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Tuesday, 25 October 2016

Public Service Announcement

yes well...  I had a moan in the previous post about the availability of supporting documentation for the two recent applications by Weaver's Mill at Avoncliff - after a fair few phone calls and emails - a mission to Bridgewater seemed like the only way to actually guarantee sight of the relevant documents before the consultation period expired...

    • NPS/WR/024504 is an application to extend the time allowed for the license holder to construct and commission a turbine at the Avoncliff weir granted to Mr. Martin Tarrant as SW/053/001/020 another 3 years to December 2019.
    • NPS/WR/024505 is an application to allow water to run under Weaver's Mill to (I imagine) create a water feature in the garden....

The application covering letter

The stream through the garden:
WR299 Abstraction Application Public Register Sheet 
WR330 Part B - with diagram (PDF)
WR332 Part C  (PDF)

The application to extend the time allowed to install a working hydropower system:
WR334 Part D  (PDF)
WR328 Part A  (PDF)

Land Registry Document    (PDF)

The Newspaper Advertisement (PDF)

Sorry about running off with the visitor pass from Rivers House - I'll mail it back.....


  1. Hundred mile round trip, get some more carbon out there help the global warming. I would shut the idiots down to lazy to put it on line. AH just twigged it there not capable. Thanks for saving me a trip....Are the EA sure they want to help the environment ??????

    1. The EA's intention is to fulfil their legal obligation but no more. For example if the scheme was in a village and the nearest local paper was in a town 10 miles away then that's the paper it would be advertised in. The fact that no-one in the village takes the local paper is of no concern to the EA. They have completed their legal obligation. This is not hearsay I can quote examples.

    2. They have however used The Wiltshire Times for ALL announcements to date - to change that policywould at best be perverse and self harming - but since they're quite good at that - maybe I ought to check the "John O'Groats Journal"

  2. Anonymous @17:31

    +1 on that

    looking at docs from Bridgewater

    why no license transfer document? - shouldn't that have been included with the Land Registry stuff?

    why no details of existing (unused / unusable)license? = a simple copy of the existing license included would let people know what the license is for.

    Really surprised Ms. Lee cites the Kingston Mill hydro re application for more time - it's still not running 14 months after installation = WTF!

    Pretty poor show really

    1. Not a turbine its an architectural feature and it has been there 2 years.

    2. It's not unreasonable to suspect that now - some 15 months after the equipment was installed that the equipment has failed is fairly terminal fashion ?

      Pretty bad show from the owner / operator that they aren't volunteering this to the community and Climate Friendly Bradford on Avon aren't prominient isn asking what on earth is going on?

  3. The license application documentation appears incomplete yet has been accepted by the EA.
    The transfer license should be for a designated flow quantity, a sweetening flow is not a quantity. On the River Thames at Maidenhead for the Jubilee River the sweetening flow can be as much as 12cumecs. A figure must be applied for. I would contend that this makes the application invalid.

  4. The forms for the extension of the licence are very nice but there is no copy of the licence, which should have been submitted as part of the application. I do not see any evidence that the ownership of the licence has been transferred from the original owner Mr Tarrant to the new owner of the property Ms. Lee. As it would appear that Ms. Lee does not own the licence she cannot apply for it to be extended until the ownership has been transferred.

  5. Am I reading it right. The EA have been paid £1500 for two separate applications. A new transfer licence and extending an existing licence. Shouldn't it be £1500 for each?

  6. Hardly a public consultation the information is not here what was the original scheme for ?

  7. From a Consultant
    There are a number of questions based on who actually owns the licence currently which is not clear in the EA data.
    I will raise points over two blog entries to keep the subject matter together.
    Part 1
    The licence clearly states everything has to be operating in the 3 years. It would appear nothing has been done except a discussion where outline verbal agreement we are told) was made for the transfer of the licence.
    Has Flood Defence Consent been applied for?
    Has Fish and Eel Pass Design been submitted to the National Fish Pass Panel and been agreed?
    Has Planning Permission been applied for?
    Has a grid connect agreement been made with the DNO?
    Has a tariff application been made to OFGEM?
    Has an agreement been made with the owner of River Cottage to work in their riparian area? Although the EA pointed out to the previous owner, Mr Tarrant, that his original design encroached on land (river bed) he did not own the revised design still requires equipment to be located outside the Weavers Kill riparian area for the work to be completed.
    I believe the answers to all these points are no. Nothing has been done.
    The EA knowingly issued a paper licence.
    Some time after the licence had been issued I spoke with and honest and reliable EA officer (yes there are some) who told me if nothing was done in the 3 years the licence would fail and my clients could apply again.
    It appears that the EA are attempting to show the bias towards the Weavers Mill project which has been remarked on by the Parliamentary Ombudsman.
    No doubt the licence will be extended.

  8. From a Consultant
    Part 2
    To extend the Licence requires the data used by the EA in the original paper licence, biased determination to be valid. There are a number of areas which the EA accepted which are now invalid, some were at the time but the EA chose to ignore the inconvenient truth, like the riparian access issues mentioned in part 1.
    The EA used Mott MacDonald to perform Flood Modelling. Mott MacDonald used the known design of the North Mill scheme to access the potential flood effect but as was pointed out at the time there were errors, another inconvenient truth. Mott MacDonald used an outline design of an un-built turbine for Weavers Mill. It had been pointed out to the EA that a number of major manufacturers stated the scheme would not work to the design. The EA chose to accept the design of a first time home build and ignore the inconvenient truth again.
    The EA used AMEC to advise them on the likely generation. AMEC and the EA accepted that a first time self build would be as efficient as major manufacturers they were proved correct in this assumption. When the proposed ATL turbine is not working its efficiency is 0% the same as major manufacturers. Unfortunately the one ATL turbine, in the 14 months it has been installed has not operated for a long enough period to assess its efficiency. to date its overall efficiency is 0%. The EA and AMEC were told by the then owner of Weavers Mill, who is also the owner of ATL, that 3 turbines had already been manufactured. The then owner of Weavers Mill refused to tell the EA were these schemes were. I and my clients rubbished this as the EA have all the information on where turbines are located, if only they wish to look. The then owner of Weavers Mill produced an image of two graphs side by side claiming that this was the data from his turbines. The EA decided to accept this even though the fact that it was spurious was made known to them. The graphs were from an twin Ossberger turbine site in Wiltshire. In the Licence it states that anyone submitting knowingly false data will be prosecuted, this is unlikely to happen as the inconvenient truth is the EA were complicit in knowingly accepting the data.
    Extended to a third section

  9. From A Consultant
    Part 3
    A further interesting conundrum is that each time the Weavers Mill generation figures were calculated during this saga they increased and ended up significantly higher than those initially produced by the original consultants employed by Weavers Mill, however each time the North Mill figures were calculated by the EA's consultants the figures reduced even when the errors in the calculation were pointed out, inconvenient truth again.
    The incorrect generation data due to the efficiency was compounded by the fact that AMEC used level data based on the turbine proposal for North Mill which would maintain a level over the weir at all times. Without the North Mill scheme the levels were incorrect. The waterwheel channel at North Mill significantly lowers the river level making the level data for Weavers Mill incorrect. Therefore the incorrect levels data and efficiency data totally invalidate the calculated generation for Weavers Mill and consequently the CO2 savings and the revenue generation. The revenue generation is further compromised due to the reduction in the Feed in Generation Tariff. The viability of the scheme is compromised. The cost of a self build was also nowhere near the cost of a turbine purchased from a major manufacturer. The inconvenient truths were raised prior to the time of the issue of the licence but were ignored due to the overarching bias shown by the EA to the Weavers Mill scheme. In the determination paperwork produced by the EA prior to the issue of the licence it was noted that the Weavers Mill scheme would require an operating agreement with my clients as they had control of the river level. Needless to say in the almost 3 years since that date no approach for discussions has been made by the former / or present owner of Weavers Mill.
    Simply put the extension of the Weavers Mill licence will end up with a paper licence for a further 3 years where no scheme will be built. This may effectively halt worthwhile generation ever happening on this section of the River Avon. The scheme at Kingston Mill, Bradford-on-Avon, licenced by the EA, is a failure and the EA will no doubt be happy to further improve the environment by halting any other worthwhile projects.
    In truth I do not expect the EA to operate openly, transparently or with any honesty and logic. The EA's desire to prove that their initial decision was not flawed however obvious the evidence is and their complete bias towards Weavers Mill will end up with the licence being extended. I believe the EA will accept the almost farcical excuses given for not progressing the project to date.


Get it off yer chest - please keep it civil