Memorandum by the British Trout Association
The British Trout Association is grateful for
the opportunity to respond to the consultation on the draft legislation
for the Water Bill. The Association has already responded to earlier
consultations on: The Review of the Water Abstraction Licensing
System in England and Wales (DETR June 1998), Economic Instruments
in Relation to Water Abstraction (DETR April 2000), Catchment
Abstraction Management Strategies (EA April 2000), copies of the
latter two I enclose for your information.
Our over-riding concern remains with the potential
loss of Abstraction Licences without compensation. Water supplied
to freshwater aquaculture is equivalent to land for a terrestrial
farmer and there is no precedent for confiscation of land without
compensation. Many farms have been in existence for long periods
(25 years or more) and the prospect of uncertainty over future
continuity may well have an adverse effect on future investment
and development, both of which are imperative if farms are to
In Clause 17(d), there is no definition of how
"serious damage" is to be defined. Despite the presumption
in favour of continuity, this further adds to the uncertainty
for Trout Farmers.
In the earlier consultation documents a period
of a minimum six years' notice was proposed for changes to abstraction
licence conditions (or their cancellation). The present Bill does
not confirm this, but in view of the long time scale for achieving
a return on investment a long notice period is essential.
We remain concerned, as a consequence of the
new legislation which is proposed, that costs will be increased.
Trout Farmers in England and Wales already bear more and higher
charges than their counterparts elsewhere in the United Kingdom
and the EU and this will cause further erosion to their competitive
We note that issues of competition and licence
trading remain to be considered, and would draw your attention
to our response to the consultation Economic Instruments in Relation
to Water Abstraction referred to at the start of this letter.
We hope these comments are helpful and would
be pleased to provide oral evidence should it be required.
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