Say no to hydro power on the Afon Conwy in the Snowdonia National Park

Archive for ‘August, 2016’

So it has happened again. RWE have resubmitted the planning application for a hydroelectric power station on the Afon Conwy. Save the Conwy has spent the last week pouring over the hundreds of pages of information. The application contains some further information deemed missing from the previous one but essentially describes the same scheme. There is no change in the size or position of the infrastructure, the power that will be produced or the amount of water taken. The application can be viewed below:

http://goo.gl/kb2Wj8

As a result Save the Conwy along with all associated groups;

Snowdonia Society, North Wales Wildlife Trust, Woodland Trust, Canoe Wales, Betws y Coed Anglers / Gwydir Fisheries, Campaign for National Parks, National White Water Centre, Snowdonia Active, Plas y Brenin National Moutain Centre, BMC Cymru.

feel this application must be strongly objected to and need your help to do it. This is a brand new application and even if you objected last time and your objection letter is still valid in all its’ points it must be sent again with the new reference numbers and scheme description.

A template letter head can be found below.  Make sure you add your own name address and it is obviously only a letter head, add the details of you own objection below. The letter can be posted or emailed.

Use this letter template to object.

Please object and let the RWE know that we will not lose interest in preserving our National Park and that we will be here to fight for it however often they try. Let the National Park know that people want Snowdonia to be protected and not exploited for its’ resources and that some places are too special for any form of development.

Think about what is important to you, the community, the environment and the national park. Some topics you might want to cover:

The National Park is the wrong place for a scheme of this size:

The Snowdonia National Park set out criteria for new developments in their development plan

See http://www.eryri-npa.gov.uk/__data/assets/pdf_file/0004/184684/ELDP-Final-6.1.12.pdf

The section on energy states

3.19 Whilst large-scale energy power generation projects are incompatible with National Park status an assessment of renewable energy in Snowdonia considered that scope might exist to contribute to reduce demand for electricity derived from fossil fuels through efficiency savings and through small-scale renewable energy developments to meet domestic or community needs. These included small-scale hydro, domestic wind turbines, photovoltaics, biomass and landfill gas.

Although the power produced by the scheme is low, set at 5MW to avoid immediate dismissal by the national park and to allow it to take advantage of very generous FIT payments meant for households and farms. The damage and infrastructure is the same as that for a much bigger scheme. A £13 million pound project by a foreign owned power giant is not a “small-scale renewable energy developments to meet domestic or community needs”. Snowdonia’s power needs are already met by the existing 82MW of installed hydro making Snowdonia a net exporter of renewable power.  From the same document:

The 20 or so hydro power stations which are located in, or use water from, Snowdonia have a combined total installed capacity of some 82 Megawatts (MW). This is far in excess of local demand and results in the area being a net exporter of electricity.

All power produced is therefore to full fill needs outside of the park, not for “domestic or community” needs

-No thought for decommissioning:

There is a legal requirement for all schemes such as this to have plans in place for decommissioning, including a financial bond set aside to finance it. RWEs statement on decommissioning is:

EIA Vol 1 5.9.5

The removal of in-river intake weir and tailrace would potentially result in more damage to the environment than leaving them in situ.  Hence, subject to the decommissioning requirements of a planning related condition, it would be prudent to make them safe and leave in-situ.

This is clearly unsuitable as the most damaging aspect of the infrastructure, the weir, is to remain in river and there is no financial bond.

-Damage to the environment:

This will occur both during operation and construction. The proposed development will affect a SSSI containing many section 42 listed species (species listed as of principle importance for conservation of biological diversity in Wales) therefore the SNPA as the planning authority have a responsibility to protect them. There is no longstanding or peer reviewed published scientific research on the effect of hydro schemes on such a site and using a pre-cautionary principle as required would suggest that this scheme should be refused.

-Loss of recreation:

Details regarding the damage to kayaking can be seen here

https://savetheconwy.com/2013/12/07/how-will-the-scheme-affect-kayaking/

The river is one of the major Salmon spawning rivers in Wales / the UK to risk damage to such an environment through reduced reach and the insertion of manmade barriers is absurd. Fishing is a major recreational pass time and creator of income for the local area, rivers on which it depends either directly or indirectly need protection.

-Damage caused to local communities during construction:

This will be the one of the largest private construction projects ever to have been built within the National Park.The scale of disturbance and damage to local communities during the construction period will be immense. Construction is proposed to last 18 to 24 months but looking at RWEs record on the Dolgarrog refurbishment it is certain to be longer. Our Planning Engineer estimates that digging the tunnel section alone will require the removal of over 6300 mof rock, equivalent to 1400 18 wheeler lorry journeys on one of the narrowest sections of the A5. This section of the A5 is used by visitors from England to visit Snowdonia and the upper works will occur at the access junction to the community of Penmachno. With large depot areas at the top and the bottom of the Fairy Glen the area will become a construction site.  How many local businesses reliant on tourism can survive 2 years of disruption?

-Limited Benefit:

There are few perceived upsides to this scheme. The level of power produced is small and variable. Using RWEs own figures the peak production of 5MW is equivalent to less than 2 modern large wind turbines and the scheme will only produce this for a maximum of 54 days a year. Due to the schemes reliance of river levels for an estimated 128 days it will produce nothing at all. It is difficult to justify the environmental cost of this scheme even in relation to fossil fuel power stations. See

https://savetheconwy.com/2015/03/28/better-than-a-power-station/

After the construction is finished (around 2 years) no significant employment is likely to be created by the scheme for the rest of its existence (the RWE scheme in Dolgarrog has run for around 90 years) and it will be run remotely from an existing RWE control centre.

RWE plan around 100m of new path to enhance the area and a short section of existing path will upgraded to provide disabled access. However an existing footpath will be used as a construction road during the building of the scheme and the area around the construction site will be closed to walkers during the construction period

robert steele

 

 

17 Comments

Thanks to everyone who wrote to the National Trust with concerns around the Conwy hydro-scheme and their hydro building policy within Snowdonia.

Save the Conwy have received a reply from Justin Albert (Director National Trust Wales) through Elizabeth Wagstaff at Business Management. Interesting department to get a reply from; not direct from the director or from an environment committee but from buisness management. That in itself shows a lot about how the National Trust think of the Afon Conwy; a business asset.

From what we can tell it is the same reply that everyone who wrote received regardless of the nature of their concerns. We also received a slightly edited version of this response from Dame Helen Ghosh (Director General) as well. This reply is attached  below along with our original letter.

Letter from Justin Albert

Save the Conwy’s original letter to the National Trust

It can be seen the National Trusts reply raises more concerns than it answers. Please take the time to read our response below, also attached as a pdf.

Save the Conwy reply to the National Trust

Dear Justin Albert


Save the Conwy and Snowdonia Society have (alongside many individuals) written to the National Trust asking them to engage with us about our various concerns. Recently we received a letter in return from you, through Elizabeth Wagstaff at business management. The same letter was sent to everyone who wrote despite the different concerns raised. A slightly edited version of the same letter was also received from Dame Helen Ghosh. Due to receiving the same reply as others with different concerns it is obviously impossible to know if you have actually read our submission or not. I would take this opportunity to respond to specific points in your reply.

We have fed into the hydro proposal and design since 2012 and have always been very conscious that any involvement must be carefully considered at all stages, and that we must listen to representative community voices in the area and more widely.

This has not happened, apart from a brief appearance at an open day held by RWE there has been no communication with the community at all.

We have recognised that standing aside from or opposing the scheme would not have stopped its development, and that it would have been simply moved further downstream to an area where we believe it would have a more damaging aesthetic and ecological impact. At present we have not seen any evidence that our actions or decisions in this respect have been wrong.

I am unsure where this information has come from, presumably Keith Jones. It is entirely incorrect. The intake is to be built just upstream of the Penmachno Bridge, immediately after this the Conwy plunges down a steep cascade into a deep gorge.  There would be no possibility of creating an access road to construct the intake weir downstream and no way of routing the pipeline from this point. Even if moving the intake downstream was possible it would significantly reduce the vertical drop thus reducing financial viability. With regards to the pipeline, if this was not tunnelled through the National Trust owned Dinas Mawr, it could only travel under the A5, unlikely to be approved by Welsh Highways, or laid on the surface through the SSSI, unlikely to be approved by NRW. It is also undeniable that the National Trust has lent credibility to a scheme proposed by one of the most heavily polluting companies in the world.

We are reassured that Natural Resources Wales, as the statutory consultee to the proposal, and as the government body responsible for protecting the environment and its natural resources, has considered potential impacts to the SSSI, Protected Species, Protected Landscapes, environmental pollution as well as access and made no objection so far to the scheme. We are further reassured that the Snowdonia National Park Authority, in line with their core purpose and statutory duty will judge the social and economic impacts of this RWE Innogy proposal.

I am shocked by this statement. The National Trust is involving itself in a major energy project in a SSSI. It is in partnership with RWE, a multinational power company that does not have a glowing reputation for social or environmental responsibility. Yet it is totally absolving itself of any concern for the effect on the habitat of the Fairy Glen or the community that surrounds it. Why is this all left to the statutory bodies to consider? Does the National Trust not have its’ own experts it can consult on environmental matters? Should it not hold a higher standard for conservation and community protection than the government appointed bodies?

In recent years we have worked collaboratively with individuals and community groups who have developed hydro power installations, including tenant farmers, community groups such as Abergwyngregyn and Bethesda in Snowdonia, and we feel we have always been open, transparent and consultative in our approach.

There can be little criticism of the National Trusts support of community energy projects; especially those such as the Ynnis Ogwen scheme in Bethesda being built in a post industrial site. You have to see that this is completely different to renting out land left in trust to a multinational energy company to build a scheme 50 times larger (by installed capacity) in an unspoilt river system.

As regards the distinctly separate matter of the Trust’s own renewable energy strategy, I warmly invite you to meet our colleagues at Hafod y Llan in Nant Gwynant, to discuss completed schemes that have been hailed as exemplary from many quarters, as a way to perhaps better help understand our energy vision.

The Hafod y Llan scheme has indeed been held up as exemplary particularly by the Trust itself. Again I struggle to see the comparison between a small scheme on an upland stream which is relatively sterile due to former mining works and the Conwy scheme; many times larger on a lowland major river and containing highly sensitive and nationally import habitats. I feel I understand the National Trusts renewable energy vision but please correct me if my understanding is incorrect. The Trust is placing hydro schemes on rivers across Snowdonia and renting land to a multinational power company to do the same. However the Trust does not use a single Watt of the power these schemes produce. This power is all sold to the grid claiming the high rate FIT payment scheme. The National Trust then buys standard mix electricity (including fossil fuel and nuclear generated power) at far lower wholesale prices. This energy policy could at the most generous be described as a form of offsetting but is effectively profiteering. I know some of the electricity generated in the community based schemes the NT assisted in will be used locally but this is not the case in the Conwy scheme or many of the NT owned and operated schemes.

Please be assured that we will continue to act in such good faith to all sides in this ongoing discussion and will keep an open mind with regards to any changes to the proposed development, or any new evidence.

The recreational users, environmental groups and local communities in objection to the Conwy scheme feel they have been involved in no discussion with the National Trust and that “good faith” has been entirely absent. To rectify this I would invite you to visit Save the Conwy and members of the local community and other objecting groups at the site of the proposed development so you can fully understand our concerns



Yours Sincerely


Save the Conwy


Keep the pressure on a key player in the inappropriate development of this beautiful river. Email them at the addresses below and post and comment on their social media feeds.

justin.albert@nationaltrust.org.uk

helen.ghosh@nationaltrust.org.uk

https://www.facebook.com/NTWales/

Fletch

 

 

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