We wish to submit our views on the work of the Environment Agency insofar as it affects the aims and objectives of our Society. The Society For The Protection Of Ancient Buildings (SPAB) (Mills Section) is a registered charity which is frequently called upon to give advice to Local Authorities, mill owners and members of the public on the preservation of the rapidly deteriorating heritage of wind and watermills in England. We also have a National responsibility to comment on planning applications relating to mills that are listed buildings.

  We have over the years had contact with the Environment Agency, particularly over matters concerning the use of waterpower. After much internal debate and some discussion with the agency we wish to make the following points.

  1.  The Environment Agency is inconsistent in the way it treats watermills

—  There are widely different attitudes in the regional offices.

—  There is a lack of communication between the different departments of the agency.

  2.  The Agency fails to recognise the importance of mills

—  There is insufficient recognition of historic buildings and structures.

—  There should be a presumption in favour of the retention of the traditional and the historic.

—  There is a total lack of recognition of the inviolability of milling rights.

  3.  The Agency should recognise the value of hydro-power

—  The use of hydro-power generally has wide benefits and should be actively encouraged.

—  The Agency should have a more positive attitude towards the use of existing mill sites for power development.

  4.  The Agency fails to consult the SPAB sufficiently

—  The Mills Section has more members who are directly associated with water mills than any other body.

—  The Agency lacks expertise and experience of operation of historic water powered sites and of hydro-power in general.

  5.  The Environment Agency should be more flexible about fish management

—  There is an unwillingness to accept scientific evidence that waterwheels or turbines do not harm fish.

—  The Agency should be more flexible about the location and specifications of any smolt screens that are needed.

—  The introduction of fish ladders must be much more sympathetic to historic mills and structures. It is important to avoid damage caused by introducing alien features and placing them in inappropriate locations.

Mildred Cookson

Chairman SPAB Mills Section

October 1999