Ahead of their meeting, the highland council, Save Glen Etive and Save Our Rivers have have presented a petition signed by 11,848 people. We are grateful to Sandra Halliday for taking the lead on this.
Last week all 7 hydro schemes in Glen Etive were approved for planning permission. There’s a final chance to stop these schemes, thanks to a motion tabled by Cllr Andrew Baxter.
Save Our Rivers would like to thank the Capel Curig Community for inviting them to speak alongside the developer in discussion of the proposed Llugwy HEP project.
Having listened to both the developer’s description of the scheme, along with the comments from members of the community Save Our Rivers has decided it will be officially objecting to the planning application.
A planning application has been submitted for the hydro electric development of Pont Cyfyng Falls on the Afon Llugwy in Capel Curig Snowdonia. This is likely to be the largest scale and possibly most damaging HEP applied for in Snowdonia since the plans to dam the Afon Conwy were rejected in 2016.
The application is deliberately vague and misleading in many aspects, but this is what we know so far:
The development is based in a National Park, will sit in an area of woodland registered as ASNW (Ancient Semi Natural Woodland) and lies shortly upstream of a SSSI. The site sits in the heart of Capel Curig village, a hotspot for outdoor tourism containing numerous pubs, cafes, hostels and the National Mountain Training Centre at Plas y Brenin. Capel Curig is popular for the beautiful free flowing Afon Llugwy and as the access to rugged peak of Moel Siabod.
The plan is to divert a large proportion of the river into a new channel, pass it through a 2m diameter 100m long tunnel dug by a 10-ton tunnel borer under the historic Telford road bridge. Then through a large diameter pipe to the turbine house to be built downstream on river right, between the second and third falls, where the outflow will fall into a newly excavated “plunge pool”.
Many of the impacts of the scheme are un-quantifiable due to the poor quality of information provided in the application. There is no assessment of traffic impacts, effects on the footpath along the river, the timescale of construction or the size and location of construction compounds. Here is what we can work out.
Impact on Ancient Woodland
The Arboricultural report lists 87 trees in the vicinity of the development, 31 are listed to be felled, over a third. Some of these trees are suffering from Ash die back, but many are not (because they aren’t Ash trees), in any case Ash die back would not have the impact of removing all the trees in a single event.
Amount of water to be removed
The HEP will remove 70% of the river above a tiny compensation flow, up to a maximum of 4.2m3/s (this will occur when the flow of the river reaches 6 m3/s). Using flow data from CEH (Centre for Ecology and Hydrology) we can therefore calculate that 70% of the flow will be diverted around the falls for over 75% of the year, and over 85% of the time during the summer months.
This will have 2 major impacts, firstly the dewatering of Pont Cyfyng will have a profound effect of the beauty of the falls, a major tourist draw; visible from the A5, a view point layby and the popular footpath up Moel Siabod. Secondly the ecological impact of this “depleted reach” on the bryophyte assemblages and other flora and fauna of this section is not to be underestimated. The ecological survey presented by the developer states:
One must bear in mind also that only a very small proportion of this large river will be abstracted so it is considered that any potential impact on the in stream ecology is likely to be extremely modest.
It can be seen from the calculations above this is simply not true. The abstraction is for the vast majority of the river to be abstracted for the vast majority of the time.
Impact of built structures on the landscape
The inlet structure to be situated on the river right bank above the falls will be huge. A 2m by 15m metal grill in full view of river users, walkers on the footpath along the river and travellers on the A5 and Telford bridge. The turbine house will be situated on the wild river bank between the second and third fall, visible from the A5 the Telford bridge and the viewpoint layby. Neither structure has a photomontage, artist impression or even detailed plan drawing to show how it will fit into the landscape.
The photo below shows the shear scale of this development compared to the site:
How much power will be produced?
The power produced is very limited compared to modern renewable production, this is one of the reasons the FIT payment subsidy this scheme will rely on to be profitable is being cancelled this year. The installed capacity of the scheme is around 400KW, roughly 1/10th of a single wind turbine of the type installed off Llandudno, or 1/20th of the new generation of one of the new wind turbines at Burbo Bank Liverpool. Whilst the application boasts that power produced will be:
the equivalent required to supply 21% of the homes and businesses per year with electricity in Betws y Coed and Capel Curig, or 71% of those in Capel Curig only.
It is important to look at this more closely, the population of Capel Curig is 226 permanent residents. However the 400kw produced during the 25% of the year the scheme reaches full power is only enough for 40 people to take a shower.
Save Our Rivers believes the scale of this scheme and the impact it will have on the Afon Llugwy and its surrounding Ancient Woodland. Along with the social and economic impact it will have on the tourism dependant community of Capel Curig is disproportional to the extremely limited impact it will have on combating climate change.
On a more basic level Save Our Rivers believes the free flowing rivers and falls of our National Park are worth far more in their natural state than when diverted and dammed to make kilowatts and pounds.
We urge everyone to attend the public meeting on Friday 8th Feb at 7.00pm Capel Curig Community Centre and raise their concerns with the developer there.
Details on how to respond to the planning application will provided when we have more information.
2018 has been another great year at Save Our Rivers, here are some of our highlights:
National Parks Saved
In 2017 we ran our huge National Parks Matter campaign against Welsh Government plans to remove the main environmental protection governing our National Parks. Following widespread opposition from across the conservation sector these plans were finally dropped in March of this year with an announcement from the new Environment Minister.
Save the Blue Heart
In the spring we supported Patagonia’s Save the Blue Heart campaign against over 2700 dams planned for the Balkan Peninsular. Touring with the Blue Heart film around the UK and Ireland giving talks and answering questions about this unfolding environmental tragedy. The campaign resulted in the hand over of a petition with 120,000 signatures to the European Bank for Reconstruction and Development. The largest petition ever received by the bank on an environmental matter.
The National Trust plans new dams in the Ogwen Valley.
Once again we found ourselves campaigning against the National Trust’s plans for new dams in the free flowing streams of the Ogwen Valley SAC (Special Area of Conservation), Snowdonia National Park. This time on the Afon Bodesi. This Autumn we learned that the National Trust have not only dropped the plans for the Afon Bodesi but for all their planned Ogwen Valley Hydros.
Hydro Schemes without Planning Permission
Welsh Government plans to allow small scale hydro to be built without planning permission saw us asking our followers to respond to an NRW consultation. The overwhelming number of responses in favour of keeping full planning requirements for all hydro schemes meant that these plans have been dropped for now.
The Autumn saw us headed out to support our friends at Balkan River Defence on the Balkan River Tour 3 , with street actions in Podgorica and river actions on the Tara it was an action packed and inspiring trip. Can you make it next year for Balkan River Tour 4 and do your bit to keep the pristine rivers of the Balkan Peninsular flowing free?
Free Rivers Fund
This year Free Rivers Fund has gone from strength to strength with more money granted to more projects from more countries than ever before. Save Our Rivers were stoked to be able to represent Free Rivers Fund this year at Tryweryn Fest, Kayak Fest Tara and on the paddlesports stage at Kendal Mountain Film Festival.
Keeping the Rivers of Snowdonia Flowing Free
A huge part of our work is to respond to the almost constant planning applications for new hydro schemes on the rivers and streams of Snowdonia. Some great news is that one of the most damaging proposals for a 600kw scheme on the Afon Cynfal has just be rejected by the planning department.
Save Our Rivers has been getting it’s teeth stuck into some cool side projects as well. Tom has become a key player in the new Trash Free Trails and Dan has joined forces with Surfers Against Sewage Anglesey to work towards the Plastic Free Anglesey community status.
It hasn’t just been campaigning work this year; Save Our Rivers has skied French glaciers, Canadian tree runs and Argentinian couloirs. We have multi-day hiked in the Alps, paddled the deepest canyons on Earth in Peru, kayaked down the pristine rivers of the Balkan Peninsular and spent every other spare minute biking, climbing, skiing and kayaking in the place we call home; Snowdonia National Park. Oh yeah and we somehow held down our day jobs and managed not to get divorced in the process.
If just 2 guys (and their friends) with a passion for outdoor sports and the wild places it takes them can do all this in 2018 , imagine what we could all do together in 2019.
Massive thanks to Patagonia , NRS and Radical Rider for helping us on our campaigns and our adventures. Plus a big shout out to our comrades in arms Snowdonia Society , The Rivers Trust and Balkans River Tour.
Once again we are teaming up with the Snowdonia Society for another evening of talks and films about the places we love and the people who protect them. Read More
At the start of the summer the Welsh Assembly Government (WAG), launched a consultation on proposals to allow Permitted Development Rights PDR for “small scale, low risk hydro schemes”. I.e allowing some hydro schemes to be built without the need for planning permission (including within National Parks and AONBs).
Save Our Rivers is opposed to the development of wild and free flowing streams and rivers for hydro power, especially those that sit within designated areas. We believe that the minute amounts of power produced by micro hydro does not compensate for the environmental damage that they cause.
With FIT payments for small scale hydro due to end in April 2019 we a seen a rush of applications for new hydro schemes with developers trying to beat the deadline for these lucrative subsidies.
One of the worst examples is in Glen Etive, Scotland. A stunning location and home to some amazing whitewater, the developer is planning 7 schemes. 1 on every tributary of the main Etive river. These schemes will produce tiny amounts of power in relation to modern renewable generation, with all the dams in place the power production will only be equivalent to large offshore turbine.
Save Our Rivers is objecting to the proposed schemes on the Allt a’ Chaorainn and Allt Mheuran. These are the 2 schemes we believe to be most damaging in terms of landscape and recreational impacts.
Please help save this iconic valley and add your objection on the planning website.
For the Allt a’ Chaorainn scheme click here to register and comment :
For the Allt Mheuran click here to register and comment :
Save Our Rivers objection is shown below, it is suitable for using for objecting to both schemes. Feel free to copy, paste and edit as you see fit, please make sure you add your own name and details.
I am writing to object to the proposed scheme
The building of 7 schemes of the same type, by the same developer all within a small geographical area and affecting the same main river valley would have large environmental, recreational and landscape impacts. To properly consider the accumulative impacts it would be more appropriate for the developer to file a single large application than 7 separate ones. I therefore do not feel the current application allows for proper evaluation of the probable impacts.
The proposed development cannot be considered a sustainable use of the landscape. The generation of renewables through small scale hydro schemes and their subsequent impact on the landscape and environment has become inappropriate in the current era of large scale renewable production. For comparison this scheme would only produce around 1/10th of a modern offshore windturbine.
FIT tariffs will end April 2019 due to the high cost to the consumer and lack of any real contribution to meeting overall renewable targets. The timing of this application is an attempt to obtain these lucrative payments before the deadline rather than any real effort to combat climate change.
The EIA does not adequately address the visual impact of the schemes. Although details of the structures to be built are included there is no photomontage representations of these structures in place making proper assessment impossible. There is also no consideration of the visual amenity provided by the tributaries as flowing streams and cascades. The proposed development will reduce flow rates, therefore reducing the visual quality of the cascades and their contribution to the landscape. Photo surveys of the affected stretches at different flow states would be required for an accurate assessment of landscape impacts.
The geomorphological impact of multiple schemes within the single catchment has not been adequately addressed in the application. Theses tributaries are active sources of gravel and sediment for the ecology of the main Etive river, the construction of river barriers will have a marked impact on sediment transfer and will therefore not meet WFD (Water Framework Directive) conditions on geomorphology grounds. WFD impacts of the intact structure will be the responsibility of the planning authority, it is worth remembering that WFD must be considered on an individual project basis and not just on a catchment wide assessment.
Court of Justice of the European Union judgement July 2015, case C-461/13. Paragraph 51 of the Weser judgement provides:
“Article 4(1)(a)(i) to (iii) of Directive 2000/60 must be interpreted as meaning that the Member States are required — unless a derogation is granted — to refuse authorisation for an individual project where it may cause a deterioration of the status of a body of surface water or where it jeopardises the attainment of good surface water status or of good ecological potential and good surface water chemical status by the date laid down by the directive.”
The schemes construction will consist of multiple new river crossings, including a pipe bridge, an access bridge and fords. These are both significant impacts on landscape but also due to the in river works required a significant impact to the environment.
The Allt a Chaoriann is considered a “classic” in the UK for the quality of its whitewater kayaking, a large draw to the area and a contributor to Scotland’s crucial outdoor tourism industry, calculated to be £2.6 billion in expenditure in 2012.
The highland council has also made commitments to “… maintain and improve our active infrastructure – people and places, including the natural environment..” for the benefit they hold in improving the health of the nation.
Hydrological assessment shows the building of the proposed scheme would have a negative effect on the possibility for kayaking on this river. The number of days the river would be available to kayakers would fall from around 180 per year to around 60 per year, a reduction of 2/3. There is also evidence it would make the kayaking of the river more dangerous by forcing kayakers to use the river when flow rates are changing more rapidly. A full assessment can be seen here:
There is an allusion that the developer has been in discussion with the SCA (Scottish Canoe Association) with regards to possible mitigation. I do not feel that planning can be considered until those discussions are resolved and any possible mitigation detailed in the application.
A hydrology assessment of the HEPs impact on kayaking the Allt a’ Chaorainn written by Calum Pedum, a Civil and Water Engineer, on behalf of the SCA (Scottish Canoe Association).