Energy and Climate Change CommitteeSupplementary written evidence submitted by The Bristol Port Company

Dear Mr Yeo

The Bristol Port Company wish to provide the following additional information to the Energy and Climate Change Select Committee, in order to correct errors in the evidence given to the Committee by Hafren Power on 30 January 2013.

Hafren Power contend that access to the Port of Bristol would be improved following the construction of the barrage; this is incorrect and ignores a number of crucial factors:

1.All the shipping to the five docks (belonging to three independent and competing companies) upstream of the barrage would converge on locks, increasing the risk of collision and delays, and requiring active traffic management and a complex system of prioritisation. The safety of shipping will need to be regulated and assured by a new Statutory Authority and prioritisation of shipping movements will need to be independent and fair.

2.It is not clear where the locks will be positioned, but by definition these will need to follow the deep water channels, where they will be exposed to the full force of the weather. There are likely to be delays to shipping unable to transit the locks when they have to be closed in bad weather. By contrast, ports are located in relatively sheltered positions and rarely affected by the weather today.

3.The transit through these exposed locks would introduce the risk of damage to vessels using them, as well as a significant time delay from the slow approach speed, the duration of the levelling period and the time taken to build up speed once clear of the lock. To suggest that this time delay will be as short as 45 minutes and no more than the current time delay resulting from waiting for the tide to flood is wrong and demonstrates a fundamental ignorance of port operations. Today, with the pressure to provide maximum efficiency, ships calculate their speed of advance so as to arrive at their pilot boarding time (which in turn is calculated to maximise the benefit from the speed of the flood tide) to minimise fuel consumption and emissions and achieve a minimum passage from pilot station to port.

4.The number of locks to be provided in the barrage was unclear from the evidence session; we would contend that there would need to be at least two in order to provide concurrent ship movements and business continuity in the event of a lock failure. Severn Tidal Power guaranteed a minimum of two locks with dimensions sufficient to provide a future proof solution.

5.Bristol Port has some 3,000 vessel movements per annum. The predicted reduction by c2.0m in the height of high water levels upstream of the barrage affects the docks of both Royal Portbury and Avonmouth. At Portbury, the current Panamax plus trades (65,000 tonnes dwt) would be killed off, with insufficient water for the deepest draught ships (13.0m and above). Access to Avonmouth by many current vessels would also be severely restricted by the loss of water depth. For example an existing 11.0m tide would be reduced by the barrage to 9.0m or less meaning that only vessels with a maximum draught of 7.8m would have unencumbered access to Avonmouth. The loss of water depth would impose an unacceptable limitation and leave the port commercially unviable.

6.Hafren Power has portrayed a projected higher low water level as a benefit, which is incorrect. A 2.0m increase in a 3.0m low water level would limit the maximum draught movement in or out of Avonmouth to 4.0m, which is well below the arrival draught of virtually all commercial shipping. In addition, ballasted lock gates require a minimum water level in excess of this raised low water level in order to operate.

Hafren Power sought during their evidence to allay our fears of a reduction of up to 2 metres in the water level upstream of the barrage by stating that the barrage would be a “complete control mechanism”. They confidently asserted that the water level upstream could be (a) adjusted by allowing unimpeded flow through the turbines and (b) further increased by pumping. Whilst we have seen no detail of this control mechanism, we find it surprising that the power capacity of the pumps could enable the upstream water level to be raised by 1 metre when the area involved is 600 million square metres. This would imply pumping an estimated 600 million tonnes of water; a barely conceivable challenge, yet alone one which would be compatible with generating a reliable supply of electricity.

Bristol Port is seeking independent expert analysis of Hafren Power’s claims in order to quantify the true effects on upstream water levels of a barrage conforming to the scant design detail available to us. This analysis will be made available to the Committee.

Hafren Power accepted that the barrage operating company would absorb all the costs associated with the integration of the barrage into the shipping activity in the area. It is not clear whether or not Hafren Power recognise the full span of services which would need to be provided, free of cost in perpetuity, to all commercial shipping in the Estuary. These include VTS providing traffic organisation and information, pilotage, towage, line handling and conservancy (including frequent surveys and the dredging of an estimated five million tonnes of mud each year which will be required to keep our deep water channel clear). A substantial fleet of tugs, dredgers, survey craft and pilot launches will be needed to meet this requirement. It is also unclear how Hafren Power intends to guarantee performance of its resulting financial obligations for the lifetime of the barrage.

It is regrettable that there was insufficient time for your Committee to debate in detail the effects of siltation on the barrage and the Estuary; the effects in navigational channels need particular scrutiny, and the consequences of the probable build up of material in the vicinity of the turbines would appear to have been ignored thus far. From the information we have, it is by no means certain the proposed barrage could generate power in the long-term without the removal of millions of tonnes of silt. We note that further written evidence will be submitted covering these points and would ask that, in view of our considerable experience of this subject, we may be permitted to comment on that evidence. We believe that our 120 years of experience of actually operating in the conditions prevailing in the Estuary gives us an unrivalled understanding of the subtleties and variations present that cannot be modelled by academic studies and predictions.

For the avoidance of doubt, Bristol Port has requested from Hafren Power details of the effect any barrage would have on water levels and increased siltation. Hafren Power has to date been unwilling to share any information with Bristol Port and has not responded to our requests made in writing, or in the meeting held with the Chief Executive, Mr Pryor, on 24 January. I attach a copy of a letter sent to Peter Hain MP, which was also passed to Mr Pryor in advance of the meeting in January.

During Hafren Power’s evidence, we were extremely concerned to hear that it is their intention to sell Hafren Power if development consent is granted. This was stated by Mr Pryor, who also said that he thought any new purchaser, while not starting afresh, would wish to discuss the commitments made by Hafren Power. This statement is of great concern as we, and no doubt others, will question the validity of guarantees and statements made by Hafren Power prior to sale. We also question why, if it only intends to monetise a development consent, Hafren Power considers itself suitable to promote the barrage scheme at all.

Finally, Mr Hain, in responding to the Committee following his oral evidence, questioned why I had raised in my oral evidence the involvement in Hafren Power of his wife, Elizabeth Haywood. The point I was seeking to highlight was the lack of consultation between Bristol Port and Hafren Power. My comments were limited to matters of fact, but if Mr Hain or his wife found this discourteous then I am very happy to apologise.

February 2013