1.  HYDROPOWER

  A.  The Environment Agency consider that the diversion of water adjacent to a fall (a weir) in the river is an abstraction although all the water is returned to the river within seconds. The Agency usually require this flow to be measured. These two requirements are patently absurd and constitute an unreasonable demand and an unwarranted mitigation, effectively a penalty against a developer of hydropower daring to promote sustainability and renewable energy.

  B.  A further point without doubt emanating from the Agency is that decision by the DETR to limit abstraction licences to 15 years. Many hydropower sites cannot pay back their capital outlay in this time.

  C.  The conclusion drawn from these points is that the Agency is utterly opposed to hydropower and particularly so if the developer is a small company or community based. The alternative conclusion is that the masters of the Environment Agency, HM Government, is itself opposed to sustainability and renewable energy.

  D.  Perceived by environmentalists and sympathetic developers, the Agency presents itself in the following ways:

(a)  demand for "mitigation" and actions such as for fish passes when there were none over low head weirs and no fish, such rivers being subject to statutory pollution;

(b)  abstraction and abstraction licences for small "round the weir" hydropower schemes;

(c)  demand for a fixed maximm use of water when a greater quantity of water is actually available, any excess of the permissive maximum being allowed to flow over the weir.

(d)  general opposition to change in the infrastructure of the river by:

(1)  opposing hydropower schemes;

(2)  opposing changes to weirs to facilitate hydropower schemes;

(3)  allowing excessive, fastidious and petty priorities for fishing, conservation, recreation, navigation and flood defence to the detriment of hydropower.

(e)  most engineers and project managers expect the answer to their requests to be no;

(f)  no incentive to "developers" of hydropower schemes (their treatment by the Agency as something dirty and no understanding that only developers are able to undertake such work, because of the Market Place and such development being outside of the remit of Local Authorities, the Environment Agency, etc);

(g)  bureaucratic behaviour, long delays, evading the real issues of Climate Change, sustainability, and sustainable energy;

(h)  considers that a viable scheme to be one that gives a five year payback (which until the Agency understand that hydropower is long term, not part of the world of Venture Capital but that of a 10 to 20 year investment, there will be no small hydropower schemes).

—  The strength of support of the Agency for hydropower is weak while its understanding of hydropower is poor.

2.  RADIOACTIVE WASTE

  A.  Of considerable concern is the spread of man-made radioactive material in the environment. This point is not particularly prompted by the ghastly accident in Japan in Tokaimura this week. It is doubly brought home to me following my return from Japan on 4 August this year, and the concern I have for my friends and colleagues there who all suffer from the undeveloped nature of Environmental Regulation, ignorance or the laissez-faire attitude of government and industry.

  B.  Concern that there will be a spread of diluted radioactive waste on agricultural land.

—  No diluted radioactive waste at whatever exemption level shall be spread on agriculatural land.

  C.  This is a widely misunderstood subject but full of horrifying dangers, hidden from us all. Without doubt our sea shores and estuaries are becoming contaminated to an unacceptable degree and quite unforeseen. Still the word is sent out: negligible!—but it is not true.

  D.  The process of diluting man-made radioactive material into metal for sale on the open market for use in the food canning industry has been approved by the Chief Executive of the Environment Agency himself. This is unbelievable. I believe that Mr Gallagher has been misinformed and that radiation is a subject beyond the skills existing within the Agency.

—  I am bitterly opposed to a relaxation of standards and a deliberate dilution to enable a massive distribution of low level radioactive waste material into the natural environment, be it on the land, in the sea, in the air, or contained within the infrastructure of the built environment.

3.  THE LOWER SEVERN AREA

  The Lower Severn Area, Environment Agency, has produced a consultation document. The consultation document, The Severn Vale, Local Environment Agency Plan is well presented and offers an insight into the workings and thought of the Environment Agency. Mr Forbes and his team are to be congratulated for the presentation and further, thanked for their work in protecting the environment.

  I submit these points respectfully and humbly suggest that they may be taken into account while appreciating my deep concerns particularly with radioactive waste.

October 1999