CHAPTER I INTRODUCTION 1.1 Background of the Research 1.2 Research Scope, Aims and Hypotheses 1.3 Case Selection, Case Studies and Methodology 1.4 Overview of the Conceptual Framework 1.5 Significance of the Research 1.6 Organization of the Dissertation Abstract This chapter outlines the background of the research, research questions, brief review of the literature, research scope, aims and hypotheses, significance and limitations of the research, the overview of the conceptual framework and definition of terms, case selection, case studies and analytic methodology, as well as a road map for the rest of the dissertation. 1.1 Background of the Research There are more than 32,000 golf courses worldwide1, with a rate of development increasing annually, along with their adverse impacts on the environment. And for the last 20 years, the world has seen a considerable proliferation of golf courses in Asia owing to sustained economic growth in the region.2 Moreover, golf has become the preferred sport amongst Asians nowadays and many governments have adopted golf tourism as national policy to spur economic growth.3 The Philippines, for instance, boasts of seventy-eight golf clubs compared with just 20 courses from two decades ago.4 Thailand has 2225 courses, Viet Nam is hurriedly catching up with 1 Visit http://www.golf-research-group.com/start.html. Accessed on October 16, 2012. 2 The proliferation commenced in 1990s and peaked before the 1997 Asian economic downturn started to implode. There was a development hiatus for seven years and construction started to pick up again, with China building hundreds of golf courses annually (in 2004, there are 170 courses which grew to 645 in 2011). Read “New Golf Openings”, Golf Research Group (2003) at http://www.golf-research- group.com/start.html. Also visit http://en.wikipedia.org/wiki/Golf_in_China. Accessed on May 5, 2013. 3 Thailand and Philippines, in many news accounts, have declared a national policy to promote golf tourism, e.g. construction of infrastructures to connect and link golf courses to the national highway and city centres; grant of fiscal and non-fiscal incentives to golf complexes established in tourism economic zones. “Golf Tourism Exploding in Asia”, Golf Asian.com at http://www.golfasian.com/about/golfasian- press-releases/news/golf-tourism-exploding-in-asia/. Accessed on January 23, 2013. 4 Visit National Golf Association of the Philippines (NGAP) at http://www.ngaponline.net/History.php. Accessed on May 17, 2013. See generally, Golf Guide Philippines, 2010, JTech Publications listing of partially developed or temporarily shelved golf courses for various reasons, e.g. lack of funds or legal problems. 5 Visit Thailand Golf Association (TGA) at http://www.tga.or.th/#suwcontent=contentsuwcntdispcontentpagesuwcntDIV_MAINCONTENTsuwcntC ONTENTTYPE%3Dhistorysuwcnt1368740286848. Accessed on May 17, 2013. twenty-eight6 and Singapore has eighteen golf clubs with twenty-six courses.7 These figures are increasing steadily at an average rate of two new courses being constructed annually.8 Most of these golf courses are considered “traditional” or conventional, because they pursue a particular mode of construction and management, i.e. prodigious use of chemicals, water, white sand or pebbles, and hybrid turf grasses - not only to ensure the playing quality of the surface but also aesthetically to enhance the greens and a substantial portion of the golf course (tees, fairways). Moreover, most courses are built either on pristine or un-spoilt lands, hilly plains and mountainous areas for breathtaking landscapes and challenging games. During the construction and landscaping stage, the earth-moving activities generally destroy topsoil, re-direct riverine and wild life habitats, as well as damage ecosystems. But mostly, golf courses have converted vast tracts of agricultural lands, particularly paddy fields, which bring trepidations about food security in the region. Significantly, the “traditional” or conventional method of construction and operation of golf courses is causing adverse environmental, health, social and economic impacts. Firstly, golf courses require vast tracks of land for the construction of complexes. These lands could either be agricultural, hilly or mountainous areas, reclaimed marine or coastal areas, or mostly state lands. Secondly, golf courses use large quantities of chemicals which are highly toxic and can also bio- accumulate in organisms9 . Chemicals also pose risks to people exposed to them. Thus, there is a need to regulate the use of these chemicals (fertilizers, pesticides, herbicides, fungicides and coagulants). The problem is exacerbated in developing countries, where government policies encourage agro-chemical use as chemicals are seen as production enhancers – similarly, substantial chemical application has become the popular “culture” in turf grass management in golf courses. There are however, “sustainable” golf courses – those courses that break from the norm to explore and adopt new practices and principles, disproving the notion that golf courses 6 Twenty-eight courses are under construction. Data taken from Viet Nam Golf Association (VGA) at http://www.vga.com.vn/?show=intro&ic=1&list=6. Accessed on May 17, 2013. 7 Visit Singapore Golf Association (SGA) at http://www.sga.org.sg/Association/History/tabid/175/Default.aspx. Accessed on May 17, 2013. 8 The approximation is based on reports culled from the national bodies of golf and news reports. 9 Bi-accumulation is a “general term describing a process by which chemicals are taken up by an organism either directly from exposure to a contaminated medium or by consumption of food containing the chemical”, United States Environmental Protection Agency (EPA), available at http://toxics.usgs.gov/definitions/bioaccumulation.html. Accessed on March 24, 2011. 2 invariably are destructive.10 “Sustainable” golf courses observe or conform to a combination of legal and regulatory compliance, self-regulation, best management practices, good governance, transparency and corporate social responsibility, etc. These types of golf courses also adopt the principle of ethical and responsible utilization of land, water, chemicals, sand and hybrid turf grasses. The non-traditional or sustainable golf courses meet the aim of balancing the philosophy of PPP (People, Profit and Planet) that lies at the heart of the sustainable development paradigm. It can be stated that, “tradition and practice” have popularly considered golf course management or turf maintenance as agriculture.11 This “misplaced” treatment and recognition – both by the government regulators and the regulated golf course industry actually results in dis- order or confusion, particularly in the compliance and enforcement of laws and regulations. This is evident in the use and application of chemicals, which is one of the core operations of golf courses. Currently, legislation and regulations on chemical application specifically applies only to agricultural activities and production. Theoretically, turf management is not agriculture. Agriculture is defined as “an activity intended for food production”.12 Food production is not the goal or the objective of golf course management 13 rather it is the cultivation of the greens and other golfing surfaces to ensure playing quality. It follows that turf management would appear to be excluded from the coverage of chemical regulation of agricultural activity. This also means that the laws governing the use of chemical pesticides and fertilizers in the context of agricultural activities may not apply to golf courses. Presumably, the confusion was due to the fact that turf grass management is a branch of a broad and multi-disciplinary science of agriculture, which encompasses soil science and fertility, pest control, ornamental horticulture, landscape design and environmental science, etc. Moreover, golf course superintendents have 10 The TAT Filipinas Golf Club, Philippines, received the Inaugural “Custodian of the Environment Award” for sustainable golf practices and management. Underwritten by the government of the Royal Sultanate of Brunei, the prize was awarded last December 11, 2012, in Brunei Darussalam. The International Sustainability Council, Asia-Pacific Golf Conferences and the Audubon Lifestyles also support the inaugural award. Visit the Ministry of Industry and Primary Resources website of Brunei Darussalam at http://www.bruneimipr.gov.bn/index.php?option=com_content&view=article&id=555:asia- pacific-golf-summit-dinner-and-award-presentation-for-the-inaugural-custodian-of-the-enviromment- award&catid=79:news-highlights and http://www.theborneopost.com/2012/12/12/call-to-make-golf- courses-environmentally-sustainable/. Accessed on January 23, 2013. 11 See, Scott R. Templeton, David Zilberman and Mark S. Henry, Golf Courses in California As Modern Agricultural Enterprises, available at http://agecon.ucdavis.edu/extension/update/articles/v13n3_3.pdf. Accessed on March 11, 2011. 12 Britannica Concise Encyclopedia 2007 Edition defines agriculture (n.) as the science, art, and business of cultivating soil, producing crops, and raising livestock; farming. 13 Turf grass management pertains to the science and study of grasses. See generally, http://cropsoil.psu.edu/turf/outreach. Accessed on November 3, 2010. 3 traditionally “treated” or considered turf management as agriculture owing to adhered conventional practices and orientation. As habitat for wild plants, aquatic animals and other organisms, golf courses have a considerable impact on biodiversity. However, existing laws focus on habitat protection, nature and wildlife conservation, as well as regulation of the trade in endangered species. There are also golf courses, which are constructed or developed in natural, coastal, marine or protected areas, which can destroy intertidal flats, reefs and corrals, but existing laws have not incorporated the regulation of golf courses on reclaimed lands. The environmental cost arising from golf course development on reclaimed coastal areas have not been considered although these maybe determined through a Cost-Benefit Analysis (CBA). The adverse impacts, associated by dredging and landfill operations on land and water resources of coastal reclamation should also be considered, as there are environmental trade-offs. Golf courses also consume significant amounts of water to keep them green and of excellent playing quality. The United Nations Environmental Programme (UNEP) estimates that golf courses worldwide consume some 2.5 billion gallons of water a day.14 In a world where water is getting more scarce as a result of climate change, urbanization, industrialization, population growth and inefficiencies, there is a need for better regulation of water consumption by golf courses. Water for golf courses come from various sources: from rainfall, from the ground, from rivers, from water re-use, etc. The amount of water that golf courses consume – in competition with other uses – raises an issue on the pricing of water that golf courses must pay. This implies a need for special regulation on water consumption by golf courses that would otherwise not be normally covered by regulations on water consumption by domestic and industrial sectors. Other critical issues discussed in this dissertation include hybrid turf grass use15, which involves “genetic selection and recombination resulting in the introduction of new and improved 14 Water Facts, Water Information Program, available at http://www.waterinfo.org/resources/water-facts. Accessed on June 24, 2012. Sources, Water Usage: Chris Reuther, Know Your Environment, Academy of Natural Sciences, 1999; National Golf Foundation; State of the World 2004; Pesticides: “EcoMall: A Greener Golf Course, 2004” 15 When golf courses grow hybrid turf grasses, conventional maintenance practices require huge watering demand and massive chemical usage, etc. Read generally, James B. Beard, Turf Management for Golf Courses, United States Golf Association (USGA), Macmillan Press, 1982. 4 cultivars”.16 Genetic modifications naturally increase chemical requirements owing to the special characteristics of the species, which may vary from temperate to tropical zones. The possibility of “trans-gene release or escape into the wild from transgenic plants may result in ecological disaster.17 There are also instances when historical and archeological sites are disturbed, damaged or destroyed to make way for golf course development, particularly the case of Eastridge Golf Course in the Philippines, one of the case studies in this dissertation. In developing countries golf per se is linked with socio-cultural issues e.g. corruption, displacement of farm-workers, land use conversion18, “land grabs”19 and prostitution20. A. Sustainable Development There is concern that the proliferation of traditionally managed golf courses represents the type of economic growth, which conflicts with sustainable development. The Brundtland Report (1987) in “Our Common Future” first coined the notion of Sustainable Development as “development that meets the needs of the present without compromising the ability of future generations to meet their own needs”. Seminal works have been written about the definition and meaning of sustainable development, including debates and contestations Saunders (1990)21, Pearce (1993)22, Beckerman (1994)23, Daly (1995)24, Alder and Wilkinson (1999)25, Jacobs 16 Craig W. Edminster, Future of Turfgrass Breeding Techniques, Cebeco International Seeds, Australia. Available at http://www.intlseed.com/documents/info_future_of_turfgrass_breeding.htm. Accessed on May 30, 2011. 17 See Luo, H., Development of Environmentally Safe Transgenic Turf Grass with Improved Traits, Clemson University, United States Department of Agriculture. Visit http://www.reeis.usda.gov/web/crisprojectpages/208011.html. Accessed on May 30, 2011. 18 In the Philippines, Executive Order 292, Series 1987, Book IV, Title XI stipulates that the Department of Agrarian Reform (DAR) is authorized to approve or disapprove conversion of agricultural lands to non- agricultural uses, such as industrial and commercial conversions under Republic Act No. 6657, the Comprehensive Agrarian Reform Law. 19 Land Grabbing: The Global Search for Food Security in Southeast Asia (2010), NTS-Asia (Consortium of Non-Traditional Security Studies), Issue 1, May 2010. “Land grab” refers to the farmland acquired by government-backed foreign investors to secure food security. A 2009 Report by the Food and Agriculture Organization (FAO), International Fund for Agricultural Development (IFAD) and the International Institute for Environment and Development (IIED) suggest that, “food security concerns and strategic investment opportunities are the key drivers of farmland acquisition”. 20 Current practices in most Asian countries involve the hiring of young women (ages between 16-20) as caddies and umbrella girls. However, the social impact of prostitution in golf courses will not be examined in this dissertation. 21 Saunders, John Owen, ed.,“The Legal Challenge of Sustainable Development: Essays from the Fourth Institute Conference on Natural Resources Law”, Canadian Institute of Resources Law, 1990. 22 See Pearce, David (ed), Blueprint 3: Measuring Sustainable Development, London, Earthscan, 199 and Pearce, David, Economic Values and Natural World, London, Earthscan. 23 See Beckerman, Wilfred, A Poverty of Reason: Sustainable Development and Economic Growth, Oakland California, Independent Institute, 2003; Beckerman, Wilfred, Sustainable Development: Is it a Useful Concept, in Growth, the Environment, and the Distribution of Incomes, Essays by a Skeptical Optimist, Aldershot, UK, E. Elgar, 1995. 5 (1999)26 etc. Nonetheless, it was not until after the conclusion of the United Nations Conference on Environment and Development (UNCED) at Rio de Janeiro, Brazil in 1992 that the word sustainable development has attracted the attention of legal scholars, particularly, to explore the question of how the law can further the objectives of sustainable development, for instance, Campbell-Mohn et al., (eds. 1993)27, Boers et al., (eds. 1996)28 and Robinson (1998).29 Other scholars have proposed principles, concepts and prospects for a legal sub-field called Sustainable Development Law, e.g. Segger and Khalfan (2004)30, Schrijver and Weiss (2004)31, and French (2005).32 This dissertation primarily explores the question of how the law, coupled with good governance and management can promote sustainable development by using a cross-national comparative study involving golf courses in the Philippines, Thailand, Viet Nam and Singapore - a subject that has not received adequate attention from legal scholars studying sustainable development or environmental law. B. Law and Governance It is vitally important to discuss the aspects of law and governance in general, and in particular, the rule of law, including the institutional and internal governance in the golf course industry. Black’s Law Dictionary (2010) defines rule of law as the "supremacy of regular power as 24Daly, Herman E., On Wilfred Beckerman’s critique of Sustainable Development, Journal of Environmental Law, Volume 7 (1995), Oxford University Press, p. 49. 25 Alder, John & Wilkinson, David, Environmental Law and Ethics, Macmillan Law Master, 1999, UK 26 Jacobs, Michael, Sustainable Development as a Contested Concept, see in Fairness and Futurity, Essays on Environmental Sustainability and Social Justice, Edited by Andrew Dobson, 1999, Oxford University Press, Part 1, at page 1 27 See Campbell-Mohn, Celia, et al., eds., Environmental Law from Resources to Recovery, St. Paul, MN: West, Environmental Law Institute, 1993 and Campbell-Mohn, Celia, et al., eds. Sustainable Environmental Law: Integrating Natural Resource and Pollution Abatement Law from Resources to Recovery. St. Paul, MN: West; Environmental Law Institute, 1993. 28 Boer, B., "Sustainability law for the new millennium and the role of environmental legal education", Water Air and Soil Pollution, Vol. 123, No. 1-4 (2000): 447-465. 29 Robinson, Nicholas A., "Comparative Environmental Law Perspectives on Legal Regimes for Sustainable Development" (1998). Pace Law Faculty Publications. Paper 377. Available at http://digitalcommons.pace.edu/lawfaculty/377. 30 Segger, Marie Claire Cordonier and Khalfan, Ashfaq, Sustainable Development Law, Principles, Practicesand Prospects, 2004, Oxford University Press. 31 Schrijver, Nico and Weiss, Friedl, “International Law and Sustainable Development: Principles and Practice”, Martinus Nidhoff Publishers, 2004 32 French, Duncan, International Law and Policy of Sustainable Development, (Manchester: Manchester University Press, 2005. 6 opposed to arbitrary power." It has been considered as one of the key dimensions that determine the quality and good governance of a country33. The Rule of Law cannot exist without a transparent legal system, the main components of which are a clear set of laws that are freely and easily accessible to all, strong enforcement structures, and an independent judiciary to protect citizens against the arbitrary use of power by the state, individuals or any other organization.34 Former Singapore Chief Justice Chan SK shares that the Rule of Law “means an independent judiciary, one that is independent of government and not dependent on it or subservient to it”. 35 The United Nations (UN) promotes the rule of law at the national and international levels,36 and refers to a principle of governance in which all persons, institutions and entities, public and private, including the State itself, are accountable to laws that are publicly promulgated, equally enforced and independently adjudicated, and which are consistent with international human rights norms and standards37. In this dissertation, relevant laws and regulations are evaluated and reviewed comprehensively under Chapter III, Part II, which have direct and indirect impact on the development and operation of golf courses in the four subject countries. Meanwhile, the word “governance” has not been clearly defined and remains contested owing to lack of clarity over its definition. Kooiman (1993) however elucidates that in governance, “no single actor, public or private, has all the knowledge and information required to solve complex, dynamic and diversified problems; no actor has sufficient overview to make the application of 33 Kaufman, Daniel et al. “Governance Matters VI: Governance Indicators for 1996-2006. World Bank Policy Research Working paper No. 4280 (July 2007). Available at http://papers.ssrn.com/sol3/papers.cfm?abstract_id=999979, accessed on May 17, 2013. 34 Visit http://www.lexisnexis.com/en-us/about-us/rule-of-law.page. Accessed on April 12, 2013 35 “The Courts and the “Rule of Law” in Singapore”. Speech given by Former Chief Justice SK Chan before the International Bar Association (2012), Singapore Journal of Legal Studies, p. 209, December 2012. Also available at http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2242727. Accessed on May 28, 2013. CJ Chan mentioned that, “an independent Judiciary is absolutely essential to the ‘rule of law’, and vice versa”. He also cited See Li-ann Thio, “Rule of Law within a Non-Liberal ‘Communitarian’ Democracy: The Singapore Experience” in Randall Peerenboom, ed., Asian Discourses of Rule of Law: Theories and Implementation of Rule of Law in Twelve Asian Countries, France and the US (London: RoutledgeCurzon, 2004). 36 The UN Reports states that, “establishing respect for the rule of law is fundamental to achieving a durable peace in the aftermath of conflict, to the effective protection of human rights, and to sustained economic progress and development. The principle that everyone – from the individual right up to the State itself – is accountable to laws that are publicly promulgated, equally enforced and independently adjudicated, is a fundamental concept which drives much of the United Nations work. The principle of the rule of law embedded in the Charter of the United Nations encompasses elements relevant to the conduct of State-to-State relations. Read (S/2004/616) Report of the Secretary-General on the Rule of Law and Transitional Justice in Conflict and Post-Conflict Societies. Accessed April 12, 2013 37 Id. 7 particular instruments effective; and no single actor has sufficient action potential to dominate unilaterally in a particular governing model.38 On the other hand, environmental governance according to Seymour and Faraday (2001) is “used as authority and capacity exercised by governmental and non-governmental actors in the management of the natural environment”. Seymour, et.al, also mentions that the term “refers not only to the institutional framework of the environmental sector, but also to the actors and the powers they exercise over the use of natural resources”. Thus, Seymour, et al, believe that “environmental governance includes broader governance issues like representation, legal recourse, civic activities, and protection of human rights that provide the context for society’s management of its natural environment”.39 This dissertation proposes three (3) different aspects of governance, namely, (1) institutional governance,40 (2) governance in golf courses (industry norms), and (3) NGO or civil society participative governance. Thus, governance in golf courses may be classified (a) within the national and international golf associations and federations, and (b) within the golf club itself. In this thesis, the phrase “environmental governance” covers the application of law, best practices, transparency, accountability and social responsibility. It also includes the policy and norms of the golf course industry, which involves the interaction, collaboration and interplay of government, private individuals and civil society to achieve environmental protection in golf courses. C. Gap in Legal and Academic Literature Despite the proliferation of golf courses in Asia, very little is known in the literature about law and governance in golf courses. Are golf courses coherently, effectively and adequately regulated or governed under existing national laws? Is there a common trend, in substance and procedure, across legal traditions in the subject countries? Are there industry norms, which have been adopted by the golf course industry? What are “traditional” or conventional golf courses? What are sustainable golf courses? What is the difference between “traditional” or sustainable 38 Kooiman, J., “Social-Political Governance: Introduction”, In Modern Governance New Government – Society Interactions, edited by J. Kooiman. London. Sage, 1993a. 39 Seymour Frances and Faraday, George, “Emerging Environmental Governance”, The Asian Environment Outlook, Philippines: Asian Development Bank, 2001. 40 In this dissertation, institutional governance refers to the system of administration, supervision and control exercised by state administrative agencies over the development activities of golf courses. The notion of an institution embodies several elements: formal and informal rules of behaviour, ways and means of enforcing these rules, procedures for mediation of conflicts, sanctions in the case of breach of rules, etc. Read http://www.wto.org/english/res_e/booksp_e/anrep_e/wtr04_2d_e.pdf. Accessed on May 5, 2013. 8 courses? Are there laws and regulations, which promote sustainable golf courses? This dissertation hopes to explore these questions. For these reasons, law and governance in golf courses require a more coherent approach than is currently done in most countries. In most developing countries, golf course regulations, e.g. EIA requirements, biodiversity protection, nature conservation, land, water and chemical use controls, etc. are not strictly enforced because of jurisdictional overlaps and lack of clarity in the separation of powers and duties among the different administrative agencies. Enforcement would have to be carried out by numerous government agencies – agriculture, water, environment, local and national governments, etc. thereby rendering these regulations less than effective. This multi-sectoral approach of governance results in jurisdiction overlaps, conflict and turf wars. There are also problems stemming from the lack of institutional capacity due to budgetary constraints This paper explores these issues and asks how the law and good governance can help promote sustainable development, and consequently, the construction and management of sustainable golf courses. This dissertation also asserts that self-regulation is possible in the golf industry and provides documentation of an example of a sustainable golf course. It argues that for golf courses to be sustainable and become an industry norm, the following conditions are necessary: self- regulation, benchmarking, public pressure, market demand, incentives and disincentives (“carrots and sticks”) from regulators and reliable verification and enforcement mechanisms. Civil society and NGO participation is likewise important, in order to check and balance regulatory enforcements and implementations41. 1.2 Research Scope, Aims and Hypotheses This dissertation proposes to answer the question of how the law and good governance can further the objectives of sustainable development in the context of golf courses. More specifically, this thesis aims to fill the gaps in the legal literature about golf courses. To achieve this aim, this dissertation primarily, proposes and tests a framework to cross-nationally evaluate and compare the laws and governance, from across and within the four countries. The analytical framework - discussed in the next section - compares the coherence, adequacy and 41 Several NGOs and environmental advocacy groups promote sustainability and best practices in golf courses, among them, Golf Environment Organization (GEO), International Golf and Life Foundation (IGolf), Audubon Society, among others. Nonetheless, there are many aspects of sustainability, which the case studies in this thesis will discuss. 9 responsiveness of both law and governance, particularly those related to the planning, construction and operation of golf courses. The framework then is applied to the study of laws and governance in golf courses in Southeast Asia particularly in the Philippines, Thailand, Viet Nam and Singapore. The rationales for selecting these countries are explained in the methodology section. Using the framework of analysis, this dissertation qualitatively tests for the following hypotheses: Hypothesis 1: Law and governance in golf courses tend to be incoherent, ineffective and inadequate. This is because both law and governance have evolved in traditional, fragmented, compartmentalized and reactive or ad hoc manner. Examples can be drawn from the following, (1) The regulation of water quality - water laws generally focus on the quality of drinking water and therefore seek to control pollution and contamination of the water supply, by prescribing effluent standards. Not many jurisdictions have considered the regulation of groundwater extraction and the installation of flow meters; (2) The regulation of the use of fertilizers, pesticides, fungicides and other chemicals - these are derived from agriculture-related regulations, so it is unclear if the use of chemical in golf courses is regulated; (3) Most of land use regulations are intended for urban planning purposes and do not adequately take into account the concerns of agriculture and the need for food security Thus, many agricultural lands, particularly paddy fields are converted for commercial or residential uses. In short, because these regulations evolved and were designed for purposes other than to regulate golf courses, they have become incoherent, unresponsive and inadequate for purposes of regulating its adverse environmental impacts. This thesis argues that a coherent and effective legal framework and governance is necessary to reduce the adverse environmental impacts of golf courses and to encourage the construction and development of sustainable golf courses. The second hypothesis to be tested explores the idea that self-regulation by golf owners and operators is desirable and feasible under certain conditions. Because the enforcement of regulation tends to be costly and imperfect, and technology for golf construction and operation is dynamic (evolving) it makes sense for environmental policy to promote self-regulation. There is 10