Public testimony: Amplifying GCSAA’s voice

Testifying is a powerful form of advocacy that helps you get your message to legislators and regulators.


Public testimony is one of the many advocacy tools that GCSAA’s government affairs team uses to make sure golf’s voice is heard. When a federal agency asks for the public’s input, it provides the opportunity to address regulators’ concerns as well as to educate them on how their actions impact the industry. 

GCSAA’s government affairs team recently provided testimony to regulatory agencies on two issues of great concern to golf course management: the ongoing implementation of the “Waters of the United States” (WOTUS) rule, in the wake of the Supreme Court’s Sackett decision; and the ongoing implementation of the Endangered Species Act (ESA) Workplan. These were high-profile opportunities where the team spoke about issues directly impacting golf course superintendents and golf facilities.  

Bob Helland, GCSAA’s director of congressional and federal affairs, spoke at a virtual listening session hosted by the EPA and Army Corps of Engineers to discuss ongoing efforts to regulate WOTUS in the wake of the Supreme Court’s decision last year in Sackett v. Environmental Protection Agency. The court limited WOTUS to waters that have a “relatively permanent flow” and those wetlands that have a “continuous surface connection” to these waters to such a degree as to be “indistinguishable” from them. However, the clarity Sackett provides has been hurt by confusion as to how the agencies are interpreting this, especially at the local level. Comprehensive guidance is not available to the public, but what has been made available indicates that wetlands could be considered WOTUS with a subsurface connection to another water. 

Helland addressed these issues when he testified. He urged the agencies to be public and transparent when implementing rules and guidance in the wake of Sackett. Basic projects vital to golf course operations — such as planting trees, installing drainage and dredging ponds and wetlands — could trigger federal permitting requirements. Helland also spoke of the important role water plays on a golf course: Of the 146 acres on an average golf course, 5.7 are streams, ponds, lakes and/or wetlands. Water features account for approximately 141,746 acres of the 2-plus-million acres golf courses provide nationwide. 

Too much is at stake to get this wrong or leave interpretations foggy. Golf needs clear rules. We will continue to make this argument with federal agencies and Congress. 

Chava McKeel, GCSAA’s director of government affairs, spoke at a Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Interagency Working Group meeting in Washington in February focused on the ESA-FIFRA intersection. The EPA is working with a broad range of stakeholders to ensure the agency can comply with their ESA obligations. Specifically, 100-plus individuals representing four federal agencies, industry groups, nongovernmental organizations and congressional staff met to work through many pressing issues related to the rollout of several ESA Workplan strategies. 

McKeel spoke about GCSAA’s Best Management Practices initiative and the use of BMPs to protect endangered and threatened species and their habitat on golf courses, particularly in the areas of spray drift, runoff and general conservation. 

GCSAA is working with EPA on the recognition/inclusion of golf-specific BMPs as part of the ESA Workplan pilots. The meeting in February provided an opportunity for GCSAA to share the importance of continued cooperation with all stakeholders, using the best available science as we work toward solutions, and truly focusing on practical mitigations that balance species protection with the benefits that pesticides bring to our industry. 

Testifying can be done at all levels of government. Michael Lee, GCSAA’s senior manager of government affairs, testified at an EPA hearing regarding California Air Resources Board small-engine emissions regulations. GCSAA field staff representatives and association members have also provided testimony at the local and state levels. 

Testifying is a powerful form of advocacy and allows you to get your message out to a wide audience. Few things are more impactful than telling your story in person to legislators and regulators. And speaking of telling your story to elected officials, the 16th annual National Golf Day is near. Hundreds of golf industry representatives will converge on Capitol Hill to share the golf industry’s values and contributions with policymakers. Stay tuned the week of May 6-10 for extensive National Golf Day and Community Service Project coverage. 

Bob Helland is GCSAA’s director of congressional and federal affairs. Chava McKeel is GCSAA’s director of government affairs.