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turf hokie
07-03-2009, 07:32 AM
EPA WaterSense Alert



June 30, 2009



The Environmental Protection Agency’s (EPA) WaterSense draft specification for new home construction promotes water conservation measures such as low-flow toilets and fixtures for indoor water use and has been expanded to include “Outdoor Water-Efficiency Criteria”. As currently drafted, section 4.0 “Outdoor Water-Efficiency Criteria” will have a drastic impact on our industry. It requires builders to limit the amount of turfgrass to 40% of the landscape area or utilize a complicated water budget. While WaterSense is being proposed as a voluntary program, it will undoubtedly be used as a basis for future city ordinances and regulations similar to the EPA’s voluntary LEED certification program. There have already been attempts to codify WaterSense language into proposed legislation.



TPI is part of the National Turfgrass Federation (NTF), a coalition that has been in contact with key decision-makers as well as representatives of the EPA. EPA will be accepting comments on its latest WaterSense new home draft specification until July 7, 2009. The EPA plans to issue a final specification in November. We encourage you to read the following and take the necessary action to address the WaterSense issue. Your immediate action would be greatly appreciated.



1. EPA WaterSense Comments Needed!



While both TPI and NTF will submit comments on behalf of the turfgrass industry, it is important that multiple constituents from various states submit as many comments as we can to ensure that EPA understands that the proposed criteria which limits turfgrass is severely flawed.



We have included a copy of draft comments developed by NTF (below). We have used the preferred comment “template” provided by USEPA on its WaterSense website. Please feel free to use any of the verbiage included in our comments; however, we encourage you to personalize your remarks as much as possible so the EPA understands the far reaching negative impacts of this flawed criteria. We have also provided suggested talking points (below) to assist you.



Please email your completed comment template to the following email address: watersense-newhomes@erg.com. Again, the deadline is July 7. If you need additional information, including a copy of the draft specification, please visit www.epa.gov/watersense.



2. EPA WaterSense Legislative Action Needed!



We also need you to contact your legislators now and ask them to help bring our concerns to the EPA’s attention. As part of the NTF coalition effort, the following information was prepared by Tom Delaney, Director of Government Affairs for Professional Landcare Network (PLANET).



BACKGROUND:

In May, Congressional Water Caucus Cochairs Bart Stupak (D-Mich.) and John Linder (R-Ga.) sent a letter to the EPA expressing concern with the proposed turfgrass deselection and requested revisions to the specification. We would like you to ask your congressional representatives to consider sending a similar letter to the agency, asking that the landscape provisions be set aside to allow for a stakeholder process to improve the specification and advance the goals of water efficiency.



REQUESTED CALL TO ACTION:

To make this as easy as possible, PLANET has provided their software to coalition participants. The following hyperlinks will take you to documents you can use to contact your senators and representatives about the WaterSense new homes draft specs. This WaterSense sample constituent letter template is written from a seed/sod producer perspective. Please use the letter to write your U.S. Senators and House members, and either fax or e-mail it to them. You may personalize it by including information about your own operation and how these draft specs will adversely affect your business. Additional talking points are provided at the end of this correspondence.



ADDITIONAL INFORMATION:



EPA WaterSense new homes specs Website: http://www.epa.gov/watersense/specs/homes.htm


EPA WaterSense draft spec can be found on the Web: http://www.epa.gov/watersense/docs/home_rev-draftspec508.pdf


EPA water budget tool information: http://www.epa.gov/watersense/docs/home_waterbudget508.pdf


We would appreciate copies of any communication you have with your U.S. senators and/or House members. Please contact me and forward letters/e-mails, etc. to me so that we know who has been contacted. We can then follow up with that office to encourage them to contact the EPA.

Again, thank for your interest in and action on this issue. If you have any questions, please feel free to contact me.

T. Kirk Hunter

Executive Director
Turfgrass Producers International

847-649-5555
847-649-5678 (fax)
khunter@TurfGrassSod.org









National Turfgrass Federation (NTF) Comments/Template:



Template for Public Comment Submission on WaterSense Documents




Commenter Name: Kevin Morris



Commenter Affiliation: President, National Turfgrass Federation



Date of Comment Submission: June 23, 2009





Topic: Outdoor Water Efficiency Criteria 4.0



Comment: The draft specification’s limitation on turfgrass is arbitrary, not supported by science and may undermine the goals of the Water Sense program. Our concerns are specific to the 40 percent turfgrass limitation, the ban on turfgrass for steep slopes and the single, nationwide .7 evapotranspiration factor for calculating the water budget.



Rationale: The one-size-fits-all home specification imposes a 40 percent turfgrass limitation on landscapable areas of new home sites whether that home site is located in the arid, desert southwest or in cooler, damp climates such as Seattle, Washington or Portland, Maine. Under the proposed criteria, a homebuilder constructing a house in Phoenix could plant cool season Kentucky Bluegrass on 40 percent of the property-a scenario that would require non-stop irrigation--and qualify that house for the Water Sense label. Conversely, a homebuilder in Northeast Michigan could mulch and hardscape the entire landscapable area and also qualify for the label. We believe that these are outcomes that should be avoided. There are many other scenarios that we could provide that would fit the Water Sense criteria, yet be environmentally unsound as well as undesirable to the consumer.



The proposed restrictions assign a negative environmental value to turfgrass and suggest that a yard covered in turf is somehow less preferable or less eco-friendly than other landscape choices. On the contrary, studies show, in compelling fashion, the myriad environmental benefits of turfgrass. Consider, for example, the cooling benefits of turfgrass. In some instances, ground level temperatures of grass-covered land areas are 30 to 40 degrees cooler than bare soil. They are also 50 to 70 degrees cooler than hardscaped (asphalt or concrete) areas1. Reducing turfgrass only contributes to the “heat island” effect that plagues urban areas across our nation. In addition to its cooling properties, managed turfgrass plays a positive role in our efforts to confront climate change. A well maintained, growing lawn that is fed by nutrients from grass clippings sequesters carbon from the atmosphere and helps to minimize the property’s carbon footprint2. Reducing the turf area and replacing it with mulch or hardscape makes an active carbon “sink” inactive, and it may actually increase the carbon released back into the atmosphere by exposing soils or using non-growing, decaying materials such as mulch. These alternative methods have great aesthetic value and help control water run-off and use, but they do not contribute to the reduction of greenhouse gas emissions, a major environmental concern today. Finally, the benefits of turfgrass in regard to soil erosion are also well documented. According to the University of Minnesota3, storm water runoff due to increased impervious surfaces has reduced the quality of runoff water that ends up over-burdening our storm sewer systems and ultimately pollutes our lakes, streams, and rivers. However, research shows that a healthy, well-managed lawn, with dense turfgrass, has near zero storm water runoff.



These erosion and stormwater control benefits that turfgrass delivers makes the steep slope ban on turfgrass in the specification perplexing. Under the draft specification, plants other than turfgrass can be planted on steep slopes. Turfgrass, because of its fibrous root system, is better than other plant in controlling erosion, a key factor in choosing a ground cover for slopes. Turfgrasses are used on most roadside slopes because turfgrasses are the best species at controlling erosion. And in the case of roadsides, turfgrass is effective on slopes, when using an adapted species and cultivar, without requiring supplemental irrigation. The same came be said for turfgrass on slopes within a landscape.



Our final concern regards the single, nationwide ET factor for calculating a water budget. We believe strongly that builders seeking the Water Sense label will avoid the complexities of a water budget and related calculations and simply opt to limit turf. Furthermore, designating a single ET rate ignores the regional climatic variations and average rainfall levels in different regions of the country.



In addition, the new draft specs require that the user of the water budget tool, to determine monthly ETo, access the International Water Management Institute World Water and Climate Atlas. To utilize the tool, the user is required to input exact latitude and longitude, after which an estimate of monthly ETo is provided. This is interesting as the scientists that met with EPA on Feb. 10th discussed the lack of ETo data available nationwide. Therefore, it is highly questionable how useful this tool really is in providing accurate ETo, as well as if most people will go through the trouble of identifying their longitude and latitude. We feel most builders will opt for the 40% turf limit because this is easiest. This brings us full circle back to the many concerns listed above.



In summary, there is no research supporting any of the tenets of the Section 4.0. Turfgrass can be maintained with limited or no supplemental irrigation in many regions of the U.S, but this fact seems to get lost in the shuffle when the only concern is water savings on the outside portion of the home. As the scientists told you back on Feb. 10th, using the latest in irrigation technology, with smart controllers and efficient systems, will easily result in 20% (or more) water savings, without having to limit builders and consumers in their desire to plant turfgrass. The scientists also recommended that the outdoor requirements be instituted in phases, as more regional information on ETo is available. We think the turf limitation will have serious consequences on the success of Water Sense and its adoption. We want to see Water Sense succeed, but we also know that many people want to plant, cultivate and enjoy turfgrass at their homes. We feel the current draft of the outdoor portion of the new homes specs will not satisfy this desire and will ultimately lead to the demise of the Water Sense new homes program.



[1] The Lawn Institute; How The Environment Benefits From a Well-Maintained Lawn; http://www.turfgrasssod.org/lawninstitute/environmental_benefits.htm

2 Dr. Ranajit (Ron) Sahu; Technical Assessment of the Carbon Sequestration Potential of Managed Turfgrass in the United States; www.opei.org/carbonreport/

3 University of Minnesota; Sustainable Urban Landscape Information Series; Environmental Benefits of a Healthy, Sustainable Lawn. http://www.sustland.umn.edu/maint/benefits.htm.







Suggested Change (or Language): We respectfully request that EPA set aside the Outdoor Water Efficiency Criteria at this time. Based on reaction at the public hearings and the webinar the Agency hosted, the outdoor criteria has raised many concerns about the negative impacts these criteria will have on the environment and suppliers that serve the homebuilding industry. Setting aside the Outdoor component will allow time for a stakeholder process to forge outdoor water efficiency solutions that actually reduce water consumption and do not result in unintended consequences.







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Suggested Talking Points on EPA’s WaterSense Draft Specification:



Reducing use of turf to 40% of a landscaped area will present negative environmental consequences and eliminate the known benefits of turfgrass such as:

· Cools the air

· Produces oxygen

· Filters the air

· Reduces pollution

· Suppresses dust

· Filters and recharges ground water

· Controls erosion

· Sequesters and stores carbon

· Reduced storm water runoff

· Dissipates heat

· And MUCH MORE



The economic impact of diminishing the landscaped turf area to 40% would have a significant and impact on a broad segment of the economy, including but not limited to:

· Turfgrass producers

· Seed producers

· Equipment manufacturers

· Small businesses

· Landscape specialists

· Home & Garden centers

· Nurseries

· Landscape architects

· Major retail outlets

· And MANY MORE



The “one size fits all” concept doesn’t take into consideration:

· Regional weather differences

· Regional rainfall variables

· Soil types

· Location of the landscape

· Warm or Cool season grasses

· Use of drought tolerant grasses



The consequences of proposing that landscaped areas cannot have turfgrass on slopes exceeding 4:1 (exceeding a one foot of drop per four feet of landmass.) doesn’t take into account:

· The scientific and acknowledged role turfgrass plays in controlling soil erosion on steep inclines

· Rainwater capture and recharge

· Substantially reducing runoff

· The environmental consequences of using other materials that don’t offer these benefits







WHAT THE EPA SHOULD DO

· Drive deployment of best technology solutions through WaterSense approved products.

· Support use of certified irrigation professionals for installation and audit, when practical.

· Support education of all stakeholders including homebuilders, landscape contractors, consumers, and others in the selection and management of appropriate turfgrass and plants for a given location, utilizing Best Management Practices for water use, and understanding the importance of water audits.

· Enlist the green industry to drive messages and results.

· Work with USDA to develop research to optimize water use for turfgrass and landscapes

· Educate the public on water conservation

· Encourage and support research related to new varieties of turfgrass that are:

o More drought tolerant

o Require less water

o Have high tolerance to salt

· Educate and promote the use of recycled water in appropriate locations

Tscape
07-03-2009, 08:20 AM
Our government is out of control!

AI Inc
07-03-2009, 08:32 AM
If they want to start somewhere they shoul be looking at rainwater harvesting and minimum loam requirements