MHA response to the EA abstraction reform consultation

Please respond to the consultation here.

Below are the EA's factors relating to hydropower schemes alongside Defra's reform aims:

The EA's aims of reform are in black, the MHA's responses are in red.

• Maximise the amount of water available to abstractors; new and existing hydropower have no impact on the amount of water available to abstractors since hydropower is 100% non-consumptive 

• Promote efficient use of water through charging for actual use; new and existing hydropower have no impact on the amount of water used since hydropower is 100% non-consumptive - hydropower schemes abstract only the kinetic energy of flowing water

• Facilitate trade, maximising the economic value from available water and allowing new entrants to access water; hydropower schemes serve only to release economic value from available water with no consumption

• Provide reasonable certainty for abstractors for planning their business;  Agreed

• Protect water ecosystems in line with legal requirements, particularly ensuring that reform does not create risks of environmental deterioration; the legal requirements stem mainly from the EU Water Framework Doirective which seeks to protect and improve the status of Water Bodies.  The majority of low impact small scale hydropower schemes have no or insignificant impact on Water Bodies as defined by the Water Framework Directive so should not be made subject to the constraints imposed by the WFD or related legislation.

• Ensure the new system is able to respond to longer-term changes in water availability.  Hydropower has no long term impact on water availability as no water is made unavailable.
We want to do this in a way that minimises the administrative costs whilst still achieving our aims. This is about smarter regulation that reduces the cost to businesses of dealing with the challenges of the future. We also want to make sure we move to a new system in a way that takes into account both current licensed volumes and the amount that abstractors actually take. 

A registration process will considerably reduce the costs of licensing hydropower abstraction.