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Wednesday, 30 November 2016

Is it just a question of making it up as they go along?

Does the left hand care or even know what the right hand is doing?

I was curious about the Environment Agency's policy and obligations regarding the quality of equipment (certification) which is being installed to control water flow in rivers and generate electricity from hydro power schemes.

Specifically I wondered if equipment has to adhere to a set of standards - BS Kite Marking or EU Type approval  - in order to ensure that a product that meets a minimum set of regulatory, technical and safety requirements - as in - that it is fit for purpose and presents no risk to the public. There is also the question of ISO9000 - but I left that alone...

I formally asked the EA via a Freedom of Information request  (and they would have treated it as one anyway) about their policy.

 given our experience - extraordinary.

(Please... go and read the whole thing)


We do not generally check that the primary machinery in a hydropower installation meets BSI Kite Marking, EU Type Approvals or similar certification from an independent body” as this would generally be outside of our regulatory and advisory role in relation to hydropower schemes.   (my bold)

I think the term cognitive dissonance is appropriate ....

It would appear that the EA do not bother when it suits them to check their own records to see if an equipment manufacturer has actually installed any product anywhere  - and if it works properly. I personally know several lawyers who'd have an absolute field day with negligence there....

The EA has clearly failed to perform its regulatory and advisory role competently at Avoncliff and as a result they have willfully squandered in excess of £2 million pounds indulging in administrative overreach, fraud, lies and bullying. 

In fact they will not even answer / are refusing to answer  Freedom of Information requests asking for their own reckoning of how much public money has been self indulgently squandered - they could just make it up...  as they have done in the past!   

FoI Question #1 about costs - (18th June 2012)  1600 days overdue.
FoI Question #2 about costs - (29th Nov 2016)  1 day overdue

Interestingly BSI actually have a significant specialty in certifying water control equipment used in flood control and other riverine environments....

Sunday, 20 November 2016

Got a Generator?

last week ... National Grid issued a capacity warning - which means that safety margins for UK electricity generation have got too low...


This is being played down ...  as it is a consequence of the stupid antics of incompetent, deluded and corrupt politicians like Ed Miliband, Chris Huhne and Ed Davey.

I have a generator.... do you?

Wind is 1.2% and solar? ... well it's night time....

Hydro holding up - but nothing from Bradford on Avon as far as I can see....

Monday, 7 November 2016

Some Avon Valley Eye Candy

I just noticed on YouTube that several drones have been up and down the valley. One user (Abbey Aerial Video) has posted some recent aerial camera footage of the Avon valley at Avoncliff - and very pretty it is too.

LINK to full screen in a new tab/window
(well worth it if your connection is fast enough)

Video captured with with one of these:

There are other videos from drones on YouTube of the Avon Valley

Thursday, 3 November 2016

Last Day TODAY !

Today is the last day to make representations about the license applications related to Avoncliff that are presently in process with Environment Agency Water Resources at Quadrant 2 in Sheffield.

Helpfully the EA have a guide about the process which they seem to be now sending to all folk who lodge comments / criticisms and perhaps praise even!  Doing it a bit backwards that -imho / I think...

It might be seen as wanton nit picking by me - but I can't help thinking that this guide should be linked from the consultation page on the www.gov.uk site where a Water Resources public consultation notice is placed. The bundle of public documents relating to the application should also be there too - it would be trivial to put a link in the newspaper ad as well - in the Weaver's Mill case the documents were already in PDF format on the 21st September:

two weeks before the Wiltshire Times advertisement

How to verify email 

Anyway... enough grizzling - if you have a view on this .... PRO - or - ANTI I'd urge you to read the document linked above before you dash off an email to :


quoting the reference numbers below

  • 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. (application PDF files)
  • 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.... (application PDF files)

  • It'll be interesting to see if the EA bring the determination "in" 
    inside the 120 day statutory window....

    I forget what our record was but no doubt somebody can remind me....?

    A Consultant's View....

    The hydropower consultant / project manager engaged by North Mill has made a series of comments on matters surrounding the present license - I thought it worth collecting them into a post of their own and highlighting a few parts (I beg forgiveness for some minor editing too...).

    "From a Consultant"

    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 Mill riparian area for the work to be completed.
    I believe the answers to all these points are "NO".

    Nothing has been done.

    The EA is knowingly and very deliberately about to issue yet another "paper licence".

    Some time after the "Tarrant" licence had been issued in 2014 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 continuing to show the bias towards the Weavers Mill project which has been remarked on by the Parliamentary Ombudsman and no doubt the licence will be extended.

    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 and only ATL turbine, in the 14 months it has been installed (at Kingston Mill in Bradford on Avon) -  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,- a few keystrokes and clicks away.

    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 knowingly submitting false information will be prosecuted - this is unlikely to happen as the inconvenient truth is the EA were complicit in knowingly accepting the data.

    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 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.