I am writing on behalf of the Avon Fishing Association to object to the above application in respect of a proposed hydropower development at Gara Mill. The Association owns and rents several miles of fishing on the Devon Avon with a significant economic and recreational value. We also wish to protect the salmon and sea trout stocks of the river for their intrinsic ecological value.
Our objection is based on a detailed analysis of the application and supporting documents. It is unfortunate that Western Renewable Energy did not engage our association in pre-application discussions which could have resolved our concerns and avoided this objection. We understand that this is not the only instance of this approach being taken by Western Renewable Energy.
Our objection is on the following grounds:
1. The assessment of the fish population in the Avon for the Water Framework Directive is ‘Moderate’ with a target of ‘Good’ by 2015. There are no actions in the River Basin Plan to achieve this improvement and any threat to the fish population, such as that posed by the proposed development in its present form, must be resisted.
2. The site of the proposed control sluice is unacceptable – unless the leat is completely watertight the sluice should be at the point of abstraction to avoid losses. This is especially important given the fine control necessary at flows between Q90 and Q46.
3. The weir is reported to be in poor condition resulting in some of the flow passing through the weir, reducing the flow available for fish migration – thus the proposed Hands Off Flow of Q90 (0.546 cumecs as measured by the Agency) will not all pass over the weir – this should be compensated by a higher Hands Off Flow.
4. The proposed change to an Archimedes Screw is welcome but there is no reference to monitoring to confirm the safe passage of downstream migrants, or of the use of compressible rubber buffers to minimise fish damage.
5. The long tailrace passing under the railway line could attract upstream migrating salmon and sea trout – the tailrace design should be modified to reduce the attraction flow or provided with a 20mm screen at the outfall into the river. Again there is no reference to monitoring to confirm that upstream migrants are not diverted.
6. Given the long depleted reach the Hands Off Flow condition in the licence should be designed to protect flow variability rather than produce long periods of Q90 or less which could have an adverse impact on both fish migration and geomorphology/sedimentation.
7. In correspondence the Agency required an Ecological Assessment which included
· An ecological baseline on mammals, birds, invertebrates, plants, fish
· Changes to the hydrological regime, wetted perimeter, geomorphology, and sedimentology
· An assessment of impact on above features and any mitigation measures
The Ecological Assessment failed in a number of these and the application should have been rejected rather than passed for advertisement.
8. There is no application of the Precautionary Principle as required by the North Atalntic Salmon Conservation Organisation Treaty to which the UK is a signatory.
Please confirm that you have received this objection and keep me informed of progress of the application.
Chairman and trustee Avon Fishing Association
By email to Nick Prall, Licensing Officer, Environment Agency email@example.com