SCGA Public Affairs


Thursday, July 21, 2022

As most of you are painfully aware, effective June 1, Southern California’s Metropolitan Water District (MWD) issued some dramatic conservation mandates to those of its 19 million customers (MWD is the purchaser/provider of imported water for 26 Southern California Water Districts) dependent entirely upon the state water project for their imported sources. Roughly 6 million Southern Californians fall into that category; the rest (13 million) have access to imports from the Colorado River in addition to the state water project (Sierra Nevada snowpack). Those “rest” are under a more moderate statewide call for a 15% reduction. However, given the high likelihood of a late summer announcement from the US Bureau of Reclamation that California has agreed to relinquish much of the Colorado River allocation guaranteed it per federal compact, those “rest” are sure to be looking at similar cutbacks come fall. How similar remains to be seen but no doubt higher than 15%.

And that’s why it is instructive for all regions, those under strict mandates now and those sure to be under parallel mandates later this summer or fall, to take a deep dive into how the largest of the providers serving those 6 million customers has determined to bring their golf courses (34 in all) into line with MWD’s June 1 diktat. That would be Los Angeles Water & Power (LADWP). By the way, the “deep dive” we are about to immerse you in was deemed a “best practice” by the State Water Resources Control Board (SWRCB) during the 2014-2016 drought.

Here are the basics. LADWP is forgoing all use of baseline methodologies in favor of a budget allocation methodology that keeps firmly in place those policies adopted 12 years ago that have led to that golf community using substantially less water in 2021-2022 than it did in 2005-2009 – policies that incentivized investments in conservation (e.g., turf reduction, elimination of overseeding, substitution of warm season for cool season grasses, upgraded irrigation systems, lake liner replacements) and in essence punished those facilities that didn’t take such action.

Golf courses that elect to participate in Los Angeles’ “Alternative Means of Compliance” program will be assigned water budgets per the MAWA (Maximum Allowable Water Allocation) formula embedded in the state’s and city’s codes (AB 1881 and the California Model Water Efficient Landscape Ordinance that is specifically incorporated into the City of Los Angeles’ Codes by direct reference). That formula involves a combination of acreage and climate (ETo) per a 1.0 plant factor for turf and a 0.2 plant factor for those areas of a golf course that have removed turf in favor of California friendly drought tolerant cover.

LADWP is going to ask each course that wants to participate in the Alternative Means program to make that clear to LADWP’s Water Conservation Unit that indeed they want to either enter or remain in the program. That can be done with a simple E-mail that confirms that the golf facility meets the criteria for participation in the program, something that every facility in the service area long ago met. It’s the parks, sports fields, and cemeteries that along with golf courses form the class of “Large Landscapes” eligible for the program that often have difficulty on that count, not the golf courses.

Here are the relevant criteria for eligibility in the program:

  • Large Landscape Areas may deviate from the non-watering days by meeting the following requirements: 1) Must have approved weather-based irrigation controllers registered with the LADWP (eligible weather-based irrigation controllers are those approved by the Metropolitan Water District of Southern California or the Irrigation Association Smart Water Application Technologies initiative); 2) must reduce overall monthly water use by the Board of Water and Power Commissioners--adopted degree of shortage plus an additional five percent from the Customer Baseline Water Usage within 30 days; and 3) must use recycled water if it is available from the LADWP.
  • Sports Fields upon written notice to the LADWP, irrigation of Sports Fields may deviate from the non-watering days to maintain play areas and accommodate event schedules; however, to be eligible for this means of compliance, a customer must reduce overall monthly water use by the Board of Water and Power Commissioners adopted degree of shortage plus an additional five percent from the Customer Baseline Water Usage within 30 days.
  • Who Can Apply:
    • Sports Fields: Sports Fields means a public or private facility supporting a business necessity or public benefit use that provides turf areas as a playing surface for individual and team sports and does not include a facility on a residential property.
    • Large Landscape: Large Landscape Area means an area of vegetation at least three acres in size, supporting a business necessity or public benefit uses such as parks, golf courses, schools, and cemeteries.
  • Request for participation in the Alternative Means of Compliance Program in order to request approval to participate in the Alternative Means of Compliance Program and deviate from non-watering days, the following documentation must be submitted by the applicant: (1) Request letter should include the following:
    • The property address where the Alternative Means of Compliance is being requested.
    • Square footage of landscaped area including percentage of turf. (Separate measurements for greens and tees & fairways and roughs, if applicable).
    • Submit documentation of methodology utilized in taking landscape measurements (GPS, GIS or equivalent).
    • List of water meters to be included in the Alternative Means of Compliance Program (meters can be aggregated by site).
    • List of Weather-Based Irrigation Controllers (WBICs), include number of stations, make and model number and whether or not you are using the weather-based capabilities of the controller. (This is not required for “Sports Fields”).
    • Submit a description of actions to be taken in order to achieve the required 20% reduction in overall monthly water usage.
    • Point of contact information for Alternative Means of Compliance request (name, address, telephone number, e-mail address).

Those facilities that primarily use recycled water to irrigate their golf courses will continue to remain exempt from all restrictions, including those courses that use a small amount of potable water to irrigate their greens. Those facilities that supplement their potable purchases with groundwater will continue to be assigned MAWA budgets that don’t factor that supplementation into the equation.

While there is a penalty structure for violations and these penalties do apply to golf courses (and all “Large Landscapes”), the real penalty for a golf course is not these fines; it’s the fact that repeated violations of the MAWA assigned budget results in excision from the “Alternative Means of Compliance” program for a minimum of 12 months, which for golf courses in summer/early autumn months is practically a death sentence. That is how important retention of 100% control of irrigation application is to the golf community; it is prepared to exceed by 5% the goal enunciated in Los Angeles’ Drought Contingency Plan/Ordinance (up to 30%) for a total of a 35% reduction from the MAWA assigned budget in order to avail itself of the privilege of this “Alternative” program, which is very much a “privilege” in Los Angeles and not a “right.”

Key takeaway: LADWP has landed on the central organizing principle of any good public policy – a system of incentives and disincentives that taken together reward the behavior that is the goal of the policy – in this case by rewarding those that have made the investments necessary to achieve significantly lessened water footprints. One size that fits all would represent the opposite – bad public policy.

If you look at this model through the same lens as the inflexible time of day / day of week outdoor watering restriction imposed on homeowners and small businesses, you’ll notice the same differential effect. Those homeowners and small businesses that responded to previous droughts by ripping out water consumptive lawns and ornamental species in favor of California friendly drought tolerant landscapes are going to be affected minimally if at all by one or two night per week outdoor irrigation regimens. Those who stuck with Connecticut lawns and redwood saplings are going to be greatly affected; indeed, they are going to end up with brown lawns and dead gardens and may well respond by emerging from this spike in the drought by changing out those lawns and saplings for California friendly drought tolerant landscapes. The workings of good public policy as it were.

The same goes for Los Angeles’ golf courses – the workings of good public policy.

That “dive” was indeed deep! But we hope it was instructive for some of the jurisdictions in Ventura County (Calleguas serves 19 separate providers) that we know are not demonstrating the same combination of flexibility and common sense that LADWP is showing – not to mention the many jurisdictions sure to be broaching this subject later this summer and/or fall when cuts to the Colorado Basin allocation are announced.

# # # # # # # # # # #

Sunday’s Los Angeles Times juxtaposed two stories about water that in one instance gave its readers cause for alarm and in the other cause for optimism that no matter how alarming the current situation, we have the capacity in terms of both knowledge and existing technology to overcome it. The first story: A rather bleak assessment of the continuing ability of the Colorado River Basin upon which so many Southwestern residents and farms depend for their water to keep delivering that water. The second story: A rather encouraging story by Jamie Ding about the capacity of recycling to offset the region’s need for imports – both for outdoor irrigation (nonpotable) and human consumption (potable reuse). Click on the following links to read the two articles in full - Scientists have long warned of a Colorado River crisis - Los Angeles Times ( and Wastewater recycling provides hedge against drought - Los Angeles Times (

These two stories in conjunction with a solid understanding of the Sierra snowpack situation should provide all the guidance you’ll need to understand where California is headed if it hopes to keep its place as the 5th largest economy in the world and we might add, keep golf a healthy recreational sector in that economy. It’s not a matter of whether the infrastructure outlined in Jamie Ding’s story gets built. It’s only a matter of when it gets built, how it gets financed, who pays, and in what proportions. It can get financed and built along the lines of Los Angeles County’s recently passed Measure W (November 2018), which applies a parcel tax only on that part of the parcel that is impermeable with credits for existing water discharge permits, a paradigm eminently fair for golf courses, or it can be financed and built per tax/fee schemes that would not be so fair to golf courses. This is a serious discussion that the golf community continues to ignore at its great peril. Difficult subjects don’t go away when one avoids them; they just get more difficult.

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