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).
The Balkans Peninsula is home to the last truly wild river systems in Europe. In a land largely untouched by modern industry lies a little-known paradise. Within forested mountains still inhabited by lynx, wolves and bear, live small communities whose lives are inextricably linked to the rivers they live alongside.
Following the publication of the worrying Future Landscape Wales (FLW) document earlier this year much has change at the Welsh Assembly.
Your letters and emails to AMs along with direct correspondence from both traditional conservation organisations and activist groups like Save Our Rivers forced the Welsh Assembly to allow public consultation on the report. This consultation resulted in thousands of emails and letters from members of the public all concerned with the same thing: The removal of the “Sandford Principle” as an environmental safeguard in National Park management and the complete lack of concern for “conservation” in it’s proposals. The list of objecting organisations included :
International Union for Conservation of Nature UK Assessment Panel, Royal Town Planning Institute, RSPB Cymru, Wildlife Trusts Wales, British Mountaineering Council, Ramblers Cymru, Youth Hostelling Association, UK Environmental Law Association, Wales Environment Link, Alliance for Welsh Designated Landscapes, Cymdeithas Eryri the Snowdonia Society, Friends of Pembrokeshire Coast National Park, Brecon Beacons Park Society, Gower Society, Cambrian Mountains Society, Open Spaces Society, Campaign for National Parks, CPRW Brecon and Radnorshire, CPRW Anglesey.
Since then there has been a major shake up in the Welsh Labour Government: Carl Sargeant who set up the FLW group is has gone for reasons which have been extensively covered in the media and Lesley Griffiths AM , who had described objections to the FLW report as “mischief making” is no longer the Environment Minister having moved to rural affairs. Dafydd Ellis-Thomas is also no longer involved, having been elected by his constituents to represent them as a Plaid Cymru AM he has jumped ship to Labour in return for a ministerial position (culture, tourism and sport) resigning as chair of the FLW group in the process.
The new Minister for Environment is Hannah Blythyn, a new AM elected in 2016. In one of her first acts in this role she released the following statement:
Following his appointment as Minister for Culture, Tourism and Sport, Lord Dafydd Elis-Thomas AM will not continue in his role with the Future Landscapes Wales group. I am, therefore, taking this opportunity to pause and reflect on the activities and future of the group.
Since October 2015 when the Future Landscapes Wales Working Group was established, Lord Dafydd Elis-Thomas AM has led representatives of the national parks, AONBs, interest groups and business in their exploration of the Marsden Review recommendations and the case for reform. He made a significant contribution to ensuring the many different partners involved were able to contribute their views, engage in frank debate, and ultimately publish “Future Landscapes: Delivering for Wales” earlier this year. The Welsh Government sought views on key proposals from this work, relating to the role and governance of the designated landscapes, as part of the consultation on Taking Forward Wales’ Sustainable Management of Natural Resources.
I anticipate making a full statement on the way forward with designated landscapes early in the New Year, by which time I will have reviewed all the responses to this consultation. My response will also consider whether a formal group, such as the one which existed for Future Landscapes Wales, is needed to develop and strengthen the partnerships and collaborative working necessary to deliver the landscapes, rich ecosystems and vibrant rural communities I want for the Areas of Outstanding Natural Beauty and National Parks.
At Save Our Rivers we are relieved and grateful that the new minister will be taking time to fully consider the concerns of those involved in the consultation and that a vital breathing space has been granted to fully considered the impact Future Landscape Wales would have had on our most precious natural assets. We wish the new minister all the best in her role, which given the visits she has already been making to 3rd sector environmental organisations, she will evidently be bringing a much need new approach to.