The Inland Waterways Association (IWA) is a registered charity, founded in 1946 and campaigns for the conservation, use, maintenance, restoration and development of the inland waterways. It has over 18,000 members whose interests include boating, towpath walking, industrial archaeology, nature conservation and many other activities associated with the inland waterways. This response is submitted on behalf of the Association's Council and Committee members and concentrates on issues that are central to the role of the Agency.

  Overall, IWA would like to compliment the Agency on good practice in a number of matters:

—  Generally good administration.

—  Reasonable flood forecasting and telemetry.

—  Improved awareness of flora and fauna.

—  More "natural" riparian management.

—  Pollution preparedness and response.

—  Implementation of EC Urban Wastewater Directive.

—  Relatively easy access to staff.

—  Openness of information.

—  Generosity with advice and statistical data.

—  Commitment to consultation.

THE ROLE OF THE AGENCY WITH REGARD TO NAVIGATION

  Canals were built and rivers were improved over the past 300 years for freight transport. The control of inland navigation for pleasure cruising has developed very haphazardly in more recent years, generally applying old legislation to cope with uses for which it was not primarily designed. Of the three major inland navigation authorities, British Waterways (BW) controls canals and navigation on some rivers, the Agency controls navigation on some rivers largely confined to three of the Agency's Regions and the Broads Authority controls the Norfolk and Suffolk Broads. A number of small private and public sector organisations control a variety of other local navigations.

  The Agency's navigations were originally controlled by River Authorities and although the NRA and the Agency have been national bodies for some years, in most aspects there has been little integration of navigation-related tasks between regions. Some regions still act in an autonomous manner. For instance, the three regions acting as navigation authorities:

—  Have different fees and charges for boat licences, etc.

—  Start their accounting years in different months.

—  Have different boat registration numbering systems.

—  Have different licence offices.

—  Have different timetables to implement the Boat Safety Scheme; and

—  Have different third party boat insurance requirements.

  By contrast British Waterways, which licences a similar number of boats in total, allows licensing to start from any month in the year and has a compulsory third party insurance requirement. The flexibility in licensing periods eases the peaks and troughs of administration throughout the year.

  The apparent lack of enthusiasm of the Agency to iron out these differences in practice is a cause for concern; the attitude being that the Agency is bound by historic primary legislation and that nothing can be done about it. We would like to see the Agency grasp this nettle sooner rather than later, particularly as it offers opportunities for long term improvements in efficiency and economy.

  The Agency argues that it can be both an environmental regulator and a manager utilising natural resources but the Association needs to be convinced of this by better uniformity and co-operation between regions. The Association is also concerned that, because of financial restraints by the Government, the Agency has reneged on promises to navigation interests by continually reducing the proportion of funding apportioned to navigation and specifically by not using licence money collected in Thames Region for the purpose agreed with users. A specific large increase in licence fees was agreed between NRA and boaters on the understanding that it would be used for reconstruction and enlargement of certain locks, but this has not been done as the funds were diverted to general maintenance.

FREIGHT TRANSPORT

  It is now nearly two years since the Government first proposed that three per cent of all freight currently transported by road should be moved by water. The total carriage of freight on inland waterways is currently about three million tonnes per annum consisting mainly of coal, oil and aggregates; some waste is carried on some wider or longer estuarial rivers such as the Thames Estuary. However, apart from a few small loads carried by narrow boats, using the rivers as connections between various canal locations, no freight has been moved on to the Agency's river navigations and there seems to be no person or organisation within the Agency charged with increasing freight traffic.

THE ROLE OF THE REGIONAL ADVISORY COMMITTEES

  The Regional Advisory Committees were instigated to give the public some input into decision making by the Agency's regional and national officers. This is something that we very much welcome and we strongly believe that these committees need to be retained, if not strengthened. We are concerned that in some instances, nominations to the committees are chosen on the basis of political correctness rather than the best candidate, but we also feel that major user groups must be allocated representation which is sometimes not the case.

  There appears to be significant differences between the Agency's regions in the effectiveness of the committees, particularly with regard to agenda papers being sent out in good time for them to be properly studied by the recipients, and for the committees to arrive at positive recommendations, even if they may be at variance with the views of the officers of the Agency.

  The future make up and lines of work of these committees, particularly the Regional Fishery Ecology and Recreation Advisory Committee (RFERAC) appears to be being reconsidered internally within the Agency. IWA would like this to be a much wider public discussion.

  Although "navigation" was the first additional item to be covered by RFERACS when their role was expanded, both "conservation" and "recreation" were given two seats on most RFERACS but only one has been allocated for navigation in most Regions. Thames and Anglian Regions have more "navigation" members as they are both statutory navigation authorities; however Midlands, North West and North East Regions have extensive navigable canal and river systems within their areas which are important fisheries although the Agency has no statutory navigation duties. The "navigation" membership should be at least the same as conservation and recreation on all RFERACS and consideration should be given to reducing the "fisheries" membership in view of these committees' wider role.

  We are also concerned that the Agency's North West Region reportedly wishes to withdraw from its navigation responsibility although that region has a considerable length of valuable fisheries which are situated on navigations, and despite the requirements of The Environment Act.

AGENCY HEADQUARTERS AND NATIONAL USER GROUPS

  The Agency's Head Office staff at Bristol have seemed responsive to the concerns of user organisations and others with regard to navigation and related matters. This started under the National Rivers Authority, has continued with the Agency and is appreciated by users. Unfortunately there has been an all too frequent turn-over of staff. As a result, job holders have insufficient time to get to know people in the regions, in user groups and in other organisations. Regional staff tend to follow their own specialist subject policies sometimes ignoring guidance from Bristol.

  Papers produced for national publication are frequently prepared by regional officers and reflect a regional outlook. Many members of staff tend to retain the views of some of the Agency's predecessors that all navigations simply create problems: they do not appreciate the amenity and recreational benefits of navigations nor that restoration of derelict navigations also re-creates wetland areas and fisheries and may delay runoff and help to recharge aquifers. There also seems a reluctance to look at new technology to control water levels by techniques such as inflatable weirs.

FISHERIES

  British Waterways and other navigation authorities put a considerable amount of effort into leasing, stocking and policing their fisheries. All the Agency's Rod Licence income is retained by the Agency. We consider that the Agency should take a greater interest in the fisheries of other navigation authorities and contribute towards their costs. BW regularly purchases the largest weight of young fish from the Agency fish farms to re-stock canals in their charge.

LOCAL ENVIRONMENT AGENCY PLANS—LEAPS

  This Association has contributed to the consultation on nearly every LEAP in England and parts of Wales. We have been concerned and have commented on the lack of knowledge in the Agency of the canal system and other water areas where the Agency is not directly involved. In some cases canals have not been included on the maps nor in the information within the consultation documents.

  Although the original Catchment Management Plans of the NRA and the LEAPs of the Agency used to have a considerable amount of background reference data this has been reduced in plans produced more recently. Sometimes a volume of environmental data is produced to aid consultees but this is often only published at a later date when the plan consultation may have closed so rather defeating the objective.

NAVIGATION RESTORATION

  The Association welcomes the Agency's "in principle" support for restoration of navigation set out in its draft Navigation Restoration Policy and its willingness to assist with water resources and environmental assessment issues. However we are disappointed at the relatively weak level of support for restoration. The Agency has recently signed up to the strategic aims of the Association of Inland Navigation Authorities (AINA) which include the aim "to take all practical steps to assist (AINA) members and those in the voluntary sector in the restoration and management of waterways using best practice". We consider that the Agency should promote or actively examine restoration schemes where the Agency is, or once was, the navigation authority. In the June 1998 report of the Inland Waterways Amenity Advisory Council on waterway restoration there are eight restoration proposals extending or linking the Agency's Anglian waterways. It would be a sign of the Agency's support "in principle" if it set up a Study Group jointly with IWA and other local interests to examine these schemes in detail.

  The Association has also been involved in commenting on drafts of the Agency's Guidance Note Navigation Restoration and Environmental Assessment. Although we feel that this will be a helpful document, the present draft seems to concentrate on possible adverse impacts of restoration works while largely ignoring the positive ones. We feel that the Agency should go further than the "welcome navigation restoration in principle" statement and be seen to be willing to help resolve issues and to find solutions to environmental problems.

Neil Edwards,

Executive Director

October 1999