Taking water responsibly3 June 2003
The Catchment Abstraction Management Strategy is hoping to show the way forward for sustainable water supplies in England and Wales. But will it help or hinder any further development of small hydro power plants? Suzanne Pritchard reports
EVENTS throughout the 1990s steered the UK on the path towards sustainable water management. A combination of drought, privatisation and regulatory pressures prompted a radical overhaul of the water industry, resulting in the publication of a government consultation paper in 1999.
Called Taking Water Responsibly, the paper outlines changes to the current abstraction licensing system that has been used to regulate water removal from English and Welsh rivers for over 40 years. One of the paper's main proposals was the development of CAMS.
'The Catchment Abstraction Management Strategy (CAMS) represents a step-change in the way that we manage this vital water resource,' said Sir John Harman, chairman of the Environment Agency (EA) responsible for administering the licensing system.
CAMS' main priority is the sustainable management of water resources to balance economic and social needs with environmental impacts. By making more information on water resources allocation publicly available, it is also striving to make abstraction licensing a more transparent and consistent process.
'One of the key reasons the government asked the EA to develop CAMS was because stakeholders wanted water resource management and abstraction licensing to be a more open and transparent process,' said Claire Dinnis, water resources regulation policy advisor at the EA. 'We believe it is the right way to progress because stakeholders have the opportunity to influence the Agency's decisions about the way in which we manage water resources, while the abstraction licensing process will become less of a black box.'
'I personally have doubts about the influence of such input on the strategy,' said Steve Cryer, chairman of the British Hydropower Association (BHA) and hydro manager of the South West Hydro Group in Devon, England. Although the BHA is encouraging all hydro operators and developers to become involved in CAMS stakeholder groups, the EA is not always contacting those who should be involved in the CAMS process, according to Cryer. 'The BHA would like to be notified by the EA when a CAMS is being done so we can talk to our members.'
A sense of scale
CAMS does not change the licensing process as such but by providing more information on resource status it determines the likelihood of obtaining a licence in a given area. Once a CAMS is published the licensing strategy within the document will be used to determine licences within that catchment. However, as Dinnis stressed, licence application and the determination process will not change. 'The CAMS results give an indication of the likelihood of water being available in a sub-catchment but a local assessment will still be required when determining individual licence applications,' she said.
This is not entirely good news for the BHA. Cryer spoke about the difficulties encountered by those trying to develop hydro power plants.
'Most micro hydro schemes will sink dead in the water at the very beginning if the costs of licensing are not associated with the scale of the hydro plant,' Cryer claimed.
The main issue with abstraction licensing is the capital needed to prepare environmental impact assessments (EIA) and other such documents. 'These need a sense of scale,' continued Cryer. 'Such costs do not vary whether you are developing a 100kW plant or a 10MW plant. Quite simply, the cost of producing an EIA more often than not drowns the benefits of some schemes. Many micro hydro developers do not have the financial resources to prepare such weighty documents. We need to consider this sense of scale or very small schemes will not be economically viable'
Cryer gives the example of a small mill owner who is involved with the Teifi CAMS in southwest Wales. In order to measure flow rates at the site, the EA has requested that monitoring and measuring devices be installed but the mill owner is very concerned about the cost of this and the effect it could have on his business.
'It's not right that a small mill owner must install all-singing and all-dancing technology that he simply cannot afford, and will not get any financial return on,' said Cryer.
The EA describes CAMS as a sophisticated management tool that simply re-packages the way water resources have been managed. Time-limited abstraction licences have now become part of this repackaging. As Ines Aguirre, from the EA's Lower Severn water resources team said: 'It became clear that the concept of issuing licences in perpetuity was not the way to maintain sustainable water supplies.'
Historically, the majority of abstraction licences have not been time-limited, although the EA says that increasingly time limits have been used. And with the greater uncertainty posed by changing climatic conditions, it claims that time-limited licences have proven to be a fair and effective tool for managing water resources. Consequently CAMS is being viewed as a vehicle to review time-limited licences, typically lasting for 12 years.
'This is a contentious issue for hydro power,' said Steve Cryer. 'Hydro fits the bill for long term licences, particularly if we are talking about new developments of small hydro. The life expectancy of such a plant is in excess of 100 years and modern turbine equipment can operate effectively with appropriate maintenance for 50 years. Considering the initial capital investment of such plants it is doubtful you will get a return on your investment over 12 years.
'CAMS is looking towards the "presumption" of licence renewal,' Cryer continued. 'But that does not hold much weight with a banker when you are asking him to lend you money.'
The BHA hopes to discuss the issue with the EA in more detail. The association believes that new licences should last for a minimum of 24 years, which will then fit in with the six-year cycle of CAMS and allow for weather variations in hydro power operation.
Another objective of the CAMS process is to facilitate licence trading. This is the acquisition of a licence, either directly from the current holder or as a result of a variation to another licence. The EA claims that by identifying the resource availability status of resource management units, CAMS will enable resource developers to identify situations where a licence relocation trade may be the only way to achieve their objectives.
'I was frightened by this to start with,' Cryer said. 'CAMS will highlight available water which will most likely be snapped up by the "big boys" in the industry. Most hydro power businesses are small to medium sized concerns but water companies are much larger entities. However, the EA assured me that hydro will not be affected by this due to its non-consumptive nature.'
Cryer believes that the important benefits of hydro and its history as an effective energy converter need to be understood when considering CAMS. 'The EA must understand the broader issues and benefits of hydro power in combating air pollution.'
In its position statement on small hydro power that was published in June 2002, the EA states that although it does not have a remit to promote hydro power it must be 'mindful of its wider environmental benefits in applying its regulatory powers'. Furthermore, the EA says it recognises the contribution hydro power schemes can make in reducing greenhouse gas emissions, as well as the potential benefits of small scale hydro power to rural communities and in meeting local needs for power.
It is perhaps with this in mind that the EA has included a special clause for small hydro power schemes when considering the resource availability status of CAMS. Even when water is unavailable within a catchment, licences for small quantities of water for non-consumptive use, such as small hydro power schemes, may be available throughout the year or at times of higher available river flows.
Steve Cryer is cautious. 'It is a glimmer of hope,' he said, 'but this may be debatable. Again I cannot stress the fact that we need to consider the scale of costs associated with such plants or they will not be economically viable within any catchment.'
The BHA believes that the non-consumptive nature of hydro power should hold its own with relicensing. 'Even if relicensing in catchments which are classified as being over stressed, we do not believe that this should affect hydro licences,' Cryer emphasised. 'At the moment hydro power is not treated any differently from big water companies which consume large quantities of water.'
'The whole point of CAMS is to look at water resources. If we find a particular catchment is extremely stressed then we will need to cut resources to ensure sufficient water is left in the river system for the natural habitat and ecology, says Ines Aguirre from the EA. 'But this does not necessarily point the finger at hydro as it is primarily non-consumptive.'
Cryer also believes that there needs to be a generic statement in CAMS which highlights the fact that overstressed river classification is not necessarily a barrier to non-consumptive users.
To date, no abstraction licences for hydro power or otherwise have been determined using the CAMS licensing strategy. The first CAMS document, which was started in April 2001, is due for publication within the next few months.
'We can only hope that the EA will give serious consideration to the non-consumptive nature of hydro,' the BHA's chairman said. 'CAMS is very much in the early stages and we appreciate that it will gather more information as it goes on. But I am very doubtful that any initial decisions about river catchment status will be reversed in the future. We can only wait and see what happens with hydro licence applications.'