According to the European Commission, three tests must be applied to hydro power to exempt it from having to make improvements to the water environment under the Water Framework Directive. These are:
1) Are alternative forms of generation technically impossible?
2) Are alternative forms of generation prohibitively expensive (we understand this applies to the member state rather than to individual companies)?
3) Would alternative forms of generation produce a worse overall environmental result?
With respect to the suggestions we have outlined for restoring the River Garry, in our opinion, the answer to all three questions is a resounding NO.
It is quite clear that the paltry amount of energy under consideration could easily be replaced by alternative means, a mere 3.5 windturbines or so.
Given that the River Garry is one of the top rivers impacted by anything in Scotland, it is hard to imagine how say another 3.5 wind turbines in Scotland, or indeed another 2 wind turbines out at sea, could produce a worse environmental result.
It is highly significant that, only recently, under their new powers over abstraction, SEPA refused an application by NPower Renewables to abstract water from the River Braan for a new run-of-river hydro scheme. This hydro scheme was projected to produce 11.6 GWh per annum, about half that required to restore the Garry.
Among the considerations on which SEPA refused the application was that the same amount of generation "can be achieved by other means which are a significantly better environmental option, and SEPA has no evidence to suggest that such means are not technically feasible or involve disproportionate cost".
Indeed, the capacity of this hydro station would have been less than that of two windturbines, of which 166 have been proposed within the Braan catchment alone!
This decision by SEPA sets an important precedent, clearly demonstrating that the Three Tests support the loss of some hydro generation for the restoration of the River Garry.
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We believe that, because the small amount of electricity required to restore the Garry can easily be replaced by other renewable means, European Law demands that the River Garry be restored.
If you also believe so, let your views be known!
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