Waterways For Everyone Consultation Response
RESIDENTIAL BOAT OWNERS ASSOCIATION RESPONSE TO THE CONSULTATION
BY DEFRA; WATERWAYS FOR EVERYONE
This response consists of an overview of the comments from the Residential Boat Owners’ Association (RBOA) followed by replies to the various questions raised throughout the document.
We are concerned that Waterways for Everyone will be seen as superseding Waterways for Tomorrow (2000) which we still see as the overriding document on the future of the Inland Waterways. It should be made clear that this new document contains additional commentary but in no way supersedes its predecessor which will remain in force.
The RBOA was pleased to be involved in the pre-consultation workshops organised by Defra but we are most disappointed that much of the content does not reflect the valuable discussions at those workshops. We believe that had this been taken into account, the current document would have been more valuable and far less future redrafting would be required.
Our general comments below are based on two criteria:
1) its success in setting the context and background for a debate on the future of the inland waterways and
2) its success in setting a course to achieve the required outcomes.
- Setting the Context
We accept that the document does set a good base for debate on many aspects of the inland waterways, with considerable detail in some cases. However, we are surprised and disappointed to find not a single reference to residential boating or residential moorings, despite their importance being acknowledged at the workshops. Residential boating has moved high up the waterways agenda and this has been recognised by many other organisations than just RBOA. The advisory document from The Association of Inland Navigation Authorities, Residential Use of Waterways (to be published shortly) and the considerable work done by British Waterways in producing a policy and guidance on residential moorings sites are testament to this.
People living afloat contribute towards increased choice in housing types and lifestyle, plus social inclusion and contributes to the life, vitality and natural surveillance of the waterway. The Government recognises people living on their boat as their sole or main place of residence as a specific household group. The key policy challenge faced by this specific household group is the supply of suitable mooring sites which have planning permission for residential use
Residential boating is important to the future of the inland waterways in making the link between the traditional boating interests and the wider agenda which is fundamental to Waterways for Everyone. It impacts on many of the policy objectives as set out under 1.7 as summarised below;
· Place making and shaping. Living on boats is all about improving the quality of life and it can be an important catalyst in bringing life back to deprived areas and giving them a sense of pride.
· The natural environment. Residential boaters are more aware than most of environmental and ecological issues and the need to manage our resources. They are in a good position to report any potential ecological problems to the relevant authority.
· Climate change. Residential boating can make a valuable contribution towards adapting to live in a changing climate for instance on flood plains.
· Cultural heritage. People living afloat see themselves as a continuation of this heritage and residential moorings can help to protect historic sites and promote interest in the traditions of the inland waterways.
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· Fairer, stronger and more active communities. Residential boating can support local communities and combat social exclusion by bringing together people from diverse backgrounds.
2. Achieving the required outcomes.
Moving on to the success of the document in setting a strategy for delivering the outcomes, we believe that it is seriously flawed. Given the current uncertainty regarding the future of the inland waterways, it is essential that this document is rigorous in identifying how the objectives are to be achieved. The future financial climate will be challenging for a considerable period and it is essential that government is given a robust steer on the action needed. There are no action plans, timescales or monitoring procedures indicated for government or other agencies. Organisations such as IWAC and AINA are referred to but there is no clear plan as to how they work in partnership or through government.
Where the document does propose action by central government, it is unclear how this will be done. We fully support the statement on the multi-functional role of waterways and the need to take account of this in a holistic way through recognition in regional strategies. However there is no indication of how this will be achieved. From our experience it is difficult to achieve a substantial reference to the waterways in Local Development Plans and Local Transport Plans.
As a particular example that is relevant to current RBOA initiatives we refer to 3.20-
Government will continue to encourage planning authorities, where appropriate, to work closely with waterways authorities and gain a better understanding of the specific issues faced by the waterways.
We have campaigned unsuccessfully through central government for planning guidance regarding the specific issues of residential boat moorings. The majority of planning authorities have little experience of this and can therefore only relate it to ‘bricks and mortar’ housing. National planning policy on housing, PPS 3, relates to built development rather than residential boaters as a specific housing group. Local planning policy needs to recognise that the issues related to this housing group are very different to those living in land based dwellings. There needs to be clear policy and guidance from government rather than leaving matters such as this to the discretion of the individual local authority.
Clearly, finance will be the key issue for the foreseeable future and Waterways for Everyone is weak in making the case for more sustainable funding. There needs to be more fundamental thought on how the waterways are funded and this document could have been a major catalyst in this. Instead, there is no clear message that waterways offer an excellent return on the expenditure of public money. There must be greater emphasis on the need for local authorities to recognise the benefits from waterways in delivering agendas such as healthy living and quality of life. The document discusses how navigation authorities can encourage local authorities to recognise this but the experience to date is that results are limited and variable without a lead from government.
The following are the RBOA responses to the specific questions asked in the consultation. We have also taken the opportunity to add comments on each section where appropriate.
Q1. Do you agree that the range of benefits of inland waterways identified above and expanded upon in the following chapters are correct? Are there any benefits that we have missed or overstated?
Yes, we are satisfied that the main benefits are adequately stated, with the exception of the lack of reference to residential boating, as noted above. As we commented above, our concern is with the lack of content regarding how these benefits are to be delivered. We reiterate that residential boating is a benefit to the waterways in addressing several agendas of both national and local government.
Q2. Do you consider that waterways are in a better condition now than they were 10 years ago? What have been the main achievements over this time and what could have been done better?
This is a very subjective question. The condition of the waterways certainly improved for a considerable period when BW’s maintenance backlog was substantially reduced. However, in more recent years the reduction in real funding is already having a detrimental effect and with a 250 year old system, this downturn could rapidly escalate. We are aware that the appearance of the towpaths and general environment has improved for the casual visitor whilst the actual ‘track’ has deteriorated primarily through a lack of dredging and bank protection.
Q3. Do you agree that it is important for regional development bodies and local authorities to work closely with those responsible for managing the Inland Waterways to ensure that the potential benefits in respect of place making and shaping are maximised? Do you have any ideas as to how this can be achieved?
We agree with this but do not believe that it will happen without a positive lead from central government. There is a wide variation in the approach of different RDAs and the support that they give their waterways.
Again, we commend the significance of residential boating in contributing to many of the benefits of the waterways as summarised below -
3.3 ‘catalyst for urban and rural development’
3.4 ‘social and environment benefits’
3.13 ‘community cohesion’.
‘supporting rural communities’
We repeat that we are surprised therefore that there is no reference to residential boating in relation to these and other aspects of the document.
We fully support the comment in 3.13 regarding the need for the waterways to be fully understood within the planning system and point to the experience of the RBOA in lobbying DCLG for planning guidance on residential moorings. We also support the comments in 3.14 and 3.15 on the need to influence regional and local authorities, but waterways authorities cannot do this alone, without a strong lead from government.
Q4. What more can navigation authorities do to encourage local authorities to consider using waterways to improve the quality for life of their local communities?
We believe that a considerable effort has already been made by navigation authorities but given the severe restraints on local government finances, further contribution will be difficult to achieve. There must be a real understanding that without a contribution from them, maintenance of towpaths and public facilities cannot be assured and this public amenity will inevitably deteriorate.
We are concerned that a focus on local amenity value can lead to any availably funding being focused on towpaths and associated landscaping at the expense of fundamental maintenance such as dredging. Without this, boat traffic will decrease and remove one of the main interests in visiting the inland waterways. Residential moorings are a positive way of encouraging more boat traffic on lesser used waterways and providing safe visitor overnight stays.
Q5. What do you think the barriers are to local authorities taking more interest in waterways in respect of place making?
There is currently little incentive for local authorities to support their waterways with funding or through the planning process. Any benefits accruing from good quality waterside development go to the developer or occupier. There should be a contribution to the local authority reflecting this increased value. Again, there is a lack of experience amongst many LPAs regarding good quality waterways design and best practice guidance would be welcomed
Q6. Do you agree that inland waterways offer an opportunity to help the UK mitigate and adapt to the effects of climate change? Are there any areas you consider that should be explored further in this context, including how the waterways themselves will need to adapt?
Yes we agree. Residential boating can offer a major contribution towards adapting to climate change. There is considerable potential for house-boats and floating homes in flood zones and this needs further exploration.
Following discussions with the Environment Agency, the DCLG has confirmed that residential moorings should be viewed as water compatible development in respect to Table D.2 in PPS25. This would allow residential moorings to be situated in any flood zone. We suggest that a reference to this should be included in Waterways for Everyone.
Q7. Do you agree that the unique cultural heritage associated with inland waterways provide a key benefit to those who use and visit waterways? How can these resources be used to further enhance and encourage use of the waterways?
Yes, but conservation of the built heritage is about finding a sustainable modern use for buildings and other waterways assets, and the funding to maintain all heritage structures.
As an example RBOA is working to protect and regenerate redundant canal arms and wharfs by introducing residential moorings there.
Q8. Do you consider the protection of the natural and built heritage to be one of the waterway authorities primary tasks?
Their primary task it to protect and maintain navigation and we do not believe that the waterways authorities alone should be responsible for protecting the natural and built heritage. There should be a national responsibility to protect all of our heritage and government should broker joint working between waterways authorities and other heritage bodies.
Q9. What area of waterway heritage do you consider most under threat?
Clearly anything which does not have positive and sustainable use is under threat. The non-bricks-and-mortar heritage (i.e. the traditions of the waterways, such as associated crafts and boating skills) are constantly under threat from a lack of education and understanding.
We believe that this risk can apply to actual stretches of inland waterway as well as heritage buildings and archives. Progressive reduction in funding could threaten lesser used waterways such as the Birmingham Canal Navigations.
Q10. Do you agree that inland waterways, including their paths and surrounding environments, provide an important resource for outdoor recreation, sport and improving public well being? What more can be done to protect and improve these important resources?
Yes, but this is not always appreciated by the people who use them or acknowledged in support from local authorities.
Q11. What needs to be done to make waterside paths more accessible and better appreciated by local communities?
Through greater education and improved access and signage.
Q12. Do you agree that waterside paths offer considerable potential for increasing green commuting, both for pedestrian and cyclists? What more can be done to encourage this further?
Yes, although multi-use of towpaths needs to be carefully managed and controlled. For example, cyclists should not present a threat to pedestrians and family use, or the needs of boaters navigating their craft.
Q13. What can be done to reverse the decline in freight on the inland waterways in recent years? Which elements of the commercial waterways have the greatest potential for freight use? How should the planning process ensure the protection of freight interests in those areas with greatest freight potential?
There must be greater investment to facilitate freight on the waterways that are designated appropriate for commercial use. For example by modern wharfage and a good standard of waterways assets which will facilitate efficient commercial use. . The retention of wharfs within new developments should be encouraged. The decreasing availability of such facilities makes it increasingly difficult for any new commercial traffic to be developed on our waterways. Such developments would go some way to decreasing the use of road highways, and cutting down pollution.
Q14. How can we best encourage a common purpose between different users of the waterways? What can be done to better manage potential conflicts?
All waterways users must come together to share our common enthusiasm for the waterways but also to understand individual needs and aspirations. By doing this in a proactive way, potential conflicts can be avoided. Examples of good practice should be used as models.
As an example, RBOA is supportive of the local mooring strategy groups that are being set up on the Kennet & Avon to bring together waterways users and local councils in managing moorings there.
Q15. What do you believe should be done to maintain and increase the number of boat registrations on our inland waterways?
Marinas and other boating facilities need to be more evenly spread around the waterways; there is currently congestion in some areas and lack of use in others. There is also a need for more entry level boats enabling young families and those less affluent to take up boating.
The RBOA is aware that residential boating is vital to the trade as a balancing vehicle during times of recession. There are clear indications that without this sector the effect of the recession on the boating trade would have been far more serious.
Q16. How can the waterways increase their share of the holiday market?
As with our reply to Q15, there is a need for cheaper hire boats to encourage new customers and those less affluent to try it. This is particularly important in getting groups of young people onto the waterways as there are few of the camping boats still operating.
Q17. Do you agree that there is scope for increasing waterway related volunteering activity? How can this be achieved?
There has always been strong volunteering activity based on the inland waterways and it is only recently that BW has recognised this and begun to support it. Opportunities need to be realised for a wider scope of volunteering than just practical restoration. Examples are heritage stewardship, visitor information and condition surveys.
Q18. How can schools and colleges be encouraged to make greater use of the waterways for educational purposes?
As in Q16 cheaper hire boats more appropriate for groups of young people would help to encourage greater use. School links with local stretches of waterway should be encouraged, with possibility of data recording (such as wildlife surveys), and awareness raising.
Q19. What can be done to help NCBA to increase the use of waterways to improve social inclusion?
By reducing access costs. Licencing, mooring, maintenance and compliance with regulations have become prohibitive to many community boating groups and support from local authorities is less forthcoming. As an example, the MCA boatmasters’ licence for public boat trips imposes a considerable cost on each volunteer helmsman.
Q20. What can be done to overcome barriers to achieving greater diversity among boaters and anglers using the waterways?
See responses to Q15 & Q16 regarding getting a greater diversity of people onto the waterways. Sharing of information at a local level (such as though NA User Group Meetings) often helps to overcome problems, and aids mutual understanding.
Q21. In view of the pressure on public finances, how can waterway authorities make the most of their resources over the next few years? Would mutual or third Sector status for British Waterways be beneficial in this respect?
We believe that the jury is still out regarding Third Sector status. RBOA has responded to the initial consultation that this and any other options are worth investigating as the current financial position is not sustainable. Our great concern is that in the immediate future the condition of waterways assets will deteriorate to a point where recovery will be long and expensive. See our reply to Q2.
Q22. What scope is there for enhanced partnership working to improve the resources available to protect and enhance the benefits delivered by inland waterways?
This has to be the way forward but must be based on a firm understanding by all agencies, both national and local of the wider benefits of the inland waterways. There are many examples of good partnership working but with the current financial restraints on both central and local government, it is difficult to see any real money being made available in the near future.
Q23. What activity should be undertaken to monitor the benefits delivered by the inland waterways over the coming years
Monitoring of benefits at the immediate waterways level, eg footfall at ‘honey pot’ sites is relatively easy. It is more difficult to monitor the wider benefits to the rural and urban economies from waterways in the vicinity. As an example, effects on the local economy resulting from recent closure of waterways were well publicised. We are not aware if there was any real monitoring of this.
The RBOA is aware that moorings for residential boats benefit the local rural or urban community. This is particularly so out of the main boating season when businesses that rely on boat traffic would struggle without them. The RBOA was disappointed that the recent report on the economic benefits of marinas, Inland Marinas Investment Guide did not identify the significance of residential moorings. In our view, a large percentage of the benefits came from these, rather than from the leisure boats that largely ‘parked’ there and then cruised away on holiday.
The RBOA is pleased to have been involved with the development of Waterways for Everyone and hopes that the issues raised in this response will be addressed in the final document.