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What you can do now.

By | Campaigns, Save the Conwy, Uncategorised | No Comments

Following publication of the Planning Officer’s recommendation to approve the RWE scheme complaints were made  to the Snowdonia National Park (SNPA) over the content of the Planning Officer’s report. The Park has now agreed to receive new submissions by the 13th November.

What you can do now.

If you have already written an objection letter

Have a look through our comments on the Planning Officer’s report below. If you do not feel your objection has been adequately considered email the SNPA and tell them so, attach your original objection letter to the email .

You can use the letter template below , please remember to add your own concerns,

Second objection template

If you have not previously objected to the scheme

Now is your chance. Our information on making a planning objection is here:

https://savetheconwy.com/2015/05/05/individual-planning-objections/

You can use the template letter below to get started, write about the parts of the project that concern you the most. Is it the environmental impact or the loss of kayaking, are you a local business owner concerned about the impact on tourism ?

New objection template

These emails or letters all need to go to Aled Lloyd (Head of Development Management) aled.lloyd@eryri-npa.gov.uk

Please if you haven’t yet sign the petition launched by the Snowdonia Society here:

https://you.38degrees.org.uk/petitions/stop-the-damming-of-the-river-conwy

Conwy Falls in the winter by Peter Glyn Firth

Conwy Falls in the winter by Peter Glyn Firth

Planning Officers Recommendations

By | Campaigns, Save the Conwy, Uncategorised | No Comments

Comment on Planning Officer’s report:

After careful consideration Save the Conwy feels the Planning Officers report does not adequately investigate the planning application and presents its report with apparent bias. We feel it does not give the Planning Committee enough information to make a well informed decision.

The report can be found here:

http://www.snowdonia-active.com/docs/conwyfalls-snpa-planning.pdf

Our comments on the report are listed below:

In listing permanent features of the development 2 major factors are missed.

  1. A large 100m long impoundment of water upstream of the intake weir.
  2. A significant reduction of flow of water through the Fairy Glen.

Non-statutory/interest groups listed

Only 3 groups have been listed here, despite many other groups listed as being consulted further up the document.

No mention of:

Strong objection by Canoe Wales – governing body for paddle sport in Wales.

Strong objection by Snowdonia Active

Objection by North Wales Wildlife Trust

Objection by Betws y Coed Anglers Club / Gwydyr Fishery – owners of the fishing rights affected by this scheme.

The objection of a campaign group, Save the Conwy, with over 2500 followers who have been engaged with the developer and affected groups from the outset .

The language surrounding the public comments shows bias.

Over 650 individual letters expressing concern.

Should this not be objecting , my personal letter and that of Save the Conwy strongly objected within the frame work of the planning policy of the national park, it did not merely express concern. To say the objectors fall into certain groups; anglers, kayakers and local businesses is also untrue and aims to portray them as self-interested. Personally my objection and that of Save the Conwy was broad based. This also totally ignored the 351 objection that came through the Woodland trust’s supporters that are presumably concentrated on environmental factors.

The statement

32 letter of support for the scheme have been received who have generally highlighted the benefits of hydro eclectic schemes of this nature, being clean, renewable energy source with long term benefits.

Shows the Planning Officer already holds the opinion that this scheme will provide long-term benefits, this is meant to be what he is impartially assessing.

The benefits of the scheme shown as

The benefits of an HEP scheme of this nature (5MW) are quoted as an average generation of electricity up to 15,000 Megawatt Hours, annual average carbon dioxide offsetting of up to 6,450 tonnes and up to an equivalent of 3177 domestic homes supplied by the electricity generated.

This shows average power production over the year and then claims the equivalent of 3177 homes supplied forgetting that the figure is an average and for 35% of the year no power is produced. The main problem with these schemes is the irregularity of supply and this is not considered here at all.

Enforcement

It is considered that the environmental and visual effects can be adequately managed and mitigated against through rigorous conditions during the construction phase and post construction. A position that is backed up by the responses from statutory consultees who have not raised objections to the proposed scheme. It is considered that sufficient powers are in position between the various agencies including the National Park Authority to ensure no long term harm to matters of importance.

Is this true? The form of / method for enforcing these conditions should be spelled out before permission is granted. Does recent experience with projects such as this back up this claim?

Other areas of concern:

Visual impact of the weir: your officers have expressed concern over the visual impact of the weir construction in the long term

Why only concerned by the visual impact of the weir. Save the Conwy submitted an experts report to planning concerned with the safety of the weir design shown in the plans. This was with regards to both its design and position.

Visual impact on Rhaeadr y Graig lwyd (Conwy falls) the extraction regime will ensure that the falls will remain a visually impressive feature. The exact nature of the extraction regime is yet to be considered, this will be done as a part of the extraction licence application with NRW. If not considered appropriate the licence will be denied.

Conwy falls will no doubt remain impressive, but obviously less impressive. The concern for ensuring this is then passed to NRW to consider after planning permission has been granted; surely this must also be the SNPA’s concern.

Only a very small part of the development site falls within an area that has been included in the inventory of ancient woodlands………..

…… However, the application does show extensive compensatory native broadleaf planting extending to approximately 2.5 acres.

New planting is not considered compensatory for loss of any (however small) amount of ancient woodland. New trees are by their very nature not ancient and nor will they become so with in the life span of the proposed hydroscheme.

A detailed assessment of the effects of vehicular movements in association with this proposal has been undertaken.

But no traffic management plan has been submitted. In fact the Welsh Highways Agency response to the application although not objecting in principle lists an enormous amount of information missing from the application that must be in place before development begins. This surely should be in place before planning permission is granted.

Based on survey work and vehicle counts it is predicted that this proposed development will result in an increase in overall traffic movements in the order of 2.6% for the A470, 0.59% for the A5 and 2.59% for the B4406. There will inevitably be peaks and troughs in vehicular movements depending on on-site development phase activities

The traffic aspect of the EIA has obviously not been studied in any detail or is being deliberately presented in the best possible light. Suggesting there will be peaks and troughs is correct. Up to a peak increase of 144% on the A470 (data taken from EIA Vol 1 Table 11-11).

Also an increase in overall traffic flow is very different from an increase in HGV traffic. Taking data from the B4406 as an example, based on August traffic flows there would be a 35% increase in HGVs. Based on October traffic flows this would rise to a 42% increase in HGVs (data taken from EIA Vol 2 Pt 2 – Tables 5.10 & 7.1).

The officer has also not picked up on the fact that 3 out of the 9 traffic surveys were carried out on an August bank holiday to give a higher baseline figure for traffic increase to be measured against.

There is also no consideration of traffic stoppages that will be required .

‘The Welsh Government has indicated that should the tunnel be constructed using ‘drill and blast’ methods there may need to be temporary road closures of up to 20 minutes to safe guard road users.’ (EIA Vol 2 Pt 2 – 8.10.2)

  

Recreational concerns:

The concerns of the angling fraternity and the use of the river by kayakers in terms of the water level in the depleted reach of Afon Conwy will be a matter that is raised at an appropriate time when the extraction regime is considered by NRW.

Concerns of the 2 biggest user groups of the affected area, who arguably will also be the 2 groups most affected have been passed over for consideration after planning permission has been granted. Recreational needs cannot be fully resolved by NRW during the abstraction licence process (abstraction licences do not normally consider recreational needs and there has been no evidence of this in similar scheme built in Scotland). Recreational needs must be the concern of the SNPA.

  • The opportunity for people to understand and enjoy the National Park actively, whilst maintaining areas of tranquillity and solitude, thus promoting aspects of health and wellbeing.

From the SNPA development plan.

A recent RWE hydroscheme on the Braan in Scotland was rejected by planners until the scheme was altered (outlet moved upstream) to meet the needs of recreational users.

It is considered that this proposal does not conflict with Eryri Local Development Plan policies

As I see it the proposal contradicts the plan multiple times mostly with regards to

3.19 Whilst large-scale energy power generation projects are incompatible with National Park status an assessment of renewable energy in Snowdonia considered that scope might exist to contribute to reduce demand for electricity derived from fossil fuels through efficiency savings and through small-scale renewable energy developments to meet domestic or community needs. These included small-scale hydro, domestic wind turbines, photovoltaics, biomass and landfill gas.

In its effects on both a fragile ecosystem and the local community the scale of this project is not small. The power produced is also not intended for “domestic or community needs “as Snowdonia is already a net power exporter and the power is to be sold to the grid by a multinational power company.

Conclusion:

On balance it is considered that the potential benefits in approving such an HEP scheme of this nature are not outweighed by the disbenefits of the scheme. The disbenefits are considered not to be long term and can adequately be mitigated against through conditions. In addition any short term disbenefits during the construction phase can also be managed to minimise disruption and harm to matters of environmental concern.

RWE’s own EIA submitted to the SNPA lists the benefits of the scheme as

‘minor contribution towards meeting the government’s regional and national targets for renewable energy.’ (EIA Vol 1 – 13.7.2).

And

‘The residual effects associated with the construction, operation and decommissioning phases of the Development have been identified as being overall negligible or of minor adverse significance with regards to socio-economic, land use and recreation effects. Whilst the Development will introduce a potential £12million project into the local area, and although the Applicant has historically demonstrated a commitment to procuring local services on projects through supply chain initiatives, there is uncertainty as to what proportion of the overall project costs would be spent in the local economy and therefore what level of benefits would arise.’ (EIA Vol 1 – 13.8.1)

With the obvious downsides of:

Loss of a very important recreational resource.

Risk of damage to unique and irreplaceable habitat.

Major disruption to local community and businesses.

I fail to see how this conclusion has been reached.

The Planning Officers report appears to have not fully investigated all aspects of the application (particularly that involved with construction traffic). Left a large number of concerns to be dealt with after planning permission has been granted (such as effect on kayaking and fisheries). Not fully considered expert opinion sent in objection letters (such as the Woodland Trust’s and Snowdonia Society’s concern over environmental damage and Save the Conwy expert’s information with regards to the danger posed by a new weir).

The Planning Officers report shows either a lack of thoroughness and use of a critical eye when assessing the application or a bias in favour of schemes of this nature.

NOTE: text in red is taken from the planning officer’s report, text in blue from the Snowdonia National Park Development Plan. 

Woodland Trust / Coed Cadw

By | Campaigns, Save the Conwy, Uncategorised | No Comments

The Woodland Trust have sent a strongly worded objection to the proposed hydro scheme, as the Uk’s leading woodland conservation charity their objection is both well informed and carries enormous weight. Save the Conwy is very greatfull for both the objection letter and the media exposure

ITV http://www.itv.com/news/wales/update/2015-06-25/proposed-hydro-electric-scheme-proving-controversial/

and

BBC http://www.bbc.co.uk/news/uk-wales-north-west-wales-33188535/

Some excerpts from the Woodland Trust’s objection:

The Trust finds this to be very concerning and highlights the lack of consideration given to ancient woodland by the applicant, despite stating the woodland will be subject to negative impacts. Throughout the planning application’s available documentation the applicant has largely failed to fully consider the irreversible damage and loss to ancient woodland that would occur as a result of this development.

The Trust is in favour of green, renewable energy and in principle isn’t against hydroelectric power schemes. However, we believe that any green energy project that results in the destruction of such a precious and irreplaceable habitat as ancient woodland could never truly be considered as ‘green’.

The Woodland Trust strongly objects to the planning application. We believe this site to be of importance on both a county and national level. The direct loss and damage to ancient woodland and veteran trees in a SSSI designated area is highly inappropriate and entirely unacceptable. 

Support their campaign here :

http://www.woodlandtrust.org.uk/get-involved/campaign-with-us/our-campaigns/hydro-electric-energy-in-wales/robert steele

Where we are now.

By | Campaigns, Save the Conwy, Uncategorised | No Comments

Just an update on where we are up to. The Community Councils have all met to discuss the planning application and a member of Save the Conwy along with concerned residents have given their views at them. Thanks to all that attended and emailed their views.

We still need you to email or post your personal objects to the planning application. This is the most important thing you can do, and please spread the word to anyone who you think may be concerned. Perhaps you want to object on behalf of your buisness, canoe club, fishing club, photography group?

Please use this template letterhead and write your personal response underneath.

https://savetheconwy.files.wordpress.com/2015/05/planning-objection-template.pdf

The Snowdonia National Park have indicated they will accept objections sent next week but no later.

IMG_7972

A view of RWE work at Dolgarrog 2013.

Community Council Meetings

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Save the Conwy was pleased to attend the Betws y Coed community council meeting last night. Concerned local residents and business owners were also present. It was a great place to meet people directly affected by the proposal and the council was attentive and sympathetic to the community’s concerns.

Penmachno and Dolwyddelan council are meeting Thursday 14th May. If you are a resident of these communities please email them your views and attend the meeting if possible.

If you are from Penmachno the meeting is at 7:30pm Salem Chapel Vestry email:
elfed.williams@yahoo.co.uk

If you are from Dolwyddelan the meeting is at 7pm in the community centre email:
info@dolwyddelancc.org.uk

IMG_7953

Contact your Community Council

By | Campaigns, Save the Conwy, Uncategorised | No Comments

The planning proposal will be discussed by both Betws y Coed and Penmachno community councils this week. If you live in either of these areas it would be well worth emailing them to let them know your view.

If you are from Betws y Coed email:
info@betws-y-coed-communitycouncil.org (and please copy in Sian Godbert Councillor tsgodbert@aol.com)

If you are from Penmachno email:
elfed.williams@yahoo.co.uk

Betws y Coed council are meeting on Monday evening so get those emails off soon.

Individual Planning Objections

By | Campaigns, Save the Conwy, Uncategorised | 3 Comments

IMG_7966

Now is the time to get your planning objection in.

The planning authority dealing with the hydro scheme is the Snowdonia National Park . Speaking to the planning officer Mr Richard Thomas he suggested the most effective form of objection would come from individual planning objections from all those concerned via either letter, fax or email.

Please include your name and address.

Perhaps if you are a member of a fishing club, canoe club, walking club , photography society or other group you could send one objection which all members could sign and add their signatures to.

A template letter head including the address and planning ref and description is provided.

planning objection template

What to include:

Have a look at the planning application and the Environmental Impact Assessment EIA. They can be found here:

http://planning.snowdonia-npa.gov.uk/swiftlg_snpa/apas/run/WPHAPPDETAIL.DisplayUrl?theApnID=NP4%2F26%2F323&backURL=%3Ca%20href%3Dwphappcriteria.display%3FpaSearchKey%3D113526%3ESearch%20Criteria%202%3C%2Fa%3E%20%3E%20%3Ca%20href%3D%27wphappsearchres.displayResultsURL%3FResultID%3D162056%26StartIndex%3D1%26SortOrder%3DAPNID%26DispResultsAs%3DWPHAPPSEARCHRES%26BackURL%3D%3Ca%20href%3Dwphappcriteria.display%3FpaSearchKey%3D113526%3ESearch%20Criteria%202%3C%2Fa%3E%27%3ESearch%20Results%3C%2Fa%3E

Remember the EIA is not an independent document. It is written to justify the scheme by a company who may bid to be main contractor.

Think about what is important to you, the community, the environment and the national park. Some topics you might want to cover

The National Park is the wrong place for a scheme of this size:

The Snowdonia National Park set out criteria for new developments in their development plan

See http://www.eryri-npa.gov.uk/__data/assets/pdf_file/0004/184684/ELDP-Final-6.1.12.pdf

The section on energy states

3.19 Whilst large-scale energy power generation projects are incompatible with National Park status an assessment of renewable energy in Snowdonia considered that scope might exist to contribute to reduce demand for electricity derived from fossil fuels through efficiency savings and through small-scale renewable energy developments to meet domestic or community needs. These included small-scale hydro, domestic wind turbines, photovoltaics, biomass and landfill gas.

Although the power produced by the scheme is low, set at 5MW to avoid immediate dismissal by the national park and to allow it to take advantage of very generous FIT payments meant for households and farms. The damage and infrastructure is the same as that for a much bigger scheme. A £13 million pound project by a foreign owned power giant is not a “small-scale renewable energy developments to meet domestic or community needs”. Snowdonia’s power needs are already met by the existing 82MW of installed hydro making Snowdonia a net exporter of renewable power.  For the same document:

The 20 or so hydro power stations which are located in, or use water from, Snowdonia have a combined total installed capacity of some 82 Megawatts (MW). This is far in excess of local demand and results in the area being a net exporter of electricity.

All power produced is therefore to full fill needs outside of the park, not for “domestic or community needs”.

-Damage to the environment:

This will occur both during operation and construction.

See this link for a description of the special nature of the area to be affected, it includes a SSSI and ancient woodland, it sits within a National Park and an Area of Outstanding Natural Beauty.

http://www.ccgc.gov.uk/landscape–wildlife/protecting-our-landscape/special-landscapes–sites/protected-landscapes-and-sites/sssis/sssi-sites/fairy-glen-woods.aspx

-Loss of recreation:

Details regarding the damage to kayaking can be seen here

http://savetheconwy.com/2013/12/07/how-will-the-scheme-affect-kayaking/

The river is one of the major Salmon spawning rivers in Wales / the UK to risk damage to such an environment through reduced reach and the insertion of manmade barriers is absurd. Fishing is a major recreational pass time and creator of income for the local area , rivers on which it depends either directly or indirectly need protection.

-Damage caused to local communities during construction:

This will be the one of the largest private construction projects ever to have been built within the National Park.The scale of disturbance and damage to local communities during the construction period will be immense. Construction is proposed to last 18 to 24 months but looking at RWEs record on the Dolgarrog refurbishment it is certain to be longer. Our Planning Engineer estimates that digging the tunnel section alone will require the removal of over 6300 m3 of rock, equivalent to 1400 18 wheeler lorry journeys on one of the narrowest sections of the A5. This section of the A5 is used by visitors from England to visit Snowdonia and the upper works will occur at the access junction to the community of Penmachno. With large depot areas at the top and the bottom of the Fairy Glen the area will become a construction site.  How many local businesses reliant on tourism can survive 2 years of disruption?

-Limited Benefit:

There are few perceived upsides to this scheme. The level of power produced is small and variable. Using RWEs own figures the peak production of 5MW is equivalent to less than 2 modern large wind turbines and the scheme will only produce this for a maximum of 54 days a year. Due to the schemes reliance of river levels for an estimated 128 days it will produce nothing at all. It is difficult to justify the environmental cost of this scheme even in relation to fossil fuel power stations. See http://savetheconwy.com/2015/03/28/better-than-a-power-station/

After the construction is finished (around 2 years) no employment is likely to be created by the scheme for the rest of its existence (the RWE scheme in Dolgarrog has run for around 90 years) and it will be run remotely from an existing RWE control center.

RWE plan around 100m of new path to enhance the area and a short section of existing path will upgraded to provide disabled access. However an existing footpath will be used as a construction road during the building of the scheme and the area around the construction site will be closed to walkers during the construction period.

 

Finally get something sent, by the beginning of next week if possible, it doesn’t matter how long or how short. I was told by the planning officer that if no one objects they think no one in concerned. Let them know your views

 

Feedback from Canoe Wales

By | Campaigns, Save the Conwy, Uncategorised | 4 Comments

Save the Conwy has had some feed back from Canoe Wales. They have set up a dedicated email account for your responses : hydro@canoewales.com . Don’t worry if you have sent to the old address they will continue to get forwarded.

RWE assert that the preservation of the Fairy Glen is only of interest to a handful of “expert kayakers” . So tell Canoe Wales a bit about yourself. Are you an expert or just a normal guy/girl searching for a bit of adventure. Are you local or does the Conwy provide a draw for you to travel to North Wales. Do you paddle on the Conwy regularly , occasionally , or never but still believe this classic is worthy of protection.

Remember time is ticking, the window for object is short , please try to get your emails of by the beginning of next week.

 

Respond to Canoe Wales

By | Campaigns, Save the Conwy, Uncategorised | No Comments

RWE have finally submitted planning to the National Park for the Conwy hydro scheme. Canoe Wales are planning their response and want to hear from as many kayakers as possible to include their views. Please email info@ukrafting.co.uk and mark the subject Hydro response. Here is Save the Conwys :

Dear Nigel

Thanks for asking for responses from kayakers to better inform your judgment on the proposed hydro scheme on the river Conwy. Save the Conwy have many concerns regarding the scheme but for the purpose of this email I will stick to those regarding Kayaking.

Two sections of river will be effected the Middle Conwy from Rhydlanfair bridge to Penmachno bridge and the Fairy Glen from below Conwy Falls to Beaver Pool.

Effects on the Middle Conwy

This section of river is generally grade 3/4 with 2 harder 4/5 rapids. It flows through stunning woodland parts of which are protected as a SSSI and parts classed as ancient woodland. It was rated 4 stars in the original guidebook and is one of classics of Snowdonia’s whitewater.
The effect on this section would be limited to a section near the egress. Here a 1m high weir will be built across the width of the river along with an access track for construction and maintenance vehicles.

The concerns regarding this are twofold

– The safety context of building a new weir on a river so widely used, especially by kayakers who are often improvers and still developing their skills. Weirs are renowned as one of the most dangerous river features and are responsible for a number of fatalities each year.

– The ruining of the tranquil , natural view at this point with kayakers and canoeists last memory of this stretch of river being that of a built environment. RWE are obviously aware of this , from the planning document:

6.4.73
Canoeists: There will be significant visual effects on canoeists where they exit the River at the new intake site during construction when access will also be limited. In the longer term, the new wire and its associated structures will introduce a new large manmade feature into the river valley with the potential to significantly affect visual amenity. However due to the limited number of people who will be affected by the change, and that some improvements are expected in the recreational pursuit due to the new access arrangements, the effect on visual amenity is not considered to be significant.

We personally do not feel that because the number of people accessing a site is limited that beauty is diminished or of less significance. The improvements suggested in the recreational activity are both limited and false as shall be discussed later.

Effects on the Fairy Glen

This section of river is generally considered grade 4/5 at the levels which will be affected by the scheme. This river is considered the classic test piece section of whitewater not only in Snowdonia but across the whole of the UK. Due to the large catchment it flows more often than any other river of this grade in Wales and is a leading draw for kayakers travelling to the area. This section was rated 5 stars in the original guidebook not just for the quality of the whitewater but for the stunning unspoilt gorge through which it flows.
The main concern for this section of river is a reduction in days the river is runnable due to the planned abstraction. RWE’s original plan was to remove up to 5.8 m3s-1 from this stretch this would reduce the number of days the river could be run from an average of 121 (33% of the time ) to 69 days (19% of the time) a reduction in 51 days or 42%. It is important to note that these lost days are at the lower rates of flow when there are often no other rivers of a similar grade available. Please see the calculations for these figures here.

https://savetheconwy.files.wordpress.com/2014/02/final-appendix_a_impact_of_afon_conwy_on_kayaking.pdf

Please note that the just released planning document quotes a figure 6.2 m3s-1 which will have a greater effect.

RWE attempt to justify this by claiming the river is paddled by a handful of expert kayakers only.

13.5.10
For those kayakers using the stretch of river below the Conwy Falls and along the Fairy Glen (approximately 1.5kms), the proposed Development has the potential to impact upon the recreational activities of such users through a reduction in water flows along the depleted reach of the river. This user group is very small comparable to the wider canoeing/kayaking community using the Afon Conwy, primarily due to the treacherous nature of accessing this stretch of the river and the very challenging nature of kayaking the gorge. It is understood from consultations that few users at periods of high flows have the capability to kayak this stretch of the river. Whilst limited to a handful of individuals, this stretch does provide some the most challenging conditions for kayaking in the UK, and is of appeal to both national and international specialists of such high grade white water conditions. Such a user group, although very small, would be highly sensitive to potential changes in water levels on the Afon Conwy as a result of operation of the Conwy Falls hydro-electric scheme.

This is no longer the case; improvements in technique and equipment have brought to the Fairy Glen a new generation of improving kayakers eager to hone their skills. This section of river is seeing more descents by a greater variety of paddlers than ever before. For those kayakers not yet able to paddle this grade of whitewater the Fairy Glen is seen as an aspirational run steeped in kayaking history and often the focus of ones goals.
Save the Conwy asked paddlers to log their descents using the Paddlebubble website. In 2014 January and February alone showed a recorded 409 descents and the total number would probably be higher.

Mitigation offered by RWE

The planning document offers mitigation to the adverse effects on kayaking the scheme will have. These are both redundant and unsatisfactory.

Reduced 13.6.6
Generation Days: the Applicant would support the agreement of reduced generation days for water abstraction for the periods 8 hours per day at weekends June to October in order to allow kayakers the opportunity to use the Afon Conwy below the Conwy Falls at high flows. In addition an egress point would be facilitated at the intake point to allow kayakers to exit the river. The Applicant will also make available on-line the river level data for the scheme that will help inform local kayakers.

-The reduced generation days are only planned for 8 hrs on a Saturday and Sunday during the Summer months. The main season for kayaking on the Conwy is through the winter. Contary to RWE’s statement below during the summer this section of river has it’s lowest amenity value. The number of summer weekend days in which there is sufficient water to run the Fairy Glen is negligible. The flow rate suggested for this reduced generation period also seems insufficient being propose at 6.5 m3s-1

5.5.45
This is based on a hands-off flow of between Q95 or 0.46m3/s during low sensitivity 5.5.45times and 6.5m3/s or Q28 when the river has greatest amenity value, based on kayaking during most daylight hours in summer weekends.

This requires the flow from the Machno being 4.78 m3s-1 to meet the 11.28 m3s-1 required for an enjoyable paddle on the Fairy Glen
(see https://savetheconwy.files.wordpress.com/2014/02/final-appendix_a_impact_of_afon_conwy_on_kayaking.pdf for calculation of required level.)
No flow data is available for the Machno from NRW and RWE provide none of their own. Local knowledge clearly shows the Machno does not reach these flow rates during the medium/low flows affected by the abstraction. RWE have been made aware of our doubts regarding their assumed flows of the Machno on several occasions.

-RWE also offer to provide an on-line gauge for river flows in the Fairy Glen to assist kayakers. An on-line gauge is already available at the Conwy Falls fish pass so this offer is completely redundant.
http://www.gaugemap.co.uk/#!Map/Summary/7932/3265

-The offer of an egress point for the Middle Conwy is deemed unnecessary by Save the Conwy and the despoiling of the natural surroundings at the egress and the danger of an introduced weir far out-weigh any advantage offered.

Save the Conwy hopes that Canoe Wales will send a strong objection to the Snowdonia National Park Authority, as can be seen the scheme will cause a massive loss to kayaking in Wales and offer no tangible benefit. The power produced by the scheme is very low and variable compared with other renewable schemes (such as the off shore wind arrays on the North Coast) and Snowdonia is already a net power exported thanks to its’ already extensive power production.

Many thanks

Save the Conwy.