and Planting of Vegetation 1) Area within a stream buffer which is subject to serious erosion may be disturbed for the purpose of planting and maintaining erosion-resistant vegetative cover. 2) Existing forested areas or any other healthy vegetation cannot be removed from a stream buffer, except where replaced with vegetation resulting in comparable stormwater runoff velocity and quantity one year after planting. An exception shall be allowed for golf courses where the line of play crosses a stream buffer, Only trees which obstruct the intended line of play may be cut. provided stumps and root mass are not removed and trees wWch are cut can be removed in a sensitive manner which minimizes additional disturbance to the stream buffer. 3) New vegetation shall be planted to capture non-point source pollutants before they reach the pemaial stream,as per applicable Orange County standards. Article 8 Special Uses 8.8 Regu"Wions Governing Individual Special Uses 8.8.7 (New) Golf Courses 8.8.7.1 Intent 1 i r� 5 2111197 Final Draft Page 9 The purpose of this article is to protect natural, visual, and cultural resources by regulating the location, planning, design, construction, operation, and maintenance of golf courses and associated uses. Applicability The standards contained herein shall apply to all new golf courses, whether proposed as a principal use or as an accessory use which is part of a residential subdivision, or included in a Planned Development District. Existing golf courses shall comply with the requirements of this article when fifty percent or more of the total playable acreage of golf holes is concurrently reconstructed or altered, or if an equivalent amount of playable acreage is added to an existing course. Playable acreage includes all tees, greens, fairways, and roughs. 8.8.7.2 Submittal Requirements The applicant shall submit the plans and documents specified in Articles 8.2, 8.8, and 14.2. The site plan prepared in accordance with Article 14 shall also indicate the routing plan showing the center line of play, the boundaries of fairways, greens, tees, roughs, hazards, and buffers. In addition the following items are required for a complete application: a. A written and graphic site analysis illustrating soils, depth to water table, slope, hydrology, vegetation, natural areas and habitats of special concern, infrastructure and other manmade features, historic and archaeological sites, and a visual analysis of views into and from the site; b. A biological inventory which identifies habitat diversity, species diversity, species of special concern such as those designated as threatened or endangered, last known sighting, candidate species likely to be present which may wan-ant protection, specimen trees outstanding in size and/or species, and the status and source of the information compiled in the inventory. The biological inventory shall be accompanied by an analysis describing habitat integrity, relationships between habitats and to ecological communities off site, any existing threats to flora and fauna, and potential for habitat enhancement; C. An Environmental Assessment as required by the Orange County Environmental Impact Ordinance; d. Grading and Erosion Control Plan; e. Stormwater Management Plan; = R 2/11197 Final Draft Page 10 f. . Utilities Plan, including schematic irrigation plan; g. Landscape Plan; h. Resources Management and Mitigation Plan including, but not limited to, construction policies, methods for protecting water resources and natural areas, pollutant monitoring program, restoration and mitigation plan for wetlands and other habitats, federal permits as may be required for alteration of wetlands, maintenance specifications for on-going site management, including solid waste,water conservation plan; i. Integrated Pest Management Program demonstrating a monitoring program for pest problems as well as biological and chemical methods to control weeds, insects,and disease; and j. Hazardous Materials Management Plan, including a description of the program for application, storage, and handling of pesticides, fertilizers, swimming pool chemicals, and any other hazardous substances; a Material Safety Data Sheet listing each substance, its known impacts, physical properties, and protective measures; a Tier Two form stating the location and quantity of each substance;and building and site plans showing location and quantities of hazardous materials. 8.8.7.3 Standards for Golf Courses The following standards are not intended to address every aspect of golf course planning, but should communicate a design objective to be applied throughout the project development. Alternatives to the standards listed may be considered if the applicant can clearly show that the proposal meets the intent of the ordinance. a Siting Course Components (1) The style and length of the course proposed shall be designed to fit the existing site conditions with minimal changes. Locations of structures, parking, tees, fairways, greens, and other site elements shall be planned to minimize land disturbance and clearing of existing vegetation; (2) The minimum setback from street rights-of-way and property/boundary lines to the center line of play of a hole is 150 feet. The minimum setback from the tee shall be 75 feet; A Y Il �lh 2111197 Final Draft Page 11 (3) A driving range shall be internally oriented. Tee boxes shall be a minimum of 75 feet from road rights-of-way and property boundaries; (4) No greens or tees shall be located where the depth to the water table is less than four(4) feet. A minimum depth of four(4) feet shall also be maintained between subsurface drainage systems under turf areas and groundwater or bedrock; (5) Buildings designated for storage and handling of chemicalss and fertilizers shall be located a minimum of 100 feet from water sources, wells, ponds, and streams, or outside a stream buffer, whichever is greater; and (6) Shelters for inclement weather and permanent rest room facilities shall be provided near the mid-point of play of each nine holes. b. Access,Circulation,and Parking (1) For a golf course proposed as a principal use, access to the site shall be limited to one (1) main entrance and one(1) service entrance per existing road frontage. If multiple uses are proposed with the golf course as part of a Planned Development such as additional recreational facilities and/or residential development, all such uses shall share a common interior access road, which may connect to existing roads more than once; (2) Parking shall be provided in accordance with Article 10 and landscaped as per Article 12; (3) Between all use areas, safe and adequate access for pedestrians ` including the handicapped is required. Conflicts shall be minimized between pedestrian and vehicular circulation. Caution signs shall be posted at all intersections of roads, cart paths, and pedestrian walkways; (4) Where a stream or other habitat crossing is unavoidable, a boardwalk or raised bridge with a free-span design shall be used to minimize adverse impacts. Other design solutions may be considered if disturbance is minimal and wildlife mobility is maintained;and 2111197 Final Draft Page 12 (5) All vehicular and pedestrian surfaces shall be designed, graded, and landscaped as required by Article 12 to minimize-visual impact by blending into the surrounding environment. C. Maintenance and Storage Areas (1) Maintenance and storage areas include, but are not limited to, the following: • maintenance equipment storage and service areas; • solid waste collection/recycling sites; • golf cart parking and service areas; • chemical storage and handling sites; and • service areas associated with a clubhouse, swimming pool, and tennis courts, or other amenities. (2) All such uses listed above shall be located and landscaped to minimize visual impact to public roads and adjacent properties; (3) Runoff from maintenance and storage areas shall be collected and pollutants filtered before release [See also 8.8.7.5.b(7)];and (4) Facilities shall be provided for composting and recycling organic matter such as branches, clippings, and leaves from course and landscape maintenance and shall be incorporated into a comprehensive solid waste management plan. d. Habitat Areas Habitats shall be identified and evaluated in the biological inventory required by Article 8.8.7.2b, and are subject to the following: (1) An undisturbed buffer is required around the boundary of habitats of rare, threatened, or endangered species as shown on the biological inventory. Buffer width shall be determined by site evaluation in consultation with the applicant's biologist and officials from the NC Department of Agriculture and/or the NC Department of Environment, Health and Natural Resources; (2) Habitat enhancements as described in the biological inventory shall be made for a broad range of species to help mitigate the loss of wildlife habitat during construction. Examples include preserving, planting, and maintaining a variety of native vegetation (also dead K Vv � 2111197 Final Draft Page 13 trees and snags); installing structures conducive for nesting such as bird houses or bat boxes designed and located for various species; or creating wetlands; (3) Conservation easements are encouraged to protect wetlands and other habitats while insuring proper long-term maintenance; and (4) Provide barriers or fencing, and signage at the edge of habitat buffers to prohibit vehicular and pedestrian access. Limited public access may be allowed if proposed in a sensitive manner for environmental education purposes. e. Landscaping and Buffers (1) Protection of Existing Vegetation (a) Existing vegetation shall be preserved as indicated on the approved landscape plan in accordance with the provisions of Article 12.2 of the Zoning Ordinance; (b) Tree protection measures shall be installed and maintained between all areas of disturbance and trees to be retained as shown on the approved landscape plan. A detail of the tree protection barrier proposed shall be included as part of the landscape plan submitted with the application; (c) Corridors connecting habitats identified in the biological inventory shall be preserved along fence rows, streams, buffers, or other wooded areas. If destroyed during construction, such connections shall be restored using appropriate plant materials; (d) Stream buffers shall be provided as per Article 6.23 of the Zoning Ordinance; (e) In out of play wooded areas, the mulch layer shall be retained; and (f) Trees and stumps cleared for the course,roads,and building construction shall either be used for timber purposes or shredded for landscape mulch,composted,buried,or burned after obtaining appropriate permits. 2111197 Final Draft Page 14 (2) Parking lots and outdoor storage areas shall be landscaped and screened as per the standards set forth in Article 12 of the Zoning Ordinance; (3) Berms, fences and walls may be used with plant materials for screening, provided such features are designed and located in harmony with other site features and functions; (4) To minimize visual impact by blending architecture into the surrounding landscape, foundation plantings are required at all structures, including free-standing entrance signs; and (5) Turfgrasses shall be selected using drought, pest, and disease resistant species and/or cultivars. f. Stormwater Management (1) Each golf course shall provide a system of stormwater management in accordance with the standards contained in Articles 6.23.3 and 6.23.4 of the Zoning Ordinance. The stormwater management plan shall be reviewed by the Orange County Erosion Control Division; (2) The rate of runoff from the site shall not be increased over pre- development conditions; (3) The stormwater management system must respect existing drainage patterns. Direct runoff away from erosion-prone slopes. Paved paths may be used to channel runoff; (4) Energy dissipaters such as rip rap aprons shall be used where runoff is concentrated and discharged, for example, at downspouts from rooftops and storm drains at parking areas. Runoff shall not be ` discharged directly into surface water or other environmentally sensitive areas ;and g. Mitigation Plan The intent of this Article is preservation and protection of natural habitats. However, a mitigation plan is required when any wetland or other environmentally sensitive area identified in the biological inventory will be altered as a result of construction or operation of the golf course or other facility (including infrastructure) associated with the golf course development. The mitigation plan shall include the following: 2111197 Final Draft Page 15 (1) An assessment of the ecological value of resources that will be lost and a statement of how that value will be replaced through mitigation; (2) A specific statement of the goals and objectives, i.e., exactly what steps will be taken to compensate for lost habitat,etc.; (3) Detailed descriptions in the form of grading plans, construction plans, and planting plans to illustrate how the objectives will be carried out; (4) A monitoring and maintenance plan to measure success of the mitigation based on stated objectives. Include a list of parties responsible for monitoring and maintenance, a schedule for each, and how results will be reported at least twice a year to the Planning and Inspections Department; (5) A plan showing how the site will be protected from impacts by human and unwanted animal intrusion, alternate plant species and construction methods that could be used in the event adjustments or substitutions are needed until the mitigation area is established; and (6) A financial guarantee is required for the total cost of the mitigation project. Once the installation is complete, thirty percent(30%)of the amount of the bond, letter of credit,or escrow will be held for twelve (12)months or until the site is established,whichever is greater. 8.8.7.4 Construction a. Drainage ` (1) All drainage structures shall be installed and maintained according to the approved Stonmwater Management Plan. (2) Golf courses that include retention/detention ponds shall comply with the requirements in Article 6.23.4, Operation and Maintenance of Structural Best Management Practices. b. Grading and Erosion Control 2111197 Final Draft Page 16 (1) Plans for grading and erosion control must comply with standards contained in the Orange County Erosion and Sediment Control Ordinance and Manual; (2) Whenever practical, construction shall be phased to minimize disturbance and sedimentation; (3) Sediment control measures must be properly installed to filter sediment from runoff during construction and shall be maintained until grading is complete and a permanent vegetative cover has been established and all slopes stabilized; and (4) Permanent landscaping, groundcover, mulch, etc. must be installed as soon as practical after construction activities for each phase are completed. C. Solid Waste Management The Solid Waste Management Plan submitted as part of the Resources Management Plan shall include the method(s) of disposal and recycling of construction debris. 8.8.7.5 Operation and Maintenance a. Integrated Pest Management(IPM) An integrated pest management plan(IPM) shall be established based on site conditions, soils, pesticide properties and management practices. The plan shall be updated as necessary to incorporate changes in pesticide choices, applications, etc. Revised plans shall be provided to the Planning and Inspections Department within ten days of said change(s). The IPM plan shall include the following: (1) Monitoring of potential pest populations; (2) Developing and integrating biological, cultural and chemical control strategies which shall include educating and training golf course personnel; (3) Timing and spot treatment preferences using biological, cultural and chemical methods; (4) Evaluating results on an ongoing basis; 2111197 Final Draft Page 17 (5) Scouting by qualified personnel trained to recognize pest problems at an early stage; (6) Specifying local problems and treatment methods for disease control, insect control and weed control; (7) Identifying the pesticides that will be used at the golf course. Include protocols used for selection of the pesticides that are most environmentally sensitive; (8)A pesticide safety program including storage, handling, disposal, and application considerations; and (9)A spill prevention and response plan for containment of chemicals used to maintain the golf couse, swimming pool, or other accessory uses. b. Best Management Practices (BMP'S) for Maintenance As part of the Resources Management Plan,the applicant shall submit a plan to establish best management practices (BMP's)for the golf course and maintenance facilities which shall include the following: (1)Isolate potential contaminants from the soil and water during delivery, storage and use of such contaminants at the golf course; (2) Fertilizer storage area shall be covered;and (3) Washing of maintenance equipment shall occur in an area that is covered from the elements. Grass clippings and debris collected from washing may be composted. Runoff from the wash pad area shall be drained to a common point and either (a)filtered through a grease trap, and recycled; (b) directed through a filtration pond; or (c)discharged to a sewage treatment facility other than a ground absorption system. C. Irrigation 3 UG3 2/11/97 Final Draft Page 18 (1) Irrigation systems shall be designed and operated according to a water conservation plan described in the Resources Management Plan submitted with the application; (2) The schematic irrigation plan required by 8.8.7.2f shall identify the source(s) of water to be used for irrigation, the volume available for that purpose, and expected consumption rates. The system design and plan for operation will be evaluated based on efficiency; and (3) Use water recycled from stormwater retention ponds, or treated sewage effluent,where it is a safe alternative. d. Habitat Maintenance (1) Habitats identified in the biological inventory and habitats created through mitigation shall be maintained in accordance with the Resources Management Plan and/or a conservation easement agreement; and (2) Maintenance of habitats shall be minimal, consisting primarily of maintaining buffers and enhancements, removal of exotic (non- native) plant species, and keeping drainage ways functioning properly. e. Maintenance of Improvements All site improvements such as roads, utilities (including irrigation and drainage structures), the golf course, habitat enhancements, recreational amenities, signage, landscaping, etc. shall be maintained in function and appearance. Maintenance specifications for on-going site management shall be submitted as part of the Resources Management Plan. L Solid Waste Management The Resources Management Plan shall include a program for the on-going recycling and composting of refuse from course and landscape maintenance, as well as solid waste from other course facilities such as a clubhouse. 8.8.7.6 Pollutant Monitoring Program An ongoing environmental monitoring program shall be established as part of the Resources Management Plan to assess the presence of pollutants in surface water, • i 2111197 Final Draft Page 19 groundwater, and sediment on site. The monitoring program shall include the following: a. Base Line and Construction Monitoring. (1) Base line monitoring shall be conducted for the three consecutive months immediately prior to commencement of construction of any component of the golf course development; (2) A minimum of three (3) surface water sample stations will be established. A minimum of three (3) ground water wells will be installed. A minimum of one (1) sediment sample station will be established; and (3) Parameters for sampling shall be as provided in 8.8.7.6c below. (4) During construction of the golf course, obtain quarterly samples from the same stations required in 8.8.7.6a(2) above; b. Operations Monitoring (1) The same stations required in 8.8.7.6a(2) above shall be used to monitor operation of the golf course; (2) A minimum of three(3) samples will be taken at each of the surface water sample locations, two(2) groundwater samples at each of the ground water sample locations, and one (1) sediment sample will be taken; (3) Monitoring will continue on a quarterly schedule for a period of three years from the start of golf course operations. After three years, monitoring may be reduced to two times per year for surface and groundwater. The three-year period may be extended if pollutant levels exceed thresholds established by U.S. Environmental Protection Agency health advisory limits (HAL) and/or standards set by the North Carolina Department of Environment,Health and Natural Resources; and (4) Parameters for sampling shall be as provided in 8.8.7.6c below. C. Parameters for Sample Testing 2/11197 Final Draft Page 20 (1) Total phosphorous, nitrate-nitrogen, total suspended solids, turbidity and pesticides will be analyzed for each sample time; and (2) The Pollutant Monitoring Program submitted with the application as part of the Resources Management Plan shall list the pesticides that will be analyzed and the rationale for such selections, which shall be based on the Tier I risk assessment set forth in Article 8.8.7.5a(8) above. d. Reporting (1) All surface water, ground water and sediment quality monitoring results will be submitted within 45 days of collection to the Orange County Health Department, Division of Environmental Health; (2) Monitoring results shall be retained on site by the golf course superintendent and shall be available for inspection; and (3)An annual report will be submitted on a date established by the Planning and Inspections Department. e. Management Response to Pollutant Monitoring (1) If contaminants are found that may reasonably be attributed to the construction, operation, and/or maintenance of the golf course, management plans shall be reviewed to assess the problem. Appropriate adjustments in the resource management and/or integrated pest management plans shall be made to prevent further contamination; and (2) If sampling and analysis indicate a trend toward increased concentrations of contaminants or if the U.S. Environmental Protection Agency health advisory limits (HAL)or State ground or surface water standards for thresholds are exceeded, then Orange County will notify the appropriate authorities. Article 22 Definitions Golf Course - A tract of land designed and laid out for the game of golf. The Golf courses include. but are not limited to courses open to the general public for a daily user fee. private courses 066 2/11197 Final Draft Page 21 available to members and their guests. courses proposed as a singles. independent use. as well as those planned as an accessory use which is part of a residential_ or recreational development. golf course development may also include the following accessory uses and buildings typi al y associated with such a facility: club house; restaurant/snack bare barroom: pro shop: billiards: table tennis- pa/health club; racQuetball. hand ball and tennis courts: swimming cool: locker rooms: and real ec ate sales office, Golf CART/Ordinance Review: Planning Board: BOCC: � L ORANGE COUNTY PLANNING DEPARTMENT tr� 306F REVERE ROAD U r HILLSBOROUGH, NORTH CAROLINA 27278 v, p V IFy L• i 'f1 t• MEMORANDUM TO: Golf Course Amendment Review Task Force(Golf CART) Dr. Kimberly Erusha, U5GA Marvin Collins, Planning Director Dr. Doug Rader, NCEDF Geof Gledhill, County Attorney Abigail Friedman, NaCo Paul Thames, County Engineer Dan Maples,ASLA Mary Bess Willis, Planner III David Bishop,GCSAA Warren Faircloth, Erosion Control Supervisor Paul Fullmer,ASGCA Ted Cashion, NCDEM-Water Quality Paul Parker,Center for Resource Mgt. )ay Zimmerman, NCDEM-Groundwater I.B. Culpepper,Town of Chapel Hill Tim Baumgartner, NCDOA-Pesticide Section Keith Lankford,Town of Carrboro Recreation and Parks Advisory Council David M. Rooks, III Mike Tapp,Orange County Fire Marshal Dr.Anita Bahe,Front Royal Aitto" 44+1i4+ Rich Ducker, Institute of Government Phil Oshida, USEPA Ron Holdway, Environmental Health Director eA No(%A%A, OWA'54 FROM: Emily Cameron, ASLA, Planner II/Landscape Architect Occ SUBJECT: Proposed Amendments to the Orange County (NC) Zoning Ordinance to Include Standards for Golf Courses DATE: December 31, 1996 COPIES: Gene Bell, Planner III Attached is the final draft of proposed amendments to the Orange County Zoning Ordinance to include standards for golf courses in the County's planning jurisdiction. Please refer to the enclosure for background information. The proposed amendments are scheduled for presentation at a public hearing on February 24, 1997. Please submit anyrcomments you may have to me by Monday, January 27, 1997. The Golf Course Amendment Review Task Force (Golf CART) will meet again to review comments and prepare for the public hearing on Thursday, February 6. If you have questions or need additional information, feel free to call me at (919) 732-8181, extension 2580. Thank you for your time and assistance. 3 � U6 �3 r R L LAW OFFICES COLEMAN, GLEDHILL & HARGRAVE A PROFESSIONAL CORPORATION 129 E.TRYON STREET P.O.DRAWER 15Z9 HILLSBOROUGH,NORTH CAROLINA 27276 February 10, 1997 919-732.2196 FROM THE DESK OF FAX 919.732.7997 GEOFFREY E. GLEDHILL Ms . Emily Cameron, ASLA, Planner II/Landscape Architect Orange County Planning Department Post Office Box 8181 Hillsborough, North Carolina 27278 RE: Proposed Amendments to the Orange County Zoning Ordinance to Include Standards for Golf Courses Dear Emily: This letter confirms our telephone conversation on February 7, 1997 . I have reviewed the proposed amendments to the Orange County Zoning Regulations concerning golf courses . It is apparent that a lot of thought and work has - gone into creating standards for new golf courses . My comments will focus on some of the concerns that I discussed with you during our conversation. By way of clarification, the changes to Section 6 .23 .7 (c) and the definition of "Golf Course" contained in Article 22, I read to apply to all golf courses, including existing golf courses . Enclosed is a recommended change to the definition of Golf Course. All of the rest of the requirements, contained for the most part in new Section 8 .8 .7, apply to new courses and existing courses when 50% or more of the golf holes are concurrently or simultaneously reconstructed or altered. The standards in new Section 8 .8 .7 include siting, access, maintenance and storage areas, habitat areas, landscaping and buffers, stormwater management and mitigation plan requirements . There are also requirements covering construction, operation and maintenance, '-and pollutant monitoring. The specific way and the detail in which each of these areas is dealt with in the regulations suggests that there is a public policy reason for dealing with these issues for golf courses that is different either in quality or quantity from the way in which these issues are dealt with in other types of development . If this is not so, then many of these areas of regulation should be applicable in some way or another to other development of comparable quality and size. If the regulations are perceived to "pick on" golf courses, they should be justified on the basis of real differences between golf courses and other development of similar size and scope. Some of the regulations related to pest management may run afoul of the fact that the State of North Carolina in its J 1 J Ms . Emily Cameron Page 2 February 10, 1997 Pesticide Control Program, North Carolina General Statutes § 143- 434 et seq. , has very clearly "preempted" regulation. N.C . Gen. Stat . § 143-465 (d) states "no county . . . shall adopt or continue in effect any ordinance, rule, regulation, or resolution regulating the use, sale, distribution, storage, transportation, disposal, formulation, labeling, registration, manufacture or application of pesticides in any area subject to regulation by the [pesticide] Board pursuant to this Article . " That subsection goes on to make clear that counties are not prohibited from exercising planning and zoning authority or from exercising fire prevention or inspection authority. Reconciling the prohibition and the authorization of this statute is tricky. I think it is safe to say that some of the provisions in proposed Section 8 . 8 . 7 . 5 and 8 . 8 .7 . 6 will not survive a challenge based on preemption. Particularly, to the extent that those sections control the selection and use of pesticides, they will be, I think, preempted by the State Pesticide Control Program. Specifically, Sections 8 . 8 .7 . 5 .a (8) , (9) and (10 ) should be culled of pesticide use requirements . Subsection "b" of 8 .8 .7 . 5 should likewise be culled of pesticide use requirements . The management response to pollutant monitoring provisions -in 8 . 8 .7 . 6 to the extent that it must contain pesticide use requirements should also be culled. It is possible to include monitoring provisions in this whole area and to also provide, either in the Zoning Ordinance or otherwise, for reporting the results of that monitoring to the State for action if appropriate under the State Pesticide Control Program. Any interest on the part of Orange County in doing so should probably be initiated at the Board of County Commissioner level and directed to the Secretary of Agriculture. Lastly, I think Sections 8 .7 and 11 . 6 of the Zoning Ordinance may need to be "cleaned up" if these new regulations are adopted. Section 11 .6 of the Zoning Ordinance makes an existing use`which would require a special use permit conforming with any enlargement, replacement or modification requiring a special use permit . Section 8 .7 of the Zoning Ordinance relating to the distinction between minor changes and modifications to special use permits, should also refer to, in the case of golf courses, new Section 8 .8 .7 to be sure that the intent of the applicability section, new Section 8 .8 .7 . 1, with respect to existing golf courses is carried out . very truly yours, ;eoffrey L GLEDHILL & HARGRAVE, P.C. E. G1 hill GEG/lsg Enclosure r Article 22 Definitions Golf Course - A tract of land designed and laid out for the game of golf, including accessory uses and buildings. The mini Q=ea €er a nine 'hel- eeuEse -shall-be fifty aeres:—the faInLmm aEea ieE a eIGjht ear- eke ge14eemsa shall be e e hued __-res include courses associated with a golf "country club, public and private courses , courses proposed as a principal use, as well as those planned as part of a residential or recreational development. i r �.Iti • INSTITUTE Of GOVEKNMENT January 25, 1997 Ms. Emily C. Cameron, ASLA Planner II Orange County Planning Department 306 F Revere Road Hillsborough, NC 27278 Dear Emily: In your memo of December 31, 1996, you invited my comments on the proposed amendments to the Orange County Zoning Ordinance as it concerns golf courses. It appears that the Golf CART includes a number of individuals with special expertise that can be brought to bear on this matter and that the work you are doing can break fresh ground and become useful in planning in jurisdictions all around the state. My only general concern is that the regulations that you may end up with become too involved, or at least more involved than those that apply to other important land uses in the county. Make sure that you place the review of golf courses in a proper context. Another issue that your committee may wish to address is how a golf course fits into a planned residential development(or any planned development for that matter). One of the issues here is whether a golf course should qualify as "open space" for purposes of the ordinance. Some ordinances limit the extent to which the land in a golf course can count as required open space; many others fail to clarify whether it does or does not. A related issue is whether the open space must be or may be private. If the open space is intended to be for the benefit of the residents of the development, then the question arises as to whether a golf course must be available only to residents and their guests or whether it may be open to the general public. One issue that recently arose with respect to a development near Charlotte was whether the developers could qualify their golf course as required open space if they provided preferential tee times and discount greens fees to residents to make up for the fact that the golf course was being operated as a commercial venture. I mention these issues simply because you may want to address them in your work so as to eliminate any confusion. Congratulations on the good work you have done so far. Let me know if I can be of any help. cerely, chard D. Ducker Assistant Director The University of North Carolina at Chapel Hill CB#3330 Knapp Building.Chapel Hill,NC 27599-3330 919 966-5381 .919 962-0651(Fax) 074 TOWN OF CHAPEL HILL 306 NORTH COLUMBIA STREET CHAPEL HILL. NORTH CAROLINA 27516 Telephone(919)968-2700 January 13, 1997 Ms. Emily Cameron, ASLA Orange County Planning Department 306F Revere Road Hillsborough, NC 27278 Re: Draft Golf Course Standards for Orange County Zoning Ordinance Dear Emily: Thank you for the opportunity to review the proposed amendments to the Orange County Zoning Ordinance to include standards for golf courses in the County's planning jurisdiction. We have no comments to offer at this time. Please let us know if we may be of further assistance. Best Regards, r 1 pe fvelop ent Coordinator b AMERICAN SOCIETY OF GOLF COURSE ARCHITECTS 221 NORTH LA SALLE STREET CHICAGO, ILLINOIS 60601 312372-7090 January 22, 1997 Ms. Emily Cameron ASLA, Planner II/Landscape Architect Orange County Planning Department 306F Revere Road Hillsborough,NC 27278 Dear Ms. Cameron: Thank you for the opportunity to respond to the proposed amendments to the Orange County Zoning Ordinance and its inclusion of standards for golf courses in the county. We have forwarded the document to four ASGCA members in North Carolina-- Dan Maples, Tom Fazio, Michael Gleason, and Tom Marzolf--who may have comments in addition to what follows. In some respects, this ordinance codifies existing ordinances and tries to adapt them to golf courses...in some cases being more stringent, and other cases being more relaxed. Each site should be evaluated on its own criteria by a qualified golf course architect. The committee is therefore wise to remove standardized acreage as required in the ordinance, and a review process of each design is more practical than setting specific standards. There are a few points where we have particular concern: 1. The document seems to build on the premise that golf courses present a special environmental challenge not associated with other developments. Actually, golf courses that are designed,constructed and maintained properly provide many environmental benefits. So the premise might be better understood as providing environmental opportunities, rather than challenges. 2. We must take exception to the phrase in the background section that reads, "...but to prevent degradation of the environment from golf course developments proposed in the future." Again, that wording implies that golf courses are harmful, which they are not. I r W . IJ 1 Ms. Emily Cameron Page Two January 22, 1997 3. We question why golf courses within residential developments have to be permitted under a special use permit. Golf courses enhance the environment as compared to a higher density residential area. Properly planned together, golf courses are a nice amenity to a housing development, as evidenced by their popularity in Hilton Head, Myrtle Beach, Pinehurst and other Carolina resort destinations. 4. Golf courses should not be summarily prohibited from critical areas of protected watersheds. Properly designed, golf courses can enhance flood protection, water filtration and purification, etc. We applaud your allowing special clearing of trees and stream buffer areas where they might block the line of play. 5. In reviewing the specific requirements for a golf course design, including minimum setback buffers, standards for parking lot, road layout and buffers, it is easy to highlight existing courses that probably violate the stringent rules, and yet are considered good neighbors. One is The Quarry Golf Club in San Antonio,which is sunk 100-feet into a vertical wall stone quarry. Under similar circumstances would the 75-feet from tee, and 100-feet from fairway centerline still be required under this ordinance? 6. While well-intended, some design requirements are subject to interpretation. For example, the phrases, "all vehicular and pedestrian surfaces shall be designed and graded to be visually unobtrusive...";"The course proposed shall be designed to fit the existing site conditions with minimal changes..."; and"Locations of...site elements shall be planned to minimize land disturbance and clearing of vegetation, and driving range shall be internally oriented..." all are well-intended, but would be incorporated by any qualified golf course architect anyway. Our concern is that, being subject to wide interpretation, these phrases could possibly be used as"straw men"to question an otherwise qualified design. 7. The issue of increased civil penalties above and beyond what might be required for other developments in the zoning ordinance should not be based on the presumption that golf courses are eithcr particularly complex, or more prone by nature to be subject to violations of any zoning.ordinance. Although this is an issue that fits the national ongoing debate of penalties and regulations versus incentive and conservation,more consideration should be given to this area. U7 7 Ms. Emily Cameron Page Three January 22, 1997 S. Perhaps the areas of greatest cost, which would affect the feasibility of new golf courses proposed in Orange County, is the strict requirement for unending pesticide monitoring, as well as the identification, protection, creation of mitigation plan, and payment of a financial guarantee for protecting habitats. Habitat corridors can be difficult to incorporate. Similarly, the integrated pest management plan, properly developed by a qualified consultant, should identify on a case by case basis whether or not monitoring is required. Thank you for the opportunity to present these thoughts to the Task Force. Sincerely, paj t Paul Fullmer Executive Secretary PF:di t y �� 1 -_ i1_1 7'4 4 Front Royal Environmental Sewices, Inc. 2200 Gatewav Blvd. • Suite 205 • Nlorrisiile. NC 2-560 (919)469-9795 • Fax(919)-169-355' January 27, 1997 Ms. Emily Cameron Orange County Planning Department 306 F. Revere Road Hillsborough,NC 27278 RE: Comments on proposed county zoning ordinance draft Dear Ms.Cameron: I appreciate the opportunity to comment on the Orange County Zoning Ordinance draft addressing the proposed standards for golf course development projects. Thank you.for providing me the copies of the Environmental Assessment requirements and the pertinent sections of the existing ordinance in the county. Hopefully my enclosed comments will be of assistance in the planning process. My comments are founded in my scientific and agricultural background as well as previous career experiences in habitat management and within the pesticide industry. The comments are my own and do not reflect the position of Front Royal Environmental Services,Inc. Where necessary I did seek input from other professionals both within our company and from other private and public institutions. If you have any further questions or needs for which I can be of assistance please give me a call. Have a good day! Sincerely, i C� R. Anita R. Bahe,Ph.D. Senior Project Manager Enclosure USi) Review comments concerning the final draft of the proposed amendments to the Orange County Zoning Ordinance as completed by the Golf Course Amendment Review Task Force Prepared for: Ms. Emily Cameron, Orange County Planner Prepared by: Dr. Anita R. Bahe, Front Royal Environmental Services, Inc. Comment#1 - In order to keep the more detailed contents of the proposed ordinance in proper context, some clarity is required concerning the purpose of the draft ordinance as it relates to statements made in the background section contained in the introduction information. In response to the"most noticeable impact . . . " sentences therein, addressing the size and extent of disturbance associated with golf courses should perhaps be more distinctly qualified. Though it is stated that not all golf courses necessarily impart the same impacts, it would be fitting to mention that the potential impacts are dependent on numerous factors including the specifics of the site;the type of course being developed(par three, championship, residential component,etc.);the architect involved in the project;and the financing available. When considering many other land use alternatives, including but not exclusive to business parks, residential development,waste disposal, and agricultural expansion,the impacts of a well planned golf course can often be minimal in comparison. This type of inclusive text helps to keep in perspective the original primary objective determined in 1995 (Natural Resources Preservation)rather than taking offense, if you will,to the golf course development industry. Revisions to Articles 6 and 22 are positive. Comment#2- With regards to the establishment of penalties to remedy violations,the type of golf course project and the ownership will both play a role in the effectiveness of restraints. A Stop Work Order is apt to be effective in dealing with blatant violations, but the permit requirements must therefore be very distinctly defined to avoid unnecessary delays to owners, investors, contractors, etc. on a project that is curtailed due to misinterpretations. Comment#3- It is good to allow provisions for changing a Special Use Permit(SUP)following the original approval,but the use of specified criteria may be inappropriate. If the`due diligence' process reveals acceptable plans are in place and risk has been minimized,then an environmental summary of the information gathered during this process should be considered. I can not comment on the ten criteria because they were not included in the draft I received. Comment#4-If's difficult to snake definitive comments about the SUP classifications(no code definitions included)and the land use restrictions by district due to a lack of familiarity and/or a lack of descriptive information about the demographics and geographic characterization of each district. It is advisable to include someplace in the document or in an appendix a thorough description of each district and each code in order to mimmize misinterpretation of the proposed requirements within the document. 6.16.1 is acceptable Within 6.23.7 number two, the exception for tree removal in a stream buffer that falls in the line of play is an acceptable change, but rather than prohibit the removal of stumps or roots,the same objective could be accomplished with an alternative erosion control, sedimentation prevention, and 1 surface water quality protection plan. It would seem appropriate to require such a plan for the golf holes where tree removal was necessary. This plan could be included in the site management/BMP plans that are already required. It seems that 6.23.7 number three should be included in the plans discussed within number 2. This helps to avoid redundancy and to encourage comprehensive planning, thus the plan encompasses the use of new vegetation to prevent erosion, minimize sedimentation, and to maximize the assimilation of potentially mobile pollutants. Comment 05-Within the applicability section of 8.8.7.1, the requirement for existing golf courses should be defined as 50%or more of the total acreage of playable golf holes. Often greens are reconstructed in order to help with BMP's. Greens constitute less than 5%of the total acreage on a golf course, but renovation of nine greens would constitute 50%of the holes as the draft currently states. The total acreage requirement would seem more reasonable. Within 8.8.7.2 "A cate og_ri zed biological inventory"may be more appropriate to a given site and much less subject to misinterpretation, with the exception of species currently protected under the Endangered Species Act. Within subpart h., a requirement to submit a comprehensive Strategic Environmental Management (SEM)plan that includes a Resource Management and Mitigation Plan as a part of(or in addition to)the BUT submitted, once again avoids redundancy and encourages greater integration. The IPM plan could serve a component of the SEM plan. Suitable IPM program requirements would include: 1)a summary of the predominant types vegetation and approximate total acreage to be managed along with, 2)the pest problems associated with each that could occur within the first few years of operations, and 3) when possible,provide a fist of the types of compounds that may be used(categorized by chemistry rather than trade names)and the biological methods appropriate, in the event the previously identified pest problems should occur. Within this plan,the proposed methods of oversight should be summarized as well(scouting, hand sampling,mechanical monitoring techniques,etc.). j. -This is already required by law Within 8.8.7.3 part a,numbers three and four- these requirements may not be unreasonable but more detail as to the basis or the foundation for the selected parameters should be stated(statistics, hydrogeological data, insurance requirements,etc.). In number five,a 50'to 75'minimum would seem adequate d1dw facilities are designed with the appropriate containment and recycling systems in place. The presence of closed loop systems and/or facility design should provide for the option for lesser dh tance requirements on a site by site basis. Within part c-number 2 strike screened(enhanced may be a better term). In number 3,facilities shall either provide on site composting and recycling. . . or provide a proof of contract with public or privatized composting and recycling vendors. Within part e-the requirement in(1)f is unreasonable unless the county is willing to provide assistance with capital costs for handling the trees for timber purposes. In(2), strike screened, (enhanced may be a better term). In(5), selection of turfgrasses should be based on local 2 • � sJ .3 geographic and climatic conditions, maintenance budget restrictions, and availability of quality seed or sod with the intent of minimizing maintenance requirements and maximizing ecological integrity of the site. Within part g, number 6 -this requirement seems a bit to restrictive in that it can be very difficult to know the total cost of mitigation for new golf development projects that often can take up to three years of permit processing and other assessment activities to complete. If adequate proof of compliance and planning is or has been demonstrated along the development pathway,then financial `holdings' by the county should be minimal at best. If 30%remains the required guarantee,then interest on that money should be paid to the financier at the end of the holding period. Comment#6-Within 8.8.7.5 a,the requirement in the first paragraph concerning a ten day IPM revisions turn around is not feasible as new pest problems,drastic climatic changes and effects, etc. may not be easily addressed. Determination of new IPM strategies within a 10 day period may often be strategies employed for crisis management, whereas long term management practices may require several months to identify. A three month time frame for revisions would seem more reasonable for alternative IPM planning. Within part a,numbers 1,3, and 6 can be categorized together and the plan should encourage integration of preventative and curative solutions based on the ecosystem characteristics, vegetation, methods available,etc. In number 8, pesticide identification categorically is a-.ceptable (as discussed in comments#5 above). In number 9, notification requirements should remain consistent with state regulatory requirements and label requirements, realizing that all restricted use pesticides(RUP)have very strict posting requirements already in place. It would be good to encourage notification procedures when RUP's are to be applied(newsletters,bulletin boards,etc.) by club managers in addition to superintendents as well. In part b number one, rather than isolate it would seem appropriate to require pollution prevention steps be taken during ...., and in number 2 to require no point source discharges of pollutants onto the soil surface. Within number 7,"washing of... shall occur in"an approved rinse area containing a rinse water management system, either for containment and storage of the rinse water or a rinse water recycling operation. The rinse water shall be filtered using an acceptable technology and water storage ponds should be properly maintained to prevent surface water and ground water impacts from occurring. Within part c number two,"shall identify the primary source(s)and alternative sources"would be acceptable. In number three simply encourage wastewater reuse where geographically, geologically,and technically feasible. Comment#7-Within part a,the monitoring requirements are not going to be feasible in all instances,nor will the same sampling and monitoring regime be necessary for each operation and construction project. A comprehensive oversight plan should be required in the BMP and IPM programs, including a detailed description of how pollution prevention activities and monitoring will be implemented. Baseline data already available should be used with GIS programs whenever possible during construction and operation of the course. This comprehensive plan would then provide the information necessary to identify the acceptable parameters used for testing various compounds and/or pollutants,thus eliminating the need for part c. The information obtained 3 during the pollution prevention and monitoring activities would then be reported to the appropriate County agency quarterly the first two years and annually thereafter. Final Comment- By adding necessary detail to the ordinance and clarifying the requirements as being consistent with the overall county objective of Natural Resource Preservation, the golf course industry will be much more receptive, the plans will be reasonable and comprehensive enough to adequately sustain the environmental integrity of the site, and the overall results can be economically viable. Some of the requirements the county has proposed are already State and/or Federal requirements. In the instances where the State already has a sound strategy in place, it seems unnecessary and risky to tighten the rules even more. This is especially true concerning the use of pesticides and fertilizers. The registration, labeling, marketing, and application requirements established for pesticides are in place to minimize the risks associated with their use and to provide management tools that can prevent catastrophic problems from occurring when these products are used properly. A comprehensive Strategic Management Plan,containing mitigation plans, BMP and IPM programs, ecological integration, and provisions for alterations will allow the County to see economic growth from the golf course industry while owners and operators utilize sustainable practices. 4