Broads Authority

Local Development Framework

Core Strategy : Issues and Options Report

Response on behalf of the Norfolk and Suffolk Boating Association

Introduction

The Norfolk and Suffolk Boating Association was formed in 1894. Our membership consists of 38 affiliated clubs and associations, themselves representing around 9,000 boating enthusiasts and more that 1,000 individual members from all parts of the UK, who have an interest in boating of all types on the Norfolk and Suffolk Broads. Our individual membership has increased by 10% in the last four months reflecting, we believe, increasing concern about the way our unique navigation is being managed.

Our objectives are:

To serve, protect and promote the interests of private users of pleasure craft in Norfolk and Suffolk;

To coordinate the regatta fixtures of affiliated clubs and open regatta committees and to publish annually a handbook incorporating a consolidated fixture list;

To cooperate with other organisations concerned with the interests of boat users in Norfolk and Suffolk or with matters affecting those interests.

The Issues and Options consultation document

We hope that future documents will be written in plain English. We found this one difficult to wade through and it contained too much jargon. The structure of the document was unclear. We found it hard to distinguish what was background, what was discussion of future options and what was statement of decisions already made in response to previous consultation. For a consultation to be effective, it should be couched in language that people can understand and engage with. We realise that there are other reasons for carrying out consultations beyond that of obtaining and responding to stakeholders’ concerns.

Draft Sustainability Appraisal report

We noticed some questionable assessments in this document. For example, in Table 1.1 we find it difficult to see a direct connection between “Ecological Enhancement” and “Reduce vulnerability to climate change and flooding”. The climate will change and floods will occur, no matter what work is done to enhance ecology

A Sustainability Assessment has to be conducted in the light of “sustainability objectives. The government expects SOs to be defined regionally or locally, so they may vary from place to place. The ODPM has, however, supplied an “illustrative” set of sustainability objectives. They are:

· maintenance of high and stable levels of economic growth and employment;

· social progress which recognises the needs of everyone;

· effective protection of the environment; and

· prudent use of natural resources

We do not accept that the very first two objectives in the Core Strategy vision statement – “Protect and enhance the natural and cultural environment” and “sustainable resources use” should be seen as in conflict with “Navigational Interests”.

Bearing in mind the importance of navigation to the local economy, the role navigation plays in the “cultural environment”, and the significance of navigation in relation to access (and thereby social inclusion issues), this scoring is blatant nonsense.

If this exercise is to have value it should be carried out objectively. The conclusions drawn at the end of the report are only as valid as the chosen sustainability objectives and the assessments. Until these are objective, the conclusions are unreliable.

The Broads Act

We are concerned to read on pages 7 and 8 about the proposal to change the wording of the purposes of the Broads (we assume you omitted the word “Authority” in error). We hear no clamour for changing the purposes of the Broads Authority as defined in the 1988 Norfolk and Suffolk Broads Act. Indeed we are suspicious of the term “special qualities” and question what distinguishes a quality such that it becomes special. Is it intended to limit enjoyment to those qualities bureaucratically defined as special and ban the enjoyment of others? We feel that particular phrase adds nothing to the Authority’s purposes and would advocate retention of the existing wording.

1. Option Vision 1 – Should we retain the vision as set out in the draft Regional Spatial Strategy?

No. The vision must include a view of the importance of recreation and navigation within the future of the Broads. These aspects cannot be relegated to being ”addressed on a topic basis”. In fact, were they to be so relegated, the Broads Authority would be neglecting its statutory duty to address its three objectives and not to show precedence, one over the other.

Boating and recreation are central to the social and economic well-being of the area. Failure to recognise this in the vision for the future of the Broads will inevitably result in decisions which neglect those important aspects of the life of the area.

NSBA support the objective of protecting and enhancing the environment and believe that this can be achieved alongside a pro-active approach to protecting and enhancing the facilities within the Norfolk and Suffolk Broads for recreation and navigation.

2. Option Vision 2 – Should the vision be amended to include reference to navigational interests?

Yes. See our comments above.

3. Option Vision 3 – Should the vision be amended to include reference to ecological and landscape enhancement.

Yes. At the same time it should be amended to include reference to enhancement of the existing navigation, restoration of those sections of the navigation that have been closed or have fallen into disrepair through neglect and those facilities, such as public staithes, which have, by one means or another, been lost. Ecology and landscape enhancement can be achieved alongside enhancement and restoration of the navigation. They are not mutually exclusive objectives. The Broads Authority has a duty to pursue them with equal vigour.

We believe that, in order to exploit opportunities to enhance the navigation, the Broads Authority will need to arm itself with the necessary information and the policies needed to allow it to take advantages of opportunities when they present themselves.

4. Option Vision 4 – Should the Core Strategy consider the identification of specific measures to secure flood protection?

Yes. It is important to realise the twin risk of flooding from run-off within the catchment area and inundation from the sea. The vision should indicate a medium term strategy for reducing those risks by means sympathetic to all three of the Broads Authority’s purposes enshrined in the Norfolk & Suffolk Broads Act 1988.

5. Option F&CC1 – Should the Core Strategy examine the options for flood alleviation?

Yes. Those options must recognise the need to maintain facilities for navigation (staithes, boatyards, moorings, adequate water depth, etc) and proposals for implementing those options should be sympathetic to the needs of the navigation. Opportunities should be sought to enhance facilities for navigation (and ecology, landscape and recreation) at the same time as alleviating flooding.

6. Option F&CC2 – Should the Core Strategy prevent all future development in flood plain and high risk areas?

No. By their nature, boatyard and similar facilities lie in the flood plain. They serve the needs of both privately and commercially owned craft, whose tolls are important to the Broads Authority and whose revenues are important to the well being of the local economy. The changing profile of boat ownership (fewer hire craft, more privately-owned craft) means that a fresh view needs to be taken about the nature, location and extent of waterside facilities to service their needs. In the light of the loss of many boatyards (generally converted to residential or holiday accommodation) consideration should be given to the development of marinas targeting the needs of private owners. These could be built close to main conurbations, where their environmental impact would be insignificant.

7. Option F&CC3 – Should the Core Strategy limit development in the flood plain and high risk areas to that which is essential, with criteria listed against which “essential” can be measured.

No. We doubt the Authority’s ability to define “essential” in a way which will stand the test of time. Similar considerations would lead us to reject Options F&CC4 and 5.

8. Option LWL1 – Should the Core Strategy protect landscape value as an over-riding priority?

No. We consider that the concept of “the Broads as a living working landscape” contains within it a major dichotomy. For example; “protecting local distinctiveness and character”. There are some areas of the Broads, such as the extensive reaches of the lower Bure and its passage through Great Yarmouth, the character of which we would wish to see changed and not preserved. Equally, it is difficult in the extreme to ascertain ‘tranquillity’ on the upper reaches of the Bure near Wroxham on a hot August Saturday with literally hundreds of day launches jostling for space. It should be remembered that the broads are essentially a man made landscape, and have constantly been subjected to change. Thus whilst the attempt at a holistic approach is understood, the Authority should acknowledge that there are substantial areas of the landscape that do not need “protecting as a whole” and within these areas development to improve facilities for navigation and recreation should be encouraged.

We believe that words such as “over-riding”, when included within strategies, provide hostages to fortune. They should be avoided.

9. Option LWL2 – Should the Core Strategy set over-riding strategic criteria against which landscape impact can be assessed, within a general framework of protection and restraint?

No. We dislike the use of the word “over-riding” and suspect that this proposal is made for reasons of bureaucratic convenience and control.

10. Option LWL3 – Should the Core Strategy identify areas where development would be appropriate in landscape terms, within a general framework of protection and restraint?

We see no reason why it should not do so.

11. Option LWL4 – Should the Core Strategy require enhancements to the landscape? If so where?

We can see a number of opportunities for landscape enhancement allied to improvement and restoration of facilities for navigation. For example: removal of alder carr and overhanging trees beside the navigation will restore the landscape to a former state, tend to make the bank more resistant to erosion and improve the habitat on the river margin for all forms of wildlife while, at the same time, improving wind flow for navigation by sail and restoring the informal bankside moorings that were available before the trees were allowed to encroach on the waterway. It will also reduce the incidence of fallen trees lying in the river. What is needed is awareness of the possibilities and the willingness to exploit them.

12. Option HCE1 – Should the Core Strategy protect and enhance the historic and cultural landscape as a key priority?

Yes on the assumption that any attempt, within the concept of a Core Strategy, to ‘protect and enhance the historic and cultural landscape’ will include the restoration of former navigable waterways lost to navigation together with their associated staithes and moorings. Many of these broads and waterways form part of the real historic and cultural landscape as former trading and transport routes used by wherries, of which the Authority is rightly inordinately fond. A real opportunity exists here to not only preserve, but truly enhance the historic cultural landscape whilst at the same time assisting to create a more sustainable tourism and navigation infrastructure by a significant increase in navigable waterways.

Again, we caution against use of words like “key” within a strategy document. What is key and what is not?

13. Option HCE2 - Should the Core Strategy define “enhancement “ and specify the measures to be taken?

No. We doubt the Authority’s ability to provide an adequate definition which will not do as much harm as good.

14. Options HCE3, 4 & 5.

We advise against attempts to codify the future.

Natural Resources

We are pleased to read on page 36:

“… a number of consultees referred to the balance in the Broads Act between the three equal purposes of protection, recreation and navigation and re-iterated the principle that none should have precedence. This latter issue was raised in respect of the vision which may be the appropriate place to address this.”

It most certainly is the place to address it and we re-iterate our comments made above under item 1.

15. Option NR1 – Should protection, enhancement and habitat recreation be a key objective across the area?

The use of the work “key”, in the same way as “over-riding” in previous Options, flies in the face of the Authority’s statutory duty to pursue its triple purposes in an even-handed fashion.

Many of the issues contained in the abstract from the Broads Plan are laudable in themselves, however it must be argued that they have been followed and pursued with an entirely inflexible approach and without proper consultation with the relevant interests, including the navigation interest which the Authority has a statutory duty to protect. For example, we regret the recent clumsy attempt at the winter closure of Horsey Mere. The assumption here seems to be that the use of the waterways for navigation and recreation is detrimental to wildlife and nature conservation. The core strategy should therefore look at the integration of wild life conservation with the navigation interest, not at wildlife conservation in isolation, as has been the procedure in the past. The most important issue here is an examination of the number of broads closed to navigation, and thus available totally for nature conservation and biomanipulative experiments and those available for navigation and recreation: an examination of the possibility of balancing these two figures should be undertaken.

16. Options NR2, 3, 4 & 5

We wonder why, given the plethora of UK and EU laws and regulation, further codification is required. To do so would inevitably create unintentional conflicts. It is hard enough at the moment to identify which particular statute, code, byelaw, precedent or regulation applies in any given set of circumstances.

17. Option NR6 – Should the Core Strategy examine and identify opportunities for sustainable flood plain management which offer nature conservation benefits and other gains?

Yes, provided that those “other” benefits include improvements to the navigation and facilities for recreation. Again, we emphasise the need for (and regret the lack of evidence of) an even-handed approach between the Authority’s trinity of purposes. The wording of this option should include specific reference to all three of the Authority’s purposes.

Our recent experience has been that flood alleviation works have been carried out with disregard for the need to maintain navigation facilities, let alone any consideration of enhancement.

18. Options DESC 1 – 7

Our concerns are raised in the issues outlined in this questionnaire. Access to the area without using a boat is, at best, poor. The best method of addressing both social inclusion and improving access is to encourage the establishment of small boatyards and moorings in some of the more remote rural areas to provide improved access by water. This might also have the effect of improving the ‘health of the local economy’. The NSBA welcomes any serious attempt to assess the future of the hire boat industry but considers that it should be developed in conjunction with a strategy for boatyard and marina development, bearing in mind the changing pattern of boat ownership. We support any increase in the provision of community facilities, especially those that are to be maintained and not closed as we believe some of those in the Broadland district to be.

There are parallel opportunities for changing use of land and buildings from agriculture to uses which support boating (e.g. repairs, winter storage etc.).

19. Option TR1 – In considering tourism and recreational development should the Core Strategy adopt criteria-based policies which apply equally across the Broads and give priority to the protection of landscape and nature conservation value?

No. The Authority must be even-handed in applying its purposes. In saying this, we do not advocate any action detrimental to the environment. The Authority must be careful not to give precedence to any one stakeholder group and should certainly not give any one such group any form of veto.

20. Option TR2, 3, 4, 5

It is most interesting to note that this was the first reference in the Core Strategy to any policy for the navigation interest, other than concerns for the economy of the hire boat industry. While some of these issues have been referred to already in this statement we are pleased to note that the issue of parish staithes and their protection is still on the agenda. This measure should also seek to definitively ascertain the ownership of all staithes, and to reclaim some that may have been taken into private hands. Likewise, we look forward to a strategy that resolves the shortage of short and long term moorings and would welcome full consultation in the preparation of such a document. Whilst the aim of ‘improving the quality of the physical infrastructure’ may be laudable, we would be interested to know how this is to be achieved, and at the same time suggest that the Authority ensures that the areas for which it is responsible are always maintained to a high standard and repaired quickly when necessary.

We are extremely concerned to read the statements on page 57 and believe that the statement that: “Whilst the Core Strategy will be seeking to promote economic sustainability this must not be at the expense of environmental sustainability and where there is conflict the environmental considerations will take precedence due to the statutory purposes of the Authority.” is in direct contravention to the Norfolk and Suffolk Broads Act 1988. In fact, the Authority is required to be even-handed in its attention to its three purposes and it must also have regard to: “… the economic and social interests of those who live and work in the Broads.”

Any strategy for managing the development framework of the Broads must recognise the rights of all stakeholders in the area. No one interest group can be given the power of veto.

21. Housing

We have no comment to offer on this matter other than a general plea for good solid design policies that reflect the local vernacular and at the same time encourage a high standard of contemporary design.

22. Access and Transport.

We believe continued unrestricted access to the broads by water is the key to a balanced and sustainable future for the area. The reopening of currently closed broads to navigation together with access by foot and cycle should form a major part of the Core Strategy.

P E Ollier

Executive Secretary, NSBA

10.10.2005