Hydropower - Enough is Enough say Fisheries Bodies
The Angling Trust, Atlantic Salmon Trust, Afonydd Cymru, Association of Rivers Trusts, Salmon & Trout Association and Wild Trout Trust have today written a joint letter to Paul Leinster CBE, Chief Executive of the Environment Agency (EA) to express their frustration at the way his organisation has failed to take account of the protection of fish and rivers in its approach to hydropower.
After more than a year of campaigning for equal involvement in the Agency's discussions with the British Hydropower Association (BHA), angling and fisheries interests were finally granted this opportunity. They provided detailed verbal and written comments on ways in which the Agency's so-called Good Practice Guidelines should be improved to ensure that new schemes have no adverse impact on fish and flows. Once again, these comments have been largely ignored in the latest draft of the guidelines. In frustration, the angling and fishery representatives have withdrawn from a scheduled meeting with the Agency and the BHA. Instead they have written to the EA Chief Executive requesting an urgent meeting at a senior level to bring about a change of policy. Their letter, which is reproduced in full below, has been copied to the EA's Chairman, Lord Chris Smith, the Fisheries Minister Richard Benyon MP and Energy Minister Greg Barker MP.
The EA has a statutory duty to maintain, improve and develop fisheries and to meet the demanding standards of the Water Framework Directive - standards which are being failed for many rivers because of poor fish populations. Hundreds of applications for low-head hydropower have been submitted in the past year and the EA is actively promoting the opportunity for thousands more. Anglers' representatives and fisheries charities are extremely concerned that these developments will damage fish populations, many of which are already in peril from diffuse pollution and over-abstraction. Hydropower turbines have been demonstrated to injure and kill fish passing through them and the developments often cause long stretches of river to suffer from reduced flows. The weirs needed for hydropower schemes can block fish migration; this is a problem for many species, but is particularly serious for those that migrate to and from the sea, such as salmon, sea trout and eels. Some single river systems have hundreds of potential schemes being mooted, and the NGOs are calling on the EA to consider their cumulative impact.
Mark Lloyd, Chief Executive of the Angling Trust said: " We have spent months and months providing information and detailed advice to the Environment Agency about this issue and we cannot identify any evidence that our input has been treated seriously. We are certainly not opposed to hydropower in principle, but healthy rivers are vital to biodiversity and anglers collectively own and lease several billion pounds worth of fishing rights on them. These invaluable assets need to be protected and we are demanding in the strongest possible terms that the concerns of anglers and fisheries charities are taken seriously. There are a small number of opportunities nationally where hydropower turbines could be installed sustainably, and they would have local benefits especially if accompanied by steps to improve fish migration, but in general they cause far more harm to the aquatic environment than they benefit the atmosphere."
Mark Lloyd, email@example.com, 01568 620447 or 07973 468198. A copy of the letter to Paul Leinster is available below.
Paul Leinster CBE
Friday, 10 December 2010
CC: Lord Smith of Finsbury, Richard Benyon MP, Greg Barker MP, John Aldrick, Mat Crocker
We are writing jointly to you to express our continuing concern at the Agency's approach to hydropower. We are not opposed to hydropower in principle - indeed we see opportunities for joint hydropower and fisheries improvement schemes on existing structures to overcome current fisheries problems - so-called win/wins.
We have expressed our concern both in writing and at meetings with your senior staff on many occasions, with little effect. It may help if we summarise our key concerns as follows:
Consultation over the development of Agency policy and practice as set out in the Good Practice Guidelines has favoured the hydropower industry to the disadvantage of fisheries, ecology, angling and riparian interests. This stems from the original decision to involve formally the British Hydropower Association in the development of the Guidelines but to exclude existing long-standing stakeholders in the health of our rivers and the social and economic benefits that flow from that health.
In March 2009, following the first public presentation of the draft Guidelines at a South West Rivers Association seminar in January, we were promised full involvement in the development of the Guidelines. However it soon became apparent that several further iterations had been produced in consultation with the BHA without our involvement. We understand that the Agency's internal fisheries specialists were also not fully involved.
We have been promised sight of the updated evidence base behind the guidelines, but this has not been provided. We have been told that Government guidance has been followed but our requests to see it have been denied.
Similarly consultation on the Permitting Process has been unacceptable.
This lack of proper consultation and involvement has continued to the present, with our carefully considered and presented input being largely ignored at every step. We have a complete history to support this assertion but trust that you will believe us without wasting your time seeing it. If you do wish to see it please let us know.
Good Practice Guidelines
We received the latest draft of the Good Practice Guidelines only two days before a planned meeting to review them. That meeting was postponed due to poor weather which has given us time to review the latest draft. It is still unacceptable to the extent that there is little point in us attending the rescheduled meeting next week with the same team that has consistently failed to take proper account of our concerns or provide the promised evidence that underpins the Guidelines.
Sub-optimal fish populations are the second biggest cause of failure of waterbodies to achieve Good Ecological Status as required by the Water Framework Directive. This should be a major strategic driver of Agency policy towards protecting the aquatic environment and the fisheries it supports. Unfortunately this is not the case in the Agency's approach to hydropower. In many cases the very limited potential benefits which might accrue from hydropower are far outweighed by the potential long term damage to the aquatic environment and fisheries affected.
Greater acceptance of our considered input to the Guidelines would help the Agency fulfil its statutory duties, including achievement of the WFD default position of no deterioration in ecological status and the genuine inclusion of a wider community involvement also explicit in the requirements for WFD delivery. Just one example will suffice to demonstrate this assertion. The current trend towards hydropower development, encouraged by the Agency's activities, is resulting in many proposals on single rivers. The cumulative effects of such multiple proposals are largely ignored in the Guidelines but have great potential for cumulative adverse effects. The current piecemeal approach is completely at odds with the Agency's professed catchment based approach to managing the aquatic environment.
We appreciate the need for efficient and cost-effective permitting processes for all stakeholders, including the Agency which derives no income from hydropower licences. However meeting this need must not be at the expense of effective regulation nor to the jeopardy of the aquatic environment, fisheries or the property rights of riparian and fishery owners - property rights which support angling estimated by the Agency to support socially valuable activity generating £3 billion of economic activity a year.
Recent experience of permitting in practice is especially alarming - again one example will suffice. The Agency has licensed two proposals on the Trent at Sawley and Gunthorpe which incorporate a de facto permitted level of fish kill, including of eels which are of special concern not just locally but internationally.
We see no point in continuing to meet or liaise with the team that has led on the development of Agency policy and practice on hydropower unless they are prepared to take a more responsible approach to the needs of the aquatic environment and fisheries. Our experience of dealing with that team over the past two years indicates that a change of approach will only come about with clear direction from above - hence this letter.
We would respectfully request that you personally meet with us so that we can agree a constructive approach to our continued involvement in the development of Agency policy and practice on hydropower. If you agree to this request we will provide the detailed evidence behind this letter. In the meantime we are withdrawing from the meeting planned for 16 December.
Given their direct interest in this matter we are copying this letter to the relevant Ministers, your Chairman, and relevant senior staff. We also intend to make it public.
For convenience may we suggest that you respond direct to me as a single point of contact - I will ensure rapid dissemination to the other signatories.
Mark Lloyd, Chief Executive, Angling Trust
also on behalf of:
Arlin Rickard, Executive Director, Association of Rivers Trusts;
Ivor Llewelyn, Director (England and Wales), Atlantic Salmon Trust;
Paul Knight, Chief Executive, Salmon and Trout Association;
Huw Evans, Chairman, Afonydd Cymru
Shaun Leonard, Director, Wild Trout Trust