I am writing on behalf of the Amenity Group, to comment on the proposals contained in the recent Government publication Waterways for Tomorrow, and on the implementation of those proposals.

  Generally, we welcomed Waterways for Tomorrow and would agree with the majority of the comments therein. As to the specific areas which you wish to consider, we have the following comments:

ROLE OF THE WATERWAYS

  Waterways for Tomorrow fully described the role of the waterways in urban and rural regeneration and in leisure, recreation, tourism and the industrial heritage. However, when dealing with the environment and enhancement of wildlife, although there was mention of the contribution from existing waterways, little mention was made of the potential for positive action from schemes such as canal restorations. For example, this group has constructed two "wetlands nature reserves" alongside restored lengths of canal. By incorporating such features at the design stage, much can be achieved at little cost; there is, however, always some cost (even if only that of purchasing/leasing a greater area of land) and it should not be left for the canal restoration body to bear this, non-canal, cost unaided.

  Similarly, although the use and potential for waterways to act as a water management tool was mentioned, the subject did not receive adequate coverage. Viewed strategically, a canal is a collector and retainer of fresh surface water, not otherwise available naturally. The channel is a potential means of flood control and water transfer. In other words, a canal both collects and moves water; it does not, however, consume it (apart from minor losses to the environment such as surface evaporation and seepage into the soil). Back-pumping as a means of re-using water is already widespread throughout the canal system. If the pump capacity of back-pumping schemes were increased where it is desired to move water uphill, and by-washes were installed around locks where the water was being moved downhill, it would be possible to move large quantities of water at a low infrastructure cost. As an example, consideration of the "Wessex Waterway Network" reveals that the Kennet and Avon Canal joins the River Avon just above the point at which the river's water becomes saline. Similarly, the Costwold Canals join the Severn just before the river enters the Bristol Channel. The installation of such schemes on those canals would transport fresh water (which would otherwise be lost to the sea) towards the south and east of England, an area which is currently short of water. The installation of a similar scheme on the Wilts and Berks Canal would then transfer some of the excess on the other two canals first to Swindon and then to the site of the proposed, expensive and controversial, Upper Thames Reservoir. As a result, the proposed reservoir could be at least reduced in size, and would possibly be rendered unnecessary. Any surplus water from such schemes could be used to supplement flows in the headwaters of rivers, such as the Kennet, where low summer flows are an increasing problem.

COMMERCIAL FREIGHT TRANSPORT AND THE GOVERNMENT'S INTEGRATED TRANSPORT OBJECTIVES

  As a restoration organisation, working on a canal which is, at present, isolated from the main system, we lack the experience to comment meaningfully on these subjects.

POLICIES AND FUNDING

  The policies and mechanisms contained in Waterways for Tomorrow appear to be adequate to ensure that its goals are met, with the exception of funding. In the area of funding, much is only outlined and although the need for maintenance and improvement of existing waterways is covered there is little mention of funding for restorations, except in the appendix covering the IWAAC report. At present, as acknowledged by section 3.11, there is fierce competition for funds; this is a sure sign that present levels of funding are inadequate.

  The many roles in which the restored waterways are expected to contribute to the national well-being (education, sport, heritage, leisure, bio-diversity etc) suggest that funding for these improvements should come from a wider basis than solely "navigation" sources. If the restored waterways are to form a public amenity, then the funding for the creation of that amenity should be public funding.

  There is not only a problem with the amount of funding but also with the current nature of funding. Current funding regimes tend to award funds on a project by project basis, where a project consists of a bridge or a local. Such a funding basis often ignores the synergistic gains of creating a length of waterway. For example, the HLF will fund the restoration of structures, but not the acquisition or dredging of the lengths of canal between those structures. Where a section of canal has been obstructed by development, HLF funds are not available for any diversion works necessary to link the sections on either side of the obstruction. Thus the logical result of sustained HLF funding is the construction of a number of isolated canal structures without any linking waterway to give them meaning. Similarly, insistence on "total authenticity in all respects" has in the past led the HLF to reject funding bids on the grounds that the materials to be used were not totally and exactly as in the original structure, regardless of the fact that use of the original materials would render the structure too weak for present safety rules. Canal restoration bodies need sustained funding over a period, to enable them to work steadily, over that period, on all aspects of the restoration of a length of waterway. The HLF grant to the Kennet and Avon Canal, of sustained funding over several years, is the model which should be followed, even if the sums involved might be more modest.

  One major current difficult for restoration bodies is maintenance of restored sections. There is no source of funding for maintenance; what funding is available is targeted at restoration. However, there is no income until the restoration is complete. As a result, as restoration proceeds, an ever-increasing effort is diverted to fund raising to support the maintenance budget and, similarly, an ever-increasing manpower input is required to undertake the maintenance. Current funding regimes therefore encourage a "restore and forget" policy, which, if followed, will generate a need for "re-restoration" in a few years time. Once again, the answer lies in changing the emphasis of restoration funding, from its present concentration on individual structures to a concentration on the creation of cohesive, useable lengths of waterway.

A M J Davy

Chairman

27 September 2000