Select Committee on Environment, Transport and Regional Affairs Memoranda

Memorandum by the British Trout Association (DWB 10)

  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[17].

  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 remain competitive.

  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 position.

  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.

January 2001

17   Not printed. Back

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2001
Prepared 29 January 2001