Wednesday 31 October 2007
SEPA published a milestone document!
On 9 October SEPA published the Significant Water Management Issues (SWMI) report.
This report is effectively a manifesto for the types of issues the Water Framework Directive may tackle in Scotland, and the means by which SEPA may do it. It is one of the major milestones in the process of rolling out the WFD. For the first time SEPA are actually suggesting that generation may be cut in order to achieve WFD objectives. SEPA's encouraging press release can be accessed here. SEPA are seeking your views on how it should proceed. For more details please click here.
Thursday 26 July 2007
Campaign goes to Scottish and Southern's Annual General Meeting
Thursday the 26th was the day of SSE's AGM, held at Perth Concert Hall. Taking inspiration from the Hoopa Valley Tribe from Oregon,who lobbied Scottish Power's AGM several years ago, SSE's AGM was a major opportunity to get across our views on SSE's proposals for the River Garry.
Shareholders arriving at the meeting were offered leaflets outside the hall by campaigners sporting tee shirts with "River Garry sucked dry by S.S.E."
This high profile act, in itself, drew considerable attention. But inside, other campaigners who are also shareholders of SSE attended the AGM. An opportunity was provided for questions. Dr David Summers of TDSFB put it to SSE that their proposal to take even more flow from the Spey for a cosmetic flow down the Garry was unacceptable and did not accord with SSE's recent achievement of having been awarded "premier league" status for environmental management. A great opportunity was now available to SSE to do something really positive on the Garry which could earn the company a lot of respect.
The Chief Executive provided the predictable reply that SSE were engaging in the Water Framework Directive River Basin Process and that, of course, any more water down the Garry would result in a loss in renewable energy, though Dr Summers pointed out that this might in fact be a tiny amount and that the Garry was the worst example of this type of damage in the country.
However, the Chairman, Sir Robert Smith, then remarked that on starting with the company he had visited the Garry and seemed to express surprise that it comprised nothing but rocks and stones!
The point was made, however. For sure, SSE now really do know about the Garry issue, as do those shareholders present.
Thursday 12 July 2007
Comments on the letter from the Chief Executive of SSE
These comments are made in response to a letter sent to John Swinney MSP by Ian Marchant, Chief Executive of Scottish and Southern Energy, on 14 June 2007, regarding the River Garry.
The letter is mainly concerned with describing the legislative process surrounding the implementation of the Water Framework Directive, which seems pretty fairly described. However there are several issues which require specific comment.
Formal process
SSE say that fisheries organisations have chosen to step outside a formal process set up by the Scottish Executive and SEPA. The only formal process we understand is that under Section 18 of The Water Environment (Controlled Activities) (Scotland) Regulations 2005, SEPA can review water abstraction licenses and under Section 19 can request a variation of the quantity of water abstracted. We were informed by SEPA in 2006 that the review of licenses was SEPA’s concern and that third parties would only have opportunity to comment when SEPA’s proposals were advertised in the press following their review. We had hoped that this process would deliver real benefits to Scotland’s overabstracted rivers, in particular the Garry. However, this hope was shattered when we were told that SSE had, as Mr Marchant described it, “proactively put forward” proposals for re-watering the Garry. Another interpretation might be pre-emptive rather than pro-active. When we were told that SSE’s proposals, which are essentially cosmetic, had been accepted in principle by SEPA and the Scottish Executive, we were obviously alarmed. Furthermore, through the Freedom of Information Act we have discovered that SSE had been trying to influence the process since at least 2005 by requesting that Scottish Ministers “direct” SEPA to implement the Water Framework Directive in such a way as no loss in “renewable” generation is allowed. Against this background we felt that if the Water Framework Directive legislation was to stand a chance of securing real benefits for Scotland’s rivers, as it is meant to do, there was no option but to start a public campaign. Therefore, rather than stepping outside any formal process, we have merely reacted to SSE’s actions.
Engagement with SEPA and other stakeholders
While we may have chosen to publicise the Garry’s plight, we do continue to “engage with SEPA and the Scottish Executive”. We have in fact conducted our own analysis of potential implications of the WFD on all SSE’s abstractions in the Tay system. This revealed that the Garry is by far the biggest issue, and even there it would be possible to breathe new life into this river for as little as 4 wind turbines’ worth of electricity. Furthermore, on the River Lochay at Killin, as little as half a wind turbine’s worth of electricity may eliminate abstraction problems during low flow periods. We continue to be in discussion with SEPA regarding this and have had dialogue with the Scottish Executive’s Electricity Fisheries Committee. Our suggestions were also sent to SSE but no written acknowledgement has ever arrived.
Loss
of “renewable”energy
The loss of electricity generation required to begin to make the River Garry function again really is inconsequential in terms of national output and renewables targets. We really cannot take SSE’s claims about the importance of this energy seriously. Recently, SSE actually downsized seven of their existing power stations in order to get below a threshold to qualify for subsidies. This voluntary act wiped out enough installed capacity as could have balanced the fluctuations in output of a wind farm of the size of the one SSE are constructing at Drumderg. The illuminating story can be found in the pamphlet Subsidies and Subterfuge which can be downloaded from www.swap.org.uk. This document also shows how, despite original intentions to the contrary, SSE managed to edge in on the Renewables Obligation. Now, something like 16 of SSE’s existing generating units within the Tay system are generating handsome subsidies leaving only about five of the biggest stations paying their own way. Surely as the recipients of this largesse, a small loss in generation for the benefit of the environment cannot be grudged?
Accepted by Ministers?
SSE claim that reallocation of water for WFD purposes without reducing renewable energy production was a principle which was “accepted by Ministers, the Executive and SEPA.” Was it really? And if so, is this still the case? If so, it is really a sad day for Scotland’s rivers and for environmental legislation. There simply just isn’t the water to spare to even begin to properly restore degraded rivers like the Garry. Indeed we were alarmed to discover recently that Scottish Power is also investigating the possibility of cutting the flow in the River Doon (the “bonnie Doon” to Robert Burns) in order to restore some flow to the River Dee in Kirkcudbrightshire.
Salmon
The paragraph entitled “salmon” hardly merits a response. It shows that SSE is struggling to find a convincing argument. That some weaker salmon may have struggled to ascend a waterfall on the Garry 100 years ago, is hardly evidence to write off the river’s suitability. The Garry is no different from many other rivers throughout the highlands which produce salmon in abundance. There is no reason why it wouldn’t have either. There is of course one sure way of answering this question. Restore a truly sufficient flow and we shall see!
The suggestion that anglers were overfishing salmon in the Tay in the 1970s is incredulous. For every fish anglers caught during that period about five were caught in nets in the Tay estuary, not to mention those caught in nets elsewhere up the Scottish coast and on the high seas. Yet the then Department of Agriculture and Fisheries insisted that juvenile production was not being compromised by fishing. The issue of changes in survival of salmon at sea was also raised. Yes, it is the case that variations in marine survival do have a big bearing on salmon abundance and that in the two decades following the construction of the Tummel-Garry scheme the total number of salmon ascending the River Tummel did increase temporarily. However, the real issue is how many more fish would have ascended the Tummel had there had been no hydro? In the bumper years of the 1960s and 70s this would have run into thousands.
Who’s
plan was it?
Finally, it is reassuring that Mr Marchant has confirmed that the plan to put some flow down the Garry at the expense of the River Spey was “proactively put forward” by SSE. Earlier, SSE had told journalists that it was SEPA’s plan.
Friday 6 July 2007
The campaign to restore the River Garry goes from strength to strength and is now really gathering momentum.
On Friday 29 June we launched a petition at the Game Conservancy Scottish Fair at Scone Palace. The response was terrific. Since then petition forms and leaflets have been widely distributed in the area to hotels, shops, fishing huts and other businesses. Already we have had nearly 3,000 people sign up within a week and numbers will undoubtedly continue to grow through the summer.
For more information on the petition click here
The campaign has now attracted the involvement of local politicians. John Swinney MSP has written to Scottish and Southern Energy and this resulted in a reply from SSE's Chief Executive which has been posted on their website. This does merit a riposte which will be posted soon. John Swinney has also written to the Environment Minister and a response is awaited.
Meetings have been held with another MSP, Murdo Fraser, and the local MP, Pete Wishart. Both can see the advantages of restoring the River Garry and are also working to try and secure a sensible solution.
We have also been greatly encouraged to receive explicit support from Perth and Kinross Council.
In a letter to the Board, the Head of Economic Development, wrote that “the restoration of the Garry would bring environmental, social and economic benefits to the area and would help encourage anglers back to Perthshire.” He also said that “whilst the Council is committed to promoting the use of renewable energy, given the small contribution the water from the Garry makes to electricity production, we feel that, on balance, it will be more beneficial to restore the Garry to its full potential.”
Thursday 14 June 2007
It is now two weeks since the campaign to restore the River Garry went public.
The response so far has been tremendous.
Excellent coverage has been achieved in the media and this has sparked considerable support both locally and further afield for the campaign. We intend to keep up the profile and there is no doubt that support will continue to grow.
Considerable political interest has also been generated and, with continued support, we hope that a satisfactory outcome will be achieved.
We are very grateful to everyone who has pledged their support so far.
But, what of Scottish and Southern Energy's reaction?
Publicly, their reply has been to state that the plan to reduce the compensation flow to the River Spey and put a small flow down the Garry was not their plan but SEPA's.
Was that really the case?
Certainly the "plan" was agreed between SSE, SEPA and the Scottish Executive and, when announced to us, it was presented as a joint plan fronted by SEPA. But who made the original proposal???
From documents released under the Freedom of Information (Scotland) Act 2002 we have made some alarming discoveries, discoveries which should be a matter of grave concern to anyone who just assumes the implementation of the Water Framework Directive will just be a matter for SEPA.
There was an exchange of correspondence between SSE and the last Scottish Executive whereby SSE clearly tried to influence the implementation of the WFD. For example, in July 2005, SSE wrote to the then Minister for Environment and Rural Development claiming that among other things,
"we believe that the time is right for Ministers to state that they intend to direct SEPA to the effect that River Basin Management Plans should be designed so that they do not lead to any reduction in the output of Scotland's hydro-electric schemes."
Furthermore,
"Confirmation from Ministers that they intend to issue it would give SEPA greater clarity in the way in which it should carry out its responsibilities.........Ministers have the opportunity, by directing SEPA, to demonstrate their commitment to ensuring that the full benefit of Scotland's renewable energy potential is fulfilled."
Reassuringly, a subsequent reply by the Deputy Minister acknowledged that a "blanket approach to hydropower as proposed in your letter would not be permitted under the Directive". But more concerning is that she then stated that "I give you my full assurance that it is that Ministers, not SEPA, who will take decisions on critical aspects of wider WFD implementation", and in another letter she said that reducing hydro output "is something we would wish to avoid".
Then a letter from the Deputy Minister to SSE on 30 June 2006 reveals an involvement between SSE, the SE and SEPA. She welcomed "the pro-active and collaborative approach which Scottish and Southern Energy has shown over the last year in relation to our joint objectives for energy generation and environmental protection" and then went on to refer to the three projects which had been agreed (which included the Garry).
A subsequent reply from SSE said that the commitment that the Executive wished to avoid a loss of generation "has provided a real spur to making progress of the kind described in your recent letter, and we are grateful for it."
We have heard it stated by SSE, in fact again as recently as this week, that the three projects (which include the Garry) were proposed by SSE - presumably the "pro-active" approach referred to by the former Deputy Minister. These were subsequently agreed in principle between SSE, SEPA and the Scottish Executive.
One of our major concerns is that the Water Framework Directive is there to improve the water environment for, among other things, the benefit of society, and it is clearly intended that the public should be involved in the decision making process. However, it is the case that, in Scotland, the WFD has still to reach the public's imagination, probably because the general public has heard little about it, apart from those who may be impacted by it. It must be a concern that the company responsible for the greatest water abstraction is Scotland has been able to try to influence the process from behind the scenes while the positive benefits of WFD have scarcely been aired.
THEREFORE A MAJOR OBJECTIVE OF THIS CAMPAIGN IS TO HEIGHTEN AWARENESS OF THE WATER FRAMEWORK DIRECTIVE SO THAT SOCIETY AT LARGE CAN DECIDE WHETHER DAMAGE TO RIVERS SHOULD BE RESTORED, AS IT IS MEANT TO BE.
Of course, we are not seeking to significantly reduce electric generation but are merely asking that some excessive and unnecessary damage done during a different era is undone as far as possible. The River Garry is the worst example of this in Scotland. Certainly in the wider Tay catchment no other abstraction issue comes near it in scale. The next most significant issues in the Tay catchment would require the loss of far less generation to rectify, as indeed we have informed SSE and SEPA. The River Garry ought to be Scotland's flagship WFD project, why not do it well?
LESSONS LEARNED - WHAT YOU MUST DO IF YOU CARE ABOUT OUR RIVERS
We hope that SEPA will be assured of the freedom to review abstracion licences in an objective manner without pressure from above. However, from the correspondence referred to above we learn that it will be "Ministers, not SEPA, who will take decisions on critical aspects of wider WFD implementation".
Therefore it is vital that if YOU CARE ABOUT THIS ISSUE YOU SHOULD MAKE YOUR VIEWS KNOWN TO POLITICIANS. YOU MUST HELP MAINTAIN THE BALANCE IN THE POLITICAL PROCESS.
Politicians have never been more accessible. They are only an email away. To do so, please click here!
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