Inland Waterways Team Department for Environment, Food and Rural Affairs Zone 2D, Ergon House 17 Smith Square London SW1P 3JR RYA House Ensign Way, Hamble Southampton SO31 4YA United Kingdom Tel +44 (0)23 8060 4100 Fax +44 (0)23 8060 4299 www.rya.org.uk Direct tel: +44 (0)23 8060 4220 Email: gus.lewis@rya.org.uk 26 March 2010 Dear Sir Waterways for Everyone the Government s strategy for the inland waterways of England and Wales We refer to the Consultation Paper published on 21 December 2009 in relation to the above. The RYA is the national body for all forms of recreational and competitive boating. It represents dinghy and yacht racing, motor and sail cruising, RIBs and sportsboats, powerboat racing, windsurfing, inland cruising and personal watercraft. The RYA manages the British sailing team and Great Britain was the top sailing nation at the 2000, 2004 and 2008 Olympic Games. The RYA is recognised by all government offices as being the negotiating body for the activities it represents. The RYA currently has over 100,000 personal members, the majority of whom choose to go afloat for purely recreational non-competitive pleasure on coastal and inland waters. There are an estimated further 500,000 boat owners nationally who are members of over 1,500 RYA affiliated clubs and class associations. A significant proportion of our affiliated clubs and members participate in recreational boating on the inland waterways and many keep and/or navigate their boats on the UK s rivers and canals. Others charter boats from the wide range of inland boat hire businesses. The RYA also sets and maintains an international standard for recreational boat training through a network of over 2,200 RYA Recognised Training Centres in 20 countries. On average, approximately 160,000 people per year complete RYA training courses. RYA training courses form the basis for the small craft training of lifeboat crews, police officers and the Royal Navy and are also adopted as a template for training in many other countries throughout the world.
2 The RYA has developed its Inland Helmsman s Certificate specifically for use on the inland waterways and the Maritime and Coastguard Agency has recognised the integrity of this qualification by accepting it as an alternative to the MCA Boatmaster s qualification for use on certain craft under the Merchant Shipping (Inland Waterway and Limited Coastal Operations)(Boatmasters' Qualifications and Hours of Work) Regulations 2006. The RYA also issues the International Certificate of Competence on behalf of the UK Government and many of these Certificates are issued to UK inland waterways recreational boaters wishing to navigate on the inland waterways of Europe. The RYA attends meetings of the UN Economic Commission for Europe Working Party on Inland Water Transport in its capacity as secretariat to the European Boating Association. The RYA works closely with other representative organisations whose members are involved with the inland waterways, including the British Canoe Union, the British Marine Federation and the Inland Waterways Association. The RYA therefore has a keen interest in the UK s inland waterways and welcomes this opportunity to comment on the Consultation Paper. We set out below some general observations as well as our answers to the specific questions posed. General Comments The RYA supports the Government s stated commitment to secure the continued and sustainable revival of the waterways and their contribution to the wealth, health and wellbeing of communities across the country and its aim of widening interest and participation in the traditional water-based activities. The RYA also welcomes the Government s proposed actions as identified in the list set out in the Consultation Paper. Chapter 2 - Our inland waterways today The RYA supports AINA s argument, as explained in paragraph 2.10, that there should be a comprehensive overhaul of inland waterways legislation, to facilitate effective management of the existing inland waterways network. Chapter 3 Place making and shaping The RYA supports the point made in paragraph 3.8 with regards protecting and restoring disused waterways. The RYA agrees that when considering planning decisions, local authorities and stakeholders should identify and protect disused waterways when there is reasonable chance of restoration proceeding in the future. In addition, we believe that the planning system has a wider role to play in support of the inland waterways. In particular, both the forward planning and the development control elements of the planning system could be used to manage, protect and enhance inland waterways generally for recreational boating and for non-navigational recreational activities. Local planning authorities could, for example, be encouraged to provide networks of readily accessible facilities, including both new and extending existing facilities; protect important waters for navigational purposes; protect waterside
3 sites from adverse development but also levering enhancements through beneficial development; protect access to waterside sites; and encourage boating generally in terms of social inclusion. The RYA publishes a Planning Handbook, which sets out a comprehensive explanation of how the local planning system interrelates with the development of recreational boating facilities. We consider that, when dealing with planning issues affecting linear features such as canals and rivers, local planning authorities should be encouraged to ensure that they consult with neighbouring authorities where relevant to ensure a joined-up, crossboundary approach. The RYA welcomes the statement laid out in paragraph 3.20 that claims Government will continue to encourage planning authorities, where appropriate, to work closely with the waterway authorities and gain a better understanding of the specific issues faced by waterways. Chapter 4 Climate change The RYA welcomes the recognition given to the Green Blue Project in paragraph 4.10 and later in paragraph 5.7 of the consultation paper. As the text box explains the Green Blue is a joint environmental awareness initiative led by the RYA and British Marine Federation. The Green Blue team has worked with a number of British Waterways Marinas and in the past with the Broads Authority, and offers extensive advice and information to recreational boaters and leisure marine business on the inland waterways as to how they might reduce their impact on the environment. This advice is supported in RYA publications such as the Inland Waterways Handbook and Go Inland, the latter forming part of a range of books aimed an encouraging children to take an active part in recreational boating. Chapter 5 The natural environment By way of clarification, the phrasing of the third bullet of Paragraph 5.7 suggests that in addition to promoting best practice the Green Blue also proposes the imposition of speed limits, which is not the case. This paragraph should therefore be restructured to separate the Green Blue s promotion of best practice from the navigation authorities imposition of speed limits. The RYA wholeheartedly supports Paragraph 5.10 of the consultation paper which states In the Government s view there is no reason why implementation of environmental legislation should threaten navigation. The Government will work with waterway authorities and regulators to ensure that the implementation of environmental legislation takes proper account of the need to sustain navigation and recreation and their associated public benefits. The RYA welcomes the point made in paragraph 5.13 with regards the essential role of dredging in preserving and restoring watercourses. The RYA supports the statement Properly undertaken, dredging need not have an adverse environmental effect and can sustain the ecology and biodiversity of the waterways and welcomes the role of the AINA Good Practice Guide.
4 Chapter 7 Health, well-being, recreation and sport The RYA welcomes the acknowledgment of the importance of water-based sport and recreation in paragraphs 7.4 to 7.13. The RYA supports comments made throughout the chapter with regards initiatives to encourage more people to take up water based activities and the Governments support for the development of all forms of water recreation in a sustainable way. However, paragraph 7.6 states Because boat ownership involves a substantial financial commitment, the ability to expand participation in this way is very limited. The RYA believes that it is a misconception that boat ownership necessarily involves a substantial financial commitment. While this may be true for some larger craft, there are myriad sizes and types of craft in use on the inland waterways and there is a healthy second-hand boat market and hire-boat fleet, which allows individuals to enjoy navigating the inland waterwyays for relatively little investment. Many people are introduced to recreational boating on the inland waterways through boating clubs and research carried out in 2009 by the Central Council for Physical Recreation suggests that the average annual subscription for a sailing club, for example, is significantly less than the average annual subscription for a swimming, tennis or volleyball club. Notwithstanding the above, the RYA believes that waterways authorities could do more to promote the accessibility of the waterways in a more socially-inclusive way. In addition, significant increases in licence fees for navigating on the inland waterways are likely to act as a barrier for those on lower incomes to access the waterways. Chapter 8 Sustainable transport With regards the statement made in paragraph 8.8 that The Government will support the transfer of freight from road to water, where it is practical and economically and environmentally sustainable to do so the RYA would like to raise the issue of recreation and sport as mentioned in the previous chapter. The RYA appreciates the potential environmental and social benefits this transfer presents but urges that it is not completed to the detriment of the inland waterways leisure and recreational industry. The RYA would also expect to be included in any future consultations with regards this issue. Chapter 9 Tourism and business development In paragraph 9.2 the RYA welcomes the recognition that boating tourism and recreation support many businesses adjacent to or dependent upon navigable waterways. The construction and operation of new and existing marinas, as well as the improvement to recreational access sustains many local economies and is encouraged by the RYA. However, Chapter 9 as a whole appears to be drafted exclusively with navigational interests in mind. This is inconsistent with the aspirations set out in Paragraph 1.3 and in Chapter 7 that the inland waterways offer a facility for a wide range of recreational activites, only some of which are water-based, and the recognition in Chapter 7 that inland waterways can provide a catalyst for urban and rural regeneration that may in turn attract visitors. We would therefore suggest that Chapter 9 should be expanded to include a discussion of the opportunities for non-navigational tourism and business development.
5 Chapter 11 The way forward The RYA acknowledges that increasing pressure on the core funding of waterways authorities and the current state of the public finances is such that the Consultation Paper cannot include financial commitments. The RYA is concerned, however, that the Consultation Paper does not identify any tangible, measurable commitments or performance indicators or timescales for delivery. Specific Questions 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? We agree that the range of benefits identified is reasonably comprehensive. 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? In general terms, we agree that the waterways are in a better position now than they were 10 years ago but there nevertheless remains a maintenance and capital works backlog that will only increase if funding deficits are not tackled. If the maintenance and capital works backlog continues to grow then the overall condition of the waterways will start to deteriorate. Many inland waterways are dependent on volunteers to undertake maintenance and restoration work and navigation authorities could do more to encourage volunteers to become involved in such activities. 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? We 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? This might best be achieved by persuading the Department for Communities and Local Government to include specific waterways-related measures in the list of National Indicators by which the performance of local authorities is measured by central Government. In addition, the Department should ensure that guidance is issued to local authorities on the need to take full account of inland waterways and recreational boating (where relevant) in forward planning and development control. Q4. What more can navigation authorities do to encourage local authorities to consider using waterways to improve the quality of life of their local communities? Navigation authorities should seek to identify how they can assist local authorities with the delivery of activities that are measurable against the National Indicators.
6 Q5. What do you think the barriers are to local authorities taking more interest in waterways in respect of place making? Finite resources and a need to satisfy central Government that they are performing against the National Indicators. 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? We agree that inland waterways offer an opportunity to help the UK mitigate and adapt to the effects of climate change. However, not only will inland waterways themselves be likely to suffer the direct effects of climate change as identified in the Consultation Paper but they may also offer a mechanism for mitigating impacts felt elsewhere, for example as part of an integrated flood management programme. 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? Q8. Do you consider the protection of the natural and built heritage to be one of the waterway authorities primary tasks? We believe that the waterways authorities primary task is to facilitate and manage navigation on their navigable waterways. We agree that the protection of the natural and built heritage may be a secondary task. Q9. What area of waterway heritage do you consider most under threat? 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? We agree that inland waterways, including their paths and surrounding environments provide an important resource for outdoor recreation, sport and improving public well being. Q11. What needs to be done to make waterside paths more accessible and better appreciated by local communities? 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?
7 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? We would broadly welcome a reversal of the decline in freight on the inland waterways, provided that it is not to the detriment of the inland waterways leisure and recreational industry (which is also an important economic sector), but we are not in a position to comment as to how this reversal might best be achieved. Q14. How can we best encourage a common purpose between different users of the waterways? What can be done to better manage potential conflicts? The RYA believes that waterways authorities should seek to provide appropriate fora to facilitate communication between different waterways users in an effort to resolve any differences at an early stage. Q15. What do you believe should be done to maintain and increase the number of boat registrations on our inland waterways? The RYA believes that the number of boat registrations is likely to reflect the amount of the registration fee with continued increases in such fees resulting in fewer registrations and, eventually, reduced net revenue to the waterways authorities. In addition, the RYA believes that it is a misconception that boat ownership necessarily involves a substantial financial commitment. While this may be true for some larger craft, there are myriad sizes and types of craft in use on the inland waterways and the RYA believes that waterways authorities could do more to promote the accessibility of the waterways in a more socially-inclusive way. Q16. How can the waterways increase their share of the holiday market? Q17. Do you agree that there is scope for increasing waterway related volunteering activity? How can this be achieved? We agree that there is scope for increasing waterway related volunteering activity and we would encourage waterways authorities to work closely with established voluntary organisations to promote volunteering activity on the waterways. Q18. How can schools and colleges be encouraged to make greater use of the waterways for educational purposes? The RYA believes that schools and colleges might be encouraged to make greater use of the waterways for educational purposes by assisting them in overcoming the riskaverse tendencies that have become endemic as a result of the perceived compensation culture. Water-based sport provides an ideal platform for developing self-reliance, responsibility and an understanding of the consequences of actions as well as a foundation for physical, emotional and social well-being. Q19. What can be done to help NCBA to increase the use of waterways to improve social inclusion?
8 Q20. What can be done to overcome barriers to achieving greater diversity among boaters and anglers using the waterways? The RYA believes that waterways authorities and local authorities could do more to promote the accessibility of the waterways and water-based sport and recreation in a more socially-inclusive way. 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? The RYA is broadly supportive of BW s proposals to move into the third sector, although the key to the success of such a move will be securing a commitment from Government to provide sufficient financial support. Q22. What scope is there for enhanced partnership working to improve the resources available to protect and enhance the benefits delivered by inland waterways? The RYA believes that there is great scope for enhanced partnership working between Non-Government Organisations such as the RYA, waterways authorities, local Government and central Government with a view to identifying and promoting common policies and objectives. Q23. What activity should be undertaken to monitor the benefits delivered by the inland waterways over the coming years? The RYA believed that the Government s strategy for the inland waterways should identify tangible, measurable commitments and performance indicators and set out timescales for delivery Please do not hesitate to contact me if you have any questions or queries arising from this response. On behalf of the RYA, I would be pleased to be involved in any future consultations or discussions. Yours faithfully, Gus Lewis Legal & Government Affairs Manager