The SOUTH SOMERSET HYDROPOWER GROUP has issued this paper in response to the EA charges for abstraction consultation.
They would like people to lobby their MPs in response to the following email chain, which appears to show that the EA Directors have made decisions on the outcome of the consultation, prior to any evaluation of the consultation responses.
Suggested email to send to your MP:
Below is a reply received from the EA on behalf of one of the Directors of the SSHG and Mr Battersby's further email to Lord Smith.
The EA Board being asked to approve the charges before the consultation process has been completed is totally unacceptable. It is clear that the EA has not followed the spirit or the letter of the Consultation principles: guidance document published on the Government web sit
On examination of the papers sent to the Board, http://www.environment-agency.gov.uk/static/documents/Agenda_and_papers_for_6_February_2014_board_meeting.pdf the only reference that we could find on abstraction charges appear in the income projections for the next three years on page 40, which remain static at £119million per annum.
It would appear that the issue of increasing the charges was brought forward under AOB with no forewarning and therefore was an unplanned item for that meeting. If this is correct it is disgraceful and goes against all Corporate Governance best practice.
Your help in bringing this latest example of EA arrogance to the notice of Government Ministers would be much appreciated.
Email to Lord Smith from Anthony Battersby, Chairman of the Mendip Power Group 18th February.
Below is an e-mail I have just received from your Agency. It fills me with alarm and despair. What is the point of going out to consultation, taking up the time of a lot of people who responded, if decisions are going to be taken BEFORE the outcome of the consultation has been published.
Did the Board receive a copy of the consultation analysis before its meeting on 6 February? As far as I am aware and as far as the South Somerset Hydropower Group has been told, the consultation had not been analysed by 6 February.
To those of us who care about the development of hydro and the reduction in CO2 emissions, this looks like a cynical charade.
Hydropower is NOT an abstractive industry and it is outrageous that the EA is treating it as such.
It is totally counterproductive to lump hydro, the one activity that actually contributes to reduction in global warming, with activities that significantly generate CO2.
It is reasonable that the licence fee should increase in line with inflation. It is not reasonable that it should increase by at least 1,100%, without ANY detailed justification of how such an enormous increase has been calculated.
I know you have a lot on your plate but this is an issue which needs your close attention.
On 18/02/2014 11:42, Bateman, Geoff of the EA wrote:
Dear Mr Battersby,
Thank you for your recent e mail to Richard Leafe. Richard is currently on leave and I hope the following response will help explain the situation and Richard will respond to you on his return.
The consultation on abstraction licensing charges closed on 31 December 2013. We presented to our Board proposals to apply an annual subsistence charge or to increase the application charge to those abstractions not incurring an annual charge. Currently applicants for a range of abstraction licences pay a £135 application charge and no ongoing subsistence charge. This level of income falls significantly short of our costs to carry out administrative aspects of receiving, validating and determining an application for these type of abstractions. Also, with the expected large amount of applications for New Authorisations, as a result of the removal of exemptions for some activities, we are facing a significant unfunded burden. Therefore, we must begin to recover the costs of processing and determining these applications; hydropower is one of the sectors affected by our proposals.
We are proposing a new higher application charge of £1,500 which is at the lower end of what we believe our costs to be. In line with the view of HM Treasury and Defra we believe it is appropriate that we apply the higher application charge of £1,500 against all licences that do not attract ongoing subsistence charges. Those hydropower operators that already hold licences will not incur this higher application; if they renew on a same terms basis the renewal charge will be £135.
The Environment Agency's Board at a meeting on 6 February gave approval for the proposal to introduce a new higher application charge of £1,500 for all abstraction licences that do not attract an ongoing subsistence charge to proceed. Therefore we are currently working with Defra to produce a formal submission covering all proposed changes to go to the Secretary of State for his approval. We envisage that this will progress over the following few weeks to allow us to publish and implement our new charging schemes by 1 April.
Defra and Welsh Government have published a joint consultation, Making the most of every drop.
They would like your views on the proposed changes and to understand what effect they will have on your scheme. The consultation will end on 28 March 2014. So please have your say: fill in the online survey about changes to how we manage water abstraction
Defra and Welsh Government are holding four workshops to help people understand the consultation proposals and to explore some of the issues in more detail. The workshops are in:
London - 25th February
Manchester - 27th February
Peterborough - 4th March
Cardiff - 6th March
The latest FiT report (to 31/12/2013) states the following for hydro:
Feed-in Tariff Installation Report 1 January 2013 - 31 December 2013
Hydro FiT commissioned:
Total Installed Capacity: 2,819.50kW
Declared Net Capacity: 2,790.38 kW
Hydro FiT applications:
Total Installed Capacity:2,521.90kW
Declared Net Capacity:2,491.99kW
However, there is now a new web page published by government: https://www.gov.uk/government/statistical-data-sets/monthly-mcs-and-roofit-statistics with a spreadsheet which includes accreditations and prelim accreditations, both complete and "pipeline"
This shows a very different set of figures (in total by month, not in detail by site)
It results in 20.348 MW total installed capacity accreditations of which 8.496MW relate to preliminary accreditations.
The decision of the Minister (5% degression for hydro because >12.5MW "deployed") has been made, although it would appear that only 11.85MW has in effect been deployed.
The MHA will be seeking clarification of this discrepancy.
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