Memorandum submitted by English Golf Union and the Golf Union of Wales

(FW 18)


Memorandum to the Public


Bill Committee submitted by Marcus White Bsc Msc CEng MIAgrE MASIC of consulting engineers - Irriplan Limited.


Irriplan is a specialist company providing engineering consultancy and project management in irrigation, drainage, water supply and reservoirs; within the UK and overseas to golf, sports-turf, agriculture, horticulture and leisure/residential development.


For and on behalf of the English Golf Union and the Golf Union of Wales:


With reference to Clause 33 concerning the proposal to lower the above ground volume covered by the Reservoirs Act from 25,000m3:


1: The English Golf Union (EGU) represents the interests of 1,960 Golf Clubs with approximately 700,000 members.


2: The Golf Union of Wales (GUW) represents the interests of 158 clubs with around 65,000 members.


3: The EGU and The GUW are against the proposal within the bill to reduce the volume which qualifies a reservoir to be classed as a Large Raised Reservoir within the Reservoirs Act.


4: The existing volume which may be held above natural adjoining ground level is 25,000m3. This figure was arbitrarily set following reservoir failure in 1925 and has been shown to be over-cautious over the last eighty-five years. There has been no failure resulting in any deaths in this intervening period and there is no technical justification for such a proposal.


5: The Reservoirs Act (1975) as it is at present, along with the Construction (Design and Management) Regulations 2007 and other existing Health and Safety legislation already offers sufficient protection for the public.


6: Lowering the qualifying volume will have a negative unintended consequence. In recent years golf clubs have been working where possible towards responsible storage of excess winter water within non-impounding (off-line) reservoirs, for subsequent re-use in summer drought periods for irrigation. This decreases reliance on summer-abstracted borehole water and on summer-abstracted potable water. Most golf courses in England & Wales can be adequately supplied for irrigation purposes with stored water from a reservoir constructed and managed under the existing legislation and having less than 25,000m3 stored above natural adjoining ground level. Lowering the qualifying capacity will impose additional unnecessary and burdensome costs on golf clubs in order to supply their irrigation needs satisfactorily. Reducing the qualifying volume shall be a disincentive to investment in such schemes.


7: In summary the proposal in Clause 33:


Has no engineering rationalisation;

Will do nothing to minimise pressure on valuable summer water resources;

Will result in increased administration and subsequent additional employment costs within the Environment Agency/DEFRA;

Will result in increased costs to existing owners of small reservoirs and increased costs in the planning, construction and management of proposed new reservoirs.


8: This proposal should be rejected.


January 2010