RWE have finally submitted planning to the National Park for the Conwy hydro scheme. Canoe Wales are planning their response and want to hear from as many kayakers as possible to include their views. Please email info@ukrafting.co.uk and mark the subject Hydro response. Here is Save the Conwys :

Dear Nigel

Thanks for asking for responses from kayakers to better inform your judgment on the proposed hydro scheme on the river Conwy. Save the Conwy have many concerns regarding the scheme but for the purpose of this email I will stick to those regarding Kayaking.

Two sections of river will be effected the Middle Conwy from Rhydlanfair bridge to Penmachno bridge and the Fairy Glen from below Conwy Falls to Beaver Pool.

Effects on the Middle Conwy

This section of river is generally grade 3/4 with 2 harder 4/5 rapids. It flows through stunning woodland parts of which are protected as a SSSI and parts classed as ancient woodland. It was rated 4 stars in the original guidebook and is one of classics of Snowdonia’s whitewater.
The effect on this section would be limited to a section near the egress. Here a 1m high weir will be built across the width of the river along with an access track for construction and maintenance vehicles.

The concerns regarding this are twofold

– The safety context of building a new weir on a river so widely used, especially by kayakers who are often improvers and still developing their skills. Weirs are renowned as one of the most dangerous river features and are responsible for a number of fatalities each year.

– The ruining of the tranquil , natural view at this point with kayakers and canoeists last memory of this stretch of river being that of a built environment. RWE are obviously aware of this , from the planning document:

6.4.73
Canoeists: There will be significant visual effects on canoeists where they exit the River at the new intake site during construction when access will also be limited. In the longer term, the new wire and its associated structures will introduce a new large manmade feature into the river valley with the potential to significantly affect visual amenity. However due to the limited number of people who will be affected by the change, and that some improvements are expected in the recreational pursuit due to the new access arrangements, the effect on visual amenity is not considered to be significant.

We personally do not feel that because the number of people accessing a site is limited that beauty is diminished or of less significance. The improvements suggested in the recreational activity are both limited and false as shall be discussed later.

Effects on the Fairy Glen

This section of river is generally considered grade 4/5 at the levels which will be affected by the scheme. This river is considered the classic test piece section of whitewater not only in Snowdonia but across the whole of the UK. Due to the large catchment it flows more often than any other river of this grade in Wales and is a leading draw for kayakers travelling to the area. This section was rated 5 stars in the original guidebook not just for the quality of the whitewater but for the stunning unspoilt gorge through which it flows.
The main concern for this section of river is a reduction in days the river is runnable due to the planned abstraction. RWE’s original plan was to remove up to 5.8 m3s-1 from this stretch this would reduce the number of days the river could be run from an average of 121 (33% of the time ) to 69 days (19% of the time) a reduction in 51 days or 42%. It is important to note that these lost days are at the lower rates of flow when there are often no other rivers of a similar grade available. Please see the calculations for these figures here.

https://savetheconwy.files.wordpress.com/2014/02/final-appendix_a_impact_of_afon_conwy_on_kayaking.pdf

Please note that the just released planning document quotes a figure 6.2 m3s-1 which will have a greater effect.

RWE attempt to justify this by claiming the river is paddled by a handful of expert kayakers only.

13.5.10
For those kayakers using the stretch of river below the Conwy Falls and along the Fairy Glen (approximately 1.5kms), the proposed Development has the potential to impact upon the recreational activities of such users through a reduction in water flows along the depleted reach of the river. This user group is very small comparable to the wider canoeing/kayaking community using the Afon Conwy, primarily due to the treacherous nature of accessing this stretch of the river and the very challenging nature of kayaking the gorge. It is understood from consultations that few users at periods of high flows have the capability to kayak this stretch of the river. Whilst limited to a handful of individuals, this stretch does provide some the most challenging conditions for kayaking in the UK, and is of appeal to both national and international specialists of such high grade white water conditions. Such a user group, although very small, would be highly sensitive to potential changes in water levels on the Afon Conwy as a result of operation of the Conwy Falls hydro-electric scheme.

This is no longer the case; improvements in technique and equipment have brought to the Fairy Glen a new generation of improving kayakers eager to hone their skills. This section of river is seeing more descents by a greater variety of paddlers than ever before. For those kayakers not yet able to paddle this grade of whitewater the Fairy Glen is seen as an aspirational run steeped in kayaking history and often the focus of ones goals.
Save the Conwy asked paddlers to log their descents using the Paddlebubble website. In 2014 January and February alone showed a recorded 409 descents and the total number would probably be higher.

Mitigation offered by RWE

The planning document offers mitigation to the adverse effects on kayaking the scheme will have. These are both redundant and unsatisfactory.

Reduced 13.6.6
Generation Days: the Applicant would support the agreement of reduced generation days for water abstraction for the periods 8 hours per day at weekends June to October in order to allow kayakers the opportunity to use the Afon Conwy below the Conwy Falls at high flows. In addition an egress point would be facilitated at the intake point to allow kayakers to exit the river. The Applicant will also make available on-line the river level data for the scheme that will help inform local kayakers.

-The reduced generation days are only planned for 8 hrs on a Saturday and Sunday during the Summer months. The main season for kayaking on the Conwy is through the winter. Contary to RWE’s statement below during the summer this section of river has it’s lowest amenity value. The number of summer weekend days in which there is sufficient water to run the Fairy Glen is negligible. The flow rate suggested for this reduced generation period also seems insufficient being propose at 6.5 m3s-1

5.5.45
This is based on a hands-off flow of between Q95 or 0.46m3/s during low sensitivity 5.5.45times and 6.5m3/s or Q28 when the river has greatest amenity value, based on kayaking during most daylight hours in summer weekends.

This requires the flow from the Machno being 4.78 m3s-1 to meet the 11.28 m3s-1 required for an enjoyable paddle on the Fairy Glen
(see https://savetheconwy.files.wordpress.com/2014/02/final-appendix_a_impact_of_afon_conwy_on_kayaking.pdf for calculation of required level.)
No flow data is available for the Machno from NRW and RWE provide none of their own. Local knowledge clearly shows the Machno does not reach these flow rates during the medium/low flows affected by the abstraction. RWE have been made aware of our doubts regarding their assumed flows of the Machno on several occasions.

-RWE also offer to provide an on-line gauge for river flows in the Fairy Glen to assist kayakers. An on-line gauge is already available at the Conwy Falls fish pass so this offer is completely redundant.
http://www.gaugemap.co.uk/#!Map/Summary/7932/3265

-The offer of an egress point for the Middle Conwy is deemed unnecessary by Save the Conwy and the despoiling of the natural surroundings at the egress and the danger of an introduced weir far out-weigh any advantage offered.

Save the Conwy hopes that Canoe Wales will send a strong objection to the Snowdonia National Park Authority, as can be seen the scheme will cause a massive loss to kayaking in Wales and offer no tangible benefit. The power produced by the scheme is very low and variable compared with other renewable schemes (such as the off shore wind arrays on the North Coast) and Snowdonia is already a net power exported thanks to its’ already extensive power production.

Many thanks

Save the Conwy.