After sitting through USEPA's webinar on the upcoming NPDES permit for pesticide applications in, over, or NEAR waters of the US, its clear that IPM Plans like the one you can get at GreenGolfUSA will be the standard for demonstrating compliance with Technology-Based Effluent Limits. BMP documentation will also be a part of the TBEL in the permit.
Its not clear what is meant by NEAR waters of the US as yet. USEPA will be issuing a draft General NPDES permit for public comment by April 2010. Permits will be required by April 2011. USEPA is currently considering six (6) scenarios for these Genreal permits. A golf course management scenario is not included, but aquatic pesticide applications to lakes and ponds will require permits.
We'll keep you up to date as information becomes available!
Tom