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.
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.
The Forestry Commission Scotland has just launched what it is calling ‘Residual Offerings’. This is the latest in a series of opportunities offered on the National Forest Estate in Scotland. It is available for applications by both commercial developers and communities and covers hydro, wind, solar photovoltaic and geothermal energy generation. You can read more on the Forestry Commission website about this new opportunity here and read the detailed guidance document here
The new Good Practice hydropower guidance for England is now live on the Environment Agency’s website: http://www.environment-agency.gov.uk/business/topics/water/126575.aspx
and for Wales: published on the Natural Resources Wales website today http://naturalresourceswales.gov.uk/apply-buy-report/apply-buy-grid/water/abstrations-impoundment/hydropower-scheme/?lang=en
From this point forward the pre-application advice for all new hydropower enquiries will be based on the revised guidance.
Twelve weeks after publication, on Tuesday 1 April 2014, the revised guidance will become the basis for the EA's determination of permit applications for any new hydropower schemes received and accepedt as valid from that date.
The full list is available from Ofgem here (2 large Excel spreadsheets):(FULL OFGEM FIT REPORTS available here: https://www.ofgem.gov.uk/publications-and-updates/feed-tariff-installation-report-30-september-2013)
I have extracted data for hydro installations in this spreadsheet (also in pdf format here)
Analyses of this data for micro hydro schemes (<=100kW) commissioned from 1 April 2010 to 30 September 2013 are given below:
The Environment Agency board will be making their decision on whether to accept the recommendations from the Good Practice Guidelines consultation this Thursday 17th October. Board papers can be found here.
The MHA will be making a response and posting it, prior to the final meeting We welcome any comments or feedback should you wish to have them included in the MHA repsonse.
DEADLINE FOR RESPONSE: 20 DECEMBER 2013
CONSULTATION ON ENVIRONMENT AGENCY CHARGING PROPOSALS FROM 2014
We invite you to comment on our charging proposals for 2014.
The licensing of ‘New Authorisations’ (currently exempt abstractions) is a requirement under changes made to the Water Resources Act 1991 by the Water Act 2003. When the regulations come into effect in April 2014 we will be required to licence previously exempt abstractions (‘New Authorisations’) resulting in an estimated 5,000 additional licence applications over the following 2 years. Currently these applications will attract only the £135 application charge and no ongoing subsistence charge.
This presents a new, largely unfunded workload and therefore to help address this we propose one of the following options:
· to introduce a new abstraction application charge of £1,500 for those permits where there is no requirement to pay ongoing subsistence charges, or
· to charge subsistence for all transfer licences in addition to the current application charge of £135.
Both of these options would take effect from 1 April 2014.
This consultation is in line with the government’s revised consultation principles and will run for 12 weeks from 27 September until 20 December 2013. All responses must be received by 20 December 2013.
The consultation documents and its annexes are available to download online – please copy and paste the following link to your browser:
Please contact us on 01179 345093 for a printed version of the consultation document.
We would prefer you to respond online. However, if you would rather respond by post, please send it to:
Charges Programme Manager
Horizon House, Deanery Road
Bristol. BS1 5AH
Or email your response by the closing date, using the response form, to:
After the consultation, we will review all responses before presenting our final proposals to the Secretary of State for Environment, Food and Rural Affairs. They will consult with other government departments, before a final decision is made. For EU ETS charges we will require the approval of the Secretary of State for Energy and Climate Change.
You can also find more information about our charges and charging schemes by accessing:
I look forward to receiving your response.
Director of Finance
NEW G83/2 standard for Grid connection <16A per phase (please visit the ENA website at this link if you have previously downloaded the draft engineering document from the Useful Information Page before). This standard comes into force from March 2014. In the mean time you can use the G83/1 standard and procedures when applying for a connection of <16A per phase.
Western Power have published this useful summary of the changes
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