Development Control Policies in the Broads – RBOA Response to Public Consultation
This response is made by, and on behalf of, the Residential Boat Owners Association, (RBOA) and our members in the Broads area and in the hope that it will help inform the authority in establishing and refining its policy. Our response is based on 45 years experience of residential boating matters in general and residential moorings in particular. The RBOA is the only organisation dedicated to representing the interests of residential boaters and as such is represented, for example, at the Parliamentary Waterways Group and the British Waterways Advisory Forum.
Background: The RBOA has 932 members nationally (a member is a vessel so that is circa 2500 individuals) and was established in 1963. It is estimated that there are, throughout the United Kingdom, between 15,000 and 25,000 vessels being used for residential purposes. Total numbers of residential boaters remained fairly static until about ten years ago since when there has been a steady increase in vessels used “residentially”. The reason for the bulk of the increasing numbers is retired or near retired couples with high disposable incomes/assets who are looking for an interesting “gentle” and sustainable life style. Most people living on boats are doing so because it is a lifestyle they love and have chosen to adopt.
It cannot be denied that there are some who are on the margins of society who live on boats in an attempt to avoid officialdom and because it is perceived as a low cost way to live. The number of vessels claimed to be in this category is exaggerated and examples tend to be used to justify draconian action against all residential boaters. It is however a fact that this is a problem that can be managed. Proper, vigorous enforcement of licence/toll evasion; insistence on current insurance and Boat Safety Scheme Certificates and similar activity is a cost effective solution. The RBOA deplores evasion of taxes, licence fees etc.
The “problem” with residential boaters is the lack of residential moorings – that is moorings with planning approval for residential use. We estimate that only 10% of vessels used residentially are on residential moorings. It is seductive to characterise all of the balance of 90% as being illegal, but this is not the case. A very significant proportion are moorings that existed before 1948; many of the balance have been used “residentially” for more than 10 years and would be able to qualify for a Certificate of Lawful Use. Furthermore it is far from established in law that a mooring has to be designated as “residential”. Whilst it is the default position of many planning departments, including your own, it is a view that has been successfully challenged in a number of cases. See T/APP/E9505/C/98/1014232 & 1014374 & 76 Riverside Moorings, Riverside Road, Hoveton. October 12 1999
It is often stated that residential boats look different - that they stand out, strike a discordant note. This is rarely the case and to prove the point we have asked non-boaters to pick out true residential boats from other vessels at a mooring site, the only boats they can identify with certainty are hire boats because they have the company name on them! Where residential boats are identified it is because they have flowers on the roof or in the well deck – hardly offensive.
It is not unusual for the first warnings about injured or diseased waterfowl to be from residential boaters; it is a similar story with regard to all forms of pollution. Frequently residential boaters are the eyes and ears for rangers, water bailiffs and lengths men and very often a source of local knowledge and advice to other boaters and shore based visitors. All of the above are particularly true in the winter months and unpleasant weather; often the residential boater will be the only person for miles – that is their choice - but it means their presence is all the more valuable in an emergency.
At the meeting on 28th January a comment was made by a senior official of the Authority that “there is no heritage of residential boating on the Broads” Some very simple research demonstrates residential boating was an established feature of theBroads in 1858.
Finally residential boaters are acknowledged to be very environmentally aware – especially with regard to water quality - We live very close to it 365 days a year. Residential boating is, by its very nature, far more sustainable than the vast majority of land based homes.
Specific Response.
PO 30 7.33 – New Permanent Moorings.
a) What is an “adequate range of services”? This is so vague as to allow the authority to deny approval on an unacceptably arbitrary basis.
b) The authority should recognise that the majority of visitors will actively seek river frontage moorings as opposed to being in a basin or marina
g) Pump out facilities are frequently connected to underground holding (septic) tanks – why preclude this option?
PO 31 7.34 – New Residential Moorings
An astonishing statement. The situation outlined in PO 30 would lend itself to some – say a minimum 10% - residential berths. As outlined previously residential boaters provide security, a source of information, and local knowledge, adding diversity and interest for the visitor experience. How does the Authority propose to judge “significant adverse effect on the landscape or local amenity” - a purely subjective test. Will the Authority advise the existing moorers about the protection offered by a Certificate of Lawful Use?
7.38 “Motor craft contribute to the increased sedimentation and increase the requirements for dredging” In some situations yes; in others regular passage by motor craft decreases the need for dredging.
7.40. You have not defined a “houseboat” This is a term which should be reserved for a vessel that is residential and has no means of independent propulsion or facilities for such means to be fitted or installed. As such these could be purpose built or converted from dumb barges and can look like floating caravans. nHowever the majority of residential craft in the Broads are converted, ex sea going vessels or truly mobile craft for example wide beam barges or narrowboats. Many are historic vessels which the owners should be commended for preserving.. Whilst it is true that use of the riverbank can be intrusive this can easily be dealt with by implementing simple rules governing what can and cannot be put on the bank. The majority of residential boats do not intrude on the bank. A residential boat is no more or less of a hazard to navigation than a vessel of the same dimensions which is non residential or visiting. If the vessel is a “boat” in the accepted sense its presence in water, by a riverbank is “natural”, contextually correct and in the eyes of the majority of visitors – appropriate.
7.44. It is truly objectionable to imply that those choosing to live afloat are “potentially vulnerable people”. The vast majority are not. They are, typically, independent, resourceful and fit. It is not essential by any means for every residential mooring to have services on site. Thousands of residential moorers around the country move their vessels to go to pump out, take on water and dispose of rubbish - it is part of their way of life – just as householders drive to the tip or recycling point. An imaginative proposal would be for the Authority to invest in a vessel capable of offering pump out, elsan and rubbish disposal to moored vessels. Doubtless with a little imagination sponsors could be found to help defray the cost – volunteers would certainly provide part, if not all, of the crew.
7.49 PO 33 Mooring Plots
These would lend themselves to residential moorings. Is this an option you are considering?
Waterside sites and Boat yards
An important element in helping to retain viable boatyards without losing the essential character is to allow their use for residential purposes. This provides some income and helps with the retention of facilities such as pump out, fuel supply etc.
RKW 6:02:2008
E mail vicechair@rboa.org