To Golf Clubs and Golf Industry Stakeholders,

The Department of Agriculture, Food and Marine has a public consultation ongoing, with submissions due by 17.30, on Friday February 24th.

The consultation relates to the EU’s proposed new Sustainable Use of Pesticides Regulation, which has the potential to have a detrimental impact on the golf industry in Ireland.

We are urging stakeholders and Golf Clubs throughout Ireland to lodge a submission to support and protect our industry and the sport we play.

Key information

• SUR background: Click here 
• Submission email address: surconsultation@agriculture.gov.ie
• Email subject line: SUR Proposal.

Whilst the regulation references Agriculture and the ‘Farm to Fork’ strategy, it could have a significant bearing on golf and golf course maintenance.

The inclusion of “Sensitive Areas” is of particular concern to golf courses.

DOWNLOAD OUR FULL DAFM SUBMISSION

The Sustainable Use Regulation (SUR)

The Sustainable Use Regulation (SUR) proposes to prohibit the use of Plant Protection Products (PPPs) within and in close proximity (3m) to a ‘sensitive area’. A ‘sensitive area is defined as, ‘areas used by the general public and vulnerable groups, human settlements/urban areas, public parks or gardens, recreation or sports grounds, non-productive areas (GAEC 8), specific areas under other legislation such as the Water Framework Directive (including nutrient-sensitive/nitrate-vulnerable areas), the Habitats Directive and the Birds Directive.’

Golf courses are, by this definition included within ‘recreation or sports-grounds’. The clause seeks to prohibit the use of PPPs on golf courses, which would preclude:

• Plant Growth Regulators – critical to fine turf health and performance)
• Herbicides – for effective weed control
• Insecticides and Fungicides – critical to preventing and controlling disease and grub infestation on fine turf

Any move to prohibit entirely the use of PPPs will have a detrimental impact to the presentation and performance of golf courses in Ireland. The impact on golf courses, associated golf clubs and golf tourism across the Republic of Ireland would be devasting.

Business case for exemption of golf courses as a ‘Sensitive Area’

With no biological alternatives available in the market at present, we call for golf to be exempt from the definition of ‘Sensitive Areas’.

1. Article 18 poses a significant threat to sports turf professionals’ ability to maintain golf courses to standards expected. Course conditioning would deteriorate rapidly and substantially.
2. Declining standards will cause a major shock to the industry. Participation levels will reduce, golf tourism will reduce given Ireland’s proximity to alternative UK links courses.
3. 8% of the European citizens that live in Ireland will experience deteriorating golf experiences. For many older people, golf is their main outlet for exercising and socialising.
4. The economic impact in Ireland could run to tens of millions of Euro and mass industry unemployment.
5. Golf courses represent just 0.17% of the land mass of agriculture and golf accounts for just 0.34% of active ingredient applied. The prohibition of PPPs application on golf courses will have little environmental impact, should the agriculture sector continue to apply PPPs.
6. Ireland will be disproportionately affected given its location in the Atlantic stream, year-round golf season and the country’s popularity within the North American golf tourism market.
7. An 18-hole golf course will use on average 11,000 litres of fossil fuel for equipment. The prohibition of PPPs will increase mowing frequencies and the use of such equipment, which will increase in CO2 emissions and adversely impact human health and the environment (two key objectives of the European Grean Deal and Farm to Fork Strategy).
8. The proposed regulations outline 5-years’ of supports that Member States may provide to farmers under the CAP to help cover the costs of complying with these imposed requirements. No such supports are available to the golf industry.
9. Should a full exemption for golf from the sensitive area definition not be achieved, or not gain enough support across Europe, it is vital the Irish Government ensures a suitable derogation is provided to protect the golf industry in Ireland.

There will be a significant commercial impact to golf in Ireland should the regulation proceed as drafted. The Department of Agriculture, Food and Marine, together with other State Departments with a beneficial interest, must take every measure to protect the golf industry in Ireland.

Yours sincerely,

Ed Pettit

Managing Director

Carr Golf Maintenance