Submission from Andrew Cooley in relation to:

Policy PR 10/9, Safeguarded Land – Upper Avon, Extension of Navigation

Objection reference 1176/AA

I want to clarify and emphasise that this objection is simply for the inclusion of a safeguarded land policy and not for the inclusion of support for the proposal, which would be premature. The safeguarding policy would ensure that the options remain open and that a full debate and environmental and engineering assessments could take place before any decision on whether to proceed. Without the safeguarding policy, the options could be closed.

2. Reasons for a safeguarding policy.

Inclusion of a safeguarding policy for this land would be in accordance with the guidance given by the Inland Waterways Amenity Advisory Council in their letter to the then Assistant Director of Planning of Stratford-on-Avon District Council, Mr. Simon Payne, dated 6 November 2001, (Appendix A) which confirmed the national significance of this route. Whilst acknowledging the controversial nature of the proposal and the need for an environmental assessment, the penultimate paragraph of this letter gives the advice:

"We also recommend that, as far as practicable, the projects included in our report should be supported by the appropriate local authorities using the full range of their statutory powers and scope for advisory and funding support e.g. for assessment and feasibility studies. The key element of support will be the safeguarding of the line of a proposed project by including it in the relevant local plan so that within the plan period options can be kept open pending further studies of impact and potential benefits."

The Inland Waterways Amenity Advisory Council is the statutory body set up under the 1968 Transport Act to advise the Government (DEFRA) and the Scottish Executive and British Waterways on strategic policy for the recreational and amenity use and development of the 2,000 miles of inland waterways managed by British Waterways.

In 2000 the Government published Waterways for Tomorrow setting out its policy for the Inland Waterways and responding to the important IWAAC report "Britain's Inland Waterways: An Undervalued Asset". It is IWAAC's current task to help to get the Government's messages over to those who will implement them. These include local authorities, the Regional Development Agencies, the Lottery Funding Bodies and many others. It has also produced for DEFRA a Good Practice Guide entitled Planning a Future for the Inland Waterways, which identifies the importance of Local Plans in securing the strategic development of the inland waterways. The level of commitment to the inland waterways by government is, perhaps, best indicated by their decision to have the contract for the M6 toll road altered to provide for the tunnel and aqueduct needed for the restoration of the Lichfield and Hatherton Canal.

It is, therefore, entirely in accordance with the government’s own stated aims to include a safeguarding policy, and failure to do so would be to ignore this guidance.

3. Inadequacy of general policies for open countryside and flood plains.

It could be argued that the general policies in the plan aimed at preventing development in open countryside and on flood plains would be adequate to prevent obstructive development on the route of the proposed extension of navigation.

My experience as a Stratford-on-Avon District Councillor for 8 years has shown me that, while such policies serve in the majority of cases, they are not always effective. There have been cases where development has had to be allowed despite such policies. Equally, there have been cases where development in the flood plain has not been opposed by the Environment Agency, leaving the Council exposed on appeal and resulting in the granting of permission to build dwellings in the flood plain.

It would only require one such inappropriate or poorly sited development to compromise the option for extending navigation on the upper Avon.

4. Relevance to the Plan period

There is, of course, no guarantee that funding will be available to advance the proposal even to the point of a feasibility study and environmental assessment during the plan period. Funding for such projects tends to be unpredictable, being highly dependent on grant aid from sources such as the National Lottery. It is, therefore, quite possible for funding to become available, particularly as this route has been identified (by IWAAC) as of strategic importance to the wide beam navigation network. There are currently many waterways projects in hand that were unfunded 5 years ago.

5. Policy proposal prior to the first deposit draft

As a member of the Stratford-on-Avon District Council during the period when the first deposit draft was being prepared, I proposed the inclusion of a policy to safeguard this route. The proposal was then defeated by a small majority, which I believe was the result of members not wishing to endorse the scheme to extend navigation without a full environmental assessment. By including a safeguarding policy in the plan, the options for that assessment and subsequent debate are kept open.

The vote at that time was also taken without the knowledge that there would be more individual objections to the first deposit draft requesting the inclusion of such a policy than on any other single matter.

Draft wording for the proposed additional section under policy PR 10 is attached as Appendix B.

Andrew Cooley
56 Longclough Road
Waterhayes
Newcastle-under-Lyme
ST5 7SW

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