Caroline Orr BA Hons, MSc
Project Officer: The Carmarthenshire Rivers Trust
Yr Ysgubor, LlwyndcoedIsaf,
Penybanc, Llandeilo.
SA19 7LS
16th December, 2015
F.A.O.: Jonathan Eirug
Planning Department, Ceredigion County Council,
Penmorfa, Aberaeron.
SA46 0PA
Dear Sir,
Re: Application A150808
Ty'n Y Cornel, LlandewiBreifi, Tregaron. Proposed hydropower scheme.
On behalf of the Carmarthenshire Rivers Trust I would like to bring to your attention the concerns that we have about the above proposal. The planned scheme is within the Doethie catchment -an important spawning habitat for our endangered migratory fish species. It is because of this importance that the Carmarthenshire Rivers Trust has been applying limestone sand in order to remediate acidification in order to enhance water quality. The planned scheme is within the restoration area. Our work is set to continue into the future and has been achieving some very positive results (water quality, invertebrates, fisheries) within the last few years. It is also positively benefiting the Tywi.
Our concerns about the scheme are as follows:
1. Lack of consultation with Carmarthenshire Rivers Trust despite our liming project to address the acidification problem in the Doethie catchment and restore aquatic ecology and fisheries.
2. The applicant states in the application form that the river is not a fishery whereas it is actually an important sea trout spawning area.
3. There is a discrepancy in the "Hands off Flow (HOF)" quoted in the summary and elsewhere of the KRS environmental report. In the summary the HOF is taken as the Q95 flow which is 0.023m/s whereas the figure quoted in table 3 p 4 is 0.014m/s which is less that Q95. NRW have apparently indicated that the HOF is likely to be between Q95 and Q90 which will be a flow greater than that quoted in table 3.
4. The scheme will deplete flows in a 1.2km length of stream (the distance between the abstraction point and the return point) which represents about 14% of total stream length. The reduction in wetted area of channel will result in a greater mortality of juvenile salmonids due to density dependent competition (they are territorial) which will result in a decrease in fish production. There is no assessment of this effect.
5. The scheme is likely to delay migration of sea trout, due to:i) confusion caused by the competing flows of water entering via the return pipe vs water flowing down the depleted reach, and ii) a hold up at the point of the weir - any structures across streams cause a fish to pause making them more vulnerable to predation and poaching. Again there is no assessment of these effects.
6. No account of the potential impact on bullheadsCottusgobio (an S.A.C. species) - the weir is likely to restrict their movement.
7. There is no reference to gridding either the return pipe to prevent fish ascending it or at the point of abstraction to prevent fish being drawn into the turbine
8. A v notch is referred to that will ensure the maintenance of HOF but the location of this notch is not specified - it would need to beat the entrance of the fish pass to ensure its operation at all flows.
9.The NRW consultation response to the planning application is inadequate as it is mainly focused on the potential impacts on water voles and does not cover the range of issues detailed above - we will also be raising concerns with them in relation to the application for an abstraction license.
10.These works would be taking place above several S.S.S.I.'s therefore there may be disruption to one or more species which are responsible for the S.S.S.I. status (sedimentation, disrupted flows, etc). For example: There are rare mossesRhynchostegium alopecuroides and Heterocladium wolfsbergii (responsible for this areas S.S.S.I. status) which are splash zone mosses, the splash zone will be dramatically reduced, therefore having the potential to negatively impact these macrophytes.
Carmarthenshire Rivers Trust supports the sustainable development of renewable energy but we are concerned in this case that action to address one environmental problem (climate change) may cause an unacceptable environmental impact. We urge Ceredigion County Council not to approve this scheme unless the above issues can be addressed.
Yours Sincerely,
Caroline Orr
BA Hons, MSc
Project Officer: The Carmarthenshire Rivers Trust
01558 823011 / 07454782858