A press release from the ATr:
As you will be aware, the Angling Trust and Fish Legal have been campaigning and taking legal action over the past few years to stop damaging hydropower on our rivers. We have been jointly working with the Salmon & Trout Association on a group set up by the Environment Agency to review the Good Practice Guidelines for hydropower developers to follow.
The Agency’s own experts have confirmed that the current version is not fit for purpose. At last, after years of delay, there is a consultation about tightening up the standards to protect the water environment from the gold rush by hydropower developers who want to benefit from the generous feed in tariffs from the government.
This is our opportunity to change the guidelines for the better, which will protect our coarse and game fish stocks for generations to come. We need your support for this – the more responses they receive, the more likely it is that we will get better protection of our fish.
Please take a few minutes to respond to the consultation, following the advice set out below, prepared in partnership with the Salmon & Trout Association.
The consultation can be found HERE
Please select “Consultation on river flow and water abstraction standards for hydropower” from the list of consultations and then follow the instructions about how to respond.
There are four questions and our suggested bullet points for incorporation into your response are given below. It is important that you add any relevant comments based on your own knowledge or experience and that you provide details of yourself/your organisation in the box after Question 4, including where possible the numbers of members/anglers you represent and the value of any fishing rights you own.
Q1 WHICH OPTION?
Our recommendation: OPTION 3
Reasons:
• The fisheries representatives on the National Working Group believe this to be the preferred option on the basis of the available evidence of the impact of flows on fish and ecology – none of the others comes close to meeting the required level of fisheries and ecological protection
• Of the four options it provides the greatest protection of river flows and flow variability, including within depleted reaches. It ensures that the river downstream of a hydropower scheme more closely mimics the natural flows required to enable fish migration, natural fish recruitment, good angling and good river ecology.
• It is consistent with the approach taken by the Environment Agency on all other forms of abstraction. Any other option gives hydropower schemes an unacceptably lower level of environmental protection
• This approach starts from a more precautionary position and puts the onus on the developer to provide evidence to deviate from the standards, rather than the Agency
Q2 SUGGESTIONS FOR IMPROVING OR AMENDING OPTIONS
• Option 3 is the only acceptable option but the proposal to allow a 30% increase in the amount abstracted from the present Guidelines (up from Q Mean (average flow) to 1.3X Q Mean) is unacceptable.
• On many rivers, especially those with many weirs, weirpools are exceptionally valuable habitats. The statement ‘if a weirpool is of high importance…a more protective allocation or flow distribution would be required’ will tend to be ignored and the default of 1.3X Q Mean applied in every case. The standards outlined for Option 3, but with a maximum abstraction of Q Mean should be the default and any deviation only licensed if supported by evidence that no damage to fisheries, fishing or the ecological status will occur.
Q3 ENGLAND, WALES OR BOTH
• Tick appropriate box
Q4 PUBLICATION OF REVISED STANDARDS 12 WEEKS BEFORE THEY COME INTO EFFECT
• The Agency has already spent two years on this revision and the hydropower industry is well aware of the probability of changes. At the least they should have immediate effect as did the Supplementary Advice issued in December 2012 on Screening, Fish Passage, Weirs and Competing Schemes. However, in view of the long delay, our preference is that no more licence applications should be determined until publication of the revised Good Practice Guidelines.
Many thanks for your help – it really will make a difference!
