
Please find below a letter updating our clients on the latest developments. A copy of the letter can be downloaded here.
Download Campaign Letter Template
Our Approach
We have been liaising with SEPA, for nearly a year, in order to obtain their approval, on your behalf, for the 150+ sites that the Freeflow Hydro scheme has so far identified. Unfortunately, as we are about to outline, it has been a frustrating process.
We first approached SEPA in May 2009 (at a meeting in Glasgow hosted by the Scottish Executive) in order to table the scope of our programme and to explain our planned installation of pico-hydro (sub 10Kw) schemes. We had already designed a cost effective turbine/generator package, recruited and trained surveying teams and negotiated with the electricity supply bodies for the replacement of existing meters with new “smart” meters for the subsequent export of power to the domestic grid. We assumed that SEPA’s requirements would be similar to those of the Environment Agency (EA) in England & Wales. The EA have carefully considered pico-hydro schemes and are actively encouraging them by granting simplified ‘Diversion Licences’. They believe that the best way to engage the public with renewable energy and carbon reduction, and to make them more accepting of power pylons and wind farms etc, is to encourage them to participate and make savings in their own homes.
SEPA, on the other hand, are discouraging pico-hydro by applying the same restrictions to your pico installation as they do for schemes at least 25 (100Kw+) times larger. This is despite Scotland having by far the best pico environment in the whole of the UK. They proudly told us that, to date, they have approved 68 Micro-Hydro Car Licence applications since the scheme began. Of these, a mere, 4 or 5 schemes went ahead - due in no small part to the expense of the submission and the restrictions imposed. That clearly demonstrates how difficult it is to obtain their approval.
SEPA Bureaucracy
The first barrier was the Controlled Activity Regulations (CAR) Licence. The EA’s simple Diversion Licence acknowledges that water is diverted from a burn through a small turbine and then returned back to the burn. SEPA however require us to apply for an expensive and time-consuming CAR licence, which typically covers water extracted for irrigation. This water after contact with fertilisers etc typically requires processing at a water treatment plant, a scenario that is very different from a pico hydro installation. Because the time delay (up to four months) and the expense (£588 plus report/survey fees) is completely disproportionate, a CAR licence is rarely applied for at the pico scale. Our objective was, therefore, to negotiate a simplification of the regulations in Scotland, in line with those applying in the rest of the UK. However, we (including the MPs & MEPs lobbying for us) were told by both SEPA and the Scottish Executive that rather than drawing up new rules for pico hydro it would be easier if they simply approved one more large wind farm that would create more green energy than all our systems put together!! i.e. they would rather continue to process 9 Micro-Hydro applications per year, and prevent you from potentially generating all your electricity for FREE!!
Our Compromise
In an attempt to avoid a complete stalling of the programme we agreed that for the first 10 to 20 installations we would satisfy the disproportionate conditions of the CAR licence and pay the fee of £588 per site. We would then demonstrate the simplicity of our systems and the minimal environmental impact that they would have. Our opinion remains that once we have 10 to 20 systems installed, all the other applications will essentially be the same, and therefore SEPA's administrative costs in processing the applications will be reduced, a cost saving which we believe should be passed on to the licence holder.
Subsequent Developments
In summary then, since the summer we have been trying to get our first 10 sites approved, but it has proved to be hugely time consuming, expensive and frustrating. What was supposed to be a simple hydro scheme has, due to SEPA's unique interpretation of the European Water Policy Directive (which obviously applies to the EA as well), become significantly more complex than anywhere else in the UK.
You may have heard about the micro-hydro project in the Welsh Brecon Beacons that has just won a National competition called The Big Green Challenge. Their installations are almost identical to ours (a simple screened inlet, a small pipe and a small turbine), the difference being that the equipment and installation are NOT FREE. This project received the full support and co-operation of the planners & the EA, and because the sites are located in a National Park they were subjected to the closest scrutiny. On completion the EA granted a Diversion Licence and collected the modest fee, thereby enabling the community to benefit from free renewable electricity
If we had received a fraction of the support, in Scotland, offered by the various authorities in Wales then many of the 150+ Freeflow schemes would have been installed by now. We trust that you now have some understanding at our great frustration in moving this project forward, and we therefore ask for your help.
How You Can Help
We would encourage you to take up the issues outlined above with your local MP, MEP, NFU Representative, local newspaper etc. To help you, we have drafted a letter template which we will make available to download from our website www.freeflowhydro.co.uk for you to edit.
Our Commitment
We trust that it is possible to resolve these issues quickly and in the meantime, we remain fully committed to: -
• being a positive influence in the renewable energy market, driving down costs and delivering free electricity to our customers
• upholding our high standards of social responsibility to our customers, stakeholders and the environment
• delivering a quality product, free of charge to the end user for the lifetime of the scheme
We look forward to installing your scheme in the near future and to helping you reap the rewards of micro hydro power.
Yours sincerely
Jonathan Cox
Eur Ing C Eng B Eng MEI
Freeflow Hydro
