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39 <br /> geographic and climatic conditions,maintenance budget restrictions, and availability of quality <br /> seed or sod with the intent of minimizing maintenance requirements and maximizing ecological <br /> integrity of the site. <br /> Within part g,number 6 -this requirement seems a bit to restrictive in that it can be very difficult <br /> to know the total cost of mitigation for new golf development projects that often can take up to <br /> three years of permit processing and other assessment activities to complete. If adequate proof of <br /> compliance and planning is or has been demonstrated along the development pathway, then <br /> financial `holdings' by the county should be minimal at best. If 30%remains the required <br /> guarantee,then interest on that money should be paid to the financier at the end of the holding <br /> period. <br /> Comment#6-Within 8.8.7.5 a,the requirement in the first paragraph concerning a ten day IPM <br /> revisions turn around is not feasible as new pest problems, drastic climatic changes and effects, <br /> etc. may not be easily addressed. Determination of new IPM strategies within a 10 day period may <br /> often be strategies employed for crisis management, whereas long term management practices may <br /> require several months to identify. A three month time frame for revisions would seem more <br /> reasonable for alternative IPM planning. <br /> Within part a,numbers 1,3, and 6 can be categorized together and the plan should encourage <br /> integration of preventative and curative solutions based on the ecosystem characteristics, <br /> vegetation, methods available, etc. In number 8,pesticide identification categorically is a-.ceptable <br /> (as discussed in comments#5 above). In number 9, notification requirements should remain <br /> consistent with state regulatory requirements and label requirements, realizing that all restricted use <br /> pesticides (RUP)have very strict posting requirements already in place. It would be good to <br /> encourage notification procedures when RUP's are to be applied(newsletters, bulletin boards,etc.) <br /> by club managers in addition to superintendents as well. <br /> In part b number one, rather than isolate it would seem appropriate to require pollution prevention <br /> steps be taken during ...., and in number 2 to require no point source discharges of pollutants onto <br /> the soil surface. Within number 7, "washing of... shall occur in"an approved rinse area <br /> containing a rinse water management system, either for containment and storage of the rinse <br /> water or a rinse water recycling operation. The rinse water shall be filtered using an acceptable <br /> technology and water storage ponds should be properly maintained to prevent surface water and <br /> ground water impacts from occurring. <br /> Within part c number two, "shall identify the primary source(s) and alternative sources"would be <br /> acceptable. In number three simply encourage wastewater reuse where geographically, <br /> geologically, and technically feasible. <br /> Comment#7-Within part a, the monitoring requirements are not going to be feasible in all <br /> instances,nor will the same sampling and monitoring regime be necessary for each operation and <br /> construction project. A comprehensive oversight plan should be required in the BMP and IPM <br /> programs, including a detailed description of how pollution prevention activities and monitoring <br /> will be implemented. Baseline data already available should be used with GIS programs whenever <br /> possible during construction and operation of the course. This comprehensive plan would then <br /> provide the information necessary to identify the acceptable parameters used for testing various <br /> compounds and/or pollutants, thus eliminating the need for part c. The information obtained <br /> 3 <br />