Year of Adventure 2016

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Snowdonia is an amazing place; the opportunities for adventure are endless and quite rightly the Welsh Government are using this to advertise Wales as an Adventure Tourism destination. £4 million pounds have been spent on making TV commercials with the strapline “FindYourEpic”

Ken Skates , Minister for Culture, Sport and Tourism said:

2016 is to position Wales as a leading destination for outdoor adventure and use our iconic destinations to inspire people to explore what our country has to offer.”

What the Welsh Government does not seem to realise is that the opportunities for adventure must be protected. These TV adverts are in contrast to the stark reality of slashing National Park budgets, the appointing of power company executives to the Future Landscapes Committee and the damming and dewatering of nationally important rivers for both kayaking and fishing. Ken Skates has so far ignored our requests to discuss this with him and simply handed our questions over to Carl Sargeant (Minister for Natural Resources) without comment.

The Year of Adventure 2016 wants us to share our adventures online with the #FindYourEpic.

Let’s show how important our wild adventures are for Wales, that the heart of an adventure is not only paying to go on a massive trampoline or surf in a big pool (not that those things aren’t cool) but should also involve our unspoilt rivers, woods, mountains and coasts. Adventures can involve getting wet and tired and sometimes a little scared, they involve losing ourselves in nature and coming out renewed, they involve the wild.

Please print out the banner below and take it on your next adventure, take a picture, share it on Twitter, Facebook and Instagram using #FindYourEpic and #SaveOurWildAdventures and tag it @Save the River Conwy @Wales

Post it here

and on


SaveOurWildAdventures – Poster Download

Whether you are fishing, climbing, kayaking, surfing, walking, taking part in an environmental project or just taking in the fantastic place that is Snowdonia we want to see it. To inspire you to get adventurous, the photo with the most likes will win a Save the Conwy prize bundle.

Here’s a few members of Save the Conwy getting out on some of their adventures, all in the last couple of weeks.

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Planning Decision Deferred

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Snowdonia National Park Authority have deferred the decision on the proposed scheme for the Conwy to ensure that they have all the information from all sources. Details are given in the agenda for the upcoming meeting on the 20th January, and can be found on page 20. They are also given below.


“Members will recall that at the 2 December 2015 Planning and Access Committee officers reported on the all members visit to the site of this application.

A decision on this matter was deferred from that meeting until such time as certain matters of concern had been resolved by the applicant through the submission of further details. In addition further comments were requested from Natural Resources Wales and Conwy Country Council planning Department and that an independent landscape consultant be contracted to comment on certain aspects of the application.

At the time of writing this report the applicant has forwarded an (incomplete) response, Natural Resources Wales responded by stating that they were still considering their reply, Conwy Council planning department responded by stating that they do not intend to comment as the application falls 3.5km outside their jurisdiction area.

An independent landscape consultant has been engaged who has now reviewed the application details and has reported back to the Authority at the end of last year. The consultan has highlighted certain issue that need addressing which will require the further attention of the applicant.

Given the above it is not, as yet, possible to provide members with a further comprehensive report on the outstanding matters on which a fully informed decision can be made. ”

The next meeting is in March.

Location – Plas Tan y Bwlch, Maentwrog

  • 2nd of December 2015 at 10.00 a.m.
  • 20th of January 2016 at 10.00 a.m.
  • 2nd of March 2016 at 10.00 a.m.
  • 13th of April 2016 at 10.00 a.m.
  • 18th of May 2016 at 10.00 a.m

Save the Conwy

Abstraction Licenses:The Shocking Truth… well what we could get our hands on

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If this blog entry looks a bit long, then there’s good reason for it. If you’ve not got time on your hands to take in the detail then I’ll open with this and you can steam-ahead to the punch-line without having to read the rest of the joke. For a joke is what it is!

…that’s potentially 14% of all hydro-schemes in the park in breach…

Of the 104 Hydro-power sites in Snowdonia for which Natural Resources Wales is responsible for licensing, from Jan – Aug 2015 it inspected 33. Of those 33, seven were found to be in breach of their abstraction license. Five of those seven were found to be breaching the terms of their licenses deliberately by altering the mechanics of the structures used to take the water.


Upscaling those figures, that’s potentially 14% of all hydro schemes in the park in breach. Playground stats aside, in fact the problem is far worse, as this doesn’t take into account the additional 49 non-hydro abstraction licenses in place, not all of which are operating (as some are historic rights), which account for another three actual breaches.

NRW would have us believe that abstraction licenses are granted taking careful account of the effect to the ecology downstream. Yet, by their own admission NRW have been unable to assess the impact of these breaches, due to insufficient studies beforehand. This raises serious questions in relation to the process of environmental impact mitigation during the license application process and what appears to be a total lack of follow-up studies once the projects are up and running. This coupled with non-committal* and evasive** answers when asked about companies that had previously breached from NRW

*  re. what steps they’re actually taking to resolve these breaches on a company by company basis.
** “which” companies mysteriously turning to “how many” companies in their answer.

Among some apparently private individuals, those responsible for these breaches are companies claiming environmental credentials until they’re blue in the face, from green energy developers to leisure providers.

If I’ve got your attention then please read on. If you’re wondering why on earth you should care whether water is taken out of a river, how much and how this is regulated then I’d suggest you watch this short film of a somewhat extreme example from across the pond. Focussing on the Colorado River, it shows what happens downstream when you start syphoning off too much water and giving into over industrialisation.

The whole film is worth watching, but if you just watch this four minute short then remember that this is the same river that cuts a wild and tumultuous route through the Grand Canyon!


The full picture – or at least what NRW would actually tell us.

Approximately 3 months ago I became aware of a document from NRW generated for a freedom of information request by the Snowdonia Society. It suggested some worryingATI-08294a Response (redacted) ATI-08294a Response (redacted) things about the state of hydro management within the Snowdonia National Park. They had asked some very specific questions, which resulted in the figures you, see in the short version above for power generating abstraction licenses in the National Park, which were then further expanded on in my own FOI request.

At this point in time Save the Conwy were drawing together evidence to present back to NRW regarding RWE’s abstraction license application for their proposed scheme on the Conwy and I was circulating on the peripheries gathering my own thoughts to present back.

The revelation that a significant proportion of the pre-existing hydro schemes within the National Park had failed inspections revealed a worrying trend that showed often deliberate flouting of the controls placed on these schemes by the regulating body, NRW. All this with potentially unknown ecological impacts.


My own thoughts turned to accountability. Who were these companies? What exactly were they each actually doing to flout the terms of their abstraction licenses? More importantly, what was being done about it by NRW? I placed my own FOI request to find out. What NRW revealed surprised, disturbed and disappointed. Ultimately, their response raised more questions for which I am yet to receive answers (their appeals process on an FOI request can take up to 40 days, in addition to the 20 for the initial request!) and offered only a few more answers than the original request.

Named: The companies and individuals breaching their abstraction licenses

Green Earth Hydro Ltd
Based in Powys and specialising in small-scale micro-hydro systems there isn’t huge amounts of information available about this company. They’ve breached but we don’t know what they’ve done, paperwork error or full on weir construction breach… it’s anyone’s guess!

DHG (Dulas Hydro Group) Hydro Ltd
Dulas… that sounds familiar… ah yes, the consultants working in partnership with RWE. Well, disappointingly for the opportunist anti-hydro campaigner, Dulas and DHG don’t appear to share any business governance (different directors etc…), but the link in the name seems a little too convenient. By their own admission the two companies work with one another. A match made in heaven, Dulas plan and consult on hydro, DHG “permit, construct, own and operate”. Here’s what DHG have to say about Dulas:

DHG describe themselves to “always have an eye on costs, performance, financial returns”. Perhaps their eyes have been a little too focussed on financial return. Could these bedfellows of Dulas be cheating the system and the environment for their own gain?

Conwy Adventure Leisure Ltd (the parent company of Surf Snowdonia)
A name I did not expect to see on NRW’s list. A quick look at their website reveals the are keen to push their environment credentials. I’m inclined to give Surf Snowdonia the benefit of the doubt here. Certainly their cleaning up of a heavily contaminated brownfield site (former aluminium works) to establish their state of the art leisure facility, that brings tourism and jobs to the area, gives them more than a few environmental and ethical brownie points in the bag. That said, the machinery used to create the waves has been beset with problems causing multiple unplanned refills of their huge surf lake. That water has to come from somewhere. Hopefully this project that has such potential for the community is not cheating the system intentionally and they’re guilty of only a paperwork error. I wish them good luck resolving their problems.

L Evans, JM Evans, RF Jones
Unfortunately, we’ve not been able to find out anything about these chaps… or whether they even are chaps.

HB Davenport
A Dolgellau builders firm. We haven’t got any further information at this time.

What have they actually done?

Well, thanks to NRW’s somewhat blinkered approach to answering FOI requests we know what these companies have done to fail their inspections, but we don’t know who. This is poignant, as some of these breaches are process driven and appear to be accidental. Others are downright deliberate abstraction of more water than the licenses allow for. [If you can cut your way through some of NRW’s technobabble then you’re doing well!]

“10 licenses were found to be non-compliant with either the abstraction or impoundment licence

or both (if applicable).

Identified non-compliances with abstraction licences:

– No blanking plate to secure seasonal variations in abstraction

– Over abstraction (maximum daily or maximum annual quantity)

– Blocked Hands off Flow / residual flow notches/orifice pipes

– Not submitting their abstraction returns / not submitting returns correctly

– HEP weir not built to specification

Particularly significant here also is that “10 licenses were found to be non-compliant”, yet only 5 companies are named as having breached. This means that at least one of the companies has multiple breaches across its portfolio (or multiple breaches on one site!)

Unfortunately, because NRW have seen fit not to match the crime with the criminal (figure of speech!) then we just don’t know who is bad at administration, construction & maintenance and who is deliberately flouting environmental safeguards. Faced with a wide range of breaches, it is hard not for your mind to jump to the worst conclusion. Assuming each of the issues causing the breaches mentioned above happened in isolation, it is possible that up to 6 licenses are being deliberately flouted! I hope the situation really isn’t this bad.

So what are NRW doing about this? Not a lot.

Well, you’ll be pleased to know that NRW have taken action to attempt to resolve these breaches. Well, they’re considering it… or are they? I’m not really sure anymore. They told me…


“Enforcement action is currently being considered for all non-compliances. Also we will be working with these licence holders until we are satisfied that they are in compliance. Previous offences are taken into account each year when deciding upon our inspection programme and sites will be revisited at more regular intervals where it is considered necessary.”


This isn’t quite what they told the Snowdonia Society. With reference to 5 of the 10 breaches identified in their FOI request they claimed “enforcement action was complete”. If it’s complete, then it’s not being considered for all is it?

The question is what have NRW actually done? It’s unclear whether they have actually done anything beyond potentially sending a leter, they were happy to point out that enforcement responses can include “prosecution, formal caution, fixed monetary penalty, warning letter and guidance depending on the individual case”.

To put this in an entirely different way, if a dishonest paperboy steals my bicycle  and I knew for a fact it was him I could call the police, I could form a renegade band of torch bearing vigilantes to hunt him down, I could send his Mum a strongly worded letter or offer him some friendly advice next time the local wrag popped through the letterbox. I know what I’d do – call the police & prosecute!

The thing is, in the context of the national park it seems to me that if I were NRW, I’d probably just claim on insurance and forget the whole thing ever happened. There’s only one problem, the little sh**e’s going to do it again.

Save the Conwy

What can we conclude? – Only more questions I’m afraid.

All in, there appear to be some pretty flagrant breaches of abstraction licenses. I can’t stress enough that some of these have been deliberate! It’s also possible that among the deliberate perpetrators are a company that have worked hand in hand with the developers of the Conwy Hydro scheme.

So to conclude, NRW have told us what the breaches were and who committed them and that some were deliberate. Despite being asked, what they have not told us is who committed which breach, what they (NRW) have actually done to enforce the licenses. They have also admitted their environmental impact studies are basically useless to the point of being non-existent.

As such, I am left with some questions that make me really uncomfortable about the management of hydro within Snowdonia. I can’t help but wonder…

Why on earth are NRW considering handing out more of these licenses when their management processes appear so inept?

Is the Snowdonia National Park really there for industrialisation and where are the credible checks on this?

Is NRW really up to the job?
It’s not looking good so far. They’re underfunded, seem to lack backbone and appear to have had their FOI responses drafted by one Sir H Appleby. If they could get out of saying it, they did.

I’ll leave you with this. When asked at a recent meeting, regarding known breaches of abstraction licenses, whether NRW had ever seen fit to take a license back the uncomfortable silence from the panel was none other than deafening.


This blog post was compiled from source material comprising of two Freedom of Information responses from NRW, company websites and web-check services on directors. This article is the opinion of the author. In the event of any factual errors please raise these with Save the Conwy and we will check and amend where appropriate. The FOI requests are available to download by following the following links.:

ATI-08294a Response (redacted)

ATI-08761a Response (3)

About the author

Richard Cregeen-Watson is a kayaker and photographer who contributed a few of the stock shots you may have seen over the course of the Save the Conwy campaign. He has dabbled in both the outdoor industry and commercial world of high street retail marketing. He lived in Snowdonia for four years, studied a post-graduate course at Bangor and explored many of the hills and rivers the park has to offer. Now a tourist to the Park he regularly returns to Snowdonia to visit friends and sample the great local produce. His favourite place to stay is the Fairy Glen Hotel.

Snowdonia National Park Response to Open Letter

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You may remember that Dan Butler wrote to the Snowdonia National Park Planners highlighting the sources of a large number of the letters of support that they had received included RWE, the company proposing the scheme, and Dulas, the company putting together the proposals for them.

Dan’s Original Letter to the Planners

Since Dan’s letter to planners, we have learnt that a number of the letters to the planners came from individuals that did not make an effort to make their role in the companies clear. We have also established that a significant proportion of the support came from outside Wales, and that most of the submissions from RWE employees used what appeared to be a standard letter as their basis. We have also learnt that the number of letters of objection now totals over 800, with objections coming from both locally and farther afield.


Letter by e-mail to Mr. D. Butler (10.12.15) – SNP Response

The SNP response is worrying, not just for the Conwy, but for the future safety of the National Park.They don’t appear to have the resources to effectively look at any volume of correspondence, and so are apparently happy to just leave the issue as it is, rather than stir up something with a developer. Is this the first time this has happened? What other schemes have been put though across the National Park based on letters from the very people putting them forward? If the proposed scheme is so good, shouldn’t the application speak for itself?


The Entrance to the Fairy Glen during the recent flooding.


Questions with Carl Sargeant

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Aberconwy AM Janet Finch-Saunders has been busy tabling questions for her constituents to Carl Sargeant AM. Mr Sargeant is the Minister for Natural Resources. The correspondence is given below, and there are copies of each question for download given at the end, along with part of Natural Resources Wales’ Remit and the responsibilities, as stated by them.


Carl-Sargeant-1 Carl-Sargeant-2


Carl Sargeant states that NRW do not consider tourism or recreation, but in their own statement, taken from here they are considering the effect to lawful water users, which we must assume includes recreational users both local and “tourist” in nature.

Clarity is needed on this issue, especially as the Conwy has been declared to be an issue of “High Public Importance”.

NRW Remit

NRW-Resp NRW-resp2

Urgent! Another chance to help.

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The window for objections to the abstraction licence closes soon. All objections need to be in by the 4th Dec. If you have already objected to NRW (this is separate to the planning objection) then great. If not here is what to do.

Want to write your own submissions:

The guidelines for objecting are shown here

making your views count eng

see our NRW submission below for ideas , also guidance from the Snowdonia Society here:

Snowdonia Society Guidance

start with the text: 

RWE Innogy UK Limited for a full licence to abstract water from the Afon Conwy near Betws-y-Coed,  Conwy at National Grid Reference SH 81139 53409                                                           

Ref N# WPCC3508 and WPCC3510

I am writing to object to the proposed applications.

and email to:


Want a bit more help. Use our completed template below, add your own comments and name / address then email to the above address.

template nrw submission

Remember however you do it , it needs to be sent by the 4th Dec . 2 days !


Kayaking on the Afon Conwy, Fairy Glen

Kayaking on the Afon Conwy, Fairy Glen, by Tom Laws

Canoe Wales Response to Comments in the Media

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Canoe Wales have released a statement following news coverage in the North Wales Weekly News.




“Contrary to reports by RWE Canoe Wales do not support building a weir above Penmachno Bridge and have made representations to Snowdonia National Park Authority and Natural Resources Wales including expert analysis, stating that a weir immediately above this dangerous section of whitewater would be an added risk to paddlers and increase the likelihood of further serious incidents at this location.”


The full statement can be found at  SaveTheConwy

Shadow Environment Minister

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In recent weeks Save the Conwy has been in contact with Janet Haworth AM, Shadow Minister for the Environment. As a local AM who has previous worked in the tourism industry she has obvious concerns about the proposed hydro scheme. She has been in contact with both the National Park and NRW and has been raising the issue with fellow Ministers. Her latest press release is below:


As one of the North Wales Regional Assembly members and shadow minister for the Environment I acknowledge that we face significant challenges in the face of climate change and the need to ensure the security of the supply of energy

Those same Victorians who transformed Britain into the fulcrum of the Industrial Revolution  knew Conwy Falls and came to find peace and to reconnect with Nature  away from the frenzied life amongst the Dark Satanic Mills.

Today the café and car park have become something of a tourist hub attracting visitors en-route into Snowdonia. There are mountain bike tracks  and a High Ropes activity centre nearby. A recent attraction, ‘Go Below’ has its base at this location.  During my visit on a cold November day I met photographers, hikers and a kayaker. testament to the increasing all year round tourism business that is growing year on year here in North Wales.

The argument that carbon emissions must be reduced packs a punch but the Welsh Tourism Industry also packs a punch supporting thousands of jobs and attracting billions of pounds into the Welsh economy.

Arguments to exploit our countryside for commercial gain and the need to conserve our treasured and outstanding landscapes have until recently achieved some sense of balance within the establishment of National Parks, Areas of Outstanding Natural Beauty and SSi site designations

We  are losing natural habitats at an alarming rate. This has been highlighted recently at an event hosted at the Welsh Assembly by the Environment Committee.

RWE’s proposal  to erect a weir to generate hydropower within the Snowdonia National Park will locate an alien and industrial structure  at Conwy Falls.  I have studied the plans and attempts to adapt and mitigate with,’soft engineering techniques,’ appeared cursory.

The promise of clean renewable electricity will be modest while the long-term income  from  this project will of course be welcomed by the promoters and investors.

I have to ask would  the RWE  engineering company promoting this proposal get away with locating this plant within the beauty spots of the Bavarian mountains and forests?

Only 25% of our Welsh countryside enjoys protected status I know why places such as Conwy Falls are amongst our national treasures as do the 4000 + who have signed the petition against this plan and the various environmental agencies who have along with the Snowdonia Society raised their voices in protest.


Representations to Natural Resources Wales

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Below are Save the Conwy’s representations to Natural Resources Wales, in full as PDF documents. Each link will download or open the document.

Dear Sir/ Madam

RWE Innogy UK Limited for a full licence to abstract water from the Afon Conwy near Betws-y-Coed, Conwy at National Grid Reference SH 81139 53409
Ref N# WPCC3508 and WPCC3510
I am writing on behalf of the campaign group Save the Conwy to object to the proposed application. Save the Conwy is a group local to the Conwy Valley but with around 2800 followers both locally and nationally. Save the Conwy was set up in response to the RWE application for a Hydro Power Station on the river Conwy. It has been involved with discussions with the developer along with other concerned parties since 2013.
The full objection is attached as a PDF (NRW submission) above along with the relevant appendix.
Yours Faithfully
Dan Yates
Representative of Save the Conwy