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Frequently Asked Question - Can the DoW CoP be used to import materials for reuse on golf courses?

Can the DoW CoP be used to import materials for reuse on golf courses?

Yes, with additional requirements: Golf course Receiver sites present a unique challenge for the DoW CoP. This is due to the typically large volumes reused, long project durations, and subjective course design which can result in questionable volume requirements.  Following concerns raised by the Environment Agency / Natural Resources Wales, golf course projects will now be subject to additional checks during the Declaration preparation and submission stage and at Verification report submission.

The project team will be required to have notified the local Environment Agency / Natural Resources Wales waste team of their intent to use DoW CoP for the import of clean, naturally occurring soils, and have allowed 21 days for comment. This is therefore different to other projects using Direct Transfers, which operate on the usual liaison requirement confirmed in Table 2 of the DoW CoP (page 20). The Qualified Person (QP) must review the regulator correspondence and reference this in the Declaration. The Declaration short name should clearly reference the golf course end use. Further, the project team must ensure the Environment Agency / Natural Resources Wales waste team is updated on the project importation progression every 12 months.

During the review of these types of Declaration, CL:AIRE might engage with the regulator and additional processing time should be expected. Therefore, please allow 10 days for the issue of these Declaration Receipts.

These checks have been brought due to some poor performing sites which have:

  • not been fully tracking materials imports;
  • had discrepancies in Donor site records;
  • had material volumes and type not compliant with the original Materials Management Plan specification; or
  • included materials that are not clean naturally occurring materials.

It is hoped that this review process and future developments will ensure good practice, as required for use of the DoW CoP, and enables golf course projects to continue making use of the scheme to reuse suitable materials for these types of engineering earthworks.

CL:AIRE will not be responsible for any loss, however arising, from the use of, or reliance on, the information contained in the responses above, nor do they assume responsibility or liability for errors or omissions in the information provided. Readers are advised to use the information contained herein purely as a guide and to take appropriate professional advice where necessary.