HNGC Final 2024 Annual Monitoring Report

environmental 79 pages
Meeting: portal event 1043 (no meeting page on file)
Agenda item: New Business — Hudson National Golf Club -- 40 Arrowcrest Drive (67.15-1-4) Proposed Amendment to the Environmental Management Plan to Reduce Monitoring at Station SW-3A and SW-6 for N-N and Turbidity to Annually During the Spring
Environmental review, 79 pages. Attached to agenda item: “New Business — Hudson National Golf Club -- 40 Arrowcrest Drive (67.15-1-4) Proposed Amendment to the Environmental Management Plan to Reduce Monitoring at Station SW-3A and SW-6 for N-N and Turbidity to Annually Durin”
Retrieved 2026-04-15 from the village's meeting portal. View the original PDF ↗
Extracted text
EXECUTIVE SUMMARY 
 
The construction of Hudson National Golf Course (HNGC) was approved conditioned on 
the design and implementation of a comprehensive, multimedia environmental monitoring 
program. The Environmental Management Plan (EMP; Turf Science Group [TSG], 2000) 
contains the protocol for the monitoring program. Baseline sampling began on May 30, 1994. 
The TSG issued the baseline and the first-year monitoring reports (1996), and Environmental & 
Turf Services, Inc. (ETS) reviewed these reports. Since then, ETS has directed the monitoring 
program and issued the annual reports for monitoring years 1997 through the present. In 
addition, ETS issues letter reports summarizing the results of all sampling events routinely 
throughout the year. The monitoring results for 2024 (29th operational monitoring year) are 
summarized in this annual report.  
 
The core five-years of ‘official’ operational monitoring began with the “satisfactory 
completion of all drainage systems and water quality basins” (TSG, 2000). The HNGC satisfied 
the completion of that condition on August 31, 1999 (Ioannou, 2002). Therefore, the core five-
years of operational phase monitoring at HNGC ended August 31, 2004 for those parameters 
(e.g., pesticides) that had not exceeded response thresholds (RTs) as described in the EMP. RTs 
for two pesticides were exceeded in the early years of monitoring at surface water stations: 
PCNB in 1997 and chlorothalonil in 1999. The use of those two pesticides stopped following 
their RT exceedances and monitoring continued for an additional five years. There were no other 
exceedances of those two pesticides. In addition, no other pesticides’ RTs were exceeded during 
that 5-yr monitoring period. Therefore, monitoring of pesticides ended in 2004, in accordance 
with the EMP.  
 
Monitoring continues today as the result of RT exceedances in surface water at four 
stations and for selected parameters, most importantly nitrate-nitrite nitrogen. Nitrate-nitrite 
nitrogen (N-N) monitoring ended at SW-5 following the completion of monitoring in 2021 
because the monitoring requirements were fulfilled at that station. Total phosphorus monitoring 
ended at the end of 2021 at all stations because the monitoring requirements were fulfilled. Thus 
monitoring at three on-site surface water stations (SW-1, SW-3A, and SW-4) and the off-site 
surface water station (SW-6) continue for N-N and turbidity only. 
 
Limited monitoring continued at four remaining surface water stations in 2024: three on-
site and one off-site. In accordance with the 2000 EMP (as amended) all monitoring will stop at 
the HNGC following the completion of the remaining monitoring requirements, currently 
scheduled for 2027 for stations SW-1 and SW-4, and SW-3A in 2029 based on the condition that 
there are no nitrogen exceedances. There was one N-N RT exceedance at SW-3A in 2024; 
however, this was likely the result of the ground disturbance for the work done on the golf course 
in 2023. Monitoring at the off-site station SW-6 will continue until all on-site monitoring stops, 
due to the fact that it is the reference (i.e., background) site. 
 
Results and Discussion 
 
Surface water stations were sampled four times during the routine sampling in 2024. 
There were three base flow (BF) events that occurred in the appropriate seasons: May 21st 
(spring), July 31st (summer), and October 10th (fall). There was one storm flow (SF) event during 

2024: December 16th (fall); however, this was not a qualifying storm event in accordance with 
the EMP. There were no qualifying storm events during the spring or the summer seasons 
because there were no opportune times and/or the rain accumulation did not meet the storm 
criteria for those two seasons. Samples were analyzed for nitrate-nitrite as nitrogen (N-N) and 
turbidity. Field parameters (pH, temperature, and specific conductance) were measured when 
samples were collected during each sampling event.  
 
The N-N concentrations ranged from non-detect (ND; <0.1 ppm; SW-4 and SW-6) to 
1.31 ppm (average of duplicate samples, SW-3A) in 2024. N-N was not detected at the off-site 
station SW-6 during any of sampling events in 2024. The N-N concentrations exceeded one on-
site stations’ response threshold one time during the four sampling events: SW-3A (spring BF).  
 
The average N-N concentration for all on-site surface water monitoring stations in 2024 
is 0.38 ppm (std = ± 0.35 ppm; n=12). The overall on-site average N-N concentration was lower 
than in 2023 (0.56 ppm, n=12) and in 2022 (0.68 ppm, n= 11). This indicates a decreasing N-N 
trend at the on-site stations. The N-N concentration at the background station SW-6 in 2024 was 
less than the detection limit (i.e., <0.1 ppm) during all sampling events. Thus, we know that the 
average concentration was less than 0.1 ppm, but we cannot know the actual number. 
 
Resampling Criteria 
 
The Village Planning Board approved our recommendations to revise the sampling 
criteria for N-N and TP response threshold (RT) exceedances (ETS, 2012). This was done 
because of difficulty resampling as defined in the original EMP (2000). All total phosphorus 
monitoring stopped at the end of 2021. Thus we did not evaluate TP in this report. Below is a 
summary of the accepted resampling criteria. We have been using these criteria since that time 
(2012). Additionally, we recommended that no resampling be implemented in 2024 due to the 
major earth work that was done on the golf course grounds in 2023, which causes nitrogen 
release in the soil and is transported to the nearby streams via ground water seepage. In addition, 
we did not resample following the spring base flow event at SW-3A because we did not receive 
the lab results until August due to the lab’s omission to provide them promptly. 
 
List of Resampling Criteria 
1. Resampling should be based on an RT exceedance using the corrected RTs and a statistically 
significant increasing trend for the parameter (i.e., N-N or TP); 
2. The resampling event should be done under the same flow conditions under which the original 
samples were collected (e.g., if original samples were collected during a storm flow event, then 
the resampling event should also be done during a storm flow event); 
3. The resampling event should be completed within the same season (i.e., spring, summer, or 
fall); otherwise, routine sampling will continue; and 
4. A reasonable amount of time for resampling will be 2-3 weeks after receipt of results, 
otherwise no resampling will be done for that exceedance. 
 
Trends Analyses 
 
Temporal Trends. Quantitative and qualitative statistical tests have been conducted on the 
cumulative data generated since September 1999 in order to evaluate seasonal and long-term 

trends. This was done by comparing the results of N-N at each station from year to year (1999-
2024) to identify any significant trends for those parameters. Two on-site stations show 
increasing N-N concentration long-term trends (SW-1 and SW-3A), and one station shows a 
decreasing trend (SW-4) using the cumulative datasets. In addition, we evaluated each station’s 
N-N concentration for the last 10 years (2015-2024) in order to determine more recent trends 
(i.e., increasing or decreasing) for the possible cessation of monitoring. Two stations show 
decreasing N-N concentration 10-year trends (SW-1 and SW-4), SW-3A shows a flat trend (i.e., 
neither increasing nor decreasing), and reference station SW-6 shows a slight increasing trend. 
 
Although the pH fluctuates at both the on-site and background surface water stations, the 
fluctuations are not anomalous for this area. Therefore, no statistical analyses were done for pH; 
however, pH measurements will continue as long as N-N is monitored. 
 
Amended Nutrient Program 
 
We continue to recommend the fertilizer restriction of no more than a 1,000 lb N total be 
applied after October 15 until early spring to help prevent N-N RT exceedances at the surface 
water stations. This latter EMP amendment was approved (January 31, 2017). It was 
implemented and followed by the superintendent in the fall of 2017 and has continued since then. 
There were no N-fertilizer applications made after September 24, 2024 to any of the turf. 
 
Conclusions 
 
Overall, the course appears to be managed well, from an environmental perspective, with 
minimal nutrient impacts on surface water. The overall cumulative monitoring results (1997-
2024) show that there are increasing long-term N-N trends at two on-site stations compared with 
SW-6: SW-1 and SW-3A. However, the data over the last 10 years (2015-2024) show decreasing 
trends at SW-1 and SW-4, neither increasing nor decreasing at SW-3A, and slightly increasing at 
SW-6. 
 
The N-fertilizer applications are not the only N-source releasing nutrients into the system, 
which may be causing the N-N increasing trends. The major earthwork in 2023 is also a source 
of nitrogen release into the system. N-fertilizer applications are very low (i.e., spoon-feeding 
rates, 0.1 lb N/1,000 sq ft) except for the applications during the reseeding of the greens, tees, 
and fairways. 
 
There was only one N-N RT exceedance during routine sampling events in 2024. The 
nitrogen fertilizer applications are very low and below typical industry rates during normal 
operational periods. It is hard to imagine that the N fertilizer applications could be the only cause 
of the N-N RT exceedances, especially at the background/reference station, which also has had 
an RT exceedance. There has been much ground disturbance over the last several years and 
recently, which provides another reasonable explanation for the N-N RT exceedances. The 
combination of the two is likely the cause of the N-N RT exceedances. In any case, the average 
N-N concentration for the three remaining on-site stations combined is well below 2.0 ppm 
(0.44 ppm, std ±0.43, n=370, includes all resampling events). 
 
Recommendations 
 
We recommend that monitoring for nitrate-nitrogen and turbidity at the Hudson National 
Golf Course be reduced to monitoring surface water at only one station: SW-3A (see discussion 
in Section IV.C). In addition, we recommend that the monitoring be done annually during the 
spring base flow instead of three times a year. The background/reference station SW-6 will be 
monitored for N-N as long as on-site stations are monitored. 
 
Monitoring for N-N is required under the EMP at two on-site stations (SW-1 and SW-4) 
through 2027, at one on-site station (SW-3A) through 2029, and at the off-site station SW-6 (as 
long as monitoring on-site continues) in accordance with the EMP. However, we recommend 
that monitoring at stations SW-1 and SW-4 be stopped because those stations do not flow to any 
significant body of water and do not provide any useful information about golf course fertilizer 
management.  
 
We continue to recommend that no more than 1,000 lb N total be applied between 
October 15 and early spring (April 1). Appendix C provides the cover letter and the amended 
“Fertilizing” section of the EMP that was submitted January 17, 2017. 
 
EXECUTIVE SUMMARY .............................................................................................................. 2 
I. 
INTRODUCTION ................................................................................................................ 8 
II. 
TURF CHEMICAL APPLICATIONS, SOIL AND TISSUE TESTING .......................... 11 
A. 2024 Nutrients and Pesticides Applications ........................................................................ 11 
1. 
Fertilizer Applications ...................................................................................................... 11 
2. 
Pesticide Applications ...................................................................................................... 12 
B. Soil and Tissue Testing ........................................................................................................ 12 
III. 
SELECTION OF ANALYTES, REFERENCE CRITERIA, SUMMARY OF 2024 
SURFACE WATER QUALITY RESULTS, AND QA/QC .......................................................... 13 
A. Selection of Analytes ........................................................................................................... 13 
B. Reference Concentrations and Response Thresholds .......................................................... 13 
C. Results and Summary of 2024 Sampling Events ................................................................. 14 
1. 
Spring Sampling Events ................................................................................................... 15 
2. 
Summer Sampling Events ................................................................................................ 15 
3. 
Fall Sampling Events ....................................................................................................... 15 
D. Trends and Comparison of the 2024 Surface Water Results with Reference Criteria......... 16 
E. 
Quality Assurance/Quality Control...................................................................................... 18 
1. 
Field Personnel and 2024 QC........................................................................................... 18 
2. 
Laboratory ........................................................................................................................ 19 
IV. 
TRENDS AND STATISTICAL ANALYSES ................................................................... 23 
A. Methods................................................................................................................................ 23 
B. Parameter Trends and Statistical Comparisons.................................................................... 23 
1. 
pH ..................................................................................................................................... 23 
2. 
Nitrate-Nitrite Nitrogen .................................................................................................... 24 
C. Station SW-3A Nitrate-Nitrogen Concentration Trends...................................................... 26 
V. 
CONCLUSIONS AND RECOMMENDATIONS ............................................................. 28 
A. Nitrate-Nitrite Nitrogen ....................................................................................................... 28 
B. Turf Management................................................................................................................. 29 
C. Continued Monitoring .......................................................................................................... 29 
D. Monitoring Recommendations............................................................................................. 30 
E. 
EMP Amendment Recommendation ................................................................................... 30 
REFERENCES ............................................................................................................................... 32 
FIGURES ................................................................................................................................... Fig-1 
APPENDIX A. Superintendent’s 2024 Report ............................................................................. A-1 
APPENDIX B. 2024 Soil and Tissue Results ............................................................................... B-1 
APPENDIX C. 2000 EMP Fertilizing Section with 2011 and 2017 Amendments ...................... C-1 
 
LIST OF TABLES 
 
Table III-1. Corrected Response Thresholds .............................................................................. 13 
Table III-2. Water Quality Results for the Surface Water Monitoring Stations - 2024 ............. 20 
Table III-3. Exceedance of the Response Thresholds for Surface Water Stations – 2024 ......... 21 
Table III-4. Mean Concentrations - Surface Water Monitoring Stations Compared with RCs, 
RTs, and EPA Ecoregional Criteria (EPA, 2001) - 2024 ............................................................. 21 
Table III-5. Comparison of the On-site Stations’ Mean Concentrations (Combined) with the 
Background Station - 2024 ........................................................................................................... 22 
Table IV-1. Test of Significance (p-values): SW-1, SW-3A, and SW-4 Compared With SW-6 
(2015-2024). SW-6 ....................................................................................................................... 24 
Table IV-2. Comparison of the Average N-N Concentrations – 2023 vs. 2024 On-Site Stations, 
Cumulative and 2024 On-Site Stations vs. SW-6 ......................................................................... 25 
Table IV-3. Test for Significance (p-values) - Average Nitrate-Nitrogen Concentrations 
Between the On-site Stations (2002-2024) ................................................................................... 26 
Table IV-4. Comparison of the Average Nitrate-Nitrogen Concentrations of the Seasons and 
Flow Types at SW-3a (2002-2024)............................................................................................... 27 
Table IV-5.  Station SW-3A Student’s T-test (p-values) for Significance Between the Seasons 
and Flow Types for the Nitrate-Nitrogen Concentrations (2002-2024) ....................................... 27 
Table V-1. Nitrate-Nitrite Nitrogen RT Exceedances (1999-2024) ............................................. 28 
Table V-2. Years N-N Exceeded Corrected Response Thresholds .............................................. 30 
Table V-3. Projected End of N-N Monitoring Period for Remaining Stations ............................ 30 
 
LIST OF FIGURES 
 
Figure V-1. N-N Concentration Trends - On-Site Average vs. SW-6 .......................................... 31 
Figures and Appendices ................................................................................................................ 33 
Figure III-1. HNGC Surface Water – pH – 2024............................................................................ 2 
Figure III-2. HNGC Surface Water – Temperature – 2024 ............................................................ 3 
Figure III-3. HNGC Surface Water – Specific Conductance - 2024 .............................................. 4 
Figure III-4. HNGC Surface Water – Turbidity – 2024 ................................................................. 5 
Figure III-5. HNGC Surface Water – Nitrate-Nitrite Nitrogen - 2024 ........................................... 6 
Figure IV-1. HNGC Surface Water – pH – Cumulative 1999-2024 .............................................. 7 
Figure IV-2a. HNGC Surface Water – Nitrate-Nitrite as Nitrogen – Cumulative 1999-2024 SW-
1, SW-3A, and SW-4 vs. SW-6 ...................................................................................................... 8 
Figure IV-2b. HNGC Surface Water – Nitrate-Nitrite as Nitrogen – 10 Yr Monitoring Trends 
(2015-2024)..................................................................................................................................... 9 
 
I. 
 
The Environmental Management Plan (EMP; Turf Science Group [TSG], 2000) was 
developed to establish an environmental management and monitoring program for the Hudson 
National Golf Club (HNGC). Monitoring over the last 29 years (1996-2024) has included ground 
water from on-site monitoring wells and off-site residential wells, surface water (on-site and off-
site), and pond sediments for pesticides, nutrients, and inorganics. The monitoring program has 
been reduced over time due to minimal environmental issues, and it currently includes nutrient 
monitoring at four of the original seven surface water monitoring stations (three on-site and one off-
site), as described in this report. All monitoring of ground water, three surface water stations, and 
the pond sediment stopped because those monitoring requirements have been fulfilled in 
accordance with the EMP.  
 
Parameters were selected and analyzed prior to golf course operations to provide a water 
quality baseline. The monitoring program helps ensure that the golf course is being maintained in 
an environmentally responsible manner and that the surrounding water quality is protected. 
 
Sampling Criteria
 
. Procedures and field methods for Phase III (operational monitoring phase, the 
current phase) are detailed in the EMP (2000 and as amended). The management plan requires that 
surface water samples for storm flow be collected by the grab method between 4 and 10 hours 
following the accumulation of ¼ inch (0.25") of rainfall for the spring and fall sampling events. The 
summer storm flow event samples are collected between 2 and 8 hours following the accumulation 
of 0.25" of rainfall (the shorter response time in the summer is due to the higher intensity storms). 
Base flow samples are also to be collected by the grab method during the spring, summer, and fall 
when it has not rained for at least 48 hours preceding the sampling event.  
Reporting
 
. Individual sampling event reports are issued throughout the year. However, in 2024 
only one report was issued for all sampling events because some of the data needed for a proper 
evaluation was not receive in a timely manner. In addition, the EMP requires comprehensive annual 
reports. This annual report describes the 2024 monitoring results for the four remaining surface 
water stations: SW-1, SW-3A, and SW-4 (on-site), and SW-6 (off-site). The data provided in this 
report include field notes, summary tables of analytical results, and graphical comparisons of results 
with response thresholds (RTs).  
The first year of Phase III (1996) operational monitoring results was presented in a previous 
report by the Turf Science Group (TSG), and reviewed by Environmental & Turf Services, Inc. 
(ETS). ETS took over as the study directors after the first year of operational phase monitoring (i.e., 
Phase III), and has prepared the operational phase annual reports for the last 28 years (1997-2024). 
The 2000 EMP includes the results of baseline (Phase I) and construction (Phase II) phases of 
monitoring. This 2024 report represents the 29th year of operational golf course monitoring. 
However, the ‘official’ operational monitoring program began with the “satisfactory completion of 
all drainage systems and water quality basins” (TSG, 2000). That condition was satisfied on August 
31, 1999 (Gallelli and Ioannou, 2002). Thus, we use data from September 1999 through the current 
year for statistical analyses of the monitoring data. In addition, we use the seasonal data at station 
SW-3A from 2004-2024 to evaluate trends for each season for continued monitoring at that station. 
 
Termination of Monitoring
 
. The critical initial five years of operational phase monitoring at 
HNGC ended on August 31, 2004 for those parameters that had not exceeded the RTs, in 
accordance with the 2000 EMP at that time. Thus, all pesticide monitoring requirements were 
fulfilled following the completion of the 2004 summer monitoring events (base flow and storm 
flow) at all surface water and ground water monitoring stations. Inorganic monitoring requirements 
were fulfilled for all off-site residential ground water stations following the 2004 summer sampling 
event, and on-site well monitoring requirements were fulfilled following the 2007 winter sampling 
event in accordance with the EMP (2011). Consequently, all ground water monitoring stopped 
following the 2007 winter sampling event. Monitoring at the remaining surface water stations will 
cease when the monitoring requirements have been fulfilled in accordance with the EMP (2011). In 
addition, monitoring at surface water stations SW-2 and SW-3B ended in 2009 and 2007, 
respectively, because their monitoring requirements had been fulfilled. Monitoring at SW-5 stopped 
following the fall sampling in 2021. In addition, monitoring for total phosphorus (TP) at all surface 
water stations stopped following the completion of monitoring in 2021.  
Access to Results
 
. The results for each of the 2024 sampling events are described in the following 
sections. All of the lab’s analytical results were provided to the Village in one report (ETS, 2025) 
and will not be reproduced in this annual report except as a summary in the tables. Section II 
provides information relevant to golf course management and soil/tissue testing. Section III 
provides the details of the 2024 surface water monitoring program followed by a summary of the 
results. The surface water trends are described in section IV and the conclusions and 
recommendations are provided in Section V. The analytical results are also shown graphically in 
the figures section at the end of this report. The appendices follow the figures section. 
2024 Sampling Dates and Compliance with Sampling Criteria
 
. Base flow samples were 
collected on May 21st (spring), July 31st (summer), and October 10th (fall). Samples were collected 
on December 16th to represent a fall storm flow event during 2024; however, it was not a qualifying 
storm (see Section III below) in accordance with the EMP. There were no qualifying storm events 
during the spring or summer seasons. There was no resampling event following the RT exceedance 
in the spring because we did not receive the results until August, which is outside of the guidelines 
for resampling. Samples were analyzed for nitrate-nitrite as nitrogen (N-N) and turbidity. Field 
parameters (pH, temperature, and specific conductance) were measured when samples were 
collected.  
 
All results were provided to the Village in our letter report for the spring, summer, and fall 
sampling events in January 2025 (ETS, 2025) as explained above. 
 
Nutrient Management Amendment
 
. The nutrient management portion of the EMP (2000; i.e., 
fertilizer applications, soil/tissue sampling) was amended in 2011 (ETS, 2011). This was done in 
order to update the turf management strategies. The Planning Board-approved amended nutrient 
management program was implemented in July 2011.  
 
As reported in our 2016 annual monitoring report, the total amount of fertilizer used in 2016 
was in accordance with the amended nutrient management program, but the application timing led 
to water quality exceedances, which resulted in an additional amendment to the EMP. See below 
for more details. An EMP amendment for fertilizer restrictions was approved in 2017 (ETS, 2017a). 

The reduction in fertilizer applications for the fall through the winter months was implemented 
during the fall of 2017, and has continued through 2024. 
 
Approved Amendments to the EMP – Fertilizer Applications 
 
The superintendent’s application records indicate that he complied with the following 
amendments. 
 
We recommended that fertilizer applications incorporate some of the newer products (e.g., 
Earthworks™ and Perdue PPM) and that single application rates be reduced to no more than 0.5 lb 
N/1,000 sq ft in keeping with the EMP (2000)
Amendment 2011 – Fertilizer Application Reduction (all areas) 
*
 
. Fertilizer applications should be delayed if heavy 
rainfall is forecast. Total applications should not exceed 3.0 lb N/1000 sq ft during a growing 
season. This is a reduction of the total N applications allowed (i.e., 4-5.5 N/1,000 sq ft) in Table 3 
of the EMP (2000). 
 
Multiple “spoon feeding” applications of 0.1 lb N/1,000 sq ft should be used on greens, tees, 
and fairways during the optimum growing season (April-October). Fertilizer applications can be 
tank mixed with fungicide applications on two week intervals. These low nutrient rates have little 
risk of runoff and can be extremely beneficial to plant health especially with the management of 
anthracnose disease on putting greens. 
 
Phosphorus and potassium applications should be based on the results of the soil and/or 
tissue sample results. 
 
No more than 1,000 lb of N may be applied between October 15 and early spring (April 1). 
Amendment 2017 – Total N – Additional Fertilizer Application Restrictions 
 
Reason for Additional Fertilizer Application Restrictions of Total N  
 
It appears that the N applications made prior to the fall sampling events in 2016 were the 
cause of the N-N RT exceedances at all on-site stations and the cause of one TP exceedance in 2016 
(see our 2016 fall letter report, ETS, 2017b).  
 
It is important to note that the turfgrass in that region of the country is probably not actively 
growing after early to mid-November. This means that N that is applied during and after this time is 
more available to runoff near the soil’s surface than N that is applied, e.g., in May. Therefore, 
applications are not to exceed 1,000 total lb nitrogen after October 15 until early spring to help 
prevent N-N RT exceedances at the surface water stations. 
                                                        
* This 0.5 lb N/1000 ft2 limit should be relaxed in the future; after all N exceedance problems have been resolved. Specifically, we 
recommend that the future limit on single applications of certain controlled release N fertilizers such as POLYON® be raised to 1.5 lb 
N/1000 ft2, if it can be established that such release occurs over a period averaging at least 12-16 weeks. This change should be 
considered the next time the EMP is modified, but not at this time. Approval provided relief of this restriction in 2020 (see 
ETS,2021). 

II. 
TURF CHEMICAL APPLICATIONS, SOIL AND TISSUE TESTING 
 
A. 
2024 Nutrients and Pesticides Applications 
 
Brett Scales submitted the nutrient and pesticide application schedules and his nutrient 
management plan for 2024 (Appendix A). Those schedules provide details of the dates and rates of 
applications for the pesticide and fertilizer products used in 2024, and the specific locations where 
each product was applied. The NYSDEC now requires that the Superintendent input all pesticide 
applications into the NYSDEC’s online software. Thus, we no longer have a DEC log from the 
Superintendent. We summarized the fertilizer application schedule below. Although pesticides are 
no longer part of the monitoring program, we monitor their use to ensure compliance with the EPM, 
and those used in 2024 are listed below and shown in Appendix A.  
 
1. 
Fertilizer Applications  
 
Greens and Tees
 
. There were 15 nitrogen fertilizer applications made to the greens using three 
different formulations April through September: 20-20-20 (9); 7-7-7 (2); and 28-8-18 (4). 
Additional fertilizer applications that contained only potassium using the formulation 0-0-52 were 
applied to the greens. [The number in parentheses is the number of applications that was made to 
the area of turf described using that formulation. The numbering system refers to the percent of 
nitrogen, phosphorus, and potassium, in that order (N-P-K).] These applications yielded rates of: 
2.75 lb N/1,000 sq ft; 2.462 lb P/1,000 sq ft; and 5.262 lb K/1,000 sq ft to the greens. All of the 
individual applications during the growing season (April-September) were made at relatively low 
rates (e.g., spoon-feeding at rates of 0.1 - 0.5 lb N/1,000 sq ft). These numbers are relatively low, 
and they indicate that the superintendent, Mr. Scales, is managing the course in a relatively lean 
manner. 
 
Nitrogen fertilizers were applied to the tees 12 times using four formulations April through 
September: 5-7-5 (1) and 28-8-18 (11). Eight additional fertilizer applications that contained only 
potassium using the formulation 0-0-52 were applied to the tees.  These applications to the tees 
yielded rates of: 1.6 lb N/1,000 sq ft; 1.008 lb P/1,000 sq ft; and 2.713 lb K/1,000 sq ft. Most of the 
individual nitrogen applications were made at relatively low rates (e.g., spoon-feeding at rates of 
0.1-0.5 lb N/1,000 sq ft). The larger application of 0.5 lb N/1,000 sq ft was made to the tees for the 
spring application in May. 
 
The total N applications to the greens turf was below the 3.0 lb N/1,000 sq ft recommended 
in the original 2000 EMP. The Superintendent had reported that heading into the 2023 season that 
the golf course would be closing for a restoration project starting July 5th 2023. The restoration 
project would include replacing USGA spec greens, replacing the irrigation system, replacing all 
sand traps, and re-grassing tees, approaches and fairways. That project was completed prior to the 
start of sampling in 2024. 
 
Fairways and Roughs. There were 19 nitrogen fertilizer applications made to the fairways using 
four formulations April through September: 28-8-18 (8) and 46-0-0 (11). Six additional fertilizer 
applications that contained only potassium using the formulation 0-0-52 were applied to the 
fairways. These applications yielded total rates of: 1.77 lb N/1,000 sq ft, which is very low for 
fairways; 0.14 lb P/1,000 sq ft; and 0.897 lb K/1,000 sq ft. Individual applications for the fairways 

of nitrogen (N) were made at low rates (e.g., spoon-feeding at rates of 0.07-0.11 lb N/1,000 sq ft). 
There were no large spring or fall applications made to the fairways. 
 
One fertilizer application was made to the roughs using formulation: 22-0-5 (1) for total of 
1.42 lb N/1,000 sq ft, 0.0 lb P/1,000 sq ft, and 0.4 lb K/1,000 sq ft. This application was made to 35 
A of roughs.  
 
2. 
Pesticide Applications 
 
Approximately 19 different pesticide products containing 23 different active ingredients, 
which are consistent with the EMP as amended, were applied from April through late November of 
2024 to the greens, tees, and fairways, and roughs through September. However, not all products 
were applied to all types of turf. Some of the products contain more than one active ingredient. 
Fungicide active ingredients and growth regulator products were applied to the greens, tees, and 
fairways; herbicides and fungicides were applied to the roughs during 2024 (See Appendix A for 
details). No insecticides were used in 2024.  
 
B. 
Soil and Tissue Testing  
 
The soil and tissue analyses help the superintendent maintain healthy turf, which will result 
in less pesticide use and more efficient nutrient uptake. The soil and tissue results show no 
excessive nutrients in the soil or tissue samples (i.e., turf). See Appendix B. 
 
III. 
SELECTION OF ANALYTES, REFERENCE CRITERIA, SUMMARY OF 2024 
SURFACE WATER QUALITY RESULTS, AND QA/QC 
 
A. 
Selection of Analytes 
 
The core five years of operational phase monitoring at HNGC ended August 31, 2004 for 
those parameters that had not exceeded the response thresholds (RTs) as described in the EMP (e.g., 
pesticides). Monitoring continues today as a result of RT exceedances (as corrected in 2012) in 
surface water at selected stations and for selected parameters (e.g., nitrate-nitrite nitrogen). 
Therefore, all 2024 surface water sampling events consisted of analyses for nitrate-nitrite as 
nitrogen (N-N), turbidity, and field parameters (pH, temperature, and specific conductance) under 
base flow conditions during the spring, summer, and fall, and under storm flow conditions during 
the fall; however, as stated above the fall storm samples did not qualify in accordance with the EMP 
(see below). There were no qualifying storm flow sampling events during the spring and summer.  
 
Four surface water stations were sampled as part of the 2024 monitoring program at the 
HNGC: three on-site stations (SW-1, -3A, and -4) and one off-site/background station (SW-6).  
 
B. 
Reference Concentrations and Response Thresholds 
 
Two important types of reference points are discussed in this report: reference 
concentrations (RCs) and response thresholds (RTs). RCs refer to spatial background points in 
space (SW-6) and time (pre-construction). RTs are action/threshold concentrations that require 
some type of management response, i.e., resampling or use restrictions. [Note
 
: Several houses were 
constructed upslope from the station that is used as background (i.e., SW-6) after monitoring began. 
Therefore, station SW-6 is no longer a true background station, i.e., it has been impacted by outside 
cultural practices. However, it can still be used as a background station relative to golf course 
management for surface water at the HNGC because golf course management does not affect 
station SW-6.] 
 
See Table III-1 below for the RTs used to evaluate resampling of N-N only (ETS, 2013). All 
results 1999 through 2024 and continuing are compared with the corrected RTs to determine 
whether monitoring should be extended (see section V) and/or resampling is warranted. Station 
SW-5 was removed from our evaluation since it is no longer monitored in accordance with the 
EMP. 
 
Table III-1. 
Corrected Response Thresholds 
Monitoring Stations → 
SW-1 
(mg/L) 
SW-3A 
(mg/L) 
SW-4 
(mg/L) 
SW-6 
(mg/L) 
Parameter → 
nitrate-nitrite as nitrogen 
Corrected (2012) RT values* 
0.89 
0.57† 
0.38 
0.31 
* The corrected RT values are based on the original baseline sampling results and recalculated as two standard 
deviations above the mean. 
† This value was calculated correctly and remains unchanged. 
 
The EMP provides criteria for management response (i.e., resampling and chemical use 
restrictions) for RT exceedances of N-N for each monitoring station (ETS, 2012). The resampling 

triggers (i.e., exceedance of an RT) were revised in order to include an evaluation of additional 
criteria to determine if resampling is necessary. The additional criteria consisted of a statistically 
significant increasing trend for TP and/or N-N, sample collection under the same flow condition 
(e.g., storm or base flow), sampling within the same season, and sampling within a reasonable 
amount of time (i.e., 2-3 weeks following results; ETS, 2012). A review of management practices 
(e.g., application of fertilizers), site conditions, and weather conditions, may help determine the 
reason for the unexpected increased concentrations, which also includes major construction on the 
turf areas (e.g., removing turf and reseeding certain areas). 
 
C. 
Results and Summary of 2024 Sampling Events 
 
Four routine surface water sampling events occurred during the spring, summer, and fall of 
the 2024 calendar year: three were under base flow conditions and one under storm flow conditions. 
See Table III-2 at the end of this section for results. 
 
 Qualifying base flow samples were collected on May 21st (spring), July 31st (summer), and 
October 10th (fall). Fall storm flow samples were collected on December 16th; however, this was not 
a true qualifying storm event based on the data from on-site weather station. There were no 
qualifying storm flow samples during the spring or summer.  
 
Temperature, pH, and specific conductance were measured in the field during each sampling 
event at each station sampled. Inorganic parameters analyzed in the lab included N-N and turbidity. 
Those five parameter results are graphically depicted in Figures III-1 through III-5 for 2024. The 
results tables are presented at the end of this section (Tables III-2 through III-5). All figures are 
presented at the end of this report. 
 
Table III-2 provides the analytical results and field measurements for 2024 compared with 
respective reference criteria (i.e., RCs and RTs). Table III-3 provides a list of the stations that 
exceeded reference criteria. Table III-4 provides the average concentrations, standard deviations 
(std), and the number of samples (n) that were used to perform the statistical calculations for 2024. 
Table III-5 shows the combined average concentrations for the on-site stations compared with the 
background station. Detailed results are described below for each sampling event. 
 
The EMP requires that base flow samples be collected when there has been no rain for 48 
hours prior to sampling. This criterion was met during all three base flow sampling events. The 
EMP requires that spring and fall storm flow samples be collected between 4 and 10 hours 
following the accumulation of 0.25” of rain (i.e., first flush). The field team determined that there 
were no opportune times or the rain accumulation did not meet the storm criteria to collect storm 
flow samples during the spring of 2024. The EMP requires that storm flow samples during the 
summer be collected 2 to 8 hours following the accumulation of 0.25” of rain. The field team 
determined that conditions were not met for summer storm flow sampling. Fall storm flow samples 
were collected; however, they were not collected within the storm criteria as explained below using 
the on-site weather station data.  
 
1. 
Spring Sampling Event 
 
Routine Sampling Event – May 21, 2024 (Base Flow) 
 
The results show that nitrate-nitrogen (N-N) was detected at two on-site stations: SW-1 at 
0.356 ppm and SW-3A at 1.31 ppm (average of duplicate samples). The N-N response threshold 
(RT) of 0.57 ppm was exceeded at SW-3A; however, due to the late arrival of the results (i.e., 
received in August) and the earthwork done in 2023 no resampling was done. We have noted in the 
past that major earthwork causes release of nutrients in the ground water and to the nearby surface 
water sampling stations. Thus, no resampling will be done and we will continue to monitor the N-N 
at all station to determine when the concentrations will return to baseline levels, as recommended 
by Daniel O’Connor. See Table III-2 for results. 
 
The turbidity ranged from 2.1 NTUs (SW-1) to 6.7 (SW-4). Turbidity was also detected in 
the field blank sample at 0.175 NTUs and in the trip blank sample at 0.430 NTUs (LOQ = 0.1 
NTUs). The sample water for the field blank is lab water sent with the samples and poured into a 
bottle on-site and the trip blank sample is filled at the lab and the bottle is not opened in the field.  
 
The pH was measured at all stations: 6.8 (SW-1), 7.07 (SW-3A), 6.86 (SW-4), and 7.01 
(SW-6; Table III-2). The pH values are within the desirable range (6.5-8.5) at all three on-site 
stations and the off-site station. Thus, these values are acceptable. 
 
2. 
Summer Sampling Events 
 
Routine Sampling Event – July 31, 2024 (Base Flow) 
 
The results show that N-N was detected at three on-site stations: SW-1 at 0.489 ppm, SW-
3A at 0.343 ppm, and 0.195 ppm at SW-4 (average of duplicate samples). The N-N RT was not 
exceeded at any station. In addition, the N-N concentration at SW-3A was lower during this event 
than during the spring. Thus, no resampling is warranted. See Table III-2 for results. 
 
The turbidity ranged from 1.6 NTUs (SW-1) to 11.25 (SW-4). Turbidity was not detected in 
the field blank sample; however, the trip blank sample showed a concentration of 0.130 NTUs 
(LOQ = 0.1 NTUs). The detection of turbidity in the trip blank is of little consequence to the 
results. 
 
The pH was measured at all stations: 6.26 (SW-1), 7.04 (SW-3A), 6.64 (SW-4), and 7.24 
(SW-6; Table 2). The pH values are within the desirable range (6.5-8.5) at two on-site stations and 
the off-site station; however, it was slightly below the lower range at SW-1. These values are 
acceptable. 
 
3. 
Fall Sampling Events 
 
Routine Sampling Event - October 10, 2024 (Base Flow) 
 
 The results show that N-N was detected at two on-site stations: SW-1 at 0.713 ppm and 
SW-3A at 0.218 ppm (average of duplicate samples). The N-N RT ppm was not exceeded at any 
station. Thus, no resampling is warranted. See Table III-2 for results. 
 
The turbidity ranged from 2.3 NTUs (SW-1) to 17.0 (SW-4). Turbidity was not detected in 
the field blank sample or the trip blank samples. A value of 17.0 NTUs at SW-4 cannot be seen 
visually. Thus, this concentration is likely of no consequence to the results. 
 
The pH was measured at all stations: 6.90 (SW-1), 7.07 (SW-3A), 6.67 (SW-4), and 6.9 
(SW-6; Table III-2). The pH values are within the desirable range (6.5-8.5) at all on-site stations 
and the off-site station. These values are acceptable. 
 
Routine Sampling Event – December 16, 2024 (Storm Flow) 
 
Although this was not a qualify storm event in the strictest sense, we will use the results 
because there was rain in the area. This is not considered a qualifying storm event because rain was 
not recorded at the on-site weather station. In any case, the results show that N-N was detected at 
low concentrations at the three on-site stations: SW-1 at 0.425 ppm, SW-3A at 0.241 ppm, and SW-
4 at 0.155 ppm (ave. of duplicate samples). The N-N RT was not exceeded at any station. Thus, no 
resampling is warranted. See Table III-2 for results. Sampling results are used for this event  
 
The turbidity ranged from 2.9 NTUs (SW-1) to 9.0 (SW-4, ave. of duplicate samples). 
Turbidity was detected in both the field blank (0.71 NTUs) and the trip blank (0.35 NTUs) samples. 
These values do not affect the results. 
 
The pH was measured at all stations: 7.04 (SW-1), 6.89 (SW-3A), 6.91 (SW-4), and 6.21 
(SW-6; Table III-2). The pH values are within the desirable range (6.5-8.5) at all on-site stations, 
however, the pH is slightly below the lower end of the range at the off-site station. These values are 
acceptable. 
 
D. 
Trends and Comparison of the 2024 Surface Water Results with Reference Criteria 
 
Table III-3 shows the number of times a station exceeded its response threshold (RT) and its 
reference concentration (RC) for each parameter. Comparisons of the average concentrations for the 
relevant parameters are presented in Table III-4. Table III-5 shows the comparisons of the 2024 
mean concentrations for four parameters described below: average of all of the combined on-site 
stations’ mean concentrations compared with SW-6, the background station. In addition, Table III-5 
shows whether the mean concentrations of the combined on-site stations’ mean concentrations are 
statistically significantly different or the same as SW-6 for the parameters. 
 
The 2024 surface water monitoring results are presented in Figures III-1 through III-5. The 
lines connecting each data point may not truly represent a continuous increase or decrease over time 
for any parameter at a particular point in time. Rather, each point should be viewed as a “snapshot” 
in time, and any possible change in a parameter should be viewed over the entire dataset. In 
addition, any station that was not sampled or an analyte not analyzed during a particular sampling 
event is not represented by a data point on the figures, and non-detects are represented by one-half 
the quantitation limit/method reporting limit. 
 
Comparisons of results with response thresholds for pH, N-N, specific conductance and 
turbidity are discussed below. 
 
pH
 
The pH at all four stations ranged from 6.21 (SW-6) to 7.24 (SW-6) during the four routine 
sampling events. Note that the pH minimum and maximum range were both at the off-site station. 
The average pH at the background station (SW-6) for 2024 was 6.84 (std = ± 0.44, n = 4). This is 
about the same as the overall average pH at the three on-site stations combined during the 2024 
sampling events (6.85, std = ± 0.23, n = 12; Table III-4). 
. The pH is measured in the field at the time of sampling at each sampled station. The RT for pH 
is any value outside the 6.5 to 8.5 desirable ranges. However, the pH range is not an enforceable 
one because acidic rain in this area affects all of the stations, including the background station SW-
6 (i.e., acid rain is most likely the cause of the lower pH: <6.5). The 2024 pH results are depicted in 
Figure III-1. 
 
 The value range for pH (6.5-8.5) is a desirable range and not an enforceable parameter. 
Therefore, we only make a comparison with previous years and show trends. 
 
Temperature and Specific Conductance
 
. Temperature and specific conductance (SC) data are 
measured field parameters along with pH (Table III-2). Figures III-2 and III-3 illustrate temperature 
and specific conductance, respectively for 2024. Temperature is directly related to seasonal 
variations of air temperature, and SC is, generally, directly related to fluctuations of total dissolved 
solids (TDS; i.e., if TDS increases, then SC should increase). TDS is not measured in surface water, 
but the SC can still be used as a general guide for dissolved solids in the water.  
 
Figure III-3 shows that specific conductance fluctuates seasonally at the three on-site 
stations and the trend at SW-6 shows a decreasing trend from spring to fall. Neither of these 
parameters (temperature and specific conductance) is used for responding to exceedances of water 
quality standards; however, they are measured and reported as a general practice to enhance our 
understanding of the hydrologic system. 
 
Turbidity
 
. Turbidity is a measure of cloudiness or the amount of undissolved particles/sediment in 
the water (Table III-2). Figure III-4 depicts the turbidity at all surface water monitoring stations for 
2024. The values ranged from 1.6 to 17 NTUs during the routine sampling events. These values are 
not likely visible to the eye. The 2024 average for all on-site surface water stations was low: 5.7 
NTUs (std = ± 4.7 NTUs, n=12). The average turbidity at the background station SW-6 was slightly 
lower than the on-site stations: 5.2 NTUs (std = ± 2.1 NTUs, n=4). None of the stations exceeded 
their RTs during 2024 (Table III-2). Turbidity trends over the course of the year varied. There are 
no management responses to RC or RT exceedances of turbidity.  
Nitrate/Nitrite-Nitrogen (N-N)
 
. The 2024 N-N results are illustrated in Figure III-5 and listed in 
Tables III-2 through III-5. The on-site concentrations ranged from ND (<0.1 ppm) to 1.3 ppm (SW-
3A) during the four monitoring events. Only one station exceeded its N-N RTs during the four 
sampling events (SW-3A, Table III-2). The background station SW-6 had no detectable N-N 
concentrations during any event.  
 
The average N-N concentration for all on-site surface water monitoring stations in 2024 is 
0.38 ppm (std = ± 0.35 ppm; n=12). The overall on-site average N-N concentration was lower than 
in 2023 (0.56 ppm, n=12) and in 2022 (0.68 ppm, n= 11). This indicates a decreasing N-N trend at 
the on-site stations. The N-N concentration at the background station SW-6 in 2024 was less than 
the detection limit (i.e., <0.1 ppm) during all sampling events. Thus, showing an average 

concentration has little meaning. The difference in the mean concentrations between the on-site 
stations and SW-6 is significantly different (p = 0.008) for 2024 (see Table III-5), which is not 
surprising since N-N was not detected at SW-6 during 2024.  
 
E. 
Quality Assurance/Quality Control 
 
The HNGC monitoring study was designed and is conducted with high standards of quality 
control. As such, a comprehensive quality assurance/quality control (QA/QC) program has been 
established to ensure the integrity of the data gathered. The QA/QC program established for this 
monitoring study is in the spirit of EPA’s Good Laboratory Practice Standards (GLPs; 40 CFR
 
 Part 
160). GLPs were developed to create uniformity from study to study and to help ensure the quality 
of data collected. Listed below are the most important parts of the QA/QC program that field and 
lab personnel must follow. Pages 65-72 of the EMP (2000) describe the requirements of the QA/QC 
program for this monitoring study.  
1. 
Field Personnel and 2024 QC 
 
WSP USA (WSP, White Plains, NY), collects all of the surface water samples for the 
monitoring program. WSP (formerly known as LBG) has been collecting water samples at HNGC 
since December 1997. A major advantage of having the same field team associated with this project 
for so many years is that the same competent personnel typically collect and/or manage collection 
of the samples. Therefore, field personnel are familiar with the project site, the EMP (and 
amendments as they pertain to sampling), and the sample collection procedures. This helps to 
ensure that quality control is being maintained at every event. 
 
The most important QC procedures that field personnel must follow include calibrating field 
instruments, using properly cleaned sample collection devices at each station, taking field notes 
during the time of collection that state where the sample was collected, and noting the time and date 
of collection. In addition, icing and shipping samples to the laboratory without delay and accurately 
completing the chain-of-custody forms are important. Pages 68 and 69 of the EMP provide 
additional field QC procedures to prevent sample contamination during the time of collection and to 
help ensure the overall integrity of the study (e.g., the inner portion of the sample bottles and caps 
should not be touched with bare hands, gloves or mitts, etc.). In addition, since we started using a 
local lab, samples are delivered the same day they are collected or the following morning, which 
eliminates holding time violations or lost in transit samples. 
 
The field notes/sheets for 2024 were good. The sample bottles were delivered to the lab by 
WSP immediately after sampling or the following morning for each event. The samples were 
delivered to the lab in good condition and properly preserved on ice for all sampling events. 
 
Fall storm samples should not have been collected (December 16, 2024) based on the data 
from the on-site weather station. However, the WSP field team did not have access to the on-site 
weather station that morning, but was conscientious enough to access the local weather station to 
determine if there was sufficient rain to qualify for a fall storm event since it was raining in the 
area. In any event, the results can be used. 
 
2. 
Laboratory 
 
Overall, the lab QC was good throughout 2024. We changed labs in 2022 from Eurofins 
Eaton Analytical, Inc. (Eaton, South Bend, IN), to York Analytical Laboratory (York; CT) because 
of reduced analyses and on-time delivery issues. The lab QA/QC is perhaps the most important part 
of this comprehensive QA/QC program.  
 
The lab is required to run several QC sample analyses that help identify sources of sample 
contamination during the collection and analysis process. This process includes lab equipment, field 
sample bottles, etc., to ensure that the lab equipment is properly calibrated and that chemical 
analytes are correctly identified and quantified. The lab results would be less meaningful, and the 
concentrations of detections would be in doubt, without these additional analyses. The following 
QA/QC samples are required by the EMP and analyzed by the lab: lab blanks, field blanks, and 
duplicate samples. For an explanation of each sample type, refer to page 70 of the EMP (TSG, 
2000). Additionally, matrix spike (MS) and MS duplicate (MSD) samples are collected in the field 
to help identify poor lab equipment performance due to matrix interference (e.g., sediment in the 
water). The field team rotates these samples between stations and events; however, it is sometimes 
necessary to collect duplicate samples at the same station from the previous event due to low or no 
flow. The lab also performs continuing calibration checks on lab equipment to guarantee equipment 
accuracy. 
 
York labs uses the term limit of quantitation (LOQ), which is comparable to the method 
reporting limit (MRL) used by Eaton labs, which is virtually the same as a detection limit. It is the 
minimum concentration of a target analyte that can be reported within a specified degree of 
confidence. 
 
The lab was negligent in submitting the May (spring base flow) results in a timely manner; 
however, samples at SW-3A for the N-N RT exceedance would not have been resampled due to the 
major earth work done on the golf course in 2023. 
 
The duplicate samples collected during all four of the sampling events compared well for N-
N. The matrix spike (MS) and MS duplicate recoveries for the N-N data compared well for the base 
flow sampling events and were within the acceptable recovery ranges. However, the MS/MSD 
recoveries for N-N during the fall storm flow showed slightly high biased recoveries at 112% for 
the range of 90-110% for both MS and MSD, which indicates that the N-N concentrations could be 
slightly lower than reported. 
 
Table III-2. 
Water Quality Results for the Surface Water Monitoring Stations – 2024  
SW-1 
RCs 
RTs 
MRLs 
Spring 
Summer 
Fall 
Parameters 
5/21/24 
BF 
No SF 
7/31/24 
BF 
No SF 
10/10/24 
BF 
12/16/24 
SF** 
Flow rate (GPM) 
-- 
-- 
-- 
 
pH (s.u.) 
-- 
<6.5,>8.5 
-- 
6.8 
 
6.26 
 
6.9 
7.04 
Water temp. (°C) 
-- 
-- 
-- 
17.2 
 
21.8 
 
12.1 
6.7 
Sp. Cond. (µS/cm) 
-- 
-- 
 
NO3/NO2-N (mg/L) 
0.30 
0.89 
0.1 
0.356 
 
0.489 
 
0.713 
0.425 
Turbidity (NTU) 
7.3 
21.4 
1.0 
2.1 
 
1.6 
 
2.3 
6.2 
SW-3A 
RCs 
RTs 
MRLs 
Spring 
Summer 
Fall 
Parameters 
5/21/24* 
BF 
No SF 
7/31/24 
BF 
No SF 
10/10/24* 
BF 
12/16/24 
SF** 
Flow rate (GPM) 
-- 
-- 
-- 
 
pH (s.u.) 
-- 
<6.5,>8.5 
-- 
7.07 
 
7.04 
 
7.07 
6.89 
Water temp. (°C) 
-- 
-- 
-- 
17.6 
 
23.3 
 
10.9 
7.21 
Sp. Cond. (µS/cm) 
-- 
-- 
 
NO3/NO2-N (mg/L) 
0.21 
0.57 
0.1 
1.31† 
 
0.343 
 
0.218 
0.241 
Turbidity (NTU) 
7.2 
19.4 
1.0 
2.7 
 
2.3 
 
4.75 
2.9 
SW-4 
RCs 
RTs 
MRLs 
Spring 
Summer 
Fall 
Parameters 
5/21/24 
BF 
No SF 
7/31/24* 
BF 
No SF 
10/10/24 
BF 
12/16/24 
SF** 
Flow rate (GPM) 
-- 
-- 
-- 
 
pH (s.u.) 
-- 
<6.5,>8.5 
-- 
6.86 
 
6.64 
 
6.67 
6.91 
Water temp. (°C) 
-- 
-- 
-- 
20.0 
 
23.2 
 
11.4 
5.75 
Sp. Cond. (µS/cm) 
-- 
-- 
 
NO3/NO2-N (mg/L) 
0.18 
0.38 
0.1 
<0.1 
 
0.195 
 
<0.1 
0.155 
Turbidity (NTU) 
7.2 
19.4 
1.0 
6.7 
 
11.3 
 
17.0 
9.0 
SW-6 
RCs 
RTs 
MRLs 
Spring 
Summer 
Fall 
Parameters 
5/21/24 
BF 
No SF 
7/31/24 
BF 
No SF 
10/10/24 
BF 
12/16/24 
SF** 
Flow rate (GPM) 
-- 
-- 
-- 
 
pH (s.u.) 
-- 
<6.5,>8.5 
-- 
7.01 
 
7.24 
 
6.9 
6.21 
Water temp. (°C) 
-- 
-- 
-- 
18.0 
 
23.5 
 
11.6 
6.82 
Sp. Cond. (µS/cm) 
-- 
-- 
 
NO3/NO2-N (mg/L) 
0.21 
0.57 
0.1 
<0.1 
 
<0.1 
 
<0.1 
<0.1 
Turbidity (NTU) 
7.2 
19.4 
1.0 
2.5 
 
4.8 
 
7.5 
6.1 
RCs = reference concentrations 
RTs = Revised Response Thresholds 
MRLs = Method Reporting Limits, also LOQ = limit of quantitation 
BF = base flow; SF = storm flow; NS = no sample due to insufficient flow or dry. 
Red Bold = concentration exceeded or was the same as the RT. As for the pH, bold = was below or above the desired 
values, no bold on values exceeding the turbidity RT because no action is required. 
* Duplicate samples were collected at this station. An average for the duplicate sample results is shown above. These 
values were averaged for one concentration to perform the statistical calculations. 
† No resampling was not done for this RT exceedance because the results were received well past the season (see the 
text above). 
** Samples were not collected within the strictest sense of the storm criteria; however, the elevated flow indicates that 
the site received rain. Thus this sampling event is acceptable. 
 
Table III-3. 
Exceedance of the Response Thresholds for Surface Water Stations – 2024 
Parameters 
Exceedance of RTs1 
pH 
SW-1 (1), SW-6 (1) 
NO3/NO2-N 
SW-3A (1) 
1 number in parentheses = the number of times the station exceeded its RT in 2023, or for the case of pH the 
measurements were outside of the desirable range of ≥6.5 - ≤8.5. 
Turbidity was not included because no action is required. 
 
Table III-4. 
Mean Concentrations - Surface Water Monitoring Stations Compared with 
RCs, RTs, and EPA Ecoregional Criteria (US EPA, 2001) – 2024 
SW-1 
Ecoregional 
Criteria 
Response 
Thresholds†† 
Reference 
Concentration† 
2024 Data 
Parameters 
Mean 
SD 
N 
pH (s.u.) 
-- 
< 6.5, >8.5 
7.1±0.1 
6.75 
0.34 
Sp. Cond. (μS/cm) 
-- 
None 
117±36 
NO3/NO2-N (mg/L) 
0.42* 
0.89 
0.30±0.27 
0.50 
0.15 
Turbidity (NTU) 
0.80 
21.4 
7.3±7.1 
3.1 
2.1 
SW-3A 
Ecoregional 
Criteria 
Response 
Thresholds†† 
Reference 
Concentration† 
2024 Data 
Parameters 
Mean 
SD 
N 
pH (s.u.) 
-- 
< 6.5, >8.5 
6.9±0.2 
7.02 
0.09 
Sp. Cond. (μS/cm) 
-- 
None 
121±86 
NO3/NO2-N (mg/L) 
0.42* 
0.57 
0.21±0.18 
0.53 
0.52 
Turbidity (NTU) 
0.80 
19.4 
7.2±6.1 
3.2 
1.1 
SW-4 
Ecoregional 
Criteria 
Response 
Thresholds†† 
Reference 
Concentration† 
2024 Data 
Parameters 
Mean 
SD 
N 
pH (s.u.) 
-- 
< 6.5, >8.5 
7.2±0.0 
6.77 
0.13 
Sp. Cond. (μS/cm) 
-- 
None 
 80±78 
NO3/NO2-N (mg/L) 
0.42* 
0.38 
0.18±0.08 
0.11 
0.07 
Turbidity (NTU) 
0.80 
19.4 
7.2±6.1 
11.0 
4.4 
SW-6√ 
Ecoregional 
Criteria 
Response 
Thresholds†† 
Reference 
Concentration† 
2024 Data 
Parameters 
Mean 
SD 
N 
pH (s.u.) 
-- 
< 6.5, >8.5 
7.3±0.2 
6.84 
0.44 
Sp. Cond. (μS/cm) 
-- 
None 
 138±18 
NO3/NO2-N (mg/L) 
0.42* 
0.31 
0.17±0.06 
<0.1 
Turbidity (NTU) 
0.80 
54.3 
16.1±19.1 
5.2 
2.1 
††Baseline Mean + 2 Std. Dev. The values presented in the table are the corrected RTs (ETS, 2012).  
†The RC is the baseline mean for the appropriate reference station. 
*The 0.42 mg/L ecoregional criterion (EPA, 2001) is for total nitrogen (TN) and NO3/NO2-N is only one 
component of TN. 
√ There were no detections of N-N at this station in 2024. Therefore no statistical analyses can be run to 
compare with the on-site stations. 
 
Table III-5.  Comparison of the On-site Stations’ Mean Concentrations (Combined) with the 
Background Station - 2024 
Parameters 
Background Station 
SW-6 
Three On-site 
Stations* 
p-values 
SW-6 vs. 
On-Site‡ 
Are the 
Means 
Different? 
(p<0.05) 
Mean 
SD 
N 
Mean 
SD 
N 
Yes or No 
pH (s.u.) 
6.84 
0.44 
6.85 
0.23 
0.97 
No 
Sp. Conduct. (μS/cm) 
0.022 
Yes 
NO3/NO2-N (mg/L) 
0.05* 
0.38 
0.35 
0.008 
Yes 
Turbidity (NTU) 
5.2 
2.1 
5.7 
4.7 
0.84 
No 
*These averages are for the three remaining on-site stations during 2024 routine sampling events: SW-1, -3A, 
and -4. 
*There was no detectable N-N concentration at SW-6 in 2024. 
‡ If p <0.05, then the datasets (SW-6 vs. on-site stations) are statistically significantly different from each 
other for the parameter shown. 

IV. 
TRENDS AND STATISTICAL ANALYSES 
 
The Environmental Management Plan (TSG, 2000) requires that the data be analyzed to 
determine trends over time. This section describes the time trends for relevant inorganic parameters 
in the surface water samples. 
 
A. 
Methods 
 
We created graphs of concentration vs. time since the beginning of monitoring and visually 
inspected them for obvious trends for pH and nitrate-nitrogen (N-N): pH - Figure IV-1; N-N - 
Figures IV-2a (cumulative). These graphs represent the cumulative results from the ‘official’ start 
of monitoring (i.e., Sept. 1999) through the end of 2024. In addition, we created a graph (Figure IV-
2b) for the last 10 years (2015-2024, inclusive) to evaluate trends. Non-detectable concentrations 
for N-N are depicted by an entry of half the MRL (method reporting limit) or the LOQ (limit of 
quantitation). Note that the N-N MRL was 0.5 mg/L from 1999 through the June 2001 sampling 
event, and it was reduced to 0.1 mg/L in August 2001 (see Figure IV-2a). This likely skews the 
trends. However, the graphs are intended to highlight the overall trends at the four remaining 
sampled stations (SW-1, -3A, -4, and -6). Although it is also important to note peak concentrations 
in the graphs, it is equally important to realize each peak represents a single sampling date, not a 
longer-term average. Therefore, the cumulative results should be analyzed based on the overall 
trends. 
 
Test for Significant Differences
 
. The Student’s t-test is a statistical method used for comparing 
two groups of data. If the p-value is less than (<) 0.05, then it can be said that the two groups of 
data are statistically significantly different from each other. This test is used for the N-N results 
only. 
Linear Regression Analyses
 
. We used the coefficient of determination for linear regression 
analyses, r2, to determine if there are any increasing or decreasing trends for N-N. The coefficient of 
determination, when multiplied times 100, yields the percent variation in the data that can be 
explained by the equation/relationship; in this case, concentration vs. time. 
B. 
Parameter Trends and Statistical Comparisons 
 
The discussion below summarizes the trends analysis for surface water from 1999 (‘official’ 
start of monitoring) through 2024. Figure IV-1 compares the pH of the three remaining on-site 
stations with the background station SW-6. Similarly, Figure IV-2a compares the N-N 
concentrations with the background station. The trends for these parameters are discussed below. 
 
1. 
pH 
 
A visual inspection of Figure IV-1 shows that the pH at all surface water stations have been 
fluctuating between ~5 and ~8.5 (except for a few outliers) over the last 10 years (i.e., 2015-2024), 
including the background station SW-6. The highest pH over the last 10 years was observed at SW-
1 (8.45; 2019) and the lowest pH also at SW-1 (4.48; 2017). 
 
The average pH at the background stations for that 10-year period (2015-2024) is 7.02, and 
the average pH at the three remaining on-site stations combined is 6.78. In addition, the overall 
averages (1999-2024) of the three remaining on-site stations (6.65) and SW-6 (6.70) shows that the 
background station’s pH is slightly less acidic than the on-site stations for the official monitoring 
period (1999-2024). Although we can assume that acid rain can account for lower pH values some 
of the time, it likely does not account for all of the lower pH values (i.e., some of the lower pH 
values may be the result of golf course management). Keep in mind that slightly lower pH values 
(i.e., acidic) helps to maintain healthy turf, which means less pesticides are needed. In any case, pH 
monitoring will continue as long as N-N is monitored. In addition, the overall and the 10-yr average 
pH values for both the on-site and the background stations are within the desirable range 6.5-8.5. 
 
2. 
Nitrate-Nitrite Nitrogen 
 
Figure IV-2a illustrates the nitrate-nitrite nitrogen (N-N) concentrations at the four 
remaining surface water stations: three on-site stations (SW-1, SW-3A, and SW-4) and one off-site 
station (i.e., SW-6, background). A visual inspection of the figure with the trend lines shows that 
the N-N concentration fluctuates at all stations. Figure IV-2a shows that there have been many N-N 
concentration spikes and there appears to be slightly increasing trends at stations SW-1 and SW-3A 
and slightly decreasing trends at SW-4 and SW-6. Therefore, statistical evaluations were done to 
determine if there are any statistically significant differences (p<0.05) in the N-N concentrations 
and/or concentration trends when compared with the background station for the whole dataset.  
 
Figure IV-2b shows the last 10 years of monitoring (2015-2024) for the remaining four 
stations (SW-1, SW-3A, SW-4, and SW-6). Two on-site stations show slight decreasing N-N 
concentration trends (SW-1 and SW-4). Station SW-3A shows a flat trend (i.e., neither increasing 
nor decreasing). The background station SW-6 shows a very slight increasing trend. The 10 year 
data at each station was compared with SW-6 to determine if the means are significantly different. 
The Student’s t-test shows that there is a significant difference (i.e., p<0.05) in the means at all of 
the on-site stations compared with SW-6. Table IV-1 shows the p-values of each station compared 
with SW-6. 
 
Table IV-1. Test of Significance (p-values): SW-1, SW-3A, and SW-4 Compared With SW-6 
(20215-2024) 
 
p-values 
SW-1 
SW-3A 
SW-4 
SW-6 
3.69 E-11 
7.28 E-9 
0.001 
A p-value less than 0.05 = means are significantly different from each other. 
 
The average N-N concentration in 2024 for the three remaining on-site stations combined 
(0.38 ppm, std ± 0.35 ppm; n=12) is lower than in 2023 (0.56 ppm, std ± 0.69 ppm; n=12) and 
lower than in 2022 (0.68 ppm, std 0.43, n=11). A comparison of the on-site stations’ 2023 and 
2024 data using the two-tailed Student’s t-test and a confidence level (CL) of 95% concluded the 
difference in means between the datasets is not significant (p=0.43; see Table IV-2 below).  
 
A statistical comparison of the 2024 on-site stations’ combined N-N average concentration 
(0.38 ppm) and the average N-N concentration at the background station SW-6 (0.05 ppm, ½ the 

LOQ) shows there is a statistically significant difference in the datasets (p=0.008; Table IV-2). 
However, since there were no detections at SW-6 in 2024 the statistical comparison is skewed.  
 
We will continue to use the complete dataset beginning in September 1999 (‘official’ start 
of monitoring) for our statistical analyses to compare the remaining on-site stations vs. SW-6 
(background) results because past comparisons between the years 1999-2024 vs. 2001-2024 
(updated to include the 2022-2024 data) when the MRL changed was not statistically significant (p-
value = 0.7, this did not change when we added the additional 2002-2024 data). Therefore, 
eliminating the earlier data does not affect the statistical analytical test for significance.  
 
Time vs. concentration is represented by the regression analysis. A regression analysis (r2) 
trend line for the cumulative datasets (1999-2024) at each station shows that the overall N-N 
concentrations at stations SW-1 and SW-3 are increasing (Figure IV-2a). However, the trend at 
those two stations over the last 10 years (2015-2024; Figure IV-2b) shows that the N-N 
concentration at SW-1 is decreasing and the trend at SW-3A is flat (i.e., neither increasing nor 
decreasing). The cumulative datasets (1999-2024) trend lines for stations SW-4 and SW-6 show a 
slightly decreasing trend at both stations (Figure IV-2a). The trend over the last 10 years (Figure 
IV-2b) for SW-4 is decreasing and is slightly increasing at SW-6. All r2 values are low, which 
suggests that there is no apparent correlation between time and the N-N concentrations (i.e., time 
does not have an effect on the N-N concentrations). Thus, there is another influence on the N-N 
concentration (e.g., fertilizer applications, earth work, and/or residential influence for SW-6).  
 
In summary, there are concentration spikes and occasional RT exceedances for N-N at some 
of the on-site stations. However, the N-N concentration trends appear to be decreasing at all on-site 
stations and the cumulative average (includes only the three remaining on-site stations) N-N 
concentrations are very low (see Table IV-2 below). Additionally, we observe that the overall mean 
N-N concentration is lower in 2024 (0.38 ppm) than in 2023 (0.56 ppm) and in 2022 (0.68 ppm; 
ETS 2023).  
 
Table IV-2. 
Comparison of the Average N-N Concentrations - 2023 vs. 2024 On-Site 
Stations, Cumulative and 2024 On-Site Stations vs. SW-6 
 
Mean N-N Concentrations 
On-Site Stations§ (ppm) 
On-site  
t-test 
p-value 
Mean N-N 
Concentration SW-6 
(ppm) 
Two tailed t-test 
On-Site Mean vs. SW-6 
p-value† 
1999-2024* 
2023 vs. 
1999-2024 
2024‡ 
1999-2024 
Nitrate-N 
0.44 
0.56 
0.38 
0.43 
0.10 
0.05 
3.5E-37 
0.008 
Std (±) 
0.43 
0.69 
0.35 
0.14 
N 
§ We only compared the three remaining stations for the 2024 data set and the cumulative data. 
*This average is for the three remaining on-site stations. The MRL between 1999 and August 2001 was 0.5 
ppm, then it changed to 0.1 ppm, which impacts the results because non-detects are entered as ½ of the 
MRL, i.e., 0.25 vs. 0.05. There was no difference in the means for the datasets (See text above). 
†A p-value <0.05 = a statistically significant difference in the datasets. A p-value >0.05 indicates that the 
mean N-N concentrations are the same.  
Std = standard deviation; N = number of samples 
‡ There were no N-N detections at SW-6 in 2024. Thus, a statistical comparison with the on-site stations is 
skewed. 
 
C. 
Station SW-3A Nitrate-Nitrogen Concentration Trends 
 
We compared the results of the remaining three stations’ nitrate-nitrogen concentrations to 
determine if there is a significant difference in the means (i.e., average concentration). A statistical 
comparison was made using the Student’s t-test of the dataset for the time frame 2002-2024 
(inclusive). This dataset was selected because the detection limit (0.1 ppm) is the same for the 
complete 23 years of monitoring. As previously discussed, the detection limit from 1999 through a 
portion of the 2001 year was 0.5 ppm. A change in detection limits may skew this analysis. Thus, 
we did not use the data prior to 2002 (i.e., 1999-2001). 
 
The test for significance shows that there is no significant difference (p-value > 0.05) 
between the means of station SW-1 and SW-3A. However, there is a significant difference between 
the means of SW-1 and SW-3A compared with SW-4 (Table IV-3).  
 
Figure IV-3. Test for Significance (p-values) - Average Nitrate-Nitrogen Concentrations 
Between the On-site Stations (2002-2024) 
 
Stations 
SW-1 SW-3A 
SW-4 
Two tailed t-test On-Site Mean p-values† 
 
(2002-2024) 
SW-1 vs. SW-3A 
SW-1 vs. SW-4 
SW-3A vs. SW-4 
Nitrate-N 
0.56 
0.52 
0.29 
0.57 
6.48E-8 
1.11E-4 
Std (±) 
0.42 
0.55 
0.28 
n 
†p-values < 0.05 = significant difference between the means 
n = number of samples 
 
Based on the results above, we selected station SW-3A for further evaluation for seasonal 
comparison of results. We also selected station SW-3A because it has had the most RT exceedances 
for the 1999-2024 dataset (n=34, 27%, see the next section Table V-1). In addition, station SW-3A 
is upgradient and discharges into the arboretum area. Neither station SW-1 nor SW-4 has flow to 
any significant body of water. 
 
We reviewed the nitrate-nitrogen (N-N) results at station SW-3A to determine which season 
and flow type (i.e., base flow and storm flow) would provide the most valuable information when 
reviewing golf course fertilizer management and its possible affect on surface water. A comparison 
was made between the seasons and flow types for the last 23 years (2002-2024, inclusive). Table 
IV-4 below shows the average N-N concentrations for each season and flow type at SW-3A. The 
results show that the most RT exceedances occurred during spring base flow sampling events for 
the 23 year data (Table IV-4; N-N>RT = 9). In addition, the spring base flow event’s 23-yr average 
N-N concentration is the only season and flow type where the average N-N concentration exceeded 
its RT of 0.57 ppm (average = 0.74 ppm). The results below show that the best time to collect 
samples at this station is during the spring base flow (April-June, following the first application of 
fertilizers). None of the other season’s average N-N concentration exceeds the 0.57 ppm RT. 
 
A statistical analysis was also done using the Student’s t-test (a test for significance) 
between the seasons (spring, summer, and fall) and flow types (i.e., base flow or storm flow). This 
was done to determine if there is a significant difference between the mean N-N concentrations for 
the seasons and flow types. There are data gaps because sampling was not done during all seasons 

or all flow types (see Table IV-3 above; number of samples (n)). However, there is enough data to 
produce reliable results. Table IV-5 below shows the p-values for the seasons and flow types 
compared with each other. A p-value less than (<) 0.05 indicate that there is a significant difference 
between the means. There are no p-values less than (<) 0.05 (i.e., all the means are the same). The 
closest significant difference (p<0.05) between the means is the spring BF compared with the fall 
BF (p=0.056), which indicates that spring and fall base flows mean N-N concentrations are almost 
significantly different from each other.  
 
Figure IV-4. Comparison of the Average Nitrate-Nitrogen Concentrations of the Seasons and 
Flow Types at SW-3a (2002-2024) 
SW-3a 
Spring-BF 
Spring-SF 
Summer-BF 
Summer-SF 
Fall-BF 
Fall-SF 
Mean (ppm) 
0.74 
0.45 
0.43 
0.46 
0.44 
0.51 
Std (ppm) 
0.67 
0.55 
0.51 
0.53 
0.43 
0.58 
n 
N-N>RT 
Mean = seasonal average of the data for the years 2004-2024 
Std = standard deviation 
n = number of data points, i.e., the number of samples collected between 2002 and 2024 for that season and flow type. 
N-N>RT = number of times that the nitrate-nitrogen concentration is greater than (>) the response threshold (RT) of 
0.57 ppm during the sampling event. 
 
Figure IV-5. Station SW-3A Student’s T-test (p-values) for Significance Between the Seasons 
and Flow Types for the Nitrate-Nitrogen Concentrations (2002-2024) 
Seasons and 
Flow types 
Spring BF 
Spring SF 
Summer BF Summer SF 
Fall BF 
Fall SF 
Spring BF 
-- 
0.254 
0.099 
0.124 
0.056 
0.369 
Spring SF 
0.254 
-- 
0.878 
0.928 
0.747 
0.812 
Summer BF 
0.099 
0.878 
-- 
0.940 
0.846 
0.649 
Summer SF 
0.124 
0.928 
0.940 
-- 
0.788 
0.704 
Fall BF 
0.056 
0.747 
0.846 
0.788 
-- 
0.513 
Fall SF 
0.369 
0.812 
0.649 
0.704 
0.513 
-- 
BF = base flow 
SF = storm flow 

V. 
CONCLUSIONS AND RECOMMENDATIONS 
 
Overall, the course appears to be managed well, from an environmental perspective, with 
minimal nutrient impacts to surface water. The overall cumulative monitoring results (1999-
2024) show statistically significant increasing N-N concentration trends at two on-site stations 
(SW-1 and -3A) compared with the background station SW-6. However, the data over the last 10 
years (2015-2024) show decreasing trends at SW-1 and SW-4, neither increasing nor decreasing 
at SW-3A, and slightly increasing at SW-6. The overall N-N concentrations at the three 
remaining on-site stations range from non-detect (<0.1 ppm) to 2.3 ppm (see Table V-1 below).  
 
Table V-1. 
Nitrate-Nitrite Nitrogen RT Exceedances (1999-2024) 
Surface 
Water 
Stations 
N-N 
RTs 
(ppm) 
N-N Concentration 
Ranges (ppm; latest yr 
highest concentration) 
Most Recent 
RT* Exceedance  
(ppm, year) 
Number of Times RT 
Exceeded Overall  
(% Exceeded†) 
SW-1 
0.89 
ND - 2.3 (2017) 
0.89 (2022) 
18 (15%, n=123) 
SW-3A 
0.57 
ND - 2.15 (2023) 
1.31 (2024) 
34 (27%, n=125) 
SW-4 
0.38 
ND - 1.6 (2004) 
0.71 (2022) 
28 (24%, n=118) 
SW-6 
0.31 
ND - 1.36 (2022) 
1.36 (2022) 
2 (2%, n=109) 
* The most recent year that a N-N concentration exceeded its corrected RTs for monitoring years 1999-2024. 
† The value in parentheses is the percent that the RT was exceeded at that station between monitoring years 1999-
2024.  
ND = not detected above the MRL of 0.1 ppm (the MRL changed in 2001 from 0.25 ppm to 0.1 ppm) 
 
Our recommendation to reduce the total amount of N that can be applied between 
October 15 and April 1 to 1,000 lb (Appendix C) was implemented in 2017. The last fertilizer 
applications were made in late September 2024. No additional fertilization applications will be 
made until late April or early May 2025 for the spring applications. Thus, the amended EMP was 
followed for reduced fertilizer applications. 
 
Golf Course Reconstruction 
 
A new irrigation system installation and construction of turf at the HNGC began in 2023 
(see Appendix A). According to Brett Scales, Superintendent, the golf course closed in 2023 to 
replace all greens and sand traps. While the golf course was closed, re-seeding the greens, tees, 
and fairways was done to improve the bentgrass. This type of major construction produces N-
rich ground water, is likely the cause of the one N-N concentration spike observed in 2024 at 
station SW-3A. 
 
The rigorous schedule of soil and tissue testing was suspended in 2023 due to the nature 
of the reconstruction of the turf. Soil and tissue testing resumed in 2024 to determine the nutrient 
needs of the turf.  
 
A. 
Nitrate-Nitrite Nitrogen  
 
There was one N-N RT exceedances in 2024 during routine sampling events at one 
station: SW-3A (see Table III-2 above). There was no resampling event for the RT exceedance 
because we did not receive the results in a timely manner as discussed above.  
 
There is a statistically significant difference between the cumulative (1999-2024) average 
N-N concentrations for the on-site stations (0.44 ppm; Table IV-1) compared with the 
background station SW-6 cumulative N-N concentration (0.1 ppm; Table IV-1 above). A visual 
analysis (i.e., trend line) of each station’s cumulative results shows that the N-N concentrations 
appear to be slightly increasing at two stations: SW-1 and SW-3A (Figures IV-2a). However, the 
N-N trend at SW-4 and SW-6 shows decreasing trends.  
 
In the past, we stated that N-N increasing trends were likely caused by two factors: 1. 
Ground disturbance in 2012-2014 and recently in 2023 and 2. Too much N fertilization applied 
in the fall of 2016. It appears that the recent 2023 ground disturbance contributed to N-rich 
surface water at station SW-3A during the spring of 2024.  
 
Figure V-1 below graphical shows the cumulative (2001-2024) average N-N 
concentration of the on-site stations’ sampling events compared with the background station SW-
6. A trend line was superimposed on each of the datasets to show the trend for each dataset’s 
average N-N concentration. The trend line for the SW-6 background station shows a decreasing 
trend and the trend line for the on-site stations’ cumulative average N-N concentration shows a 
slightly increasing trend, which is expected since nitrogen fertilizer is applied to the turf and 
there have been RT exceedances at all on-site stations at some point during the monitoring 
period. A test for significance for the cumulative average N-N concentrations of the on-site 
stations vs. SW-6 shows that there is a significant difference between the means (i.e., p-value = 
3.5 E-37; Table IV-1). 
 
Figure V-1 (below) also shows that the ground disturbance produced N-N concentration 
spikes beginning in 2013 and 2014 at the on-site stations and the N-N spike in 2017, which was 
likely caused by the fall fertilization at the end of 2016. The figure shows that the average N-N 
concentration at the on-site locations is slightly increasing. In addition, we may see a spike in the 
near future due to the ground disturbance from 2023. In any case, average N-N concentration 
for the on-site stations combined is well below 2.0 ppm (0.44 ppm, std ± 0.43, n=370, includes 
all resampling events at the three remaining stations).  
 
B. 
Turf Management 
 
The superintendent (Brett Scales) applied fungicides and herbicides allowed under the 
EMP. In addition, fertilizer applications for 2024 totaled less than the maximum allowed under 
the EMP and less than industry standards for a high-end golf course. See Appendix A for the 
Superintendent’s report. 
 
C. 
Continued Monitoring 
 
Our recommendation (Section V.D below) for continued monitoring is based on the 
discussion in Section IV.C above and the N-N concentration trends for the last 10 years. 
 
In accordance with the EMP, monitoring is extended five years from the date of any 
sampling event during which an analyte is found to occur at a concentration exceeding a station’s 
respective RTs (TSG, 2000). This determination is made on a station-specific basis. Table V-1 
(above) show the surface water stations and the most recent years that the response threshold 

(RT) exceedances occurred for N-N. Table V-1 shows the most recent years that an RT was 
exceeded at each station. 
 
Table V-2 below shows all of the years that N-N concentrations exceeded the corrected 
RTs at each station since monitoring began. Monitoring is required for N-N at three remaining 
on-site surface water stations for the time specified in Table V-3 below in accordance with the 
amended EMP. Table V-3 shows the projected end of monitoring for N-N through 2027 at two 
of the on-site stations (SW-1 and SW-4) and through 2029 at SW-3A. Samples will be collected 
from the background station SW-6 as long as any on-site surface water station is sampled. 
 
Table V-2. 
Years N-N Exceeded Corrected Response Thresholds 
SW-1 
SW-3A 
SW-4 
SW-6 
2002, 2006, 2007, 2010, 
2015, 2016, 2017, 2018, 
2019, 2020, 2021. 2022 
2002, 2007, 2008, 2010, 2011, 
2014, 2015, 2016, 2017, 2018, 
2019, 2020, 2021, 2022, 2023, 
2000–2009*, 2011, 2012, 
2013, 2014, 2015, 2016, 
2017, 2018, 2021, 2022 
2007, 
* There was at least one RT exceedance each year between 2000 and 2009. 
 
Table V-3. 
Projected End of N-N Monitoring Period for Remaining Stations* 
SW-1 
SW-3A 
SW-4 
SW-6 
** 
* Turbidity will be analyzed at all stations during all monitoring events.  
**Samples will be collected from the background station SW-6 as long as any on-site surface water station is 
sampled. 
 
D. 
Monitoring Recommendations 
 
We recommend that monitoring for N-N and turbidity at the Hudson National Golf 
Course be reduced to monitoring surface water at only one station: SW-3A (see Section IV.C 
above). In addition, we recommend that the monitoring be done annually during the spring base 
flow. See our discussion in section IV.C above. Monitoring at SW-6 will be done as long as any 
on-site station is sampled.  
 
Monitoring for N-N is required under the EMP at two on-site stations (SW-1 and SW-4) 
through 2027, at one on-site station (SW-3A) through 2029, and at the off-site station SW-6 (as 
long as monitoring on-site continues) in accordance with the EMP. However, we recommend 
that monitoring at stations SW-1 and SW-4 be stopped because those stations do not flow to any 
significant body of water and do not provide any useful information about golf course fertilizer 
management.  
 
E. 
EMP Amendment Recommendation 
 
We continue to recommend that no more than 1,000 lb N total be applied between 
October 15 and early spring (April 1). Appendix C provides the cover letter and the amended 
“Fertilizing” section of the EMP that was submitted January 17, 2017. 

Figure V-1. N-N Average Concentration Trends - On-Site Average vs. SW-6  
 
On-site Stations  
y = 3E-05x - 0.8792 
R² = 0.0874 
Sampling Dates 
Hudson National Golf Course 
Nitrate-Nitrogen Concentrations 
SW-6 vs. Cumulative Ave. On-Site Stations (2001-2024; includes  stations SW-1, -3A, -4 and -5) 
Note: SW-5 monitoring stopped at the end of 2021) 
Nitrate-Nitrogen Concentrations (mg/L) 

REFERENCES 
 
ETS, 2025. January 10, 2025. 2024 Letter Report, Re: All Sampling Events. Submitted to the 
Village Croton-on-Hudson Planning Board. Environmental & Turf Services, Inc., Wheaton, 
MD. 
ETS, 2021. May 26, 2021. 2020 Annual Report Monitoring Program, 27th Monitoring Year, At 
Hudson National Golf Club, Croton-on-Hudson, New York. Prepared for The Village of 
Croton-on-Hudson. Environmental & Turf Services, Inc., Wheaton, MD. 
ETS, 2017a. January 17, 2017. The Combined HNGC’s EMP (2000) Nutrient Management 
Amendments (2000, 2011, and 2017). Submitted to the Village Croton-on-Hudson Planning 
Board. Environmental & Turf Services, Inc., Wheaton, MD. 
ETS, 2017b. January 11, 2017. Fall Letter Report: 2016 Surface Water Sampling Events. 
Submitted to the Village Croton-on-Hudson Engineer Daniel O’Connor. Environmental & 
Turf Services, Inc., Wheaton, MD. 
ETS, 2013. September 27, 2013. 2012 Annual Report Monitoring Program,17th Monitoring Year, 
At Hudson National Golf Club, Croton-on-Hudson, New York. Prepared for The Village of 
Croton-on-Hudson. Environmental & Turf Services, Inc., Wheaton, MD. 
ETS, 2012. June 11, 2012 Technical Letter Report, RE: EMP Amendments (RTs). Submitted to 
the Village Croton-on-Hudson Planning Board. Environmental & Turf Services, Inc., 
Wheaton, MD. [This letter report was submitted with a 2011 date instead of 2012.] 
ETS, 2011. Letter Report: Nutrient Management Amendment Recommendations for the 
HNGC’s EMP (2000) submitted to the Village of Croton-on-Hudson, NY on June 27, 2011. 
Environmental & Turf Services, Inc., Wheaton, MD. 
Gallelli, A.H. and K. Ioannou. 2002. January 14, 2002. Letter from The Village of Croton-on-
Hudson to Environmental & Turf Services, Inc., Wheaton, MD. 
Ioannou, K. 2002. Letter from the Village of Croton-on-Hudson to Environmental & Turf 
Services, Inc., January 1, 2002. 
TSG (Turf Science Group), 2000. Environmental Management Plan (EMP) for the Hudson 
National Golf Club, Croton-on-Hudson, New York. Turf Science Group, Inc., Raleigh, NC. 
Revised January 10, 2000. 
US EPA, 2001. Ambient Water Quality Criteria Recommendations – Rivers and Streams in 
Nutrient Ecoregion VIII. EPA 822-B-01-015 December 2001. Office of Water. Office of 
Science and Technology. Heath and Ecological Criteria Division. Washington, DC. 
 
FIGURES 
 
FIGURES .................................................................................................................................. Fig-1 
 
Figures for Section III. Graphical Presentation of Surface Water Results (2024)........ Fig-2 - Fig-7 
Figures for Section IV. Graphical Presentation of Cumulative Surface Water Results 
 
(1999-2024)..................................................................................................... Fig-8 - Fig-12 
 
APPENDICES 
 
Appendix A. Superintendent’s 2024 Report: Pesticide and Fertilizer Records 
Appendix B. Soil and Tissue Sampling Results for 2024 
Appendix C. 2000 EMP Fertilizing Section with 2011 and 2017 Amendments 
 
Fig-1 
 
FIGURES 
The plots in some graphs are discontinuous due to the inability to collect samples. Samples 
were not collected because the flow was too low on those dates. Keep in mind the lines 
connecting the points represent a point in time and not a continuation from one point to the 
next. 
 
Fig-2 
 
Figure III-1. HNGC Surface Water – pH – 2024 
 
6.25 
6.5 
6.75 
7.25 
7.5 
7.75 
8.25 
8.5 
pH 
Sampling Date 
Figure III-1. HNGC Surface Water 
pH - 2024 
 
SW-1 
SW-3A 
SW-4 
SW-6 

Fig-3 
 
Figure III-2. HNGC Surface Water – Temperature – 2024   
 
Temperature (°C) 
Sampling Date 
Figure III-2. HNGC Surface Water 
Temperature - 2024 
SW-1 
SW-3A 
SW-4 
SW-6 

Fig-4 
 
Figure III-3. HNGC Surface Water – Specific Conductance – 2024  
 
Specific Conductance (µS/cm) 
Sampling Date 
Figure III-3. HNGC Surface Water 
Specific Conductance - 2024 
SW-1 
SW-3A 
SW-4 
SW-6 

Fig-5 
 
Figure III-4. HNGC Surface Water – Turbidity – 2024  
 
Turbidity (NTU) 
Sampling Date 
Figure III-4. HNGC Surface Water 
Turbidity - 2024 
SW-1 
SW-3A 
SW-4 
SW-6 

Fig-6 
 
 Figure III-5. HNGC Surface Water – Nitrate-Nitrite Nitrogen – 2024 
 
0.25 
0.5 
0.75 
1.25 
1.5 
N-N Concentrations (mg/L) 
Sampling Dates 
Figure III-5. HNGC Surface Water 
Nitrate-Nitrite Nitrogen - 2024 
SW-1 
SW-3A 
SW-4 
SW-6 
Non detect are shown as 0.05 mg/L, 1/2 of the 0.1 MRL Response thresholds in ppm are shown in parenthesis, e.g., SW-1 (0.89). 

Fig-7 
 
Figure IV-1. HNGC Surface Water – pH – Cumulative 1999-2024 
 
4.5 
5.5 
6.5 
7.5 
8.5 
pH 
Sampling Date 
Figure IV-1. HNGC Surface Water 
pH  - Cumulative 1999-2024 
SW-1 
SW-3A 
SW-4 
SW-5 
SW-6 

Fig-8 
 
Figure IV-2a. HNGC Surface Water – Nitrate-Nitrite as Nitrogen – Cumulative 1999-2024 SW-1, SW-3A, and SW-4 vs. SW-6 
 
0.5 
1.5 
2.5 
N-N Concentration (mg/L) 
Figure IV-2a. HNGC Surface Water for SW-1, SW-3A,  SW-4,and SW-6 
Nitrate-Nitrite as Nitrogen 
Cumulative 2001-2024 
SW-1 
SW-3A 
SW-6 
SW-4 
Linear (SW-1) 
Linear (SW-3A) 
Linear (SW-6) 
Linear (SW-4) 
MRL = 0.5 mg/L (1999-2001), i.e., ND = 0.25 on graph. 
MRL = 0.1 mg/L (2001-2012), i.e., ND = 0.05 on graph. 

Fig-9 
 
Figure IV-2b. HNGC Surface Water – Nitrate-Nitrite as Nitrogen – 10 Yr Monitoring Trends (2015-2024)  
 
0.5 
1.5 
2.5 
SW-1 
SW-3A 
SW-4 
SW-6 
Linear (SW-1) 
Linear (SW-3A) 
Linear (SW-4) 
Linear (SW-6) 
Figure IV-2b. HNGC Surface Water for SW-1, SW-3A,  SW-4,and SW-6 
Nitrate-Nitrite as Nitrogen 
Ten Years (2015-2024) 
Nitrate-Nitrogen Concentratons (mg/L) 

Appendices 
 
APPENDICES 
 
A-1 
 
APPENDIX A. Superintendent’s 2024 Report 
 
Report summary, and fertilizer and pesticide application schedules 
 
A-2 
 
Hudson National Golf Club  
2024 Turfgrass Nutrient Management Plan 
Prepared by: Brett Scales, Golf Course Superintendent 
(Typographical edits were made by LaJan Barnes) 
 
This report will summarize how and why nutrients were applied to the golf course during the 
2024 season. Fertilizer application decisions have been based on the EMP guidelines, turfgrass 
health/growth, annual soil samples, tissue samples and weather.   
 
Soil samples from greens, tees, fairways, and rough were taken in March and sent to Brookside 
Laboratories Inc., for analysis. Upon receiving the results of the soil samples, REP Consulting 
Inc. helped me create a plan to balance soil chemistry and improve turf health. 
 
The 2024 golf season began later than normal as we were finalizing a restoration project of the 
entire golf course. The restoration project included replacing USGA spec greens, irrigation 
system, sand traps, re-grassing tees, approaches and fairways. 2024 proved to be a very 
challenging year with weather extremes. 
 
Greens and tees at Hudson National are sand based root zones. The approach going into the 2024 
season was to be conservative with green speeds and have elevated mowing heights on all 
playing surfaces to allow the new turf to mature. It generally takes 2-3 growing seasons for new 
bentgrass to reach its genetic maturity. Many of the fertilizer applications contained more 
phosphorus than typical to encourage rooting and expedite establishment of the young turf. I 
applied two applications of 7-7-7, an organic fertilizer to encourage microbial activity on the 
new sterile greens. The 7-7-7 fertilizer also provided a great nutrient base and was supplemented 
through the growing season with light, frequent “spoon feeding” applications of 20-20-20. I 
monitor turf grass health weekly through visual observations, color, growth rate, and with tissue 
samples to help identify deficiencies or surpluses within the tissue.  In July, following a period of 
pro-longed heat, fertilizer applications consisted only of 0-0-52 to limit turf growth and reduce 
plant stress. The fertility program on tees remained similar to previous seasons even though they 
were re-grassed. The existing root zone mix on tees was not removed or modified and did not 
require additional nutritional inputs. Tees were fertilized using the “spoon feeding” method with 
two different fertilizers, 28-8-18 and 0-0-52. Applications varied between 7 and 14 days through 
the growing season depending on turf health, growth rate, and recovery.   
 
Fairways were fertilized on a two-week schedule once the turf began actively growing.  Fertilizer 
application totals were relatively low on fairways for growing in new turf.  I believe the built up 
organic matter and decaying old bentgrass provided the new bentgrass with additional nitrogen 
reducing inputs.  Tissue samples were used to monitor plant needs and when necessary 
adjustments were made.     
 
Primary roughs on the golf course are treated a little bit differently than greens, tees, and 
fairways. The singular fertilizer application this season was 22-0-5 natural fertilizer, which 
contains 40% biosolids and 40% Uflexx. Both the Uflexx and biosolid fertilizer are released in a 
predictable manor from microbial degradation. The 22-0-5 fertilizer benefits the property by 
having an improved environmental profile by reducing the opportunity of nitrogen leaching.   
Previous seasons I have added a 2nd rough application approximately 8 weeks after the first 
application. With the new fertilizer a second application was not needed this year (2024). 

A-3 
 
All fertilizer applications have been made in an environmentally conscious manner. Weather 
conditions play an important role of when fertilizer applications are made. All efforts are made to 
avoid making fertilizer applications when rain or high winds are forecasted. Soil reports, tissue 
samples and the Environmental Management Plan again will be used to determine rates and 
timing of fertilizer applications in 2025. The goal will remain to apply the least amount of 
fertilizer while still maintaining sustainable healthy turfgrass. 
 
A-4 
 
2024 Fertilizer Applications 
 
A-5 
 
A-6 
 
A-7 
 
2024 Pesticide Applications 
 
A-8 
 
A-9 
 
B-1 
 
APPENDIX B. 2024 Soil and Tissue Results 
 
'$7(
 
&RUUHFWLYH7UHDWPHQW)RU
 +XGVRQ1DWLRQDO
),/(
 

²¾Á½¶µ
Ã¶²ʃ


ͳ
ʹ
͵
Ͷ
ͷ
͸
͹
ͺ
ͻ
ͳͲ
ͳͳ
ͳʹ
ͳ͵
ͳͶ
ͳͷ
ͳ͸
ͳ͹
ͳͺ
ʹͲ

0J/LPH
GRORPLWH












&D0J
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO VSULQJIDOO VSULQJIDOO
*\SVXP
!FDOFLXP HYHU\ZHHNVRQFH\RXVWDUWKHDYLO\UHO\LQJRQLUULJDWLRQZDWHUDVWKHSULQFLSOHVRXUFHRIPRLVWXUHDOOWKHJUHHQV!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
VXOIDWHGLK\GUDWH












[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
1LWURJHQ2UJDQLFPDWWHU
 &RQWLQXDOO\PRQLWRUWKHFRQGLWLRQRIWKHRUJDQLFLQWKHWRSRIWKHSURILOH$GMXVWPDLQWHQDQFHSURJUDPV
WRSGUHVVLQJUDWHVLQWHUYDOVYHQWLQJYHUWLFXWWLQJDHULILFDWLRQ
WRKHOSPDLQWDLQLWVRSWLPDOFRQGLWLRQDQGKHDOWK
7RWDODYDLODEOH1DWVDPSOLQJZDVTXLWHJRRGIRU	3*WKH\ORRNOLNHWKH\RXQJHVWJUHHQVDQG\RX
UHVWLOOSXVKLQJWKHP3LFNHGXSDOLWWOHIHUWLOL]HU
DPPRQLXPVXOIDWH
DIIHFWLQJWKHWHVWUHVXOWVDOLWWOHRQ
	DQGPRUHVRRQ	3*7KHDPPRQLDFDO1LVVSLNHGDQGWKHS+LVWHPSRUDULO\ORZHU7KH\RXQJHUJUHHQVDOVRKDYHORZHU3UDQJHVDQGVRDVWDUWHULVVWLOOYHU\XVHIXOVRORQJDVWKHQLJKWWLPHWHPSVVWD\ORZWR
PRGHUDWH7KHROGHVWJUHHQVKDGORZHU1OHYHOVDQGQHHGHGDSLFNPHXSRQ1$QGWKHROGHURQH
V3OHYHOVDUHEHWWHUKLJKHUEXWVWLOOFRXOGXVHVRPHDGGLWLRQDO3
3RWDVVLXP

$WVSULQJDQGIDOODHULILFDWLRQPDNHVXUHWRLQFRUSRUDWHDFRDWHGVORZUHOHDVH.6SULQJUDWHVKRXOGEHDFWXDO.DQGIDOOVKRXOGEHDFWXDO.

VXOIDWH

[
[
[
[
[
[
[
[
[
[
RU
RU
RU
RU
RU
RU
RU
RU
RU
RU
RU
$QGHUVRQV'*
[
[
[
[
[
[
[
[
[
[
3UR0DJ
[
[
[
[
[
[
[
[
[
[
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
RU
5(3&RQVXOWLQJ,QF

5LFKDUG+3VROOD6WDUWHGLQ

VHUYLQJ6SRUWV7XUI	$JULFXOWXUH:RUOGZLGH
YRLFH
	'XTXHWWH$YH1(





ID[
5(ULF3VROOD+DUWYLOOH2KLR

86$



7XUIJX\#PVQFRP
5(3&RQVXOWLQJ,QF

6WDUWHGLQ

VHUYLQJ6SRUWV7XUI	$JULFXOWXUH:RUOGZLGH

5LFKDUG+3VROOD	'XTXHWWH$YH1(




5(ULF3VROOD+DUWYLOOH2KLR

86$
7XUIJX\#PVQFRP
RU
$QGHUVRQV'*0J
[
[
[
[
[
[
[
[
[
[
RU3ODQW)RRG.06
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
$6$3
3KRVSKRUXV

7KHPRVWDFFXUDWHSKRVSKRUXVUHDGLQJRQWKHVRLOUHSRUWLVWKH0HKOLFK,,,SKRVSKRUXV!DFUHLVDGHTXDWHIRUVRPHVLWXDWLRQV7KHUHLVHQRXJK3KHUHWKDWVXSSO\LQJPRUHLVXQQHFHVVDU\XQGHUQRUPDOFRQGLWLRQV
PRQRSRWDVVLXP
7KH\ZLOOUHVSRQGZHOOWRDVWDUWHUDSSOLFDWLRQWRKHOSKHDODHULILFDWLRQDQGLQWKHVKRXOGHUVHDVRQVZKHQVRLOVDUHZHWFROG	GD\VDUHVKRUWFORXG\	WKHUHLVH[FHVVLYHZHDUIURPSOD\7RKHOSVWUHQJWKHQWKHWXUIZKHQLW
V
SKRVSKDWH


VKDOORZURRWHG	QLJKWWLPHWHPSVDUHQ
WGURSSLQJXQGHUR DQGRUVRLOWHPSVDUH!RGURSIROLDU1DQGUHSODFHLWZLWKZHHNO\IROLDU3	.VSUD\VXVLQJPRQRSRWDVVLXPSKRVSKDWH
0.3R]PDWHULDO0

0$3











[DSSOV
[DSSOV
[DSSOV
[DSSO
[DSSOV
[DSSO
[DSSOV
[DSSOV
[DSSOV [DSSOV [DSSOV
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
DQ\WLPH
VSULQJIDOO
DQ\WLPH
VSULQJIDOO
VSULQJIDOO
VSULQJIDOOVSULQJIDOOVSULQJIDOO
(SVRP6DOWV
PDJQHVLXP
RXQFHVPDWHULDOIW [HYHU\WLPHWKDW\RXVSUD\
DVRIWHQDVZHHNO\QROHVVWKDQPRQWKO\
DOOWKHJUHHQV!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
VXOIDWH0J

.HHSLWVLPSOHWKHUDWHFDQYDU\EHWZHHQRXQFHV0DQGEHILQHGU\LQJRQWKHOHDI,W
VOLNHO\\RXFDQDGGKDOIRUDZKROHEDJWDQNDQGKLWVRPHZKHUHLQWKDWUDQJH
0DQJDQHVH6XOIDWH
RXQFHVPDWHULDOIW [HYHU\WLPHWKDW\RXVSUD\
DVRIWHQDVZHHNO\QROHVVWKDQPRQWKO\
DOOWKHJUHHQV!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

0Q

<RXFDQJRDVKLJKDVR]PDWHULDOLIWKHWKUHDWRIRUFRQGLWLRQVH[LVWWREULQJRQWDNHDOO
)HUURXV6XOIDWH
)H
 RXQFHVPDWHULDOIW [HYHU\WLPHWKDW\RXVSUD\
DVRIWHQDVZHHNO\QROHVVWKDQPRQWKO\
DOOWKHJUHHQV!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
6RO8%RU
%

RXQFHPDWHULDOIW[HYHU\WLPHWKDW\RXVSUD\
DVRIWHQDVZHHNO\QROHVVWKDQPRQWKO\
DOOWKHJUHHQV!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
5HFRPPHQGDWLRQVIRUJUHHQVWHHVODZQVDQGILHOGVDUHSRXQGVRURXQFHVRIPDWHULDO WREHDSSOLHGSHUIWPXOWLSOLHGE\WKHQXPEHURIDSSOLFDWLRQV)DLUZD\VDUHSRXQGVRUWRQVRIPDWHULDOSHUDFUH 
5HYLHZ
%HLQJVRQHZDQGKDYLQJDUDQJHRIIHUWLOLW\OHYHOVLVJRLQJWRPDNHWKLVILUVW\HDUDOLWWOHKDUGHUDV\RXWU\WRJHWWKHPDOORQWKHVDPHIRRWLQJZKLOHPDNLQJLWORRNOLNH
WKH\DOUHDG\DUH.HHSDZDU\H\HRXWIRUZHDUSDWWHUQVIURPSOD\DQGPDLQWHQDQFHDQGDGMXVWWKHWUDIILFSDWWHUQVZKHUHZKHQ\RXFDQDQGXVHVRPHVXUJLFDOIHUWLOLW\
DSSOLFDWLRQVWRWKRVHDUHDVWRKHOSZLWKPDLQWDLQLQJDQGUHFRYHU\LILWJHWVWKDWIDU,
PWU\LQJWRNHHSVRPH&DDQG0JLQVRLOVROXWLRQZLWKWKHOLPHDQGJ\SVXPDQG
WKHQDGGHG0JDVDULGHUDORQJZLWKVRPH.*HWWKHKLJKHU0JPDWHULDOVGRZQQRZDQGWKHQIROORZXSZLWKWKH'*ODWHULQWKHVXPPHU,QSODFHRIWKHPRQWKO\
J\SVXPWKHUHDUHPDWHULDOVWKDWKDYH&D0JDQG.LQWKHPFRYHULQJDVSHFWUXPRIHOHPHQWVWKDWVKRXOGVWD\LQVRLOVROXWLRQRQDFRQVLVWHQWEDVLV3ODQW)RRGKDV
3KXVLRQ.063OXV+DUUHOOVKDVD	$48$$,'KDV9HUGH&DO.SOXV$QGHUVRQV'*OLQHKDV.DO7HFDQG6ROX&DOKDVD.&DO
3OXV$Q\RIWKHVHFRXOGEHXVHGLQDPRQWKO\0PDWHULDODSSOLFDWLRQWRKHOSVXVWDLQWKHVRLOVROXWLRQ&D0JDQG.RQWKHVHKLJKSHUFUDWHVDQGEDVHGJUHHQV
7UDFHPLQHUDOVDUHDQRWKHUFKDOOHQJH:KLOH,KDYH0J0Q)HDQG%LWHPL]HG\RXFRXOGXVHRQHRUWZREURDGHUVSHFWUXPPDWHULDOVWRVDYHRQLQGLYLGXDOLWHPVJRLQJ
LQWKHWDQN6LPSORWKDVDPDWHULDOFDOOHG5DSWXUHWKDWFRYHUVVHYHUDOHOHPHQWV+DUUHOOVKDVDQ,URQ0Q0J)ORUDWLQHVLPLODUZLWK0Q0DJ<RXVKRXOGDOZD\VKDYH
VRPH7HFPDQJDP
PDQJDQHVHVXOIDWH
RQKDQGWRUDPSXSWKH0QZKHQWDNHDOOLVDWKUHDWDQGLWDOZD\VLVLQWKHILUVWWZR\HDUVRQQHZJUHHQV

'$7(
 
&RUUHFWLYH7UHDWPHQW)RU
 +XGVRQ1DWLRQDO
),/(
 

²¾Á½¶µ
Ã¶²ʃ

ͳ
ʹ
͵
Ͷ
ͷ
͸
͹
ͺ
ͻ
ͳͲ
ͳͳ
ͳʹ
ͳ͵
ͳͶ
ͳͷ
ͳ͸
ͳ͹
ͳͺ
0J/LPH
GRORPLWH









&D0J
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
DVDS
DVDS
DVDS
DVDS
DVDS
DVDS
DVDS
DVDS
*\SVXP
!FDOFLXP
VXOIDWHGLK\GUDWH

1LWURJHQ2UJDQLFPDWWHU
9HU\PRGHVW1OHYHOVDWVDPSOLQJDQGWKH\
OOZDQWDVKRWLQWKHDUPWRKHOSSXVKGLYRWVVKXWIURPWKHVLGH7KHUHVHHPVWREHDOLWWOHPRUH1	3RQ
"
	YHUVXVWKHRWKHUV$UH\RXSXVKLQJWKHVH
KDUGHUEHFDXVHRIWKHLUHQYLURQPHQW"2UDUHWKH\WRRVPDOOKLJKSOD\"7KDW
VILQHWKHUHLVSOHQW\RIURRPWRLQFUHDVHIHUWLOLW\OHYHOVDQGLPSURYH
3RWDVVLXP


VXOIDWH

6XO3R0DJRU








.0DJ
0J

[DSSOV
[DSSOV
[DSSOV
[DSSOV
[DSSOV
[DSSOV
[DSSOV
[DSSOV
2QHWKLVVSULQJ\HWDQGWKHQDJDLQLQPLGWRODWHVXPPHUDQGWKHILQDORQHLQPLGWRODWHIDOO
5(3&RQVXOWLQJ,QF

6WDUWHGLQ

VHUYLQJ6SRUWV7XUI	$JULFXOWXUH:RUOGZLGH

5LFKDUG+3VROOD	'XTXHWWH$YH1(




5(ULF3VROOD+DUWYLOOH2KLR

86$
7XUIJX\#PVQFRP
3KRVSKRUXV

7KHPRVWDFFXUDWHSKRVSKRUXVUHDGLQJRQWKHVRLOUHSRUWLVWKH0HKOLFK,,,SKRVSKRUXV$QXPEHURYHULVDGHTXDWHIRUVRPHFLUFXPVWDQFHV
0$3
[
[
[
[
[
[
[
[
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
VSULQJIDOO
0DQJDQHVH6XOIDWH
RXQFHVPDWHULDOIW [DVRIWHQDVZHHNO\EXWQROHVVWKDQPRQWKO\DOOWKHWHHV!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

0Q

)HUURXV6XOIDWH
RXQFHVPDWHULDOIW [HYHU\WLPHWKDW\RXVSUD\
DVRIWHQDVZHHNO\QROHVVWKDQPRQWKO\
DOOWKHWHHV!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

)H

6RO8%RU
%

RXQFHPDWHULDOIW[HYHU\WLPHWKDW\RXVSUD\
DVRIWHQDVZHHNO\QROHVVWKDQPRQWKO\
DOOWKHWHHV!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
5HFRPPHQGDWLRQVIRUJUHHQVWHHVODZQVDQGILHOGVDUHSRXQGVRURXQFHVRIPDWHULDO WREHDSSOLHGSHUIWPXOWLSOLHGE\WKHQXPEHURIDSSOLFDWLRQV)DLUZD\VDUHSRXQGVRUWRQVRIPDWHULDOSHUDFUH 
5HYLHZ
*HWWKHOLPHGRZQDQGWKHQVWDUWFKDVLQJWKH.DQG0J:KLOHWKH.0DJ6XO3R0DJLVDOHVVH[SHQVLYHPDWHULDOWKH$QGHUVRQV'*0JRUWKH3ODQW
)RRG.060JERWKKDYHKLJKHU0JOHYHOVWKDQWKH.0DJ6XO3R0DJDQGHLWKHURIWKRVHZRXOGEHDJRRGILUVWDSSOLFDWLRQDQGWKHQNHHSWKDWZHHN
LQWHUYDOWKURXJKWKHUHVWRIWKH\HDUZLWKWKH.0DJ6XO3R0DJ7KH3OHYHOVDUHMXVW2.8VHWKH0$3WR\RXUJUHDWHVWDGYDQWDJHOLNHKHDOLQJDIWHUDHULILFDWLRQ
HDUO\VSULQJWRMXPSVWDUWWKHV\VWHPRUODWHIDOOWRH[WHQGWKHVHDVRQLIWKHSOD\FRQWLQXHVDWDPRGHUDWHSDFHLQWR1RYHPEHU'HFHPEHU

'$7(
 
&RUUHFWLYH7UHDWPHQW)RU
 +XGVRQ1DWLRQDO
),/(
 

²¾Á½¶µ


ȹ
 
Ã¶²ʃ
	


ͳ
ʹ
͵
Ͷ
ͷ
͸
͹
ͺ
ͻ
ͳͲ
ͳͳ
ͳʹ
ͳ͵
ͳͶ
ͳͷ
ͳ͸
ͳ͹
ͳͺ
ͳȀͳͺ ͳͲȀͳʹ
+LJK&DOFLXP/LPH
DF
DF
&D0J
2.
2.
2.
2.
2.
2.
[DSSO
[DSSO
DQ\WLPH
DQ\WLPH
0J/LPH
GRORPLWH







&D0J
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
[DSSO
2.
2.
DQ\WLPH
DQ\WLPH
DQ\WLPH
DQ\WLPH
DQ\WLPH
DQ\WLPH
1LWURJHQ2UJDQLFPDWWHU
)DLUZD\VKDGYHU\PRGHVW1OHYHOVWRVWDUWWKHVSULQJQRFDUU\RYHUIURPIDOO5RXJKVDUHURFNLQJZLWKVRPHFDUU\RYHU
RUDVSULQJDSSOLFDWLRQ"
DQGVKRXOGVWLOOEHSXVKLQJJRRGJURZWKDQGFRORU
3RWDVVLXP


VXOIDWH

DFUH[DSSOLFDWLRQDOOWKHIDLUZD\V!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
2.
2.
6XO3R0DJRU
.0DJ
0J

DFUH[DSSOLFDWLRQODWHIDOOGRUPDQWDOOWKHIDLUZD\V!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
3KRVSKRUXV

7KH PRVW DFFXUDWH SKRVSKRUXV UHDGLQJ RQ WKH VRLO UHSRUW LV WKH 0HKOLFK ,,, SKRVSKRUXV $ QXPEHU RYHU  LV DGHTXDWH IRU VRPH FLUFXPVWDQFHV
5(3&RQVXOWLQJ,QF

6WDUWHGLQ

VHUYLQJ6SRUWV7XUI	$JULFXOWXUH:RUOGZLGH

5LFKDUG+3VROOD	'XTXHWWH$YH1(




5(ULF3VROOD+DUWYLOOH2KLR

86$
7XUIJX\#PVQFRP
3KRVSKRUXV

7KHPRVWDFFXUDWHSKRVSKRUXVUHDGLQJRQWKHVRLOUHSRUWLVWKH0HKOLFK,,,SKRVSKRUXV$QXPEHURYHULVDGHTXDWHIRUVRPHFLUFXPVWDQFHV
0$3RU
'$3
DFUH[DSSOLFDWLRQDOOWKHIDLUZD\VDQGURXJKV!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
0DQJDQHVH6XOIDWH
RXQFHVPDWHULDOIW [HYHU\GD\VLQVHDVRQ
-XQHWKURXJK6HSWHPEHU
DOOWKHIDLUZD\V!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

0Q

)HUURXV6XOIDWH
RXQFHVPDWHULDOIW [HYHU\WLPHWKDW\RXVSUD\
DVRIWHQDVZHHNO\QROHVVWKDQPRQWKO\
DOOWKHIDLUZD\V!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

)H

6RO8%RU
%

RXQFHPDWHULDOIW[HYHU\WLPHWKDW\RXVSUD\
DVRIWHQDVZHHNO\QROHVVWKDQPRQWKO\
DOOWKHIDLUZD\V!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
5HFRPPHQGDWLRQVIRUJUHHQVWHHVODZQVDQGILHOGVDUHSRXQGVRURXQFHVRIPDWHULDO WREHDSSOLHGSHUIWPXOWLSOLHGE\WKHQXPEHURIDSSOLFDWLRQV)DLUZD\VDUHSRXQGVRUWRQVRIPDWHULDOSHUDFUH 
5HYLHZ
1HHGWRJHWWKH.OHYHOVEDFNDERYHDFUHZLWKDDSSOLFDWLRQ7KHOLPHLVQRWFULWLFDOEXWHVVHQWLDOWRZRUNLQWRWKLV\HDU
VSURJUDPE\WKHHQGRIWKH
VHDVRQ7KH3OHYHOVDUHMXVWRNDQGFRXOGXVHDERRVWLIWUDIILFLVJRLQJWREHKHDY\:DONHUVDUHQ
WDFRQFHUQEXWLIFDUWDQGPDLQWHQDQFHWUDIILFLVKHDY\LWFRXOG
HDVLO\VKRZ6RLI\RXZDQWHGWRVDYHDWULSZLWKWKHVSUHDGHUDURXQGWKHFRXUVH\RXFRXOGKDYHWKHDQG0$3'$3EOHQGHGKDOIDQGKDOI\LHOGLQJD
ZLWK0$3RUD
ZLWK'$36SUHDGWKHEOHQGDWDFUH7KLVFRXOGEHDQDQQXDODSSOLFDWLRQ6HFRQGSRVVLELOLW\LVWRPDNHWKHSRWDVKSRUWLRQFRDWHGVR
LW
VOHVVOLNHO\WRTXLFNO\OHDFKRQ\RXUVDQGFDSSHGIDLUZD\VDQGFDUU\WKURXJKPRVWRIWKHJURZLQJVHDVRQZLWKDVSULQJDSSOLFDWLRQ$QGDWKLUGRSWLRQLVWRDGG
VRPHPDQJDQHVHWRWKDWEOHQGVRWKH0QOHYHOVFDQJHWPRYLQJIDVWHU



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW




*5((16
)LHOG

*
*
*
6DPSOH




/DE




7RWDO([FKDQJH&DSDFLW\
0(J




S+

+2





2UJDQLF0DWWHU>R&/2,
KXPXV
@




(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH





,'($/SSP

6ROXEOH6XOIXU
SSP

$




'HVLUHG9DOXH
0(+/,&+,,,





9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,


'HILFLW
DV32




'HVLUHG9DOXH
%5$<,,
OEVDFUH




9DOXH)RXQG



'HILFLW
2/6(13KRVSKRUXV




'HVLUHG9DOXH
&DOFLXP

(




9DOXH)RXQG
OEVDFUH
;




'HILFLW
&




'HVLUHG9DOXH
0DJQHVLXP

+&



9DOXH)RXQG
OEVDFUH
$$



'HILFLW
17




'HVLUHG9DOXH
3RWDVVLXP

*,



9DOXH)RXQG
OEVDFUH
(2
'HILFLW
$1




0D[LPXP'HVLUHG9DOXH
6RGLXP

%6



9DOXH)RXQG
OEVDFUH
/

([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17






&DOFLXP







0DJQHVLXP







3RWDVVLXP






6RGLXP





2WKHU%DVHV





+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256





%RURQ
SSP





,URQ
SSP





0DQJDQHVH
SSP





&RSSHU
SSP





=LQF
SSP






$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(



12ā1
SSP

+6




1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW




*5((16
)LHOG

*
*
*
6DPSOH





/DE




7RWDO([FKDQJH&DSDFLW\
0(J




S+

+2





2UJDQLF0DWWHU>R&/2,
KXPXV
@




(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH





,'($/SSP

6ROXEOH6XOIXU
SSP

$




'HVLUHG9DOXH
0(+/,&+,,,



9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,
'HILFLW
DV32




'HVLUHG9DOXH
%5$<,,
OEVDFUH




9DOXH)RXQG




'HILFLW
2/6(13KRVSKRUXV




'HVLUHG9DOXH
&DOFLXP

(



9DOXH)RXQG
OEVDFUH
;




'HILFLW
&




'HVLUHG9DOXH
0DJQHVLXP

+&



9DOXH)RXQG
OEVDFUH
$$



'HILFLW
17




'HVLUHG9DOXH
3RWDVVLXP

*,



9DOXH)RXQG
OEVDFUH
(2
'HILFLW
$1




0D[LPXP'HVLUHG9DOXH
6RGLXP

%6



9DOXH)RXQG
OEVDFUH
/
([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17






&DOFLXP






0DJQHVLXP





3RWDVVLXP





6RGLXP





2WKHU%DVHV





+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256





%RURQ
SSP





,URQ
SSP





0DQJDQHVH
SSP





&RSSHU
SSP





=LQF
SSP






$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(



12ā1
SSP

+6




1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW




*5((16
)LHOG

*
*
*
6DPSOH




/DE




7RWDO([FKDQJH&DSDFLW\
0(J




S+

+2





2UJDQLF0DWWHU>R&/2,
KXPXV
@




(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH





,'($/SSP

6ROXEOH6XOIXU
SSP

$




'HVLUHG9DOXH
0(+/,&+,,,



9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,
'HILFLW
DV32




'HVLUHG9DOXH
%5$<,,
OEVDFUH





9DOXH)RXQG




'HILFLW
2/6(13KRVSKRUXV





'HVLUHG9DOXH
&DOFLXP

(



9DOXH)RXQG
OEVDFUH
;



'HILFLW
&




'HVLUHG9DOXH
0DJQHVLXP

+&



9DOXH)RXQG
OEVDFUH
$$



'HILFLW
17




'HVLUHG9DOXH
3RWDVVLXP

*,



9DOXH)RXQG
OEVDFUH
(2
'HILFLW
$1






0D[LPXP'HVLUHG9DOXH
6RGLXP

%6



9DOXH)RXQG
OEVDFUH
/


([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17






&DOFLXP






0DJQHVLXP





3RWDVVLXP






6RGLXP






2WKHU%DVHV





+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256





%RURQ
SSP






,URQ
SSP







0DQJDQHVH
SSP





&RSSHU
SSP





=LQF
SSP







$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(



12ā1
SSP

+6





1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW

3*

*5((16
)LHOG

*
*
6DPSOH



/DE




7RWDO([FKDQJH&DSDFLW\
0(J



S+

+2




2UJDQLF0DWWHU>R&/2,
KXPXV
@



(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH




,'($/SSP

6ROXEOH6XOIXU
SSP

$



'HVLUHG9DOXH
0(+/,&+,,,


9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,
'HILFLW
DV32



'HVLUHG9DOXH
%5$<,,
OEVDFUH



9DOXH)RXQG


'HILFLW
2/6(13KRVSKRUXV



'HVLUHG9DOXH
&DOFLXP

(



9DOXH)RXQG
OEVDFUH
;

'HILFLW
&



'HVLUHG9DOXH
0DJQHVLXP

+&


9DOXH)RXQG
OEVDFUH
$$


'HILFLW
17



'HVLUHG9DOXH
3RWDVVLXP

*,


9DOXH)RXQG
OEVDFUH
(2

'HILFLW
$1




0D[LPXP'HVLUHG9DOXH
6RGLXP

%6


9DOXH)RXQG
OEVDFUH
/
([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17




&DOFLXP






0DJQHVLXP




3RWDVVLXP





6RGLXP





2WKHU%DVHV




+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256




%RURQ
SSP





,URQ
SSP




0DQJDQHVH
SSP




&RSSHU
SSP





=LQF
SSP






$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(


12ā1
SSP

+6


1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW




7((6
)LHOG

6DPSOH






/DE




7RWDO([FKDQJH&DSDFLW\
0(J




S+

+2





2UJDQLF0DWWHU>R&/2,
KXPXV
@




(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH





,'($/SSP

6ROXEOH6XOIXU
SSP

$




'HVLUHG9DOXH
0(+/,&+,,,



9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,
'HILFLW
DV32




'HVLUHG9DOXH
%5$<,,
OEVDFUH




9DOXH)RXQG



'HILFLW
2/6(13KRVSKRUXV





'HVLUHG9DOXH
&DOFLXP

(




9DOXH)RXQG
OEVDFUH
;


'HILFLW
&




'HVLUHG9DOXH
0DJQHVLXP

+&




9DOXH)RXQG
OEVDFUH
$$



'HILFLW
17




'HVLUHG9DOXH
3RWDVVLXP

*,



9DOXH)RXQG
OEVDFUH
(2



'HILFLW
$1





0D[LPXP'HVLUHG9DOXH
6RGLXP

%6



9DOXH)RXQG
OEVDFUH
/

([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17







&DOFLXP






0DJQHVLXP





3RWDVVLXP





6RGLXP





2WKHU%DVHV







+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256





%RURQ
SSP





,URQ
SSP





0DQJDQHVH
SSP





&RSSHU
SSP





=LQF
SSP






$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(





12ā1
SSP

+6




1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW




7((6
)LHOG

6DPSOH







/DE




7RWDO([FKDQJH&DSDFLW\
0(J




S+

+2





2UJDQLF0DWWHU>R&/2,
KXPXV
@




(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH




,'($/SSP

6ROXEOH6XOIXU
SSP

$




'HVLUHG9DOXH
0(+/,&+,,,





9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,
'HILFLW
DV32




'HVLUHG9DOXH
%5$<,,
OEVDFUH




9DOXH)RXQG



'HILFLW
2/6(13KRVSKRUXV




'HVLUHG9DOXH
&DOFLXP

(



9DOXH)RXQG
OEVDFUH
;



'HILFLW
&




'HVLUHG9DOXH
0DJQHVLXP

+&



9DOXH)RXQG
OEVDFUH
$$




'HILFLW
17




'HVLUHG9DOXH
3RWDVVLXP

*,



9DOXH)RXQG
OEVDFUH
(2



'HILFLW
$1





0D[LPXP'HVLUHG9DOXH
6RGLXP

%6



9DOXH)RXQG
OEVDFUH
/

([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17






&DOFLXP





0DJQHVLXP






3RWDVVLXP






6RGLXP





2WKHU%DVHV





+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256





%RURQ
SSP





,URQ
SSP





0DQJDQHVH
SSP






&RSSHU
SSP





=LQF
SSP






$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(



12ā1
SSP

+6



1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW



7((6
)LHOG

6DPSOH





/DE



7RWDO([FKDQJH&DSDFLW\
0(J



S+

+2





2UJDQLF0DWWHU>R&/2,
KXPXV
@



(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH




,'($/SSP

6ROXEOH6XOIXU
SSP

$



'HVLUHG9DOXH
0(+/,&+,,,



9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,
'HILFLW
DV32



'HVLUHG9DOXH
%5$<,,
OEVDFUH



9DOXH)RXQG



'HILFLW
2/6(13KRVSKRUXV



'HVLUHG9DOXH
&DOFLXP

(



9DOXH)RXQG
OEVDFUH
;


'HILFLW
&



'HVLUHG9DOXH
0DJQHVLXP

+&


9DOXH)RXQG
OEVDFUH
$$



'HILFLW
17



'HVLUHG9DOXH
3RWDVVLXP

*,


9DOXH)RXQG
OEVDFUH
(2


'HILFLW
$1



0D[LPXP'HVLUHG9DOXH
6RGLXP

%6


9DOXH)RXQG
OEVDFUH
/
([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17




&DOFLXP





0DJQHVLXP




3RWDVVLXP




6RGLXP




2WKHU%DVHV




+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256




%RURQ
SSP





,URQ
SSP




0DQJDQHVH
SSP





&RSSHU
SSP




=LQF
SSP





$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(


12ā1
SSP

+6




1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW




)$,5:$<6
)LHOG

)
)
)
6DPSOH







/DE






7RWDO([FKDQJH&DSDFLW\
0(J





S+

+2





2UJDQLF0DWWHU>R&/2,
KXPXV
@




(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH





,'($/SSP

6ROXEOH6XOIXU
SSP

$




'HVLUHG9DOXH
0(+/,&+,,,



9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,
'HILFLW
DV32




'HVLUHG9DOXH
%5$<,,
OEVDFUH




9DOXH)RXQG



'HILFLW
2/6(13KRVSKRUXV





'HVLUHG9DOXH
&DOFLXP

(




9DOXH)RXQG
OEVDFUH
;



'HILFLW
&




'HVLUHG9DOXH
0DJQHVLXP

+&




9DOXH)RXQG
OEVDFUH
$$




'HILFLW
17




'HVLUHG9DOXH
3RWDVVLXP

*,



9DOXH)RXQG
OEVDFUH
(2




'HILFLW
$1




0D[LPXP'HVLUHG9DOXH
6RGLXP

%6



9DOXH)RXQG
OEVDFUH
/
([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17









&DOFLXP






0DJQHVLXP






3RWDVVLXP






6RGLXP





2WKHU%DVHV





+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256





%RURQ
SSP







,URQ
SSP





0DQJDQHVH
SSP






&RSSHU
SSP






=LQF
SSP







$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(



12ā1
SSP

+6




1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW




)$,5:$<6
)LHOG

)
)
)
6DPSOH






/DE




7RWDO([FKDQJH&DSDFLW\
0(J





S+

+2





2UJDQLF0DWWHU>R&/2,
KXPXV
@




(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH



,'($/SSP

6ROXEOH6XOIXU
SSP

$




'HVLUHG9DOXH
0(+/,&+,,,



9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,
'HILFLW
DV32




'HVLUHG9DOXH
%5$<,,
OEVDFUH





9DOXH)RXQG



'HILFLW
2/6(13KRVSKRUXV





'HVLUHG9DOXH
&DOFLXP

(



9DOXH)RXQG
OEVDFUH
;




'HILFLW
&




'HVLUHG9DOXH
0DJQHVLXP

+&




9DOXH)RXQG
OEVDFUH
$$





'HILFLW
17




'HVLUHG9DOXH
3RWDVVLXP

*,



9DOXH)RXQG
OEVDFUH
(2



'HILFLW
$1





0D[LPXP'HVLUHG9DOXH
6RGLXP

%6



9DOXH)RXQG
OEVDFUH
/
([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17






&DOFLXP






0DJQHVLXP





3RWDVVLXP






6RGLXP





2WKHU%DVHV





+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256





%RURQ
SSP






,URQ
SSP





0DQJDQHVH
SSP





&RSSHU
SSP






=LQF
SSP






$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(



12ā1
SSP

+6



1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&



,'

&URWRQRQ+XGVRQ
&LW\

+XGVRQ1DWLRQDO*ROI&OXE
$FFRXQWRI


'DWH

1<
6WDWH

5(3&RQVXOWLQJ,QF
&RQVXOWDQW



528*+
)LHOG

6DPSOH




/DE





7RWDO([FKDQJH&DSDFLW\
0(J



S+

+2




2UJDQLF0DWWHU>R&/2,
KXPXV
@



(VWLPDWHG1LWURJHQ5HOHDVH
OEVDFUH




,'($/SSP

6ROXEOH6XOIXU
SSP

$



'HVLUHG9DOXH
0(+/,&+,,,


9DOXH)RXQG
(DVLO\([WUDFWDEOH
3KRVSKDWHV

,
'HILFLW
DV32



'HVLUHG9DOXH
%5$<,,
OEVDFUH


9DOXH)RXQG


'HILFLW
2/6(13KRVSKRUXV



'HVLUHG9DOXH
&DOFLXP

(


9DOXH)RXQG
OEVDFUH
;


'HILFLW
&



'HVLUHG9DOXH
0DJQHVLXP

+&


9DOXH)RXQG
OEVDFUH
$$

'HILFLW
17



'HVLUHG9DOXH
3RWDVVLXP

*,


9DOXH)RXQG
OEVDFUH
(2

'HILFLW
$1



0D[LPXP'HVLUHG9DOXH
6RGLXP

%6


9DOXH)RXQG
OEVDFUH
/
([FHVV
(

,'($/
IRU7(&!

%$6(6$785$7,213(5&(17




&DOFLXP




0DJQHVLXP




3RWDVVLXP




6RGLXP




2WKHU%DVHV




+\GURJHQ

'(6,5('
(;75$&7$%/(0,1256





%RURQ
SSP




,URQ
SSP




0DQJDQHVH
SSP





&RSSHU
SSP




=LQF
SSP






$OXPLQXP
SSP

0RO\EGHQXP
SSP

6ROXEOH6DOWV
PPKRVFP

27
&KORULGH
SSP

7(


12ā1
SSP

+6


1+ā1
SSP

(7
56

GHVLUHGYDOXHVSURYLGHGE\5(3&RQVXOWLQJ,QF
%522.6,'(/$%25$725,(6,1&

C-1 
 
APPENDIX C. 2000 EMP Fertilizing Section with 2011 and 2017 Amendments 
 
C-2 
 
ENVIRONMENTAL & TURF SERVICES, INC. 
11510 Georgia Avenue, Suite 227 
Wheaton, MD 20902 
(301) 933-4700 
Fax (301) 933-4701 
ETS@ETS-MD.com 
 
January 17, 2017 
 
Mr. Daniel O’Connor 
1 Van Wyck Street 
Croton-on-Hudson, NY 10520 
 
RE: 
The Combined HNGC’s EMP (2000) 
Nutrient Management Amendments 
(2000, 2011, and 2017) 
 
Dear Mr. O’Connor: 
 
The nutrient management portion of the Environmental Management Plan (EMP; i.e., 
fertilizer applications, soil/tissue sampling) has been reviewed several times since 2000, in 
order to update the turf management strategies. A golf course EMP should be a living 
document (i.e., changes should be made as newer and/or safer products become available and 
as nutrient strategies evolve). 
 
We are recommending amendments to the fertilizer program at the Hudson National 
Golf Club (HNGC) because the nitrogen response thresholds were exceeded at four on-site 
surface water stations during the fall of 2016 storm flow sampling event. In addition, we 
submitted nutrient management recommendations in 2011, which were subsequently 
approved and have been incorporated into the operation of the golf course by the 
superintendents, as stated in the attachment following each amendment (e.g., the soil testing 
frequency was reduced because it was excessive). 
 
The attachment provides the extracted “Fertilizing” section pages 3-8 from the EMP 
(2000), as well as the 2011 approved amendments and our 2017 recommendation for nutrient 
management at the HNGC. 
 
The amended nutrient management program, if approved, should be implemented 
immediately. The 2011 and 2017 amendments will supersede the 2000 EMP where a change or 
recommendation is shown. Otherwise, the 2000 EMP will remain in effect. 
 
The original EMP (2000) tables are presented at the end of the attachment for 
continuity of text. Tables 2 and 3 were corrected to show the 2011 and 2017 amended 
applications. The 2000 EMP, the 2011 amendments, and our 2017 recommendations are 
attached. 

C-3 
 
Thank you for the opportunity to provide our recommendations for EMP amendments. 
If you have any questions, please let us know. 
 
N. LaJan Barnes, M.S., P.G. 
 
Project Manager, Sr. Hydrogeologist 
 
Stuart Z. Cohen, Ph.D., CGWP 
President 
 
Ken Ingram, CGCS, MG 
Turf Agronomist 
 
Attachment: “Fertilizing” Section: EMP 2000 (pages 3-8), 2011 Amendments, and 2017 
recommended amendment 
 
cc: 
Ryan Oliver, HNGC Superintendent  
 
Environmental & Turf Services, Inc. 
 
C-4 
 
ATTACHMENT: Amended Fertilizing Section - Environmental Management Plan 
 
FERTILIZING 
EMP 2000 
 
The most important aspect of a sound fertilizer program is to ensure that the nutrients 
applied do not end up in surface and/or ground water and do not drift off-site. Nitrogen and 
phosphorus are the elements most often associated with eutrophication of lakes and streams. 
Other nutrients do not seem to pose a problem to surface waters. 
 
Excessive nitrate concentrations in ground water represent a health hazard where ground 
water is tapped for drinking water supplies. Much of the nitrogen applied to golf courses is in the 
ammonium and nitrate forms. The results of research on nitrogen fertilizers applied to turf 
grasses (Petrovic; 1990) reveal that nitrate-nitrogen concentrations in soil water leaching through 
the surface soil exceeds drinking water standards of 10 ppm only where soils are sandy and one 
of the following conditions exist: 1) high levels of soluble nitrogen life applied, greater than 3 
lbs. N/1000 sq.ft. at one time; or 2) very frequent (daily) irrigation is practiced coupled with 
application of water soluble nitrogen sources. Accordingly, nitrate movement may be minimized 
by addressing efficiency in rate and timing of nitrogen inputs, through choice of materials, and 
efficiency in rate and timing of irrigation. Reports by Walker and Branham (1992) concluded 
that several management actions effectively minimize or eliminate nitrate movement: 1) limit 
irrigation to replacement of soil moisture; 2) use slow release nitrogen sources; 3) time fertilizer 
applications in relation to active uptake; and 4) use realistic nitrogen application rates. 
 
When a fertilizer is applied in excess of what the plant can use or when the turf is not 
actively growing due to temperature, water, light, lack of an individual nutrient, etc., much of the 
application could be lost. For these reasons, before a fertilizer is applied, the limiting growth 
factors must be considered. In addition, only a fertilizer containing the nutrients in the right form 
needed by the plant should be used and applied at the appropriate rate and frequency. Plants will 
respond favorably to fertilizer applications only if the application contains a nutrient that is 
deficient. 
 
To ensure that fertilizer applications address actual deficiencies, soils must be analyzed to 
determine pH, calcium, magnesium, phosphorus and potassium availability and balance. From 
this information a valid lime and fertilizer program can be developed with the assurance that 
excess nutrients will not be applied. Soils are to be sampled at all greens, tees, and fairway areas. 
Data from these analyses will be used to adjust fertilizer rates based on soil residual levels, 
thereby avoiding excess application of materials which could become nonpoint sources of 
pollution. 
 
We recommend that soil testing be done once annually, during the winter months 
(December/January). These results should be used to determine fertilizer requirements for the 
upcoming growing season. 
Amendment 2011 – Soil Testing 
 
Environmental & Turf Services, Inc. 
 
C-5 
 
Reason for Soil Testing Change 
 
Samples were not being collected in accordance with the current EMP (2000), and the 
EMP (2000) sampling frequency requirement was excessive for a well-established golf course. 
In addition, soil testing is the most reliable method for determining fertilizer applications. 
Annual testing is now sufficient given the several years of experience that has been accumulated. 
More frequent testing was needed when the golf course was young.  
 
EMP 2000 
 
Nitrogen is the nutrient used by grasses in the largest quantities. Its function is to 
stimulate vegetative growth and provide the grass with green color. Nitrogen fertilization needs 
are to be determined by color, density and rate of growth (clipping yields) of grass, and plant 
tissue analysis. Plant tissue analysis is to be conducted on selected locations every three to four 
weeks during the growing season. This will serve as a guide for determining if nutrients are in a 
sufficiency range or if fertilization is needed to balance the nutrition. Freshly harvested tissue is 
to be collected and dried in a microwave oven. The dried plant material is to be sent to a lab and 
analyzed for a standard compliment of analytes, including nitrogen, phosphorus, potassium, 
calcium, magnesium, sulfur, iron, and manganese. 
 
We recommend that tissue testing be conducted bimonthly in May, July, and September 
on selected greens and fairways. These samples should be rotated to incorporate 
underperforming greens and fairways. The rotation of tissue sample collection locations should 
provide optimum information for nutrient management. The best results may be obtained by 
comparing underperforming greens and fairways to those in good condition and adjusting 
fertilizer applications to those “weaker” areas, which will allow fertilizer application adjustments 
to the “weaker” areas. 
Amendment 2011 - Tissue Testing 
 
Reason for Tissue Testing Change 
 
The original tissue testing schedule appeared to be excessive and it was not being done in 
accordance with the EMP (2000). In addition, the EMP (2000; pg. 16) states that tissue samples 
should be collected periodically as determined by the Superintendent, which had been done. 
Tissue testing using the 2011 bimonthly schedule has mostly been followed, with a few missed 
sampling dates. 
 
The fertilizer applications and the soil and tissue sample results should be submitted with 
the Superintendent’s annual report. In addition, the report should include a section that briefly 
explains how the results from the soil and tissue analyses were incorporated into the fertilizer 
program. 
Amendment 2011 – Reporting 
 
Reason for Reporting Change 
 
The soil and tissue testing results have always been included in the Superintendent’s 
report. However, there was no explanation about how those results were being used to develop 
the fertilizer program. 
 
Environmental & Turf Services, Inc. 
 
C-6 
 
EMP 2000 
 
Leaching of nitrate nitrogen can be minimized by making controlled applications (spoon 
feeding), by using controlled materials (slow-release) or by using a combination of these 
approaches. The superintendent will personally control applications by either using soluble 
fertilizers and applying the materials with a sprayer that has been calibrated to put out an 
accurate amount of material per acre, or through fertigation. Under either approach, the 
superintendent can personally control the rate and frequency of fertilizer application; thereby 
reducing the tendency to apply excessive amounts of nitrate and ammonium forms of nitrogen on 
an infrequent basis. 
 
Controlled materials, such as natural organic sources (Milorgranite, Ringer, Sustane, 
etc.), isobutylidene diurea (IBDU), methylene ureas (MU) and coated ureas (SCU, Polyon, Poly-
S, Sulfurkote-ll and others) are all slow-release (SR) nitrogen sources. They have the advantage 
of supplying a longer more uniform source of nitrogen, a lower salt index and reduced nitrogen 
leaching. 
 
The products mentioned in the original EMP (Milorganite, Sustain, Ringer) are still 
available; however, some of the newer products (e.g., Earthworks™ and Perdue PPM) need to be 
incorporated, especially the “poly” coated ureas. 
Amendment 2011 – Other Product Uses 
 
Reason for Other Product Uses Change 
 
This was done in order to help keep the EMP a living document as nutrient strategies 
evolve and as newer and/or safer products become available. 
 
EMP 2000 
 
By combining soluble nitrogen sources with the slow-release nitrogen products, 
availability can be extended to the grass without prompting nitrogen leaching into the 
groundwater. Also, the use of fertigation will allow the superintendent to apply small amounts of 
fertilizer to locations where it is needed and thus reduce the likelihood of off-site contamination. 
 
Note 2017: Fertigation is not used at the HNGC. 
 
BASIC FERTILIZER PROGRAM 
EMP 2000 
 
Creeping bentgrass and Kentucky bluegrass grow within a wide soil pH range. However, 
for optimum soil microbial activity and improved nutrient availability it is preferred to keep the 
pH in the 5.5 to 6.5 range. Also important is the maintenance of a calcium to magnesium ratio of 
10:1. 
 
The basic turfgrass fertilization program for the Hudson National Golf Club is presented 
in Tables 2 through 5. Additional, location specific provisions are presented below. 
 
Greens. If soil test results indicate that either dolomite for soil pH correction and/or phosphorus 
are needed, they shall be applied during aerifying operations so that they can be worked into the 
root zone. The addition of potassium shall be made in three to four applications per year and 

Environmental & Turf Services, Inc. 
 
C-7 
 
applied at the rate of ½ to 1 pound per 1000 square feet. Slow release sources of nitrogen shall be 
applied at the rate of 0.5 to 1.0 pound per 1000 square feet. 
 
Tees. If phosphorus and dolomite are needed, the tee surfaces shall be treated the same as the 
greens. Nitrogen and potassium lire to be applied at about the same rate as for the putting greens. 
 
Fairways. Dolomite and phosphorus applications arc to be based on soil test results. No 
individual application of nitrogen or potassium is to exceed 40 pounds per acre and ½ the 
nitrogen is to be from a slow release source. 
Roughs. Roughs are to be fertilized two times per year. Dolomite and phosphorus applications 
are to be based on soil test results. Individual applications of nitrogen and potassium are not to 
exceed 40 pounds per acre and ½ the nitrogen is to be from a slow release source. 
 
We recommend that fertilizer applications incorporate some of the newer products (e.g., 
Earthworks™ and Perdue PPM) and that single application rates be reduced to no more than 0.5 
lb N/1,000 sq ft in keeping with the EMP (2000)
Amendment 2011 – Fertilizer Application Reduction (all areas) 
 
. Fertilizer applications should be delayed if 
heavy rainfall is forecast. Total applications should not exceed 3.0 lb N/1000 sq ft during a 
growing season. This is a reduction of the total N applications currently allowed (i.e., 4-5.5 
N/1,000 sq ft) in Table 3 of the EMP (2000). 
 
Multiple “spoon feeding” applications of 0.1 lb N/1,000 sq ft should be used on greens, 
tees, and fairways during the optimum growing season (April-October). Fertilizer applications 
can be tank mixed with fungicide applications on two-week intervals. These low nutrient rates 
have little risk of runoff and can be extremely beneficial to plant health especially with the 
management of anthracnose disease on putting greens. 
 
Phosphorus and potassium applications should be based on the results of the soil and/or 
tissue sample results. 
 
Further, no more than 1,000 lb of N may be applied between October 15 and early spring 
(April 1). 
2017 Recommendation – Total N – Additional Fertilizer Application Restrictions 
 
Reason for Additional Fertilizer Application Restrictions of Total N  
 
It appears that the N applications made prior to the fall sampling events in 2016 were the 
cause of the N-N RT exceedances at all on-site stations and the cause of one exceedance in 2016 
(see our fall letter report, ETS, 2017).  
 
We have carefully considered the formulations of the nitrogen fertilizers, the amounts 
that have been applied, and the timing of the applications. Regarding the latter, it is important to 
                                                        
2 This 0.5 lb N/1000 ft2 limit should be relaxed in the future, after all N exceedance problems have been resolved. 
Specifically, we recommend that the future limit on single applications of certain controlled release N fertilizers 
such as POLYON® be raised to 1.5 lb N/1000 ft2, if it can be established that such release occurs over a period 
averaging at least 12-16 weeks. This change should be considered the next time the EMP is modified, but not now. 

Environmental & Turf Services, Inc. 
 
C-8 
 
note that the turfgrass in that region of the country is probably not actively growing after early to 
mid-November. This means that N that is applied during and after this time is more available to 
runoff near the soil’s surface than N that is applied, e.g., in May. Therefore, we recommend that 
applications not exceed 1,000 total lb nitrogen after October 15 until early spring to help prevent 
N-N RT exceedances at the surface water stations. 
 
References: 
Dahlgren, R.A. and C.T. Driscoll. 1994. The Effects of Whole-Tree Clear-cutting on Soil 
Processes at the Hubbard Brook Experimental Forest, New Hampshire, USA. Plant and 
Soil158:239-262. 
 
ETS, 2017. January 11, 2017. Fall Letter Report: 2016 Surface Water Sampling Events. 
Submitted to the Village Croton-on-Hudson Engineer Daniel O’Connor. Environmental & 
Turf Services, Inc., Wheaton, MD. 
Petrovic, A.M. 1990. The Fate of Nitrogenous Fertilizers Applied to Turfgrass. J. Environ. Qual., 
Vol. 19:1-14. 
Environmental Management Plan (EMP; Turf Science Group). 2000. EMP for the Hudson 
National Golf Club, Croton-on-Hudson, New York. Turf Science Group, Inc., Raleigh, NC. 
Revised January 10, 2000.  
Walker, W.J. and B. Branham. 1992.  "Environmental Impacts of Turfgrass Fertilization," 
Chapter 3, In: J.C. Balogh and W.J. Walker. [eds] Golf Course Management Environmental 
Issues
 
. Lewis Publishers. 
 
Table 2. General Fertilizer Applications on Greens and Tees 
(Pounds per 1000 square feet per year). † 
Areas 
Nitrogen 
Phosphorus 
Potassium 
Greens 
 3.0 (2011) 
1 to3 
4 to 6 
Tees 
 3.0 (2011) 
1 to3 
4 to 6 
† Adjustments are to be made based upon testing results and turf response. 
 
Table 3. Fertilizer Schedule for Greens and Tees 
(Pounds per 1000 square feet per application). † 
Greens & 
Tees 
Apr* 
May 
June 
July 
Aug 
Sep* 
Oct 
Nov 
Total 
Nitrogen 
WS 
0.25 
WS 
0.25 
NO 
0.5 
NO 
0.5 
NO 
0.5 
SR 0.5 
WS 
0.5 
‡(2017) 
 
3.0 
(2011) 
SR 
0.25 
SR 
0.25 
 
Phosphorus 
0.25 
 
0.4 
0.4 
0.4 
 
1.45 
Potassium 
0.5 
0.5 
0.8 
0.8 
0.8 
0.5 
0.5 
0.5-1 
4.9-5.4 
† Adjustments are to be made based upon testing results and turf response. May be modified by the fertigation 
schedule. 
* application may be reduced or eliminated after first several years. 
WS = Water soluble; SR = Slow release; NO = Natural organic. 
‡ Applications not exceed 1,000 total lb N between October 15 and early spring (April 1; see text above). 

Environmental & Turf Services, Inc. 
 
C-9 
 
Table 4. General Fertilizer Applications on Fairways, Intermediate 
Rough and Rough (Pounds per acre per year). † 
Area 
Nitrogen 
Phosphorus 
Potassium 
Fairways 
90 to 180 
45 to135 
90 to 225 
Intermediate Rough 
60 to 120 
22 to 66 
60 to 120 
Rough 
40 to 80 
0 to 45 
40 to 80 
Vegetative Filter Strip 
† Adjustments are to be made based upon testing results and turf response. May be modified 
by the fertigation schedule. 
 
Table 5. Fertilizer Schedule for Fairways and Roughs 
(Pounds per acre per application). 
Fairways 
May 
June 
July 
Aug 
Sep 
Total 
Nitrogen 
WS 22.5 
NO 45 
 
NO 45 
WS 22.5 
SR 22.5 
 
SR 22.5 
Phosphorus 
22.5 
 
58.5 
Potassium 
 
Roughs 
May 
June 
July 
Aug 
Sep 
Total 
Nitrogen 
WS 20 
 
WS 20 
SR 20 
 
SR 20 
Phosphorus 
22.5 
 
22.5 
Potassium 
 
Intermediate Roughs 
May 
June 
July 
Aug 
Sep 
Total 
Nitrogen 
WS 20 
WS 10 
 
WS 20 
SR 20 
SR 10 
SR 20 
Phosphorus 
 
Potassium 
 
Vegetative Filter 
Strip 
May 
June 
July 
Aug 
Sep 
Total 
Complete N-P-K 
40-20-40 
 
40-20-40 
† Adjustments are to be made based upon testing results and turf response. 
WS = Water soluble; SR = Slow release; NO = Natural organic
Machine-extracted for search and reference — the original PDF is the authoritative version.