The TAC Response To The Discussion Document – Natural Environment

Thames Anglers Conservancy
P.O. Box 863
Richmond
Surrey
TW9 9BR

Richard Anthony Crimp (Secretary)

30th October 2010

Natural Environment White Paper Team
Area 3D, Nobel House
17 Smith Square
London
SW1P 3JR

Dear Sirs,

Natural Environment

The Thames Anglers Conservancy (TAC) is an organisation representing anglers throughout the Thames Tideway and the non-tidal river from Teddington Lock upstream to Staines. As a concerned stakeholder in all initiatives regarding the River Thames we would like to present our view point on behalf of the TAC and its membership in its entirety. This should be viewed as a separate document to our affiliate organisations, such as Angling Trust etc.

Firstly, we as anglers of the Thames, would like to welcome Defra’s Discussion Document concerning the Natural Environment, and would also wish to point out that, through awareness and education, the responsibility for the positive improvement of our relationship with the environment will come from all Govt. Depts. and not just through Defra. Without a broad brush approach the intention of the White Paper will struggle to fulfil the requirement.

The Aquatic Environment is often grossly disregarded in many local and national ‘strategies’, and whilst it is the TAC’s purpose to highlight this issue within this document, it is also our intention to promote the services anglers currently provide for the benefit of the environment, as well as the vision to enable others to see the potential that is currently untapped within the angling communities.

The health of the environment and the recovery of the economy have to be twinned to ensure a lasting prosperity to the UK and internationally.

Question 1 – What do we need to do to embed the true value of our natural resources in decision making at all levels?

It is absolutely vital that all stakeholders, including angling organisations, are consulted on a local level – and not just nationally through Defra for example – for the betterment of the local natural aquatic resources and to enhance their future development with conservation and recreation in mind. Local Councils need to engage with recreational user groups, as well as other concerned groups, to ensure that, any decisions made, have the views of the whole community invested within them, and not just a select few.

Websites (such as Defra’s) should be set up by Councils on a local level to consult regarding all local projects, giving the opportunity for all those wishing to assist the chance to engage and broaden the scope and potential of our natural resources, as well as to offer their services in the development where appropriate/necessary. Far too often, such projects are planned and then grown without the involvement of recreational stakeholders (and other groups) to the detriment of any use to the majority of the local people.

“We now have the opportunity to be the generation that finally puts a stop to the piecemeal degradation of our natural environment and, instead, seeks active opportunities to enhance its value.”

It is absolutely amazing that the link between angling and aquatic environmental conservation isn’t fully employed nationwide by all the agencies ultimately responsible for its welfare. This largely unused tool of assistance would see (many more) thousands of local anglers, country-wide, assisting with many local projects, to help in a physical and strategic manner as befitting the local need.
Many angling organisations are ill-considered by such agencies during the planning stages of the vast majority of future developments, and this leads to confusion, disaffection and effectively creates a situation where many opportunities are missed, as it is only once any particular project is beyond the initial stages of consultation that angling organisations become involved by default, and effectively, it has then become an opportunity missed.
Local Councils very often consider angling to be of little concern, in many regards, but would be best reminded that the opportunities that are opened to many sections of society, through angling, are numerous and incredibly beneficial to their local communities. This will lead to greater involvement of many ‘deprived’ areas of the community, through angling, which will in turn lead to a sustainable recovery of local economies and environmental concerns in a holistic sense.

“Green spaces are associated with better health regardless of socio-economic status, for every 10% increase in local green space there can be a measurable reduction in health complaints within the community (equivalent to a five year reduction in the average age)7. Increasing access to the natural environment can provide both mental and physical health benefits. Evidence from the Natural England /Department of Health Walking for Health scheme suggests that for every £1 invested in the scheme, £7 worth of health benefit is delivered.”

This could be argued to be no different, or even bettered, by the opportunities created for communities through angling. The lack of access and parking are just two small areas that are largely being overlooked on a local level, and much that is planned and built does not take into consideration the associated benefits created through maintaining, or re-establishing, recreational facilities alongside many new developments. Such opportunities provide an invaluable resource for local communities, from reducing youth crime, providing opportunities for the disabled and OAP’s, assisting those with mental health problems etc. and generally bringing communities closer to their natural environment.

It is through ‘joined up’ planning and legislation that the concerned parties will eventually reap tremendous benefit from local communities, for local communities. Through such connected chains of engagement, the 3rd Sector way (‘The Big Society’), will then truly have established itself as the model that allows all those wishing to take responsibility in their local communities to do so. Local aquatic ecosystems will benefit greatly with the involvement of anglers and it should be incumbent upon Local Authorities to engage with angling groups to the fullest extent possible, for the benefit of the local environment.

“Of course, we will need to deliver on our ambitions for the natural environment within the context of our primary aim to reduce the deficit, and reflecting the Government’s plans for reducing regulatory burdens including introducing a one-in-one-out system for new regulations. We will need to seek new innovative ways of working to achieve the outcomes we need.”

Taking into consideration the excerpt above, the TAC would like for the Dept. to strongly consider its position concerning Hydropower and its serious limitations in terms of enhancing the value of green energy resources to the nation at large. The resource has little value in terms of providing renewable energy – less than 0.5% of the national requirement and this at its top-most level of consent – and is little more than a ‘pseudo green by-product’ that will have serious implications to the aquatic environment concerning the vast majority of projected schemes countrywide. This isn’t to say, however, that a small percentage of Hydropower schemes will not be of benefit to a very few local communities.

The cost to the Govt./Tax Payer should also be of strong consideration when such Hydropower schemes are considered at the point of application, as the cost of such schemes should be viewed as prohibitive to the purse strings of England and Wales, albeit that they are considerably cheaper than many other ‘invasive’ forms of ‘so called’ greener energy supplies (such as wind power). Before such renewable energy resources are considered to be the panacea for all of the UK’s energy needs, serious consideration needs to be considered of the detrimental effect on the aquatic environment in regards to Hydropower. Rather surprisingly, it appears that nuclear energy providers will supply the most cost effective and greenest form of energy on a national level, providing waste treatments are effective for the long-term.

The Dept. must also consider the debilitating effect climate change will have on the ability for Hydropower to fulfil its potential through reduced river flows, greater abstraction etc. and all in all, Hydropower begins to look like ‘pig in a poke’.

a. How can we reflect all the different kinds of value described above?

Much will depend on the local Councils being fully supportive of the ‘Big Society’, providing the local communities with the conduit to engage through consultation, and the opportunity to assist in meaningful projects that affect them on a day-to-day basis. The local community resource is seriously underestimated by many Councils and the value of the community’s true worth would be greatly assisted through Govt. & Councils providing the vision of the ‘Big Society’ in clear and plain language.

The Civil Society needs to be fully engaged and utilised for the ‘Big Society’ to actualise its ambition. Without full local engagement it fails, and we end up with ‘more of the same’, and a case of the ‘emperor’s new clothes’.

Question 2 – Have we identified the right overarching challenges for the White Paper to consider?
Climate Change, Demographic Changes & the Incremental Impact of change

As a brief on the overarching challenges we all face, and considering the broad generality of the Discussion Paper, I believe it could be said to encompass all topics.

a. If not, what should we focus on?

There are many points of focus that a Discussion Document could highlight, however, from the TAC’s perspective it would be remiss of us not to point out that anglers view this as an opportunity to establish the fact that angling has a big role to play in the preservation, enhancement and conservation of the UK’s waterways. This would naturally dovetail with the intention of the White Paper/Big Society and see the angling community invest and assist in many regards, in accord with the transformation of our local communities to shape our collective futures.

It is in anglings interests to ensure that we all have good quality water resources available, but this has to be achieved with the aquatic environment in mind, lest the further and heightened level of works to be carried out in the future – in accordance with the EU Water Framework Directive – should fail in its objectives, and see further expense incurred upon the nation through the failure to achieve the minimum standard of good ecological status within the timeframe agreed.

b. How should we approach these challenges?

The challenge we are all facing is considerable. In regards to the inland aquatic environment, the pressures that are being placed on our rivers at this current time are immense. Current legislation does not mitigate the ‘tipping of the balance’, to the detriment of the structure of our waterways as a natural resource now, today, and the demographic changes that are to come about will see the responsibility of those owning the Water Utilities increase many fold. It will need robust policy to reflect not only our current needs for sustainable and adequate structures to be put in place, but will also need to set a standard for the next 40 years to ensure a balanced aquatic environment that considers all facets of our natural environment for today and the future, a sustainable future.

Get this right now, during the current Govt’s tenure, and you have created the platform for the future. Get it wrong, and legislate without creating an even stronger statute book to face the forthcoming challenges head on, and the future enhancements of a balanced environment will never occur, leaving a legacy of failure. Currently so much of the natural resource is wasted through ill-maintenance and inadequate development (leaking pipes, inability to deal with excess rain water etc.), and legislation needs to ensure that the Water Companies are brought ‘on board’, and fully realise their responsibility to the environment in a constructive manner, which should be of a higher value, but, not excluding profit. The waste and mismanagement of our aquatic environment is quite horrific and many incidents of pollution, as just one example, would testify to that statement without the TAC having to clarify such points.

The Dept. needs to realise that it is the guiding hand in this regard and legislate accordingly. It needs to be quite clear within its remit, constructive and committed in its ideology, and unbowed in its principles, as is the overriding intention of the Discussion Document leading to the White Paper. That being so, it needs to create a Blue Print, platforms if you like, at all levels, by which all parties can express their points of view with equality and it needs a back bone of conviction to ensure a sustainable future through constructive policies that enable the participants on a local level to deliver on the White Paper’s ambitions.

Question 3 – What are the existing policies and practices aimed at protecting England’s natural assets (including but not limited to those set out above on our biodiversity, seas, water bodies, air and soil) that currently work most effectively?

Sites of Special Scientific Interest (SSSIs) work extremely well by and large, only once again, this does tend to vary in accordance with those entrusted with their management. Far too often individual opinion tends to cloud the judgement of those entrusted with collective management of such projects leading to a lack of engagement on a number of issues, not least angling issues. Once again, the TAC would like to highlight the potential that is currently locked within the angling community that is not being utilised by those groups that should share an equal responsibility regarding the long term biodiversity of SSSIs, as one example.

a. What works less well – what could we stop doing or do differently?

Whilst the TAC acknowledges the need for the otter populations to be protected, and under no circumstances contradict ‘their’ right to existing in the UK, to have arbitrarily re-introduced them without due consideration of the environment they were being released into, was naive beyond reason. Very little is being done concerning the feasibility of the enhancement/re-introduction of the otter and the subsequent impact upon many environments remains a recipe for disaster, not only for fisheries on a local basis in heavily affected areas, but for the otters themselves. Recent anecdotal evidence of dog otters killing each other concerning territorial issues is just one example where release programmes are ill thought out, for example.

Since the decline of the otter in post war Britain, much has changed and the re-introduction has unfortunately led to many problems within many aquatic environments and is destabilising many local ecosystems and many local businesses, such as privately run fisheries. There needs to be safeguards to protect aquatic environments and businesses, as well as the otters, which are causing irreversible damage to a number of communities nationally.


Question 4 – What mechanisms should we focus on to ensure we manage our natural systems more effectively in future?

Whilst the TAC acknowledges the need for business and conservation to form a balanced partnership to forge new paths to lead to a successful future for our natural environment, it is nevertheless astounding the amount of neglect that appears in the statute to protect such environments? Chemicals and phosphates, for example, in simple washing products cause immense environmental problems within aquatic environments, why are they allowed to be manufactured containing such harmful by-products? Baffling to say the least? Simple changes in legislation to guide and steer industry would effectively wipe out a part of the problem facing our aquatic environment in this instance alone.

a. How should we define success?

Lasting, effective and tangible change that has substance and support in the vast arena of the majority of conservation groups. If you fail to put the meat on the bones of your good intentions under the banner of the ‘Natural Environment’, this Govt. will be remembered for failing the environment at its most critical hour. The opportunity to steer towards the correct course is one that has to be made now, please do not miss the opportunity through a lack of balls, the choice is ours! Please help us make the correct choice…

b. How can we agree on common goals and assess our progress towards them?

The targets need to be outcome based and focused on integrated/holistic goals. It would be the Govt. that would provide the tools and the choices for the communities to coordinate collaborative results that will be for the betterment of the whole, and not imbalanced in favour of one group or another.
With that in mind, please do not allow this Govt. to bind itself with bureaucracy and paperwork. It is not very difficult to gauge the mood of the ‘active population’ in such regards, as long as the ‘Big Society’ functions, those groups concerned will be openly exhorting its contentment or otherwise (in regards to the progress) through local forums. Papers such as this one regarding local concerns, through local Councils, will aid the local communities and effectively this Govt. no end in assessing the development of the collective will of the people of any given area and on a national basis.
Also, when the TAC stop writing such damning criticism concerning the way our rivers and sport are being treated, rest assured, the environment WILL be in a much better place! We need to ensure that biodiversity is considered through an integrated approach on a national, and ever increasingly necessary, locally-led level.

Question 5 – How best can we reduce our footprint on the natural environment abroad, through the goods, services and products we use?

The mindset of the UK has to be given a sharp dose of reality, goods that are traded between nations are, in some instances, beyond sustainable means and our national policy has to reflect the ‘environmental hand’ in as much as it reflects the benefit afforded to many communities worldwide through the procurement of products, goods and services offered. This in an age where instant gratification has become the norm and the collective psyche of the nation expects the ‘exotic’ to be readily available and affordable to cater for our thirst for diversity, regardless of the impact that it has globally… at the expense of the ‘natural balance’.
In the early development of this Govt. it has displayed the strength of character to radically change our aspirations on a personal and collective level to reduce the financial deficit/burden that has been created by the Govts. of the last 30 years plus. The TAC would sincerely hope this brave and pragmatic approach will be applied across the board to redress the parlous state that the global environment is suffering, which will only lead to devastating consequences concerning the invaluable environmental resources on a worldwide scale unless a lead is taken by the ‘1st World’ Govts. – not least our own – to make lasting change for the better. It is incumbent upon us all to develop a 22nd Century philosophy (in this the 21st) to ensure our children’s children have the opportunity to live in a world that functions harmoniously with the planet which supports us. To do anything less will see this generation consigned to annals of history as the destroyers of the natural balance on the planet Earth. This isn’t a melodramatic statement it is a vivid and tangible fact…


Question 6 – What best practice and innovative approaches to protecting and enhancing our natural environment do you think should be considered as we develop the White Paper?

For those of us directly concerned with the aquatic environment, we would strongly recommend the correlation between the need for renewable energies allied with the Water Framework Directive (WFD) for example.
It is patently obvious that the use of Hydropower has very little benefit to the countries need for renewable energy (as briefly highlighted in our answer to Q1 above), and if the WFD was adhered to in its intent, no Hydropower facilities could be built considering the correct application of the WFD. Please reconsider the parameters for the granting of applications concerning Hydropower, as the vast majority of these projects are little more than pseudo green renewable energy resources that compromise the aquatic environment, and Defra’s apparent need to ‘rob Peter to pay Paul’ in this respect is galling to say the least.

The TAC is developing a close working relationship to the Environment Agency, as well as many other local stakeholders, and this can only bode well for the future of the River Thames in terms of sustainable and lasting management programmes that place conservation at the heart of such affiliations through monitoring operations that give the EA another early indicator of developing poluution problems etc.

Question 7 – How best can we harness and build on public enthusiasm for the natural environment so people can help improve it through local action, as informed consumers or by shaping policy?

The TAC would once again like to reiterate the underused resource of the angling communities, which is primarily caused through a sense of disenfranchisement among the entire community, through a neglect of that resource over the last 30 years plus, FACT!
The Angling Trust has recently communicated its willingness to assist post the changes made within the Environment Agency concerning the removal of the Statutory Advisory Committees, and the opportunity is there for this Govt. to utilise the resource that is ready, willing and available to help. There needs to be a transparency and openness within the Agency to ensure that angling’s contribution through the licence fee is accounted for, so that anglers can have their say in how that money is spent and this will lead to an increase of availability of the voluntary resources available within the angling community. The ‘Big Society’ at work…

Question 8 – What should be our vision for the role of Civil Society in managing and enhancing the natural environment and for engaging individuals, businesses and communities in setting the agenda for that work?

‘Vision’ has a pre-emptive ‘feel’ and it will take a strength beyond ‘vision and words’ to assist a truly ‘Civil Society’.
It will need strong guidance concerning clear objectives on a local level, as what may be appropriate in one area of the UK, will almost definitely be different in another area. That said, all too often ‘Civil Societies’ are found competing against one another, ending up with a disgruntled disarray of confused, directionless and subjective counter-points that achieve very little on a local basis through mistrust and entrenchment of factionalised groups.
‘Civil Society’ will need forums for local communities, businesses etc. to engage most definitely alongside local Councils and they will need to form clear and rational objectives to achieve the greater good for those communities on a local basis and arbitration from an external source would undoubtedly be invaluable.
Along the banks of the entire River Thames there are angling clubs, riparian owners etc, that integrate with the EA on a local level and their input to management of the river system should be enhanced to ensure that the future of this ‘world renowned resource’ is safeguarded for future generations. Angling Trust Thames Regional Forum is one avenue of direct influence that needs to be embraced by all concerned Depts.

Question 9 – How best can Government incentivise innovative and effective action on the natural environment, across England, at the local level?

As briefly suggested in the document so far, there will need to be access to forums on a local basis to engage the respective areas of the community to achieve and activate representation, without the opportunity to participate, the ‘Big Society’ becomes a contradiction in term.

“The Coalition Government has embarked on a radical programme of reform to free up local councils from top-down bureaucracy, and devolve responsibility to the local level.”

Taking the above as a typical quote from this Discussion Paper, for the concept of embracing the natural environment and harmonising that in real terms to 3rd Sector modelling, the Govt. has to be absolutely clear in its intent. The initial stages of “freeing up” local communities from top-down bureaucracy have to be handled responsibly, and not purely as an exercise in “deficit reduction”. Without clear and concise development structures conceptualised/initiated by the Govt. the ‘re-birth’ of the ‘Big Society’ becomes a damp squib relatively quickly and no amount of rhetoric will disguise that fact.

The aquatic environment needs to be managed with sustainability in mind, and its future needs a coherent strategy involving all the stakeholders to ensure that biodiversity is enhanced through a broadened knowledge base, which will naturally include angling communities as a vital link in their sustained development through initiatives such as the Water Framework Directive and the revamped Blueprint for Water.

a. How best can local Government and other local partners work together to improve local outcomes on the natural environment, and pursue a more integrated approach linking a healthy natural environment to economic prosperity, sustainable development and a better quality of life, health and wellbeing?

Lofty ideals to say the least, and whilst much of this paper detracts from Govt. involvement on a local basis, etc., it is nevertheless Govt. that will have to initiate the framework for this to even begin to find a foothold in the most relevant and needy areas. To incentivise an urban population to assist in this great wave of progressive responsibility/ownership of local communities will take more than words.
Post the second world war successive Govt’s. have taken more and more responsibility for the nations local communities and those self-same communities will in part view the concept of the ‘Big Society’ with an air of artifice.
Those that are ready and willing within those communities need to be stimulated and incentivised through early inclusion lest the opportunity wither on the vine. This will take courageous and inspirational leadership to genuinely realise, and the incumbent Coalition Govt. needs to find such vigour, which isn’t immediately apparent in truth.

b. What are the most effective mechanisms for managing the natural environment where cross-boundary issues are involved, and making the link to other mechanisms for economic growth, transport and planning?

Quite simply local communities form a part of a wider regional map, and bordering Councils, businesses, stakeholders etc. need to engage where necessary, to ensure continuity. Very often regional/local boundaries form prohibitive obstacles to further collective environmental objectives and these ‘boundaries/obstructions’ need to develop cooperatives to manage cross boarder issues, certainly regarding rivers that are often situated in many counties. Forums and websites will provide people with a knowledge of what is actually occurring in and around their local communities, and the Information Age has long been with us, and the use of electronic communications in a wide regard can be utilised to form the mechanics of assimilated growth and collective prosperity in all regards.

c. How best can the value of the natural environment be considered within local planning?

All due consideration of the natural environment should be considered by local Councils in regards to the potential that surrounds any given development regardless of its size and magnitude. So much opportunity is missed simply through a lack of knowledge and vision that, remains on the periphery of planning issues at an early and formative time, and far greater involvement among the local denizens should see many more successful advancements concerning the local environment and a greater benefit to the local communities should occur through broader engagement. If people within local communities are involved to a greater extent in the day-to-day running of their communities, then the sense of ownership will reinvigorate those communities to ensure success in the conservation and utilisation of the natural environment to the best possible extent through an affiliation of involvement.
Naturally the water resource has many current pressures placed upon it through abstraction, climate change and waste services, all planning needs to consider the impact that further environmental and demographic changes will bring to our natural aquatic resources in the future.

Question 10 – How best could the economy reflect the true value of nature’s services in the way business is done, to drive smarter, greener growth?

This is an issue of awareness, and in all honesty a large section of the business community does not have the natural environment on their radar when considering future developments, which has lead to many ecological disasters in the past. All so unnecessary, as there is fantastic reward to be gained if lateral environmental views are considered, the opportunities are manifold and all that is lacking is the vision.
The White Paper that grows from the various Discussion Papers presented to Defra needs to be expansive and imaginative, it needs to daringly challenge all concerned parties to alter their thinking radically, as anything less will not create an impetus to drive the necessary change to alter the perceptions of all sections of the local communities to make change happen. Without applied growth and the participation of many concerned local businesses, stakeholders etc. the ‘Big Society’ fails.
Financial incentives concerning environmentally sustainable businesses is going to be paramount to the success of the White Paper, as well as, appropriate measures to ensure that those that have a detrimental impact on the environment pay for environmental indiscretions, such as those that pollute rivers etc.

Question 11 – Responsible businesses are already looking for ways to reduce their impact on the environment. How can we encourage more action like this?

There is a massive opportunity to phase in ‘best environmental practice’ through financial legislation. Reward those that do things correctly and punish those that don’t, as there is nothing like the pocket to incentivise people where it often matters most!

Question 12 – What are the barriers to joining up and seeking multiple benefits from our natural assets?

In many regards it will be the disenfranchisement of the local communities over the last 50 years that will create the biggest barrier in the greater community joining up. Angling has seen a dramatic decline in the opportunities to fish in urban environments (for example) due to many differing reasons, not least the privatisation of many once accessible areas, plus the perception of the sport having altered in that time.
So in regards to our waterways etc. the TAC would advocate a greater involvement of angling organisations on a local basis to ensure the conservation of the aquatic environment, in addition to giving the local communities access to angling projects for the social benefit of those communities, and most importantly bringing the millions of anglers back to the table to enable participation on a local level for the benefit of the whole community.
For anglers, the health of the aquatic environment is absolutely pivotal for the enhancement of their sport first and foremost, additionally, and by no means of any less importance the health of the associated flora and fauna is of vital regard in maintaining balanced and robust ecosystems on a local basis and anglers can assist to a massive extent in the preservation and enhancement of the aquatic environment.

Question 13 – What are the barriers to thinking big and taking a landscape scale approach to managing our natural assets?

Many sections of the community fail to understand the connectivity of land, water and air, the integration between all parts of an ecosystem, and how we are best served preserving these whilst expanding nature’s services for the benefit of all.
The TAC would suggest that the development and conservation of the natural environment has been somewhat contradicted in recent decades and that an appreciation of our natural assets has decreased among the population in general to the detriment of a ‘natural concept’ and development among many depts. of Govt.
This needs an holistic approach within Govt, and strategies need to be formed to mitigate the decades of soil erosion, the contamination of land and aquatic resources, the over fishing of our coastline, the mismanagement in terms of initiating renewable energy resources etc.
Considering that many of our institutions are situated within urban conurbations it would seem ‘natural’ that, the concept of a ‘landscape scale approach’ would be alien to many students in many relevant fields of development that directly affect our natural world, and all too often ‘projects’ lack synergy and sympathy to the environment that surrounds it, on many levels at this current juncture in time. A collective approach to ensuring the ‘profitable’ and sustainable future of our natural environment is a long time in coming, please make sure the vision and the incentive is provided today.

The TAC would suggest that educational institutions begin to assimilate the natural environment within much of the curriculum (as appropriate) and that the potential of a balanced and sustainable development is allied to the natural environment to ensure future generations understand what those of recent times have barely begun to understand.

For a landscape scale approach to managing our natural assets to be successful it will need a strong and tactile approach from the relevant Govt. Depts. to ensure the mantle is lifted in as many areas of society as is possible, as quickly as possible. The challenges are already before us, and without the ‘many’ becoming aware of those challenges (with the help of civil society, business etc.) and furthermore being given the opportunity to participate in encountering those challenges, our society will be all the poorer for it, and not least anglers and our natural environment.

Question 14 – What should be the priorities for the UK’s role in EU and international action, to protect and enhance the natural environment at home and abroad?

First and foremost a balance has to be quickly established within the UK concerning the enhancement of our natural environment, only then can we truly be seen to be taking a lead in the development of balancing our own natural assets toward the betterment of our own environmental protection in conjunction with building a platform for growing the natural economy, and not least in the recreational use of our environment in many regards. Well balanced recreational use of our natural assets brings much to our economy and teaches many the value of the natural environment which can only bode well for our future relationship with our environment.
This then allied with our EU partners and the international community to assist and legislate accordingly, to protect European and global environmental economies and ensure a sustainable yield for the foreseeable future, within a symbiotic framework that enforces good practice to ensure societal development within an environmentally aware matrix. It is only through conceptual collaboration among a broad number of nations that a true path of environmental protection and enhancement can be achieved.

It is, however, vital that we get our own house in order as soon as is possible, the next decade will be pivotal in the destiny of our natural environment.

Question 15 – If you could choose just one priority action for the Natural Environment White Paper to drive forward locally, nationally or internationally – what would it be?

Enforce the EU’s Water Framework Directive to ensure the protection of our aquatic environment. Do not compromise on the need to protect our water from the pressures that will continue to grow on a daily basis, through climate change, demographic shift etc.

The water companies of the UK have a lot to answer for and far too much of their emphasis is placed on profit at the expense of the aquatic environment. The consumer pays disproportionately for the improvements that are being made and it is long overdue for the water companies to match that commitment with its own resources to ensure that waste and profligacy are a thing of the past. The incidents of pollution are barely tackled by the authorities and to many of those directly affected by such incidents, it appears as though the water utilities have a ‘get out of jail free card’, which leads to a lack of incentive to engender structural change from within.

The Govt. Dept’s. are equally to blame for this disgraceful situation simply due to poor legislation which has existed since the privatisation of those water utilities in the late 80’s. Stop ‘talking’ about enhancing our natural assets Defra and start legislating to make positive change. It is no good encouraging companies to adopt ‘best practice’ with a softly, softly approach please legislate, to make sure they do!


To give TAC members further insight into this consultation, please click on the following link which will take you to the relevant section of the DEFRA Website
Posted in News | Comments Off on The TAC Response To The Discussion Document – Natural Environment

Fisheries officers seize illegal traps on Tideway

Environment Agency fisheries enforcement officers have seized three illegal nets on the tidal River Thames in Greater London and Kent.
Officers on a river patrol today (Tuesday) uncovered the nets in the Barking, Bow and Greenwich areas. Among the nets found was an unattended gillnet, which can trap fish and wildfowl, and two homemade traps.
This latest find follows the discovery of 17 illegal traps at Greenhithe, Kent, on Saturday October 9, which were seized by officers following a number of calls from river users and the public.
Routine patrols are carried out on the Thames estuary as the Environment Agency enforces legislation to protect fish stocks. This includes a legitimate eel net fishery licensed and regulated by the Environment Agency which stretches up to Tower Bridge. This fishery has developed as water quality in the Thames has improved.
European eel stocks are at a historic low and continue to decline. Loss of habitat and barriers to migration are believed to be the main causes for this decline in England and Wales.The Environment Agency wants to ensure eel fisheries continue to be sustainable, but also that they do not increase pressure on stocks.
Carl Rasey, an Environment Agency fisheries enforcement officer, said: “These discoveries are disappointing, as legitimate eel netsmen respect the rules.
“Whoever has set these traps is in breach of an emergency close season and has also allowed them to dry out, which is a separate offence. Whilst these traps are primarily set for eels,  they often catch a range of other species which will die if the traps are left exposed at low tide.
“Eel populations are declining across Europe but if we want to ensure that Thames eel fisheries continue to be sustainable then this sort of irresponsible behaviour is unacceptable. We would urge anyone who sees suspicious-looking traps to contact us immediately.”
There are 15 individuals which are currently licensed to use nets or traps to take eels in the tidal Thames. A condition of the licence is that the eel fishermen send in catch-returns detailing what they have caught during the year. The Environment Agency uses this and other data to regulate the levels of exploitation of this valuable and totally wild resource.
If anyone sees suspicious-looking fish traps they should call the Environment Agency on our emergency hotline 0800 807060.
Posted in News | Tagged , , , | Comments Off on Fisheries officers seize illegal traps on Tideway

Environment Agency pledges focus on sources of river pollution through state of the art technology

Environment Agency pledges focus on sources of river pollution through state of the art technologyThe Environment Agency today revealed that it will be deploying state of the art technology to help tackle diffuse pollution from farms and urban areas. This is part of a programme of 8500 studies the Environment Agency will carry out to help improve the quality of rivers over the next two years. Improvements in water quality over the last two decades have primarily been achieved through successful action on pollution from sources such as factories and sewage treatment works (‘point source pollution’). Last month, the Environment Agency published its annual classification of water quality in rivers in England – revealing they are the cleanest they have been since the industrial revolution. Recent reports have shown that record numbers of otters, salmon and trout are now being found in rivers like the Thames and the Tyne. The Thames, which in places was declared biologically dead in the 1950s, was last week crowned winner in the International Theiss River prize, the world’s biggest environmental award. The Agency will increasingly focus on pollution from agricultural land, highways and urban areas, which is now the main cause of failing water standards in many areas, but is harder to identify. One way of better understanding this issue is the deployment of new technology in areas of concern. Tamar trial A pilot study for the new technology will take place on the River Tamar between Devon and Cornwall. A variety of sensors will be placed in the river to automatically sample water quality and send the results back electronically to a central location. New software will allow the sensors to work together as one, providing an instant snapshot of the health of the river. If successful and cost-effective, the Environment Agency will look at using the technology in other problematic areas around the country. The trial on the Tamar will start in November and last for an initial five months. It will involve placing 11 sensors along a 20km stretch of river and will help identify and tackle the problem of agricultural pollution in the river – one of England's most beautiful waterways. Although the river is cleaner than 20 years ago, the impact of diffuse pollution has continued to create challenges in some stretches. New standards The trial comes as the Environment Agency publishes its classification update of rivers under new, tougher standards set out under the EU Water Framework Directive (WFD). The WFD assessment focuses on the ecological health of waters. In total, 37 measures of water quality, including the health of river insects and plants, are assessed and the grading of each water body is determined by the measure which scores the lowest result. Under this more stringent system, 27.8 per cent of water bodies are classed as ‘good’ or ‘high’, 57.2 per cent ‘moderate’, 13.1 per cent ‘poor’ and 1.8 per cent ‘bad’. However, more than a third of water bodies missed out on the ‘good’ status by just one of the thirty-seven different indicators. This means that by taking action to improve a single measure, many more waters will achieve ‘good’ status. These results are an improvement on last year’s and indicate that the actions already being taken are improving water quality. River modification, including walled banks through towns and cities, culverts, dams and weirs is a factor in over a quarter of rivers failing to achieve ‘good’ WFD status. Dr. Paul Leinster, Environment Agency Chief Executive said: “River quality in England and Wales has steadily improved over the last 20 years and newer, more stringent EU standards will help ensure that they continue to do so.” “The return of wildlife including otters and salmon to rivers demonstrates the tangible benefit this provides for wildlife and for people, but we are not complacent. The Environment Agency is committed to tackling diffuse pollution and will be working with community groups, River Trusts and wildlife and angling organisations who all have important roles to play in improving waterways.”
Posted in News | Tagged , , , | Comments Off on Environment Agency pledges focus on sources of river pollution through state of the art technology

Angling Trust to Fill Gap Left by Axed Statutory Committees

Angling Trust to Fill Gap Left by Axed Statutory Committees
The Angling Trust intends to work with the Environment Agency to put in place new arrangements for anglers, angling clubs, fisheries and consultatives to have a say in the management of fisheries and angling, following the Government’s decision yesterday to axe the Agency’s statutory advisory committees.
The Government announced that it is to cut the Environmental Protection Advisory Committees (EPAC) and Fisheries, Ecology and Recreation Advisory Committees (FERAC) as part of a wide-ranging reduction in arms-length bodies. It has also called for statutory agencies to become more customer-focused and accountable.
The Trust, which is the representative body for all disciplines of angling, will be meeting with senior Environment Agency staff in the coming weeks to work up a new system for anglers to have their say in fisheries and angling management and policy – and to move delivery of a range of activities out of the EA and into the voluntary sector. The Trust has nearly 1,500 angling clubs, riparian owners, consultatives and river associations in membership, and is already working to establish a national network of voluntary organisations representing each catchment in the country. It has set up four regional forums to provide a focus for discussion about regional issues affecting fisheries. The inaugural meeting in the North West was attended by more than 50 Angling Trust members.
The news that the statutory committees are to be cut makes it even more important that these forums are established without delay. The Trust currently relies on volunteers to chair and administer these groups and is calling for volunteers to help establish forums in the South East, South and North East regions. Anyone interested in volunteering should contact the Angling Trust office as soon as possible.
At present these Forums are based around the Environment Agency’s regions, but the Trust understands that the Agency will soon be restructuring its administration around river catchments and the regional forums will follow suit. The Trust has recently submitted, in partnership with several fisheries charities, proposals to Government for the reform of fisheries management which included much greater delivery by the voluntary sector. This will require angling and fisheries organisations to work together at a catchment scale to prioritise action and co-ordinate activities.
Mark Lloyd, chief executive of the Angling Trust said: “The loss of the statutory advisory committees removes the formal structure for fisheries and angling interests to influence the work of the Agency. We need to work swiftly to ensure that they are replaced by a new system for representation and accountability so that anglers can have a say about how their money is spent and get involved in taking action to protect and improve their waters.”
Mike Heylin, chairman of the Angling Trust said: “There is a very rapid change going on in the way that our fisheries are managed. If anglers, clubs and fisheries want their voice to be heard, they should get involved by joining the Angling Trust, and help us to help them.”
Posted in News | Tagged , | Comments Off on Angling Trust to Fill Gap Left by Axed Statutory Committees

Angling and Fisheries Organisations Press for Reform of Fisheries Management

Angling Trust Member News
Thursday 14 October 2010
 
 
 
Angling and Fisheries Organisations Press for Reform of Fisheries Management
The Angling Trust, Atlantic Salmon Trust, Association of Rivers Trusts, Salmon & Trout Association and Wild Trout Trust have today issued a detailed joint proposal for reform of the way in which rod licence and government funds are spent on managing angling, fisheries and biodiversity in England and Wales.
These organisations are determined that, in light of planned cuts to public expenditure, maximum value is achieved from the limited funds available to help achieve a sustainable future for fisheries and biodiversity in rivers, lakes, canals and estuaries.
Following a meeting with senior EA staff and Board Members on Wednesday, the organisations welcomed the EA's response to its concerns about accountability, in the form of more detailed reports on expenditure and activity by the Fisheries function.
They called for this transparency to be built into a new structure which would meet the Government's Big Society agenda by involving angling and fisheries interests in decision-making, and for Defra to transfer to the third sector most of the funds currently spent by the EA on delivering river improvements and monitoring. The third sector also had an important role to play in rod licence enforcement and promoting angling.
Fish Netting Team
In a joint letter to the Chairman of the EA, Lord Smith of Finsbury, the organisations also pressed the EA to maintain sufficient funding from Government grant in aid (GIA) to support delivery of the Agency's statutory duty to maintain, improve and develop fisheries. While GIA contribution to fisheries has remained static at £9.4 million for the last decade, funds raised from anglers' rod licences have almost doubled in the same period to a high of £26 million. The latter currently covers the EA's work on trout and coarse fish, but GIA is vital to continuing efficient enforcement and monitoring of salmon and sea trout.
Executive Summary of Report 1. We support the continued delivery of the Fisheries statutory duty by an integrated Environment Agency.
2. We support the continued requirement of freshwater anglers to pay a rod licence fee, but wish to see greater transparency and accountability for the application of these funds to external bodies and local communities.
3. We wish to see Government funding for fisheries, which largely supports salmon and sea trout monitoring and enforcement, maintained.
4. We are opposed to the creation of a separate national body and/or regional bodies with responsibility for fisheries.
5. We propose the creation of a national committee with external and senior EA representatives to advise the EA about delivery of its fisheries function and other activities which affect fisheries.
6. We propose that RFERACs should focus on fisheries and conservation, and lose responsibility for recreation and navigation.
7. We believe that the Agency should be reformed to become an effective regulator rather than a regulator and a delivery body. Delivery should where possible be carried out by Rivers Trusts, the Riverfly Partnership, the Angling Trust and other third sector organisations, which are much more cost-effective.
8. We would like to see dedicated, specialist fisheries officers employed by the Environment Agency as a single point of contact in every catchment.
Mark Lloyd, Chief Executive of the Angling Trust said: "As the representative body for all anglers, we are determined to ensure that our members' substantial contribution to the management of fisheries and angling is spent effectively and efficiently. We are calling for the EA to account for the way it spends our money and delivers its statutory responsibility to maintain, improve and develop fisheries in partnership with others."
Paul Knight, Chief Executive of the Salmon and Trout Association said: "Given the current pressures on public funding, we are keen to explore how opportunities can be seized to accelerate and multiply the growth of partnerships between the EA and organisations in the non-governmental sector to deliver real and measurable improvements to fish stocks and fly-life more cost-effectively."
The full proposal is available for download in PDF format HERE.

     
Posted in News | Tagged | Comments Off on Angling and Fisheries Organisations Press for Reform of Fisheries Management

Government Cuts announced affecting our waterways

The government has announced that 192 quangos are to be scrapped.
Some will be abolished altogether others will see their functions carried out by government or other bodies, the Cabinet Office says.
A further 118 will be merged. Some are still under consideration but 380 will be retained,
Cuts announced today, full list is here
For the rivers we have, more or less as expected:

Defra
British Waterways
No longer a Public Corporation – Abolish as a public corporation in England and Wales and create a new waterways charity – similar to a National Trust for the waterways

Defra
Environment Agency

Retain and substantially reform – Reform through structural, process and cultural change to become a more efficient and customer focused organisation; and clarify accountabilities. Further announcements after the spending review. The Environment Agency in Wales may move to form part of a WAG Environmental Body.

Defra
Inland Waterways Advisory Council

No longer an NDPB – Abolish body and functions, as previously announced

Posted in News | Comments Off on Government Cuts announced affecting our waterways

River Thames wins world’s largest environmental prize

The Environment Agency has collected the world’s largest environmental prize after Britain’s most iconic river was crowned the beauty queen of the planet’s waterways.The River Thames was selected out of hundreds of rivers across every continent as the winner of International Theiss River Prize, which celebrates outstanding achievement in river management and restoration.

London’s renowned waterway was up against the world-famous Yellow River, in China, Hattah Lakes, Australia, and the Smirnykh Rivers Partnership, in Japan in the competition’s finals.

The Thames scooped the prize thanks to its dramatic recovery from a biologically dead river in the 1950’s to today’s thriving waterway; teeming with fish, and with returning salmon, otter and sea trout populations.

The chemical quality of the rivers within the Thames catchment classed as ‘Very Good’ or ‘Good’, has improved from 53% in 1990 to 80% in 2008 while the estuary supports viable shellfisheries and is a nursery ground for commercial sole and bass stocks. The numbers of fish are increasing, with 125 different species recorded, including internationally important smelt and shad.

Since April 2005, 393 habitat enhancement projects have been completed and nearly 70 km of river has been restored or enhanced.

Alastair Driver, the Environment Agency’s National Conservation Manager, said: “In the last 150 years the Thames has been to hell and back, and it has taken thousands of people many decades to restore it to this point. Tighter regulation of polluting industries and our work with farmers, businesses and water companies to reduce pollution and improve water quality, have all helped to make the Thames a living river once again.

“But the recovery is fragile, and under increasing pressure from a growing population, ageing infrastructure and climate change. Through innovative projects such as the Thames Tideway tunnels and the London Rivers Action Plan, we and all of the people and organisations we work with are proving that we are tackling these challenges head on to ensure that the Thames remains an iconic river for many centuries to come.”

The Environment Agency has pledged that the $350,000 AUD (Australian Dollars) prize money will go to the Thames Rivers Restoration Trust. Part of the prize fund will be used by the Trust to establish a twinning project to help restore a river in the developing world.

Boris Johnson, Mayor of London, said: “The Thames is one of our most precious assets, so I am thrilled to see that efforts to improve and preserve its good health are being lauded on the world stage. Congratulations to all those who have played a part in this success.”

The actor David Suchet, a keen boater and chairman of the River Thames Alliance said: “I am fortunate in my life to have travelled extensively and enjoyed many other rivers worldwide. But the River Thames is priceless and one of the most glittering jewels in the crown our English heritage.”

Sally Chatterjee, CEO, Visit London commented on the shortlist, “The River Thames is a huge part of tourism in the capital. Not only do the banks of the Thames offer great walks, attractions and places to eat and drink but the river itself is a popular alternative for travelling across the city. For visitors, leisure cruises offer wonderful and unique views of some London’s most iconic landmarks.”

Chris Poupard, Chair of the Thames Rivers Restoration Trust, said: “We are delighted to have helped the Thames reach the finals of the International River Prize. This is a recognition of all of the hard work and investment by many people and organisations over the past 50 years. We will continue to play our part in delivering the plans that are in place to make the river even better in future.”

Richard Aylard, Thames Water’s External Affairs and Sustainability Director, said: “Major investment at our sewage treatment works, paid for by our customers through their water bills, has greatly accelerated the clean up of the River Thames. Biologically dead for many years, there is now a much greater diversity of wildlife in the river. But we need to maintain this progress in the face of population growth and climate change, and not slip back. Delivering our London Tideway Improvements programme is now essential to tackle the increasingly frequent overflows of sewage into the river.”

The award was presented on October 12, at the International Riversymposium in Perth, Australia.

About the entry
The Environment Agency submission for the international river prize focused on five innovative projects put in place to further improve the quality of the Thames and its tributaries:

Working with farmers – which has helped to reduce pollution from nutrients and pesticides.

The Jubilee River Flood Alleviation Scheme – which has created a new 11 km stretch of naturalistic river and habitats, whilst delivering flood protection to 5,500 homes.

The London Rivers Action Plan – which is helping restore London’s urban rivers, with 58 new river restoration projects in progress since its launch in 2009.

The London Tideway Tunnels – a £3.6bn scheme tackling the 39 million tonnes of storm sewer overflows that enter the tidal Thames annually.

Thames Estuary 2100 – a 100-year adaptable plan to ensure the future sustainable management of tidal flood risk in the Thames estuary, and protecting over 1.25million people and £200bn in property value.

The London Tideway Improvements – three Thames Water schemes to tackle the 39 million tonnes of storm sewer overflows that enter the tidal Thames in an average year. These are the £675m Sewage Works Upgrades, the £635m Lee Tunnel, and the proposed Thames Tunnel (estimated cost £3.6bn).

Posted in News | Comments Off on River Thames wins world’s largest environmental prize

Angling Trust – Environment Agency Breaks Promises on Hydropower

Angling Trust Media ReleaseMonday 11 October 2010 Angling Trust, the voice of angling  
 
 
Environment Agency Breaks Promises on Hydropower
 The Angling Trust has written to Ian Barker, the Environment Agency’s Head of Water Resources, expressing anglers’ frustration at a string of promised actions which have not been delivered to protect fisheries from damage from a spate of applications for new hydropower installations on rivers. In particular:
1. The Environment Agency (EA) promised a review of the so-called Hydropower Good Practice Guidelines by June, with angling and fisheries interests involved in the review. Nothing has been arranged.
2. There was to be a catchment review of hydropower potential to highlight those barriers that could not be removed and which might be suitable for development, and to consider a pragmatic limit on schemes. It would also highlight those schemes where win:win, by improving fish passage, might be possible. This has not happened.
3. In parallel, there was to have been a review of catchment continuity to migratory fish, including several species of coarse fish. No progress has been reported.
The Angling Trust believes that the EA may be failing in its statutory duty to maintain, protect and improve freshwater fisheries because it is pressing ahead with a process to make it easier and quicker to submit planning applications, without safeguards first being put in place. The Trust has been examining, and where necessary objecting to, more than 100 applications throughout England. The Trust’s experts are appalled by the standard of environmental information submitted with hydropower applications, many of which do not even mention any potential impact on fisheries. They are also very frustrated by the difficulties they face in some areas with accessing information about applications. Often only the application itself, without the vital supporting environmental statements, is available in hard copy format in an office which may be many miles away. The comments of the EA’s own fisheries staff on applications are not divulged.
Mark Lloyd, Chief Executive of the Angling Trust said: “The Government and the Environment Agency are rightly spending millions of pounds each year removing barriers to fish migration in rivers. It is bizarre that taxpayers’ money should at the same time be spent on subsidising these new barriers into rivers with generous feed-in tarriffs. Other countries are busy removing low-head hydropower installations built in the last two decades because the damage they do to fisheries and biodiversity hugely outweighs the benefits of exploiting the renewable energy.”
Roger Furniss, Chairman of Fish Legal, the Angling Trust’s legal arm, said: “The lack of information available and the poor standard of applications leave riparian and fisheries interests unsighted on the aspects of applications which directly affect their legitimate property and sporting rights, which have significant financial and social value. This lack of information often leaves riparian and fisheries interests with no alternative but to object to all applications.” The Angling Trust has welcomed the Environment Agency’s agreement to a high level meeting on 19 October to discuss these and other concerns.   Media Enquiries:  admin@anglingtrust.net. www.anglingtrust.net
Posted in News | Tagged , | Comments Off on Angling Trust – Environment Agency Breaks Promises on Hydropower

Invasive Species Alert – Killer Shrimp!

What is it?
A highly invasive non-native species that has spread from the Ponto-Caspian Region of Eastern Europe. As a voracious predator it kills a range of native species, including young fish, and significantly alters ecosystems.
The first known outbreak of this species was found in Grafham Water on 3 September 2010.
Please watch  BBC TV: Countryfile, 6.30pm, BBC1, Sunday 10 October 2010
  How do you identify it?
  • Total body length of up to 30 mm (large for a freshwater amphipod).
  • May appear striped or uniform in coloration pattern.
  • Mandibles are relatively large.
  • Behaviour is particularly vicious and destructive.
Dikerogammarus villosus www.nonnativespecies.org
If you find this species, please send a photo and details of the sighting to: alert_nonnative@ceh.ac.ukHelp stop the spread of this species by:
Boaters
  • Inspecting and cleaning boats and kit before and after use
  • Inspecting and cleaning launching trailers
  • Draining all bilge water from boats before leaving the site
Anglers
  • Inspecting and cleaning tackle before and after use.
  • Clean and dry all nets and tackle after use.
  • Check for any signs of the Shrimp on your equipment.
  • Making sure no lake water is taken away with your kit.
  • Not transferring live bait between water bodies.
External links to news reports
Defra
BBC
Gofishing
Posted in News | Tagged , , , | Comments Off on Invasive Species Alert – Killer Shrimp!

Hydropower Permitting Review by the TAC

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
 

Posted in News | Tagged , , | Comments Off on Hydropower Permitting Review by the TAC