14th April 2021Comments are off for this post.

Kendal Flood Risk Management Scheme – Overview

The River Kent flows through the heart of the town of Kendal and has the highest level of protection afforded to a river in Britain, being both a Site of Special Scientific Interest and a Special Area of Conservation. It is also just outside of the Lake District National Park, and is often billed as the “Gateway to the Southern Lakes”. A number of features that the river Kent has been designated for are likely to be impacted by Kendal Flood Risk Management Scheme.

Read more

17th November 2015Comments are off for this post.

Open Letter to the Snowdonia National Park Planners

Application Ref:          NP4/26/323
Registration Date:       23-Apr-2015
17/11/2015

Dear Mr Lloyd
We are writing this open letter to you in your capacity as Head of Development Management for the Snowdonia National Park. As you will know from our earlier objection letter we are opposed to the proposed Hydro Scheme on the River Conwy.

Earlier, through the online petition (https://you.38degrees.org.uk/petitions/stop-the-damming-of-the-river-conwy) we became aware that a manager at Dulas Ltd (one of the contractors involved in the bid) was trying to influence public opinion through leaving a comment on the petition. If you haven’t seen it we have included a screenshot of the comment below, with a link to the page it was on, as an appendix to our letter. As this individual had failed to provide any information of his interest from a commercial point of view while making his comments, this led us to wondering if there had been other instances of this during the planning application phase.
We were helpfully assisted by your planning department who gave the names of all those who had written to you in support of the scheme, and have spent some time looking them up on LinkedIn. For your information we have included the list below, along with the positions they hold either in either RWE or Dulas Ltd.
There are others on the list that can also be traced back to either of those companies, or have been contracted by them to assist in their application. All of this information, along with the links for verification is below.
List of those who have written to the park in support of the Project:

 

Vince Read (Head of Hydro at RWE)

https://uk.linkedin.com/in/vince-read-1781a133

 

Paul Bellis (Health and Safety adviser Hydro UK at RWE)

https://uk.linkedin.com/in/paul-bellis-b3a64330

 

Duncan Morrison (Senior Hydro Project Manager at RWE Npower Renewables)

https://www.linkedin.com/in/duncan-morrison-990b5b9

 

Tina Watson (Hydro Procurement manager at RWE)

https://uk.linkedin.com/in/watson-tina-b8283a90

 

Oliver Wilson (Commercial analysis for RWE)

https://uk.linkedin.com/in/oliver-wilson-41468362

 

Rebecca Rankine (Assistant project manager at RWE)

https://uk.linkedin.com/in/rebecca-rankine-5774aa20

 

Oliver White (Operations Engineer at RWE)

https://uk.linkedin.com/in/oliver-white-ab81022b

 

Sarah Ostermann (No linkedIn profile, but works for RWE as a Project Manager)

http://www.karrierefuehrer.de/branchen/green-tech/jung-und-erfolgreich-bei-rwe-innogy.html

Link leads to a German Language page, but translates perfectly with Google translate

 

M (Matt) Palmer (No LinkedIn Profile, but is a Senior Hydro Engineer, Dulas Ltd)

http://www.dulas.org.uk/dulas-people.cfm

 

Catherine McLennan (Customer Sales and Marketing at Dulas Ltd)

https://uk.linkedin.com/in/catherine-mclennan-81140766

 

Rachel Harper Bit cheeky this one – maybe used her pre/post married name – Rachel Kennedy (who comes up when you search for Rachel Harper on linkedin) is a senior at Dulas Ltd

https://uk.linkedin.com/in/rachel-kennedy-140b7727

 

Laura Hiscox (Communications co-coordinator at Dulas Ltd)

https://uk.linkedin.com/in/laurahiscox

 

Elfed Williams (Not directly linked to Dulas, but has a history of applying pressure in applications where there is a lot of support against the scheme – see his LinkedIn page for more information)

https://uk.linkedin.com/in/elfed-r-williams-llm-ma-frics-mrtpi-42b23318

 

We would like to ask you to consider the following points when reviewing their letters of support for the application:

1: They work for Dulas Ltd or RWE, or have could have been contracted by them.

2: It is unclear whether they have set out in their letters that they work for either of the above companies or have declared their apparent professional interest.

3: When people write in support of projects in which their employers have a vested interest, it is very difficult to know what influence (proper or improper, direct or indirect) has been put on them to write.

4: I would suggest this leads to a natural conclusion that these particular letters of support require treating with an appropriate amount of caution, as it seems clear that their provenance is in doubt.

We trust that you will see the seriousness of the situation, and ask that you provide assurances that this information is acted upon with the utmost urgency.

Regards

Dan Butler

Representative of Save the Conwy

www.savetheconwy.com

Appendix 1: Screenshot of comments left by Dan Hammond (Dulas Ltd Employee) on the petition page in the comments section.
Dan Hammond

11th November 2015Comments are off for this post.

NRW Drop-In Thursday 12th November 3pm-7pm

Tomorrow afternoon you can drop-in to the Waterloo Hotel in Betws Y Coed (just along from the petrol station) from 3pm until 7pm and speak to representatives from Natural Resources Wales about the proposed scheme.

NRW have made it abundantly clear that they don't care about your opinion, only facts, so here's some topics to think about if you are popping in...

"In making our determination, we will consider all relevant information submitted to us. Amongst the issues we consider when reaching our decision are:

 the environmental effects of the abstraction and impoundment and their impact on designated sites, the biological and/or geological features of interest they support, and on protected species and habitats"

The area is a SSSI and within the National Park - why has it been chosen?

 "the likely effect of the proposal on the protected water rights of existing licence holders and other lawful water users"

The data shows a significant drop in the number of days the gorge will be useable by kayakers, and also the introduction of a weir is both unsightly and unsafe. The area above Conwy Falls has sadly seen a number of tragedies and near misses that would have been worsened by a man-made weir. Who is responsible if their construction kills someone?

Glen_Photography

" the reasonable requirements of the applicant for water and its efficient use"

Is 5MW an efficient use of a pristine valley?

 "the sustainability of the proposal and any effects on biodiversity"

As a SSSI containing a previously uninterrupted corridor of life... why not ask about that?

However, often we receive comments on matters which are beyond the remit of our determination.

Among the issues we cannot consider are:

 Noise
 Dust
 Transport
 Future connections to the national grid
 Cultural heritage
 Construction impacts
 Rights of way

But by all means, you could ask about those things. Why don't they care about cultural heritage? Why does it take 20 days to get some documents out?

See you on Thursday 12th November, Waterloo Hotel, Betws-y-Coed

 

9th November 2015Comments are off for this post.

Frequently Asked Questions

A lot has been going on recently, so it seemed fitting to pull together a bit of a summary of where things stand, and answer a few questions you might be asking.

What's going on?
The Conwy is one of the largest rivers in Snowdonia National Park.  It rises high on the moors before squeezing through a number of impressive gorges, culminating in the twin falls of "Conwy Falls", close to the café of the same name.  Below here the beautiful Fairy Glen has been capturing the hearts of recreational users including fishermen, walkers, canoeists and photographers for many years.  It features in Victorian guides to the area, and has done ever since.  This area also supports a wide range of flora and fauna.  Below the Fairy Glen the river meets the Llugwy and Lledr as it passes the tourist hotspot of Betws y Coed before meandering more gently to the sea, making its mouth on the North coast at the town of Conwy.
In simple terms, a large company have applied to put a hydro-electric power generation scheme on the river.  Under their scheme a weir with a large metal grill will be built just above the spectacular Conwy Falls, siphoning off a significant volume of water and channelling it into a large pipe that will run parallel to the river down to the confluence with the Lledr near Beaver Pool.  This will reduce the flow of the river significantly as well as breaking the living corridor of the river.  It introduces a new hazard to recreational river users, and we believe it will cause not only significant disruption but also some serious ecological damage to this area during construction and beyond.

Fletch

Isn't hydro power good for the environment?
It can be, and all of us should be in favour of reducing the use of fossil fuels to generate electricity.  However this scheme will only generate, at a maximum, 5MW - less than the electricity used if half of Betws y Coed put the kettle on, and roughly the same as just two offshore wind turbines.  According to the company's own plan, for a third of the year the scheme won't generate any power at all.  None of this sounds very green!

Surely this is just NIMBYism? ("Not In My Back Yard")
Not at all.  There are plenty of more suitable sites in and around the National Park.  Within a couple of kilometres is the Penmachno mill site where there is already a disused mill building, a weir site and other hydro infrastructure that is just not being used.  On the fringes of the park, the Ogwen has a scheme planned that uses a section of river that has already been canalised by the quarrying in the area.  Hydro-electric power generation certainly has a place in the park, but the site chosen should be suitable and make use of existing infrastructure where possible, and especially given there are many areas that are already industrialised.

GlenKayak

Shouldn't the National Park be protecting the area for people to enjoy?

The Fairy Glen is in an ancient woodland and designated as A Site of Special Scientific Interest, as well as being within the National Park.  This should afford it some protection but it doesn't appear to matter to the planners in this case – which is why we are objecting.

 

How can I find out more?
The Planning Officer's Reccomendations

Flyer containing a map and further information

Information on the impact of the proposed scheme

 

What has been done so far?

During the initial planning application, over 600 letters of objection were submitted.  Just 30 were filed in support.  It is clear to us that the planners’ report failed to take into consideration a large number of relevant factors.  These included significant and detailed objections from groups such as Canoe Wales (who represent canoeists), Betws y Coed angling (who own the fishing rights), and Save the Conwy (us), each of which raised various concerns as to why the scheme should not be given approval.

 

How can I help?

Objections can be made to the National Park, the organisation responsible for looking after the area.

If you objected by letter before, you can reiterate your concerns, using 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

As part of the scheme an application has been made to Natural Resources Wales to abstract water by means of a weir. They are holding a public consultation in the Waterloo Hotel in Betws y Coed on Thursday 12th November from 3-7pm.  Anyone is welcome to view the abstraction plans and ask questions at this event.  If you feel you can attend, then please do, and help us prevent the destruction of such and important area.

You could also sign a petition.  This petition, which gained over 3000 signatures in 10 days, can be accessed using the link below.

https://you.38degrees.org.uk/petitions/stop-the-damming-of-the-river-conwy - a shortened version for sharing can be used - www.bit.ly/savetheconwy

There is also a second petition for signatories without a UK postcode which can be found below.

https://www.change.org/p/carwyn-jones-first-minister-of-wales-stop-the-damming-of-the-river-conwy
In addition, you can use social media to ask questions to either NRW and / or the National Park:
Tweet @NatResWales - Natural Resources Wales

Tweet @VisitSnowdonia - Snowdonia National Park Authority

Facebook Natural Resources Wales

Finally, you can download and print out a poster to help raise awareness of the scheme in your place of work.

Save the Conwy Poster - PDF Download

SaveTheConwyPoster

Thank you for taking the time to read through this information. If you want to get in touch the best ways are through Facebook "Save the Conwy" and Twitter @SaveTheConwy

4th November 2015Comments are off for this post.

What you can do now.

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

20th October 2015Comments are off for this post.

Planning Officers Recommendations

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. 

28th June 2015Comments are off for this post.

Woodland Trust / Coed Cadw

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

15th May 2015Comments are off for this post.

Where we are now.

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.

12th May 2015Comments are off for this post.

Community Council Meetings

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

9th May 2015Comments are off for this post.

Contact your Community Council

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.

9th May 2015Comments are off for this post.

Flyer /Poster

A great flyer made for Save the Conwy highlighting some of the main points of the scheme. Please print one out , show your friends , neighbours, fishing club , canoe club.  hydro posterhydro map

Pdf versions here:

SaveTheConwyflyer