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Water use - has your club registered?

​EU Water Policy Regulations require golf clubs that abstract 25 cubic metres of water on any single day each year to register their water extraction with the Environmental Protection Agency.

  • 05 June 2019

PLEASE NOTE – this content below was provided by the EPA in the Republic of Ireland. Golf clubs in Northern Ireland should note the requirements and contact the Northern Ireland Environment Agency

In December the GUI wrote to all affiliated golf clubs to advise them of the requirements of the EU Water Policy Regulations. These regulations require everyone that abstracts 25 cubic metres of water or more per day to register their water extraction with the Environmental Protection Agency.

Only 20 clubs have completed the required registration process and we are calling on clubs to ensure compliance with the regulations at the earliest possible opportunity.
 
As an industry we need to be mindful of the environment in which we operate and compliance with the regulations is a minimum standard we have to adhere to. 

Under the Water Abstraction Regulations, a prosecution may be taken by the EPA if a person fails to comply with the Regulations. Following prosecution, a person guilty of an offence under the Regulations is liable to a class A fine (up to €5,000).
 
Please ensure your club registers as outlined below if your golf club exceeds the daily limit ON ANY ONE DAY during the year.
 
Kind regards
Alan Kelly
Communications Manager
Golfing Union of Ireland
 

1. Why it is necessary for all those who extract more than 25,000 litres of water in any single day from wells, rivers, lakes to register with the EPA?
 
The Department of Housing, Planning and Local Government (DHPLG) launched a register of water abstractions in accordance with the European Union (Water Policy) (Abstractions Registration) Regulations 2018 (S.I. No. 261 of 2018) in August 20181. Under this legislation, everyone who abstracts 25 cubic meters (m3) (25,000 litres) of water or more per day are required to register their water abstraction with the EPA. Abstractions include taking water from surface water (rivers, lakes, streams, estuaries etc.) and groundwater (wells and springs). The threshold of 25 cubic meters (25,000 litres) applies in any single day i.e. if 25 cubic meters or more is abstracted in any single day of the year, then that abstraction is required to be registered.
 
The register of water abstractions is a requirement of the EU Water Framework Directive. The data from the register of water abstractions is being used by the EPA to manage water resources and assess the flows and water levels in rivers and lakes to support and maintain their ecology and function.
 
The information gathered are being used to identify if there are any surface waters or groundwaters that are being abstracted from in an unsustainable manner, such that there are / may be impacts on the ecology and health or function / use of those waters. In a recent public consultation, the DHPLG indicated that it is their intention to introduce legislation to facilitate a water abstraction control regime (including licensing) for large abstractions (> 2,000 m3 per day) and any abstractions > 250 m3 per day that singularly or in combination with other abstractions that are identified as causing an impact on waters. As such it is important that robust data on abstractions and its use are available to inform any such assessment, as absence of information or incorrect information could lead to erroneous decision making in the future.
 
The EPA believe that the majority of GUI member clubs are required to register, based on the following water use estimates for golf courses in Ireland:
 
9-hole course Parkland 20m3/day;
18-hole course Parkland 40m3/day; and,
18-hole Hotel Resort or Links courses likely to be greater than 75 m3/day and potentially up to 250 to 300 m3/day.
 
2. How has the EPA followed up with other landowners, manufacturers and businesses etc.?
 
The DHPLG and the EPA has engaged with representatives of all the major sectors involved in abstraction registration, including agriculture, aquaculture, commercial, drainage, drinking water, horticulture, hydropower, industrial, quarries / mining, navigation and recreation (mainly golf courses and racecourses). Most sectors are compliant with the regulations, however, to date, agriculture, golf course and racecourses have had a poor response to registration. The EPA is engaging further with these three sectors and this letter to the GUI is part of this further engagement with golf courses. The EPA are similarly engaging with the racecourse sector and will communicate with the Department of Agriculture in relation to following up with the agricultural sector.
 
3. In relation to non-registration, what are the list of penalties, as set out in the statutory instrument?
 
Under the Water Abstraction Regulations, a prosecution may be taken by the EPA if a person fails to comply with the Regulations. Following prosecution, a person guilty of an offence under the Regulations is liable to a class A fine (up to €5,000).
 
4. How many golf clubs that have registered to date?
 
There are approximately 20 golf courses registered with the EPA, as of May 2019. In addition, ten courses have completed step one of the registration process (by signing up to the EDEN website) but have not submitted a completed registration.
 
The DHPLG estimated in the 2018 River Basin Management Plan4 that there are approximately 300 golf courses that require registration. Thus, there is a major shortfall in the number of golf course registered, with only around 5% of golf courses having registered to date.
 
       
5. Has the EPA communicated the need to register with golf clubs other than thorough the circular sent to the GUI?
 
The EPA had ongoing discussion with a golf sectoral representative in relation to the Ready Reckoner / Quick Volume Estimator5 development prior to the launch of the abstraction regulations register and then specifically followed up with the GUI in December 2018. The EPA requested the GUI to send a communication to all golf courses requesting them to register their abstractions in December 2018. Engagement with the GUI has been the only direct contact with golf clubs that the EPA has undertaken. Separately, golf clubs may have heard about the requirement to register through coverage of the Regulations on radio and print national media.
 
6. Has the EPA any other means of communicating with golf clubs other than through the GUI?
 
Currently the only other means of contact the EPA has with golf clubs, other than through the GUI, would be through direct contact with each individual club. Under GDPR, the GUI is not allowed to provide membership information to the EPA (without permission from the golf course), so the EPA would have to source contact information (e.g. from Golden Pages, websites) and then directly follow up with each golf course.
 
7. Can you also set precisely out what you want the GUI to do in the short-term and whether you expect the GUI to have any role in this regard as time progresses.
 
In the short term, the EPA would request that the GUI communicate to all of their members that have a water abstraction which is greater than 25 m3 per day, requesting them to register their abstraction(s) as soon as possible. Information on how to register is included below. The next step would then be for the EPA to independently gather contact information on the golf courses and seek approval from its Board to directly contact those clubs who have not registered by writing to the secretary of each club asking them to register.
 
8. Information on how to register
 
The following are the steps to register an abstraction -

1. Sign up to the EDEN website (www.edenireland.ie) and request access to the Water Abstractions Module. Guidance on this process is available on the EPA website.

2. Submit your abstraction details in the Water Abstractions Module via the EDEN website. Guidance on this process is available on the EPA website.

3. When your registration is complete, you will receive a confirmation email from the EPA.
 
Please contact the EPA on edenabstractionsupport@epa.ie with any queries.