Renewable Heat and Power Ltd are concerned with the development of small-scale hydro-electric generation in the UK. It is with specific regard to small-scale hydropower that we would like to make the following submission to the House of Commons Select Committee inquiry on the Operation of the Environment Agency.

  The Environment Agency (EA) have responsibility for awarding licences for the abstraction for water and, based on our experience, there are several points that we feel should be brought to your attention.

  1.  There appears to be little or no connection with the EA's rhetoric about commitment to sustainability and renewable energy sources and their actions when considering applications for abstraction licences for hydropower generation.

  2.  This lack of any real commitment to sustainability is exacerbated by there being no real expertise within the EA beyond the most superficial level regarding renewable energy in general and hydropower in particular.

  3.  The majority of small-scale hydropower schemes use existing civil works (weirs etc) where derelict mill sites once generated mechanical power over long periods of history with little environmental impact. A well designated hydropower scheme, with proper screening, should have no detrimental impact on fish. A hydropower scheme often involves the repair of a weir structure and improves fish passage as part of the development and ensures the structures remain in good condition. Nonetheless operation is often restricted and often irrelevant conditions are imposed by someone with little or no understanding of hydropower.

  4.  The EA seem to make little distinction between abstraction, where the water is permanently removed from the river course, and a hydropower scheme where 100 per cent of the water is returned to the river, usually very close to the point of abstraction. Perhaps a new type of licence should be introduced called a "diversion licence" or something similar to make the distinction clear?

  5.  One gets the impression that the EA feel that hydro-electric power owners make substantial profits from the developments. However, such small schemes are generally very marginal at best and only progress because of the owners commitment to developing renewable energy and the knowledge that in the long term (15-20 years say) the scheme will be profitable. If the EA were more aware of the marginal nature of the economics perhaps they would be more willing to allow larger quantities of water to be diverted for hydropower.

  6.  An abstraction licence typically deals with one abstraction officer, but a whole team of fisheries officers. The decision process is very diffuse; sometimes a matter seems to be settled but then later someone else raises fresh objections, nullifying previous guidance.

  In conclusion, we feel that the Environment Agency should be proactive and supportive of renewable energy and measures should be taken to ensure expertise exists within the Environment Agency, so that they can deal with renewable energy in an informed way.

Dr Robin Cotton

for Renewable Heat & Power Ltd

October 1999