Response Form

Hydropower Permitting Review

Respondent details;

Name: Richard Anthony Crimp Organisation: Thames Anglers’ Conservancy Address: P.O. Box 863 Town/city: Richmond County: Surrey Postcode: TW9 9BR Telephone (including code): telephone number supplied Email: email supplied

Put a cross in this box if you are requesting non-disclosure of your response. Please provide an explanation to support your request. Not requested

1. Do you agree we should develop a single decision process for our permissions as defined in Box 1?

Please tick the relevant box Yes ✓ No Don’t know

If no, please explain your answer.

If yes, what do you think it should or should not include?

Single decision processes’ for Hydropower schemes should be fully encompassing and at no stage mitigate aquatic environmental issues. It appears to be in the wording; “single decision process”, please ensure that all applications are considered singularly and not combined. Each environment has its own unique considerations and must be treated separately.

– Fish passes should be mandatory considerations during planning.

– Abstraction issues should be considered at the very earliest planning stages and during the serviceable life of any successful application once built.

– Anything less than a displayed local necessity for such hydropower schemes, and this balanced and against the aquatic environmental impact, should not be considered in the single decision process.

– The process must be wholly beneficial to the entire environment and one that seeks to achieve ‘good practice guidelines’ from application to operation, synergistically with all facets taken into consideration on a local basis, including the aquatic environmental considerations.

2. How can stakeholder participation in our decision-making be improved?

There should be far wider consultation with angling groups through the regional structure of the Angling Trust Forums on many issues, not least hydropower.

Locally, angling concerns through clubs, riparian owners and lease holders etc. should be part of the process at the earliest stage possible. Without the input of anglers, the Agency loses a vital cog and much knowledge that if not utilised, is to the detriment of the whole process and the environment in its entirety.

The Agency’s website could be used as a nexus for all stakeholder groups and greater synergy would be of massive benefit to the Agency. All process and applications, planning specs, environmental reviews and consultations should be available to view, for all stakeholders, via the website.

The opportunity is here, today, for the Agency to broaden its compass with no additional financial obligation. In fact it will prove a cost saving once lateral thinking can be applied.

3. Do you agree with our good practice principles in handling hydropower applications?

Please tick the relevant box Yes No ✓ Don’t know

If no, please explain your answer.

Whilst the Thames Anglers’ Conservancy agrees that the Agency’s ‘good practice principles’ are sufficient in principle, in actuality they are not implemented by the Agency to their fullest effect.

The majority of applications are extremely poor in their proposed execution and are primarily based around utilising the ‘opportunity’ of ‘green’ energy implementation, with little or no consideration for the wider environmental implications – notably upon the aquatic environment – that are attached to the conversion of hydropower energy resources from fossil fuels through hydropower.

Why is it that applicants can appeal in respect to a refusal to allow permission of a hydropower scheme, but objectors cannot? This makes the whole process appear arbitrary and grossly imbalanced. The process of appeal for objectors should be introduced without any delay.

4. How can we improve co-ordination between permitting and the planning permission process?

The whole process through the Agency needs to be transparent and ecologically sound. Councilors, stakeholders and all concerned parties need to understand the environmental impact of such schemes, and it is the Environment Agency’s obligation as the statutory ‘body’ to address the ‘superficial’ view, that that this energy resource is fully ‘environmentally friendly’. That is clearly not the case and needs to be addressed by the Agency with paramount urgency.

5. What do you consider to be the key environmental issues for small-scale hydropower that require further evidence to understand and mitigate?

The evidence of the impact on the aquatic environment is largely dismissed by the Hydropower industry and it is myopic to believe otherwise. The Agency does not appear to support the evidence either and I would refer you to the answer given in Q4.

6. What aspects of technical guidance in the Good Practice Guide do you think are missing or need further development?

Environmental evidence based permissions – in respect to granting hydropower applications – are clearly seen to be sorely lacking. The detrimental impact on the aquatic environment is undoubtedly of lower importance when the granting of applications are considered and the knock on effect of this impact will be felt for generations to come, in many regards.

Does the EA wish to be held responsible for less than good practice as clearly displayed within the GPG? This needs to be addressed with the utmost urgency.

7. How can the provision of information in support of applications be simplified?

Once again the Thames Anglers’ Conservancy must unequivocally request that, comprehensive information and transparency through the Agency regarding the environmental impact, is the key to open and evidence based support of applications. Without all considerations/implications being fully considered it is folly to suggest that there is a need to ‘simplify’ such applications through the ‘watering down’ of available information.

Hydropower schemes, unless they are fully supported with evidence based planning applications based on key environmental issues; plans that are publicly accessible and consulted upon before any such schemes are given permission using all stakeholder input are, in all honesty, little more than a fudge to build numerous ‘pigs in pokes’.

The Thames Anglers’ Conservancy would like to reiterate that the Agency has the vast resource of its website to clarify and support the application process. The need to ‘simplify’ the application is at best misused within the question, and is not a term that should be used lightly, when considering the impact that hydropower schemes will have upon the environment.

8. How much monitoring should operators be required to carry out after licensing to demonstrate their hydropower scheme is not having a detrimental environmental impact?

Initially the sentence above is quite damning and shocking! Such monitoring should obviously be always uppermost in the responsibility of Hydropower operators after licensing, and fully paid for by those that are responsible for such schemes, namely the operators themselves. However, the Thames Anglers’ Conservancy would express deep concern if the monitoring was not carried out through an independent monitoring agency.

Another concern that immediately springs to mind, wouldn’t such hydropower schemes have already been refused licences during the application process, or is it that they will be built first and then their environmental impacts studied? Please refer to the answer for Q1.

9. How can we improve the advice and guidance available to prospective applicants?

Once again we as the Thames Anglers’ Conservancy would like to express our deep concern in regards to this question.

It has been apparent to the Thames Anglers’ Conservancy that EA resources are being wasted in the active promotion and guidance to prospective developers, this to ‘sell’ the hydropower scheme with little or no mitigation on behalf of the aquatic environment or any sense of the limited scale of the energy created nationwide, on a one-to-one basis to ‘prospective clients’.

All information and guidance should be – in the main – electronically based and the Agency has the vast resource of its own website to be used for such purposes. Used effectively, such resources are invaluable in being able to give fully comprehensive guidance to prospective applicants, fully vested with a code of ethic to ensure the environmental responsibilities are also fully understood/considered in an aquatic sense, as well as those from an environmentally renewable energy perspective.

Get this right from the very beginning and ‘we’ (tax payers, rod-licence holders) won’t be paying for the inevitable problems in the future.

10. What additional help should we provide specifically for community groups and individuals to help them through the application process?

This question is loaded and is a visible attempt to simplify the application process on a nationwide scale. The Agency has the responsibility to ensure that community groups are fully aware of all the environmental implications of such schemes, not least the damaging effect they can have on the river itself, and all that lives within its ecosystem.

The environmental impact is not an easy-to-understand issue and any attempt to minimise the complex challenges faced by local communities when assessing the need for hydropower schemes would be irresponsible.

That said, the Thames Anglers’ Conservancy would once again refer to the unparalleled opportunity via the facility of the EA’s website, to be used as a resource to provide applicants with a comprehensive guide which is sorely lacking at this moment in time.

11. Please identify and define low environmental risk hydropower scenarios that might become common and justify making specific arrangements?

It would be the opinion of most informed users of the river (most notably the creatures and plants that inhabit the environments, but have no voice), that ‘low environmental risk hydropower scenarios’ is little more than an oxymoron that seeks to mitigate the real and lasting impact such schemes will bring to the rivers of England, in the vast majority of cases.

12. What do you think are the implications of Article 4.7 of the Water Framework Directive for hydropower projects?

In the majority of cases concerning applications for hydropower projects, Article 4.7 of the WFD, should – if considered even superficially – prevent such applications being given permission/licences at all. It is obvious that hydropower will not provide enough energy to mitigate the damaging implications of its potential environmental legacy, when weighed up against its meagre return of potential energy resources for England.

Hydropower will never be able to meet the conditions of Article 4.7 if considered correctly, and there are obviously far better renewable energy resources to be explored; if it is a ‘truly green’ and renewable energy source that this country requires.

Do you think it would be a helpful simplification if ecological or perhaps energy thresholds are provided in guidance?

Please tick the relevant box Yes No ✓ Don’t know

If yes, how would you define and justify them?

The Thames Anglers’ Conservancy has answered ‘No’ to this rather ambiguous question and feels the need to expand upon what may be misconstrued by some as an attempt to create a ‘blind spot’ in the process of consultation through this polysemous question? Was the “Don’t know” box created for this question alone!

We would presume that that the question infers that small scale hydropower projects should be given a green light and basically sidestep a potentially thorough and mitigated application process? If that is the question, then the answer is a resounding NO!

The highly environmentally sensitive issues surrounding all hydropower projects, regardless of their size, should be properly assessed under the most considered scrutiny of the Agency and all stakeholders. Anything less will be an abnegation of the Agency’s responsibility.

13. Do you agree that we should develop catchment level strategies for hydropower?

Please tick the relevant box Yes ✓ No Don’t know

If no, please explain your answer.

If yes, what do you think catchment strategies should aim to deliver? Please consider in your response environmental and other impacts.

The Thames Anglers’ Conservancy would hope that such strategies would deliver continuity throughout the entire length of any river’s course, strategies that would help to identify areas of obstruction, over abstraction etc. that are prohibitive to anadromous and catadromous species once ubiquitous in our aquatic environments.

Suffice it to say, that any further ‘blockages’ to the natural course of any indigenous species, natural sediments etc., not least those that utilise freshwater only, will create even more pressure on the sustainability of our rivers resources. This would not only damage the aquatic environment, but that which relies on its resources on the river’s ‘surface’ and surrounding areas, the level of impact will be far reaching if said catchment strategies aren’t all encompassing.

Many environments could not sustain hydropower installations, and this will only increase in number as the demand increases with the projected growth in populations, notably in the South East of England.

Managed correctly, and with foresight, the Agency has the opportunity to deliver strategies that will lead the way into a sustainable development for the 21st Century.

Should they seek to identify sites that are suitable and not suitable for hydropower?

Please tick the relevant box Yes ✓ No Don’t know

If no, please explain your answer.

If yes, please explain your answer.

An unequivocal ‘Yes’! Please refer to answer given above.

14. How could the legal framework for permitting hydropower be changed to streamline the permitting process without compromise on environmental protection?

There can be no ‘streamlining’ of the permitting process without further undermining the environmental impact.

That said, however, the suggestion given on numerous occasions concerning the need to give comprehensive environmental ‘Good Practice Guidelines’ and clear and comprehensive information, through the EA’s website, should mitigate the need to streamline the process, as sound guidelines would preclude the need to change what is essentially a robust instrument of legislation.

15. What additional proposals do you have to speed up the permitting process whilst protecting and enhancing the environment?

Without wishing to belabour the point of sound and considered judgement regarding the process from application, permission and implementation of hydropower schemes, there is no need to ‘speed up’ the process at all.

In fact, in ‘real’ environmental terms, the impact of hydropower schemes will have severely damaging consequences in years to come, as is patently obvious to anyone with a modicum of foresight regarding finance, climate change and aquatic welfare to name but a few.

Concerning the welfare of our rivers, and the impact of the use of our natural resources to provide renewable energy through hydropower schemes, the Thames Anglers’ Conservancy would fervently advocate the responsible use of our vulnerable aquatic habitat, and that would largely preclude the widespread usage of hydropower.

In short, the EA has the opportunity to create a basis for continuity for years to come and hydropower has minimal benefit to the “Overriding interest of the public…” and its renewable energy needs, and should only be permitted where absolutely appropriate and necessary.

Thank you for taking the time to complete this form. Please return by email to: Hydropower_permitting@environment-agency.gov.uk

Or by writing to this address:

Better Regulation Environment Agency Block 1 Government Buildings Burghill Road Westbury on Trym Bristol BS10 6BF

 

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