Energy and Climate Change CommitteeWritten evidence submitted by the Angling Trust
1. Overview
The Angling Trust is the representative organisation for all coarse, game and sea anglers in England. We have more than 1,500 member clubs who have a combined membership of more than 350,000 anglers. Angling has been shown to have great benefits for individuals’ health and well-being, for community cohesion and for the national economy. It generates more than £3.5 billion each year, employs 37,000 people and is enjoyed by 3.5 million participants.
The Angling Trust welcomes the opportunity to provide evidence to this Committee, but we are constrained in so doing by the lack of specific information available about the latest proposals for a barrage.
Our principal message to the Committee is that the proposals must be worked up into much more detail before any firm view can even begin to be formed about the costs and benefits of this scheme. In addition, rigorous, independent, peer-reviewed assessments must be carried out to calculate the impacts of the proposals.
We remain highly sceptical that a development on this scale, in such a sensitive environment, will not cause unacceptable damage to the ecological and geomorphological functions of the Severn Estuary. For good reason, the estuary and many of the rivers which flow into it are heavily protected by domestic and European legislation. Any project of this scale would require a Strategic Environmental Assessment (SEA), as per the SEA Directive, to consider the impacts on the Basin as a whole including, inter alia, socio-economic impacts, impacts on Eel Regulations; the NASCO Precautionary Principle, Salmon Action Plans, Water Framework Directive, and the Habitats & Birds Directives.
The Habitats Directive would require compensatory habitat to be created elsewhere to replace that which is damaged in the Severn. This could involve the creation or restoration of thousands of hectares of intertidal habitat and/or hundreds of miles of salmon and shad river habitat. If the damage to habitats is on the scale that we believe it might be, this would be even more unfeasible than stocking salmon to the wadis of the Yemen, and considerably more expensive. What’s more, this habitat would have to be in place and functional before work could begin on the proposed barrage.
We do however believe that there are significant opportunities for generating renewable energy in and around the Severn Estuary, but these are far more likely to lie in a series of smaller-scale projects which would need to be co-ordinated strategically on a regional basis and should be developed in ways which minimise impacts on other ecosystem services.
2. Individual Questions
What contribution could the Cardiff-Weston Barrage make to UK energy security and climate change objectives?
The Angling Trust believes that urgent action is required to reduce damaging CO2 emissions and to slow the pace of climate change, which is one of the most significant threats faced by humanity.
A large barrage, if it achieves all the necessary approvals and is successfully constructed, could hypothetically generate significant amounts of electricity. The developers claim this might be as much as 5% of UK electricity demand. However, the proposals are at such an early stage that it is difficult to make any meaningful assessment; they cannot tell us what type of turbines will be used. There would be very substantial carbon emissions arising from construction.
It will be important for the Committee to assess the risk of a Barrage being unable to operate in the future due to unforeseen environmental damage becoming apparent and/or due to unexpected sediment accumulations which might prevent it operating.
Whatever the potential for power generation might be, the estuary’s vital functions as a habitat for wildlife and as a provider of ecosystem services to the South West of England and Wales and to the nation as a whole must be protected. The best way to do this will be to take a strategic view of the potential for energy generation at a number of sites and to select a suite of measures which are designed to have the lowest environmental impact and which optimise power generation in a particular location. This proposal appears to seek to generate too much power from a single project.
The scheme will also be extremely expensive to construct, particularly if compensatory habitats are created on an appropriate scale elsewhere. The electricity it might one day generate is therefore likely to be sold at a very high unit price.
What risks and opportunities could it pose to wildlife and habitat in the Severn estuary, and how might any risks be mitigated?
Our response to this question focusses principally on fish, because we have most expertise in fisheries and an obvious particular interest in the impact on fisheries. However it should be noted that fish living in the Severn Estuary are a vital part of the marine and freshwater ecosystem of the estuary, many large river systems and the Atlantic Ocean. Any significant impact on fisheries in the estuary would impact on fish that travel as far as Greenland and the Sargasso Sea. These include several species which are protected, such as eels, shad, lampreys and Atlantic salmon. Some of these species form part of the designation of habitats in and around the estuary as Special Areas of Conservation. Approximately 25% of all salmonid spawning habitat in England and Wales lies upstream of the barrage and the stock of fish in each of the rivers is genetically distinct from any other. It is difficult to see how compensatory habitat for such species could ever be constructed.
The River Severn is one river where the European eel remains relatively abundant. The population numbers of this species have declined by some 95% across Europe in the last few decades. Any significant impact on fisheries in the estuary would impact on recreational and commercial fisheries alike in a large number of rivers and potentially throughout the Irish Sea and Eastern Atlantic Ocean.
The Severn Estuary provides a habitat to around 100 species of fish, at every stage of their lifecycle from tiny larvae to large adults. It is a very important breeding site for many marine fish species, a nursery area for young fish, a feeding area for fish of all ages and a thoroughfare for fish migrating into and out of several large river systems that flow into the estuary. These species which migrate between freshwater and the sea have to carry out a remarkable transformation at this point in their lifecycle to adapt to changes in the salinity of the water. This puts them under considerable stress and makes them particularly vulnerable.
Most species will spend a considerable amount of time in the estuary (ranging from days to years) and will naturally move several miles in each tidal cycle. They would therefore be likely to pass through turbines many times and therefore even a small risk of damage to individuals on each passage could have a population-limiting impact. Estuaries are probably the most important habitats for fish and many of these species are already threatened by a host of other environmental challenges such as excessive commercial fishing, damage to habitats, pollution and over-abstraction. Our understanding of fish behaviour in estuaries is very limited and considerable work would be required to improve this understanding to make any realistic assessment of the impact of a barrage on the scale that has been broadly described.
What is known is that most fish will usually seek out the areas of maximum flow to pass an obstacle. Therefore any attempts to divert them from passing through turbines and into a fish pass are unlikely to be successful, because the vast majority of the water would be passing through the turbines.
We have asked the developers to allow us to input to the terms of reference for independent, peer-reviewed, assessments of the impact at an individual and population level of:
their particular designs,
specifically in the highly turbid waters of the Severn Estuary,
on all relevant fish species at all life stages,
swimming both with and against the flow, and
passing through the turbines both head and tail-first.
Our concerns lie particularly, but not only, in the following areas:
Fish being struck by turbine blades which would cause them injury or death. The developers have claimed that their turbines are “fish friendly” and that they have a tip speed of 9 metres per second. We have yet to see the design of the blades or any further technical data. The Severn Estuary is also extremely turbid; the water has a very high sediment load and visibility is extremely limited. Studies must be conducted that meet the requirements listed above.
Fish being disorientated by passing though the turbulent water passing in and out of turbines (or any fish passes) and becoming more vulnerable to predation by birds and other fish.
The feeding, spawning and nursery areas of fish being damaged by deposition and erosion of sediment as a result of changes to flows in the estuary. Because the water is saturated with sediment, even small changes to velocity and discharge could cause very significant changes to deposition of sediment. Water that has less sediment in it tends to have more capacity to cause erosion. These impacts have the potential to extend well beyond the Severn Estuary.
Delays to fish migration leading to them failing to complete their lifecycle. Many fish will avoid passing obstacles, or spend considerable time seeking safe ways of passing over or round them. This could cause delays to fish migrating up rivers or out to sea which might make them more vulnerable to predation or pollution incidents. They might also miss key opportunities to continue their journeys, such as a spate in their natal river.
All of these impacts and more need to be rigorously assessed and tested on the basis of specific proposals from the developers. A strategic environmental assessment would be required for a project of this magnitude to consider its compliance with a wide range of environmental legislation.
In terms of mitigation, the options might include reducing the size of the head of water, reducing turbine speeds, reducing the proportion of the water which passes through turbines and preserving some natural flow, or considering alternative methods of generating power as part of a suite of measures compiled on a strategic basis for the region as a whole.
What risks and opportunities could it pose to local employment and community, and how might any risks be mitigated? In particular, what are the consequences for current ports, fishing and aggregate extraction industries in the estuary?
Until the proposals are more clearly developed it is very difficult to answer this question. Clearly there would be short term benefits to the economy from construction of such a large civil engineering project. However, these would not be realised for many years and possibly several decades because of the work that will be required to justify a project of this scale.
There are highly likely to be negative impacts from the scheme for employment and communities. The scale of the latter for the angling industry will depend largely on the impact of the proposals on fish stocks. Angling is a vitally important part of the social and economic fabric of communities along rivers throughout the Severn basin and along the coastline of South West England and Wales. Any further threat to already degraded fish stocks would have a very damaging impact on this existing industry.
The best way to maximise the long term benefits and minimise the negative impacts would be to identify a wide range of methods of generating renewable power which have the least impact on the natural environment.
3. Conclusions
We strongly recommend that the way forward for considering the generation of renewable energy in the Severn Estuary is:
To carry out a strategic appraisal of the range of options available for generating renewable energy in and around the estuary (with proven technology);
To conduct peer-reviewed, independent assessments of each of these options and their environmental impact;
To develop a plan for harnessing renewable energy sustainably;
To carry out a Strategic Environmental Assessment of that plan;
To modify the plan accordingly and then implement it sequentially, with some elements of it awaiting development of new technology or further research into environmental impacts and their mitigation.
December 2012