UAF25-4-10
Ulster Angling Federation
Hydro-electric Power Generation
Degradation of Rivers and Fisheries due to NIEA failure to Protect the Environment
1Background
1.1The Ulster Angling Federation is the representative body for game angling associations in Northern Ireland. We have a membership of some 60 associations with a total individual membership of some 6,000 anglers. Our member Angling Associations are very concerned about the pending large scale development of hydroelectric schemes on rivers as these have great potential to harm the river environment generally and fisheries in particular.
It is important that the natural integrity of streams is protected to allow conservation of the ecology of the stream, and to allow fish populations to prosper.
1.2The current trend in the salmon and sea trout populations generally is one of steep decline, and the Loughs Agency among others is working hard to protect the stock. For instance the local situation on the river Roe is tenuous, with a failure to meet the Management Target two years ago. The River Finn has suffered a stock collapse.
1.3The Pricewaterhouse Coopers Report of July 2007 for DCAL 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 habitat is absolutely vital for our fisheries
The DCAL study 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 day tickets to visiting anglers and are generating considerable interest in NI among anglers from outside the area. It is therefore important that a proposal which may jeopardise this community activity should be subject to reasonable assessment.
1.4NIEA have adopted the English approach to assessment of hydroelectric proposals which is very detrimental to the protection of rivers, the Loughs Agency has adopted the Republic of Ireland approach, which is to protect salmonid fisheries from hydroelectric development. The Ulster Angling Federation has supported the Loughs Agency approach in that area, and has made reasonable recommendations for schemes,but NIEA are determined to go down the English line and almost entirely ignored our views.
1.5The benefit in renewable energy to NI of hydroelectric development will be extremely small (approx 0.75 %), and in effect will have no influence on our ability to meet renewable energy targets.
1.6The former use of waterwheels in NI is often cited as a justification for new widespread use of hydroelectric development; but the new demands are infinitely greater than the old, and many of the rivers and fish populations aregenerally in poor condition and cannot sustain this assault on their health.
2Problems
2.1NIEA should be an independent party in the assessment of hydroelectric development, but is unreasonably biased in favour of hydroelectric development, not least because it is a hydroelectric developer itself. (River Roe Scheme).
2.2It has established a Working Group to provide Development Guidelines for hydroelectric development - this Group includes the British Hydropower Association, but excludes any input from NGO conservation organisations such as The Ulster Angling Federation.
2.3In 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). This is supported by the recent ‘’Guidelines on the Planning, Design, Construction and Operation of Small Scale Hydro-electric Schemes and Fisheries’’ document produced by the Irish Government. This has not been done.
2.4NIEA has ignored representations based on science which NIEAthemselves have quoted as Best Practice in the field.
2.5A single hydroelectric scheme on a river system could, by itself, have a detrimental impact on the fish population. Where there are a series of hydropower developments on one river system, each contributing to a delay in upstream and/or downstream migration, and possible loss of spawning or nursery habitat, then there is a high risk that cumulative impact will be unsustainable. This aspect has not been examined by NIEA.
2.6The need to protect eels as exemplified by the EU Regulation needs to be recognised and observed. None of the issues regarding eels have been either examined or assessed in hydroelectric applications. Reasonable examination is neededto protect eels.
2.7The protection of rivers which have been designated as SACs - Special Areas of Conservation - by NIEA has been almost non-existent, as this is a threat to the promotion of hydroelectric development.
2.8The UKTAG Guidance on the protection of waterways is wholly inadequate; see Appendix 1
A number of organisations are now critical of the lack of protection offered to rivers; The DCAL Salmon and Inland fisheries Advisory Forum, The Institute of Fisheries Management, the Salmon and Trout Association, The Loughs Agency. More organisations are adopting this view as the ramifications of current NIEA policy become apparent.
2.9NIEA have broken their word on the issues of cumulative impacts, and the provision of a Q80 Hands Off Flow on salmonid waters. We are now informed that these assurances are subject to all sorts of “get out clause“ qualifiers which mean that the original assurances are meaningless.
3Examples
3.1NIEA have licenced a hydroelectric scheme on the Ballynahinch River which will take up to 90 % of the water out of the river, leaving a stretch of the river at low summer levels for some 65 % of the year.
3.2NIEA are going to licence at least 7 hydroelectric developments on the river Roe alone, leaving at least 8 km of river denuded of flow, and do not intend to examine the cumulative effects of this.
3.3NIEA’s own hydroelectric development scheme on the River Roe is in breach of two EU Directives; the Water Framework Directive, and the Habitats Directive.
3.4NIEA has applied for Derogation from the Water Framework Directive on it’s own River Roe scheme as the dewatered stretch is too long. There is at least one other private hydroelectric scheme on the River Roe which also is in breach of the Water Framework Directive for the same reason. As a result, NIEA will now be unable to enforce the Water Framework Directive and will have to grant a Derogation to this private operator. All this on an SAC designated as such for salmon.
3.5NIEA has ignored the effects of climate change on the river Roe, and hence its analyses to date are fundamentally flawed.
3.6NIEA generally makes no comment on, or response to, submissions by outside bodies, and do not inform anyone of their decisions.
4A New, Balanced Approach is Needed
4.1NIEA has presumed all judgements in favour of hydroelectric development. This needs to change so that NIEA takes a reasonable, balanced, independent stance.
4.2NIEA need to change their outlook, to give some reasonable degree of protection to rivers and their environment.
4.3It is unreasonable that the Working Group to provide Development Guidelines excludes any input from NGO conservation organisations such as The Ulster Angling Federation.
4.4The almost complete exclusion by NIEA of the Loughs Agency and anglers from decision making on hydroelectric development, and the partial exercise of its powers to the exclusion of conservation considerations, is not reasonable and needs to change.
4.5 NIEA need to start making a reasonable response to submissions, and inform other bodies of their decisions instead of keeping them secret.
APPENDIX 1
From “Response by Wildlife and Countryside Link to the Consultation on Directions to the EA for the Classification of Water Bodies”.
“Link believes that all ‘consultation’ on classification undertaken so far has been fundamentally flawed. We have experienced extreme frustration and dissatisfaction with the two ‘technical reviews’ held by UK Technical Advisory Group (TAG) on their development of the standards for classification. As a collective of NGOs supported by 8 million members and employing significant specialist aquatic knowledge, we invested a great deal of our limited resources in compiling a detailed critique of these standards. However, despite our efforts, no changes at all have been made, and in the case of our comments on the UKTAG guidance on Good Ecological Potential, the submission from the RSPB was not even acknowledged, and there has still been no response even after resubmission. This experience reflects most of our dealings with UKTAG, which we have found to be an impenetrable and uncommunicative body.”
From“Response by Wildlife and Countryside Link to the Consultation on River Basin Planning Guidance.”
1 Introduction
“Taken as a whole the standards, compliance regime and questionable interpretation of ‘disproportionate cost’ and ‘technical feasibility’ appear to be an attempt to minimise change rather than maximise benefits. Such an approach will do nothing to increase the resilience of the water environment as it struggles to cope with the combined pressures of development, abstraction, pollution and climate change.”
A regulatory regime must be based on standards. No one would disagree with this, however, we remain dissatisfied with many of the standards that UKTAG has developed. Overall we have the impression that a desire to minimise change means that the UKTAG have sought to
distort the interpretation of the WFD to fit their existing monitoring and classification schemes rather than change their business model to fit the fundamental challenge set by the WFD.
In particular we are concerned that the UKTAG approach seems to be over emphasising the weight of physico-chemical determinands rather than introducing new ecological and hydromorphological based standards to assess water body status, in line with the ecological approach of the Directive. We are also uneasy that proxies are being used for some biological quality elements where there is little ecological justification.”
“It is clear when a river dries up that this causes serious environmental impacts”!
References
Butterworth, Dr A. J. June 2008 The Green Energy Gold Rush Journal of the Institute of Fisheries Management
Butterworth, Dr A. J. 2009 Hydropower; The Effect of Flows on Fish Populations and Continuity (personal paper)
Butterworth, Dr A. J. January 2010 Salmonids, Hydropower and Flow “Managing River Flows for Salmonids Conference Proceedings (York)
Cowx & Frasier 2003 Monitoring the Atlantic Salmon Conserving Natura 200 Rivers Monitoring Series No. 7
DCAL/DETIMay 2001 Small hydro-electric Schemes - Impact on River Fisheries in NI; Response to the Study Recommendations and Public Consultation
Hendry & Cragg-Hine 2003 Ecology of the Atlantic Salmon Conserving Natura 200 Rivers Monitoring Series No. 7
JNCC Version August 2005 Common Standards Monitoring Guidance for Freshwater Fauna
NIEAJune 2009Environmental Impact Assessment for the Roe Valley Country Park Hydro-Electric Power Scheme.
Petts, G. and Gray, J. 2009“E-flows” to Protect Salmonid Rivers Gamefisher
Autumn 2009
Solomon, Milner, Smith January 2010Migration into and Through Rivers
“Managing River Flows for Salmonids Conference Proceedings (York)
UKTAG UK April 2008 Environmental Standards and Conditions (Phase 1) Final Report (SR1-2006)
UKTAG UK December 2007 Recommendations on Surface Water Classification Schemes for the Purposes of the Water Framework Directive
Various departments within the Irish Government; October 2007 Guidelines on the Planning, Design, Construction and Operation of Small Scale Hydro-electric Schemes and Fisheries
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