UAF/Env. Comm./Hydro 20-9-12
Damage to Fisheries and Rivers by Hydroelectricity
The Ulster Angling Federation
Presented to the Assembly Committee for the Environment
Thursday 20th September 2012
Damage to Fisheries and Rivers by Hydroelectricity
by the Ulster Angling Federation
Presented to the Assembly Committee for the Environment
Thursday 20th September 2012
Index
1 The Ulster Angling Federation
2 Game Angling
3 Government Reports on Angling and Fisheries
3.1 Pricewaterhouse Coopers Report on the value of Angling (2007)
3.2 APEM Report on Salmonid Catchment Management (2009)
4 Present Unsatisfactory Situation
5 Problems with the Introduction of Regulations
6 Where it is going wrong
7 Implementation of the Guidelines
8 Conclusion
Appendices
Appendix 1 “Hydropower: A New Source of Green and Sustainable Electricity
– Or Destroyer of Aquatic Life?” by Janina Gray
Appendix 2 “Salmon at Sea” by Dr. Ken Whelan
1 The Ulster Angling Federation
The Ulster Angling Federation is the representative body for game (trout and salmon) angling clubs in Northern Ireland. We have a membership of around 60 clubs with a total individual membership of some 8,000 anglers. The Federation represents anglers in discussions with Public Bodies, Government and other NGO’s and has been in existence since 1930. We are represented on a wide range of committees to ensure the concerns of anglers are heard.
2 Game Angling
Local Angling Associations have worked extremely hard for many years to conserve, protect, and enhance not only the wild fishery on rivers but the entire river environment, for the benefit of local people and increasingly, visitors. Countless (voluntary) man-hours and hundreds of thousands of pounds have been spent to improve rivers and associated fisheries: these Associations continue to provide a self-financing and voluntary community-based effort to look after the rivers.
A huge effort is now underway to protect and conserve the wild trout and salmon – many sea nets have been retired and limits on rod catches have been brought in. Government Reports have highlighted the impressive record of angling in promoting a healthy, outdoor activity with an almost unmatched record in eliminating sectarian influences.
Angling Associations are now responsible for selling large numbers of day tickets to visiting anglers and are generating considerable interest in NI among anglers from outside the area.
3 Government Reports on Angling and Fisheries
3.1 Pricewaterhouse Coopers Report on the value of Angling in NI (2007)
The Pricewaterhouse Coopers Report of July 2007 on the social and economic value of angling in NI, states that all forms of angling in NI support some 780 full time equivalent jobs, and are worth some £40m p.a. to the NI economy, mostly from game angling. If this jobs/economic benefit is to maintained and enhanced, the provision of good water quality and satisfactory fish stocks are absolutely vital for our fisheries and tourism.
The Pricewaterhouse Coopers Report highlighted the impressive record of angling in promoting a healthy, outdoor activity with an almost unmatched record in eliminating sectarian influences. Angling Associations are now responsible for selling numbers of day tickets to visiting anglers and are generating considerable interest in NI among anglers from outside the area. It is therefore important that proposals which may jeopardise this community activity should be subject to reasonable assessment.
3.2 The Report on Salmonid Catchment Management (2009) by APEM Aquatic Scientists, was produced for the NI Government. The extract below highlights the
benefit to be derived from angling;
4 Present Unsatisfactory Situation
There is insufficient protection by NIEA for fisheries and the water environment in hydroelectric scheme proposals;
4.1 Depleted sections of rivers - diversion of flow for turbines leaves stretches of river depleted of water. This will degrade the river and eliminate or decrease the window of migration opportunity.
4.2 Upstream migration - fish are usually attracted to the greatest
flow. The greater flow from a turbine may prevent or delay fish from finding a fish pass.
4.3 Downstream migration - fish migrating downstream may be impeded by being unable to find a passage route, or damaged by contact with structures
at a hydropower scheme.
The Ulster Angling Federation have been able to establish that DCAL are not legally competent to comment on fish migration issues, with the exception of grids/screens and fish passes as these are set out in the 1966 Fisheries Act. On all other fish migration issues, particularly the effects of diminished flows on migration, they have no legal competence to provide an opinion. This has been confirmed by DCAL.
Presently NIEA issue licences for many hydroelectric schemes without examination of many fishery issues by developers. Note that the DCAL Committee previously recommended that all such developments should be subject to independent Environmental Impact Analysis. The present licencing Guidance allows developers to take too much water out of the rivers.
5 Problems with the Introduction of Regulations
NIEA commenced the licencing of hydroelectricity schemes without any guidance as to how they were to be assessed for suitability. For several years, licences were issued when no one knew what criteria were being applied, or indeed if any criteria were applied.
The Ulster Angling Federation met with NIEA on a number of occasions to elicit such criteria and failed. The most we achieved was to extract one or two verbal assurances which were later ignored.
When a Working Party was set up by NIEA to consider the drawing up of assessment criteria a number of Government Departments were invited to join, along with the British Hydropower Association. No angling or conservation interest was permitted to take part. When we asked for copies of the minutes of one of the meetings attended by some 20 civil servants and British Hydropower Association representatives, we were told none were taken. When we asked for copies of notes of the meeting, were told none were taken. When we asked for copies of notes taken by individual NIEA attendees, were told none were taken. Angling and conservation interests were completely ostracised.
A “Stakeholder Engagement” document was published in June 2011to which we and others made a written response. No outcome of the “Stakeholder Engagement” was ever made known, we were not informed of any result, we have no idea what views were put to NIEA.
A “Consultation” document Guidance for run-of river hydropower schemes in Northern Ireland was published in November 2011to which we and others made a written response. No outcome of the “Consultation” was ever made known, we have no idea what views were put to NIEA. We were not informed of any result, nor were we informed as to when any such Guidance was or was not to be adopted.
We are aware that a number of fishery protection measures have been omitted from the list of required information as set out in the draft of June 2011, e.g.;
• Details of fishery protection and fish migration mitigation
Thus there is no longer any requirement for developers to assess these aspects.
6 Where it is going wrong
The present licencing Guidance allows developers to take too much water out of the rivers. Up to 91% of water may be taken out – we feel this is far too great and needs to be reduced. In addition all water above a set minimum (the “hands off flow”) is licenced to be taken so that the rivers are condemned to a flat very low flow regime for two thirds to three quarters of the year which is wholly unnatural. In many cases the “hands off flow” is simply not enough.
The anglers throughout England, Wales and Northern Ireland have overwhelmingly condemned the criteria being used in hydroelectricity schemes as being inadequate to protect the rivers and the fisheries. The following is needed;
3.1 An Environmental Impact Assessment (EIA) is needed for each hydropower application, as stipulated by the DCAL Committee; in their “Report of the Inquiry into Inland Fisheries in NI”, the DCAL Assembly Committee said that a “thorough and independent EIA prior to any approvals being granted” should be produced for hydro-electric proposals (Rec. 11.40).
3.2 There should be reasonable protection against impact on water flows, including maintaining natural flow variability, so that the scheme does not adversely affect the aquatic environment and its dependent species.
3.3 Post-scheme monitoring should be conducted to ensure that protection is being implemented and is effective.
3.4 The cumulative effect of multiple hydroelectric schemes on the same river is commonly ignored, this needs to be changed.
3.5 Where rivers have been declared as a Special Area of Conservation (SAC) no additional protection is applied by NIEA, this needs to be changed.
3.6 NIEA Environmental Heritage use staff for the assessment of hydroelectric schemes on SAC rivers, who do not have adequate competence to carry out the duties involved, consequently protection is inadequate, this needs to be changed.
There is no scheme of regular inspection by NIEA – they simply ignore the schemes after licences have been issued, and it is left up to the anglers to monitor schemes on a voluntary basis. Additional workload is also levied on DCAL Inland Fisheries and the Loughs Agency who periodically inspect fish passes and grids.
At plant commissioning time NIEA have no interest in verification or checking that the installation is doing what it is supposed to do – everything is simply ignored after the licence is issued.
7 Implementation of the Guidelines
The application of the Guidance for run-of river hydropower schemes in Northern Ireland presently being used by NIEA seems to be falling down in some respects;
3.3 Applicants installing new schemes, or re-using old infrastructure, must also submit an assessment of the potential impacts the proposed scheme will have on the habitat and fishery within the depleted stretch and the weir pool. (See Section 4.6 for further details)
This is commonly ignored in licence applications
3.3 Details of the proposed abstraction regime including the proposed residual
flow and river flow monitoring mechanism.
-Details of flow monitoring mechanisms are commonly ignored in licence applications
A draft management plan for monitoring the operation of the scheme
-This is commonly ignored in licence applications
4.3 Sediment Management
Applicants will have to assess the impact their installation is having, or likely to have, on the river and include the appropriate mitigation in their management plan.
-This is commonly ignored in licence applications.
4.5 Maintenance Activities
Within the monitoring plan, the applicant must provide details of routine
maintenance activities and the measures taken to prevent these activities having
a negative impact on local ecology.
-This is commonly ignored in licence applications.
4.6 Ecological Assessments
Any application for a new hydropower scheme, or a scheme that will install new
equipment on existing infrastructure must provide (at the time of application) an
assessment of the potential impacts the proposal may have on the local ecology.
-This is commonly ignored in licence applications.
8 Conclusion
We believe that NIEA have followed the English EA example in order to become a promoter of hydroelectricity. The UAF is not wholly opposed to the introduction of Hydro-electric power generation; however we are opposed to the partial and unscientific basis used for the present guidelines. It is largely follows the England and Wales EA guidelines, written by the British Hydropower Association. This is not a reasonable basis for an impartial set of guidelines.
This is exemplified by the NIEA promotion of their own Roe Valley Country Park scheme which ignored the limitations of the Water Framework Directive and the Habitats Directive. This attitude compromises the ability of NIEA to judge other schemes: it cannot be both a strident promoter of hydroelectricity and an independent regulator at the same time.
If balance is achieved, then why is the entire angling community, and the Loughs Agency, opposed to the way in which NIEA administer the Abstraction Regulations. The Guidance document is not balanced.
The licencing of hydroelectric schemes in NI has been partial in favour of developers and does not afford reasonable protection for fisheries and the water environment. A revision of the Guidance for run-of river hydropower schemes in Northern Ireland is required.
Appendix 1
Hydropower: A New Source of Green and Sustainable Electricity
– Or Destroyer of Aquatic Life?
The key requirements necessary to make a hydropower scheme truly sustainable
Janina Gray, Head of Science, Salmon and Trout Association
1 Background
The Salmon and Trout Association (S&TA) believes that, alongside energy efficiency; increasing the uptake of renewables in the UK is fundamental to reducing greenhouse gas emissions and averting dangerous climate change.
However, the recent drive to provide renewable energy has resulted in an explosion of schemes to develop small hydro power projects around the UK. Hydropower is the harnessing of power derived from the energy of failing water. Most schemes are run-of-river, which means they have no capacity to store large quantities of water, and therefore the majority rely on an impoundment to create a head of water or to facilitate the abstracting structure. Others rely on the natural gradient of the river to create a head by diverting water into a separate channel.
S&TA supports hydropower developments where it can be clearly demonstrated that they will not cause damage to fish populations, and will not prevent the river reach from achieving Good Ecological Status (GES) or Potential (GEP) or cause deterioration of the water body as required by the Water Framework Directive (WFD). Currently with the existing Good Practice Guidelines (GPG) and the failure to have a coordinated national strategy on hydropower, we do not believe environmental protection can be guaranteed.
2 Hydropower – The Problems
2.1 Depleted reaches - Diversions of flow to or away from turbines can leave stretches of river depleted of water. This will impact the channel morphology and ecology.
2.2 Impoundments - Impede migration of diadromous and potamodromous fish and
invertebrates, and fragment aquatic habitats. Some impounding structures and
natural obstructions may be passable to fish at certain flows; however the diversion
of water for hydropower may eliminate or decrease the window of migration
opportunity.