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.