River Garry - The Water Framework Directive - Review of Licences

When SEPA do review an abstraction licence, the process, we have been told, will be a matter for SEPA as official regulators. However, contentious proposals will be advertised after SEPA has formulated its own opinion and only then will wider third party views will be sought. Ultimately the final decision in controversial cases will rest with the Scottish Government. The Scottish Government will also ultimately sign off each River Basin Management Plan. It is not clear to what extent the Scottish Government may be involved in directing SEPA’s review process, but this presumably may occur.

However, it seems quite clear that the Directive intended the full participation of society when considering improvement measures. The European Commission's website states that:

" Caring for Europe 's waters will require more involvement of citizens, interested parties, non-governmental organisations (NGOs). To that end the Water Framework Directive will require information and consultation when river basin management plans are established: the river basin management plan must be issued in draft, and the background documentation on which the decisions are based must be made accessible.....Too often in the past implementation has been left unexamined until it is too late - until Member States are already woefully behind schedule and out of compliance." 

It was initially hoped that much might be delivered by the first, the 2009, Scottish River Basin Management Plan. It is now clear that it will of necessity be of relatively limited scope owing to the relatively short timescale now available and because SEPA have still a significant amount of preparatory work to do to administer this process.

While there may not be time to consider activities which impact on rivers in a complex way (e.g. ecological impacts downstream of reservoirs), we think there is a lot which could still be achieved in the first, 2009, Plan, especially with regard to water abstraction where the effects and remedies are often very apparent.

We think that an effort really should be made to make significant gains in this area first time round. Otherwise the first Scottish River Basin Management Plan may be in danger of delivering very little! The European Commission's quote "woefully behind schedule and out of compliance" springs to mind!

Since there seems little official scope to directly influence SEPA's review process the most obvious way for third parties to exert influence must be to make representation to the Scottish Government direcly.  This is exactly what hydro operators have been doing.

 

view from upstream of an abstraction weir

....upstream

      downstream....

view from downstream of an abstraction weir

The remedies to hydropower abstractions are often immediately apparent. All the flow is being taken? Then open the sluice!

There should be no technical reasons why overabstraction like this cannot be addressed in the first Scottish River Basin Management Plan.

 

 

Read More - Representations by hydro operators

 
   


Tay District Salmon Fisheries Board, Site 6, Cromwellpark, Almondbank, Perth, Perthshire, PH13LW.
Telephone (01738) 583733 . (Mobile) 07974 360 787 .
Fax (01738) 583753 (Please call beforehand as the Fax is usually turned off to avoid spam)

   

 

© Tay District Salmon Fisheries Board 2005, 2006, 2007