WATERWAYS FOR EVERYONE: INLAND WATERWAYS ASSOCIATION
RESPONSE TO CONSULTATION
This document is the Inland Waterways Association‟s (IWA‟s) response to the
DEFRA consultation on the Government‟s strategy for the inland waterways of
England and Wales – Waterways for Everyone.
IWA priorities for central government action.
An IWA overview of the strategy.
Our views on the list of Government actions.
Our response to the 23 questions.
A commentary on the 11 chapters.
Annex A: An Inland Waterways Conservancy – The IWA Vision.
IWA PRIORITIES FOR CENTRAL GOVERNMENT ACTION
IWA recognises that the future of the inland waterways is not simply a matter for
central government. It requires partnership between central government, local
government, other public sector bodies, the private sector, the third sector and the
full range of other stakeholders, whatever their status.
Nevertheless, the securing of the future of the waterways requires central
government to really focus on the waterways over a relatively short period during
which it would need to take a pro-active lead in many areas and be willing to
fundamentally revisit certain waterways policies and change them so that they
become effective. During this period the actions which IWA believes central
government should prioritise are to:
1. reach agreement with the publicly owned waterway authorities (BW and EA) on
the works required to remedy the maintenance backlogs on their respective
networks and thereafter annual maintenance required to keep the networks in
2. provide a powerful policy steer to local authorities and other public bodies,
including Regional Development Agencies, so that locally led funding packages
are developed (accessing private, public and third sector funding) to help finance
the works required at 1;
3. provide the balance of funding required through grant-in-aid;
4. facilitate volunteering on the publicly funded waterways so that it can make a
5. ensure that the packaged funding approach described at 2 and 3, supplemented
by more effective volunteering, delivers a high quality waterways network within
6. change planning guidance and the planning system, as appropriate, so that
planning authorities protect the lines of all disused waterways that have realistic
prospects of being brought back into use.
7. reappraise the approach given to incentivising the transfer of freight carriage
onto inland waterways so that the current grant system is replaced by a fresh
package of financial incentives that are sufficiently attractive to ensure that there
is a marked increase in the transportation of goods and materials by waterway.
8. supplement the current low key local promotion of inland waterways by national
9. encourage the waterway authorities to voluntarily agree to a marketing
proposition that presents the waterways with a common identity to become
imprinted on the nation‟s consciousness.
10. help facilitate the launch of an Inland Waterways Conservancy, as a third sector
organisation embracing as a minimum the waterways currently operated by the
publicly owned waterway authorities and flexible enough to incorporate other
waterways when appropriate, with a long term service contract and associated
Service Level Agreement.
IWA OVERVIEW OF THE INLAND WATERWAYS STRATEGY – WATERWAYS FOR
The Inland Waterways Association (IWA) is responding to the Defra consultation on
„Waterways for Everyone‟. In making this response it wishes to raise some
fundamental concerns at the outset.
IWA welcomed the opportunity to participate in the pre-consultation workshops
organised by Defra, and on being able to put forward its own views on the content of
the document, specifically in shaping the views on what role the waterways can fulfil
in meeting the public agenda.
We deem that the document produced for consultation is good in terms of detailing
the public agenda and in setting the background and context. However, we believe
that it is seriously compromised in not providing enough focus on what actions are
needed to be done to achieve the outcomes, nor is there enough rigour on
deliverability. The 9 actions for government are identified but not with a clear course
of action, and there is no such listing for other bodies and organisations. The whole
presentation of actions and delivery arrangements needs finessing (see below).
The tracking success needs to come much earlier in the process, will also need to
track failure, and this earlier monitoring will help to inform the metrics.
The Defra Impact Assessment provides more flesh on how the Government
envisages arrangements for post implementation review of the strategy (under
that heading) and this should be on the face of the strategy itself. It is helpful in so
far as it goes, in identifying IWAC and AINA as potential agencies for contributing to
monitoring. However, this is a government strategy and it needs to be monitored by
government. To allow monitoring to proceed effectively, each individual action needs
to stand out in each chapter (presentational – but could be in a box with a different
colour background). Furthermore, the actions should be brought together in a
schedule which clearly identifies:
The nature of the action.
Which body or organisation is primarily responsible for pursuing that action.
The expected timescales for milestones to be met.
That is the minimum requirement. Those with lead responsibilities should be
answerable to the Defra waterways stakeholders committee which meets twice a
year so that they can be held to account for success or failure. Without this degree
of rigour there is every risk that the strategy will not be delivered and so we do not
believe that the strategy should be issued without such arrangements being included
on the face of the document.
Waterway Authority Burdens
The identification of lead organisations for actions, as detailed above, would bring
out just how much is being required of waterway authorities. Our concern is that
without these being costed, and resources being provided, they will be unaffordable
by waterway authorities or resourced from other already hard pressed budgets
which can ill afford depletion.
The stand out criticism of Waterways for Tomorrow by IWAC in its 2007 report THE
INLAND WATERWAYS OF ENGLAND AND WALES: What has been achieved
since the publication of WfT and what need to be done was that the failure to
establish a secure source of funding has proved a significant weakness. So we
applaud the statement that:
“Maintaining investment in the quality and quantity of waterway infrastructure during
times of recession to support these opportunities for economic growth should be
considered by Government and its agencies at all levels.”
We could not agree more. But this will not happen without strong leadership and that
will have to come from central government. We are concerned that the references to
partnership in the strategy obscures the magnitude of the funding issue and how
much leverage will need to be applied to deliver packaged funding solutions.
Partnership may help access additional private sector finance. But it will not „magic
up‟ new money from the public sector. It will require central government to give very
powerful signals that waterways offer an excellent return on the investment of public
money allocated locally for additional funds to be made available for waterways.
Clearly more thought needs to be given to how the waterways are funded. There
could be greater consideration of how to effectively tap local government funding to
supplement other funding streams, including that from central government, in
recognition of the local benefit that waterways bring. There could also be
consideration of other sources of funding. For example some contribution to the
waterways could come from the privatised water companies, reflecting that as more
water is abstracted, the greater the potential adverse effects on the recognized
public benefits conveyed by the waterways.
Inland Waterways Conservancy
We believe that with over 5,000kms of navigable waterways in the ownership or
control of over 30 waterway authorities, strategic consideration should be given to
how these could be more efficiently managed so that there are greater synergies to
achieve cost efficiencies and a consistent high quality customer focus. A starting
point might be to consider a merger of the two largest government controlled
agencies, British Waterways and the Environment Agency. This could preserve best
practice by both organisations but capture a third sector ethos through a
transformation into some form of inland waterway conservancy (IWA vision for an
Inland Waterways Conservancy attached at Annex A).
The strategy is refreshingly honest about issues that need to be addressed to
facilitate volunteering. However these barriers have been apparent for some time
and there appears to be no great urgency from navigation authorities to remedy
them, even though this would access resources for them. This may need some
honest brokering from outside the waterways community eg Office of the Third
Sector, to drive change.
The draft strategy suggests that waterborne freight is declining. Elsewhere we
question that but it remains marginal. The government grant schemes simply aren‟t
working. The Government needs to give much more robust pricing signals if it wants
to achieve a significant increase. That may mean some form of financial incentive
via payments/tax breaks to reflect carbon saving. This requires examination to
achieve the most cost efficient option for government which nevertheless is effective
in achieving a complete transformation in how the benefits of waterborne freight are
perceived by transporters of goods and materials.
The Government Actions
The commitments proposed by central government in the document are summarised
below together with our commentary.
Government recognises the multi-functional role of waterways and the need to
maintain and improve the quality of the waterway resource and infrastructure if the
public benefits delivered are to be maintained and grown. Government departments
therefore encourage regional and local delivery bodies and stakeholders to take
account of this in a holistic way through considering the waterways‟ potential
contribution in regional strategies, Local Development Frameworks, Local Transport
Plans, green infrastructure initiatives etc.
IWA Comment: How will this be done? What processes will be put in place to
Government will continue to encourage planning authorities, where appropriate, to
work with the waterway authorities and gain a better understanding of the specific
issues faced by waterways.
IWA Comment: Government needs more practical levers to be more influential
with local authorities, there needs to be clear policy and guidance to ensure
that this happens. Relevant stakeholders need to be consulted by planners as
well as waterway authorities.
Government to 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.
IWA Comment: We fully support the view that navigation and recreation are
fundamental to the raison d'être of the waterways, and contribute substantially
to the means by which public benefit is realised. As such we agree that they
should not be compromised by other concerns.
Government to gain greater understanding of the drainage function of waterways
and its economic / social / environmental impact and to look at any implications for
IWA Comment: We support this in principle but wish to understand the
process and timescales.
Government to promote the role waterways can play in delivering improved health
and well-being to Primary Care Trusts and other physical activity partners.
IWA Comment: How will this be done? What measures of success will be
adopted? What are the timescales for implementation?
Government to support the transfer of freight from road to water, where it is practical
and economically and environmentally sustainable to do so, in line with the
recommendations of the Freight Study Group.
IWA Comment: What specific actions will be taken to deliver more effective
incentives for transporters of goods and materials to use the waterways for
freight compared to the current grant regime and what timescales will be
adopted for implementation?
Government will promote the contribution that waterways make to sustainable
transport to their agencies and local transport authorities, particularly in relation to
the use of towpaths as walking and cycling routes.
IWA Comment: What specific outcomes are desired? What specific actions
should result and what are the timescales for implementation?
Government to support waterway authorities in seeking changes to legislation where
there is a strong business case for doing so, but recognising that secondary
legislation is more likely to be achieved than primary.
IWA Comment: Government decides the legislative programme and pursues it
so it is entirely within the gift of Government to determine priority. What
schedule of specific actions relating to which waterways & authorities is it
prepared to take in this respect?
Government with the waterway authorities will pursue the application of an
ecosystems services approach to inland waterways, which will:
establish and quantify the wide range of goods and services delivered by inland
waterways, building upon the initial work carried out by Defra into the benefits of
carry out further research to close gaps in evidence;
inform the policy leads and beneficiaries of these benefits; and
look to identify new and innovative funding mechanisms to support the delivery of
the goods and services that waterways provide.
IWA Comment: What are the timescales for these actions?
Summary List of 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?
IWA Comment: We were pleased to have been allowed to have input via the
stakeholder sessions into shaping this aspect of the document and are in the
main satisfied that the document adequately states the main public benefits of
The UK waterway “heritage experience” industry is the envy of the world, as
evidenced by tourism and developing overseas replication. No account of the
potential for increasing export earnings has been made in relation to the sale
of intellectual property, as it relates to waterway expertise in - cultural heritage
management (CHM), restoration engineering, decontamination and tourism
development. Other countries also include CHM in Foreign Aid packages,
generating good will and jobs in the supply of specialist equipment, services
and maintenance exports.
We have a concern however, that the section on Freight doesn‟t correctly
identify the full value of the opportunities that freight present and that the
figures used suggest a fall in usage – which is not strictly true.
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?
IWA Comment: We welcome the degree of investment made in the waterways
by central government up to the early years of this century. But the waterways
have noticeably declined in quality and condition compared to say 5 years ago
through decreasing investment in recent years. There is a declining trend.
Examples of the decline in standards are:
reduced vegetation control on the towpath.
bank erosion and associated towpath collapse.
inadequate towpath maintenance.
failure to upgrade towpath surfaces so that suitable for multi-use.
a neglect of low level structural maintenance such as attention to lock
gates and paddle gear, so that they are becoming less fit for purpose
and consequently harder to use.
A significant issue is depth of navigable water. On many waterways it is now a
critical issue. Dredging is not keeping up with the rate of siltation, possibly
due to exceptional rainfall trends in recent years, especially on BW and EA
waters. The failure of navigation authorities to invest further in equipment, to
increase dredging capacity, means that current dredging capacity could not
cope even if it was used continuously. BW currently indicate a spend on
dredging of £8m p.a. However, this is a losing battle. It is a cost/funding issue,
because unless dredged materials can be deposited adjacent to the removal
site the removal and treatment cost is excessive. Some of these costs are
incurred in dealing with an industrial legacy accumulated over 200 years of the
waterways‟ life, some is removing non-local silt that came from flooded
watercourses entering the waterway.
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? Do you have any ideas as to how this can be achieved?
IWA Comment: We are disappointed at the huge variation between Regional
Development Agencies (RDAs) in this respect. The East Midlands
Development Agency are seen by ourselves as demonstrating the fullest
activity in this respect, by comparison some others seem to have no idea that
waterways even exist in their areas.
RDAs should work closely with relevant stakeholders as well as those
managing the waterways.
RDAs need firm guidance from government backed up by KPIs to ensure
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?
IWA Comment: We don‟t believe that it is the waterway authority‟s role to
ensure this; this appears to be a primary function of government. There is a
huge variation between local authorities in how they approach this issue but
inevitably it boils down to whether and to what extent they recognise the
public amenity provided by waterways and in particular their towpaths for
their community – health, leisure, social cohesion and integration. They need
to appreciate that without a contribution from them, waterway authorities may
not be able to adequately fund towpath maintenance and improvement, with a
loss of public amenity for the local community.
Q5. What do you think the barriers are to local authorities taking more interest in
waterways in respect of place making?
IWA Comment: Currently, although certain authorities are positive, there are
many that do not recognise the incentive to fund waterways and associated
infrastructure. Regeneration can transform the benefits of waterways for local
communities. Additionally, the planning system is weak in recognising and
safeguarding the waterways.
Waterside sites often have restricted access, leading to complex design
solutions and associated additional infrastructure costs. Many local
authorities have little experience of the benefits of a successful waterside
development and therefore may have little incentive to go the extra mile in
achieving design solutions and incurring additional cost unless these are
picked up by a developer.
Other places require less radical attention to contribute to place making –
some enhancement and, if appropriate, associated sympathetic development.
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?
IWA Comment: Yes - hydro power; „staycations‟- increasing leisure and
tourism; flood control, especially river navigations; climate control of
buildings using local water cooling; and low carbon transport.
There is also a major opportunity at some time in the future to consider a
national water grid, however, this would require significant improvement and
development of the network to widen and deepen capacity, to iron out
bottlenecks and resolve environmental considerations. This could be
considered as part of a development of inland shipping by creating a strategic
waterway system for freight and water transport between major cities. We
recognise that this would be at significant cost, but as water resources
become stretched in the south east in particular, it could potentially be
considered comparable to the vision exercised in creating the national
electricity grid in the 1930‟s which subsequently rendered the country a
significant strategic benefit.
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?
IWA Comment: Agree. There is scope for more use of heritage, especially
unused or underused sites or buildings and structures. However, such use
needs to be sympathetic in the modern context.
Alongside such use, there needs to be an educational programme for the
general public to fully appreciate this heritage.
Q8. Do you consider the protection of the natural and built heritage to be one of the
waterway authorities‟ primary tasks?
IWA Comment: We do not believe it is a primary role of the waterway authority
to ensure this, nor should we aim to preserve the system as a museum or in
„cultural aspic‟. However, we believe that they share a duty of care to manage
their estate sympathetically in partnership with the heritage agencies and local
It is essential that as much as possible is protected and used for future
generations to continue to enjoy. This can only be achieved through a
detailed understanding and knowledge of the subjects by waterways staff and
contractors so that they are able to identify important features and uses of
these features. Proper, appropriate conservation will not restrict future use
and development but enhance both functions for the benefit of all users.
There needs to be an up to date and comprehensive record of the historic
features existing on the waterways. Without a detailed record features, in
particular small but no less important ones, slowly disappear without any
monitoring or control. We recommend that such a record be created as soon
as possible. This is a project that could involve many volunteers throughout
the country, be supported by outside funding and educate many into the
history and development of the inland waterways.
Q9. What area of waterway heritage do you consider most under threat?
IWA Comment: Non-operational buildings and structures for which no re-use
can be found are most at risk to unsympathetic development or loss through
lack of use. We also note that maintaining 200 year old structures to heritage
standards costs considerably more than modern structures and techniques
and this needs to be recognised in the funding of the waterways.
It is often the small structures, features and details that are at risk both from a
lack of knowledge and maintenance. Too many small buildings are vulnerable
to being left in a deteriorating condition which eventually means they are lost
or the cost of restoring them is far greater than if they were kept in good order.
Too many historic features are spoilt by the multiplicity and siting of modern
signs either too close or adjacent to them, when with a little thought and no
cost they could be sited without damaging the setting of these structures.
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
IWA Comment: Yes. See the answer to question 4. In addition, there need to be
additional facilities at appropriate sites to support these uses e.g. toilets,
parking and refreshments (see also the answer to Q.11).
In developing multi-use towpaths due regard must be taken of the
requirements of waterway dependent industry and different user groups.
Q11. What needs to be done to make waterside paths more accessible and better
appreciated by local communities?
IWA Comment: Provide better bankside protection to reduce erosion and to
protect and improve the width of access for users. Also, improve signage,
facilities and vegetation management.
Additionally, where there are areas of intensive use, where undue wear may
occur, it may be beneficial to improve the towpath using an appropriate all-
weather surface, having due regard to the heritage and visual amenity of the
waterway corridor. It may also be advantageous for there to be additional
ramp access provided at key locations to facilitate improved cycle and
Opportunities to support other activities such as canoeing access and angling
could be better facilitated by shared facilities such as blocks with toilets and
showers. We are aware from user group forums that angling clubs are
impeded from teaching children to fish because of the absence of hand
washing facilities – this also applies for the launch and removal of canoes and
small boats where there is perceived to be a risk of infection associated with
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?
IWA Comment: See 11; additionally improve signage and security for persons
travelling alone. Improve communication of available routes to residents and
potential users to improve take-up.
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?
IWA Comment: Freight isn‟t declining. But remains marginal. However,
Government isn‟t encouraging further take up by incentivising use and in
particular encouraging switch over from road haulage for which there needs to
be a marked financial incentive in ongoing operational cost for businesses to
be prepared to incur the initial start up costs.
It is principally the larger waterways and tide-ways that are suitable, and a
priority list should be made and action focussed on improving these for
There needs to be more investment in wharfage, and in addition to the carbon
footprint benefits, consideration to reducing road congestion in population
centres should also be added to the mix in determining the case for public
benefits of waterborne freight.
Q14. How can we best encourage a common purpose between different users of the
waterways? What can be done to better manage potential conflicts?
IWA Comment: Clearer KPIs to guide policy making by waterway authorities,
coupled to better stakeholder representation on user groups and governance
boards. There is a need for an overarching national policy – suggesting again
a need for an Inland Waterways Conservancy.
Q15. What do you believe should be done to maintain and increase the number of
boat registrations on our inland waterways?
IWA Comment: More needs to be done to encourage usage to be evenly
spread across the system, and avoid congestion as at present. Access costs
need to be reduced. This suggests that the present licensing system doesn‟t
work effectively and needs a major overhaul – starting from first principles.
Lack of coordination and effort due to over 30 waterway bodies operating
different regimes and policies isn‟t helping the situation.
We would also encourage more community boats (see Q19) and cooperatives
to improve affordability. We would ask that consideration be given as to how
to encourage entry level boating and whether the licensing arrangements are
putting people off trying; we are aware that explorer licences are about to be
withdrawn by BW this may be a retrograde step in encouraging entry level
More could also be done to encourage shared ownership opportunities, where
friends can club together to defray major costs. In this category there is also
the opportunity to consider how to incentivise club owned boats and
incentives for firms to run boat clubs - as currently done by some firms such
as the BBC or NatWest Bank to give employees the chance to sample boating.
Q16. How can the waterways increase their share of the holiday market?
IWA Comment: In recent years the trend has been for more and more
expensive „Luxury boats‟ (e.g. 4 star rating) whilst this is a good thing in
providing an upmarket high value commodity which is profitable for hiring
companies it has been at the expense of facilitating wider access at the
cheaper end of the market. There needs to be a mechanism to encourage
cheaper hire boats that less affluent people can afford ( 2-3 star rating). Could
this be facilitated by reduced licence fees and tax breaks?
We note that tourism initiatives are often regionally based – not recognising
the fact that waterway network crosses their boundaries so needing a joined
up coordinated approach. Additionally, there appears to be no national
marketing plan for the waterways – given that they are in differing ownerships
and control, thus making the proposition unclear to the customer.
Q17. Do you agree that there is scope for increasing waterway related volunteering
activity? How can this be achieved?
IWA Comment: Clearly – up until now IWA and its restoration arm WRG has,
together with boat clubs and waterways restoration societies and trusts, led
this, but has had little opportunity to work on BW or EA waters for reasons of
health and safety. This contrasts with the exemplary record that WRG has
enjoyed in working with restoration societies and trusts.
Volunteering isn‟t however just about practical restoration, opportunities need
to be realised in management, hospitality and customer service areas as well
as for administration. BW, EA and local authority navigations in particular
need to model themselves more on third sector organisations and look at how
they encourage and use volunteers to accomplish many of the day to day
tasks utilising a few paid managers to organise and control quality and
standards. There also needs to be a national coordination of volunteering
effort - all in one place so that volunteers can easily find something to suit
their needs and time available and get the right training to gain and enhance
their skills, including health and safety considerations. An Inland Waterways
Conservancy could facilitate this role.
Q18. How can schools and colleges be encouraged to make greater use of the
waterways for educational purposes?
IWA Comment: Support the roll-out of the Wild over Waterways educational
initiative at Key Stage 1&2 across all schools in England and Wales; and to
develop and implement a more advanced educative programme about the
waterways to support the national curriculum for Key Stage 3 to 5 across
England and Wales. However, access costs and availability of facilities are an
issue in facilitating on the water experiences for schools and youth groups
Colleges could represent another educational avenue for volunteers if they
could provide a learning facility for volunteers to gain and enhance necessary
Q19. What can be done to help NCBA to increase the use of waterways to improve
IWA Comment: It‟s not just NCBA – there are hundreds of other organisations
striving to deliver these services around the country. Access costs are an
issue, with the provision, berthing and maintenance of boats suitable for use
being significant. As is the imposition of the MCA Boatmasters‟ licence for
public trip boats – which adds approximately £1,000 cost to each organisation
per person requiring completion of the training and validation necessary to
achieve registration under the scheme, as organisations may need several
volunteer helmsmen this recently imposed cost burden is not insignificant.
Q20. What can be done to overcome barriers to achieving greater diversity among
boaters and anglers using the waterways?
IWA Comment: Reduce access costs and stimulate an increase in hiring
provision in centres of population. Specific initiatives to target minorities and
other hard to reach communities – the public sector has developed great
expertise in the tools to employ to achieve results. See also the answer to
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?
IWA Comment: We believe that third sector or mutualisation is an attractive
option worthy of consideration, but not just for BW – all waterways need to be
considered , especially government funded inland waterways, and these need
to be considered in the wider context of an Inland Waterways Conservancy
where economies of scale and reduction in overheads, rationalisation and
sharing of best practice can be realised.
Q22. What scope is there for enhanced partnership working to improve the
resources available to protect and enhance the benefits delivered by inland
IWA Comment: Create an Inland Waterways Conservancy and rationalise the
Q23. What activity should be undertaken to monitor the benefits delivered by the
inland waterways over the coming years?
IWA Comment: Best practice to be considered by waterway authorities should
be to measure, to common standards - towpath usage; community access;
diversity; benefit to the rural economy; benefit to tourism; and benefit to
manufacturing and marine economy.
WATERWAYS FOR EVERYONE – IWA COMMENTARY ON THE CHAPTERS
Chapter 1: Introduction
Para 1.6 This includes that an issue for delivering the Government‟s
public policy agenda is a more stringent and competitive
funding environment. Reduced funding should not be the only
interpretation of that statement. The benefits to be gained can
mean that the return on investment justifies higher
expenditure on waterways compared to other programmes
which do not deliver comparable benefits.
Para 1.10 Government recognises the need to maintain and improve the
network if the public benefits are to be maintained and grown.
However infrastructure cannot be maintained and improved
without investment, and that includes the financing required
from central government for the publicly owned waterway
authorities. There needs to be a commitment that, after
enhanced local funding from the public, private or third
sectors, grant-in-aid will deliver the balance of the investment
Government Departments are required to encourage regional
and local delivery bodies and stakeholders to take account of
waterway multi-functionality in regional strategies, LDFs,
LTPs, green infrastructure initiatives etc. The IWA
consultation response overview makes the point that a flaw
compromising the draft strategy is the absence of practical,
rigorous and disciplined arrangements for monitoring to
ensure delivery of objectives. The specific practical actions
required to ensure that the plans etc. referred to above are
delivered need to be developed and the main protagonists
identified so that they are accountable and answerable for
success or failure.
Chapter 2: Our Inland Waterways Today
Paras 2.3,2.6 IWA has publicly launched its vision for an Inland Waterways
and 2.7 Conservancy (IWC) and that is discussed in the IWA
overview response. Certain disadvantages of the current
waterway management arrangements are identified in this
chapter. It is not efficient and does not ensure a consistent
focus on key waterway objectives for there to be over 30
waterway authorities with different priorities, characteristics
and legislation. Not least the different core objectives of BW
and the EA whilst also required to deliver complementary
An IWC could do a great deal to address these tensions.
However, an intermediate step which would help to register
the waterways with an identity in the nation‟s consciousness
would be to achieve some sort of common marketing
proposition for the nation‟s waterways. Waterway authorities
could voluntarily sign up to this with no implications for their
current separation as authorities but with the benefits that
would flow from a common identity.
Para 2.12 The statement that most smaller waterway authorities receive
no support from public funds should be extended to discuss
the implications of that lack of funding. For example, how can
they be expected to fulfil national (such as drainage or flood
defence) or Water Framework Directive (WFD) obligations
when they are unable to fund them.
Para 2.14 BW and EA have indeed identified significant funding gaps in
current and future operations. But they are far from having
strategies in place to address the problem. BW has no such
strategy. EA did have a strategy to close the funding gap
within the next few years but whether that can survive EA
spending constraints is doubtful. Furthermore, both
organisations have significant maintenance backlogs.
Chapter 3: Place Making and Shaping
Para 3.7 There are suggestions that waterway restoration and new
waterways meet local priorities and provide benefits for local
communities; and that costs should be met by local
beneficiaries. These are based on an artificial limitation on the
benefits. They are not gained just locally. The wider
community benefits as waterways users make use of other
parts of the waterways network to access these new and
improved waterways. So costs should not be expected to be
met just by beneficiaries in the immediate locality.
These wider benefits are part of the answer to question 15. If
boat registrations are to be maintained and increased boaters
need to be able to access an extended and improved
Para 3.8 PPG.13 is unduly restrictive in encouraging the protection of
the line of disused waterways only when there is a
reasonable degree of certainty of a restoration project
proceeding in whole or in part within the development plan
period. Such lines should also be protected when there is
clear potential for restoration outwith the development plan
period. Derelict waterways are linear entities which often
cross planning authority boundaries. It‟s no good for one
planning authority to protect a part of a proposed restoration,
perhaps because work has started or is about to start, if
another then fails to protect the route because no work is
planned in its area for the foreseeable future. Restoration
schemes may take several decades to achieve their aims and
routes crossing authorities planning boundaries are
vulnerable to disparate attitudes. This is not a theoretical
problem - often the most difficult bit is left till last and this
difficult bit can be that most vulnerable to further
Paras 3.11 The IWA vision of an IWC is a suitable alternative model for
and 3.12 BW and would address the current limitations on EA
Paras 3.13 – The recognised need for planning at all levels to take full
3.20 account of the contribution that waterways can make to
communities is welcome.
A great deal is being required of waterway authorities. It
should be recognised that currently they may not have either
the financial resources or personnel with the appropriate skills
set to undertake the roles described. If funding is required it
will need to be made available to fulfil this agenda.
There is a great deal of guidance already emanating from
central government on waterways. However, it is disparate
amongst a range of guidance documents and within context
has a very low profile. If that profile is to be enhanced central
government should consider bringing the sense of that
disparate guidance together into a single piece of summary
guidance, developing it as necessary to reflect the thrust of
renewed central government waterways policy, whilst
providing linkage back to the existing disparate guidance as
Chapter 4: Climate Change
Para 4 – A range of responsibilities for waterway authorities which
whole need to be costed and funded.
Para 4.11 The waterways network needs to be considered for use as a
water grid. Whilst the economic case may not be justified for
some years it may be possible that as climate change affects
Britain more deeply the economic case for the waterways
acting as a water grid will become more of a practical
Chapter 5: The Natural Environment
Para 5 – A range of responsibilities for waterway authorities which
whole need to be costed and funded.
Paras 5.5 and As referenced at the comments on paragraph 2.12,
5.10 paragraph 5.5 recognises the concern about the cost of WFD
obligations and actually states the fear that some navigations
may have to close. The document records the Government‟s
view that there is no reason why implementation of
environmental legislation should threaten navigation. How
has that conclusion been reached? What is the Government‟s
proposal should this conclusion be inaccurate and some
navigations do in the future face closure due to an inability to
fund environmental obligations?
Chapter 7: Health, Well-being, Recreation and Sport
Para 7 – A range of responsibilities for waterway authorities which
whole need to be costed and funded.
Para 7.18 The suggestion that no public authority is required or funded
to maintain many riverside paths and towpaths should be
reviewed by lawyers. Even when there is no public right of
way, a duty of care could well apply, even in those cases
where paths are physically intended to be closed to the
public. It could be dangerous to suggest that there is no duty
of care should such authorities then find themselves exposed
to actions under health and safety and related legislation.
Chapter 8: Sustainable Transport
Paras 8.2, 8.3, This chapter records that the trend for the carriage of freight
8.7 and 8.8 by water is downward; that freight transport by water can be
cleaner than by road (more fuel efficient); that the cost
differential is not sufficient to encourage modal shift; that
there are grant schemes to encourage shift.
Elsewhere we question whether waterborne freight is
declining as suggested by the draft strategy. Nevertheless,
the grant schemes have been available for years and are
clearly not working. The pricing signal, via grant, is not
promoting modal shift so it must be made more robust so
that it does reverse the trend. If this requires fiscal
measures or such like e.g. based on carbon credits to
reflect carbon saving, then government must address a
completely new method of incentivising modal shift.
Para 8.20 See the comment on paragraph 7.18 concerning path
Chapter 9: Tourism and Business Development
Para 9.9 An important aspect of a review of the marketing and
promotion of waterways is to consider how to make better use
of the network so that underused parts of the network are
better utilised, with all the benefits that will flow to local
communities, rather than focussing on the already overloaded
Chapter 10: Fairer, Stronger and More Active Communities
Para 10 – A range of responsibilities for waterway authorities which
whole need to be costed and funded.
Para 10.2 The waterways are equally compatible with the PSHE
(personal, social and health education) curriculum.
Para 10.13 Barriers to volunteering are identified. These are particularly
evident for BW and EA. There needs to be greater urgency in
tacking these barriers. The danger is that volunteers and
volunteer organisations will become disenchanted with a
perceived lack of progress, losing interest and find other
volunteering opportunities so risking a permanent loss in
volunteering for the waterways.
Para 10.14 The waterways branding referred to for paras 2.3,2.6 and 2.7
above would help to improve public awareness.
Chapter 11: The Way Forward
Paras 11.1, These paragraphs recognise that maintaining investment
11.2, 11.9, in the quality and quantity of waterway infrastructure
11.14 and during times of recession to support opportunities for
11.16 economic growth should be considered by Government
and its agencies at all levels. But in the same breath they
talk about tighter funding for BW and EA, increased costs
from environmental legislation and; recommending
partnership working whilst recognising that partnership
between organisations with different strategies and different
funding pressures can be very difficult. Leadership is
required. See IWA response overview.
Para 11.17 The IWC would deliver. See IWA response overview.
Para 11.21 The monitoring proposals need to be developed so that they
are effective. See IWA response overview.
An Inland Waterways Conservancy - The IWA Vision
1. Over 50 years ago the Inland Waterways Association‟s (IWA) co-founder and great visionary
Robert Aickman proposed that a National Waterways Conservancy be created as an all purpose
authority concerned with all the functions and potentialities of every navigable waterway in the
country. Since that time IWA has always maintained the vision of a single body managing the
inland waterways although it remained a long term aspiration. However change for the waterways
is back on the national agenda with DEFRA producing a new consultation document Waterways
for Everyone, BW proposing a move to the third sector with their 2020 vision and political parties
beginning to lay out their stall in the run up to the general election. IWA believes it is time to
revisit the idea of an Inland Waterways Conservancy and this paper sets out the arguments in the
2. The Inland Waterways Association was founded in 1946 and acted as a champion of the
waterways setting out to transform public and official attitude to the nations system of navigable
rivers and canals. At that time freight, the original purpose of the waterways, was in sharp decline
and early IWA effort was devoted to preventing further closures because it never lost sight of the
potential of the waterways for a new role as a unique national asset available for public
appreciation and enjoyment in a variety of leisure pursuits, as well as a continuing role for freight.
Further closures were prevented by the end of the 1960s and IWA effort shifted to campaigning
for, and taking the lead on, restoration of derelict waterways with hundreds of miles of derelict
waterways reopening, the peak of this activity occurring around the millennium.
3. Since those early years the waterways have, as IWA predicted, undergone something of a
renaissance and are now appreciated by the public as a multi user recreational facility for
boaters, anglers, walkers and cyclists with around 11 million members of the public regularly
using them. There has also been a steady shift in government opinion moving well away from a
desire to close the system in the early IWA years to recognition that the waterways have a role to
play in the modern social agenda with Waterways for Everyone identifying the following key
initiatives where waterways are making, and can continue to make a contribution:
Climate change mitigation and adaptation.
Healthy lifestyles and improved wellbeing.
Neighbourhood renewal, including the role of green infrastructure, community cohesion and
4. However, management arrangements for the waterways have not fully responded to the new
challenges and opportunities. Following nationalisation of many of the waterways in 1948 there
were a number of changes resulting in the formation and regularisation of British Waterways in
the 1960s but little change since. The formation of the National Rivers Authority (NRA) in the
1980s, transitioning into the Environment Agency (EA) in the 1990s should have represented a
step forward but the profile of navigation within the multi purpose EA has remained low and the
three disparate waterway groups under EA control (Thames, Medway and East Anglian waters)
have stayed largely locally managed with little harmonisation or achievement of economies of
scale. The Thames is worthy of note as the formation of NRA and then EA did away with the old
Thames Conservancy, which on a small scale could have been the model for a national body with
its early realisation of the wider role for waterways (leisure boating taking off in Victorian times),
its strong stakeholder engagement and close links to the local communities it served with its rate
precept funding model.
5. Today there are more than 30 waterway authorities, mostly public bodies, reflecting the complex
evolution of the waterway system and frankly is a historical anachronism which starting afresh no-
one would create. Some are operating under antiquated legislation which is in need of updating
or replacement, for example the Middle Level Commissioners have no authority to seek payment
from leisure boaters using their waterways. This disparate management system is ill placed to
respond to national challenges and initiatives and it is time to look for something better. IWA
believes that their original concept of a National Waterway Conservancy is as relevant today, if
not more so, as when it was first suggested over 50 years ago.
The IWA Vision
6. The vision for a Conservancy is that of a single authority controlling as much of the inland
waterway system as possible (scope is more fully addressed later). This body would not only
produce an economy of scale but would also be a powerful influence able to represent the
interests of the waterways and its stakeholders at a strategic level. Waterways for Everyone set
out a vision for how waterways can contribute to a wide range of public policy objectives
identifying eight themes:
Place making and shaping.
The natural environment.
Health, well being, recreation and sport.
Tourism and business development.
Fairer, stronger and more active communities.
Responding to these objectives will require new strategic arrangements and could not be fully
met with the current disparate and fragmented waterway management bodies.
7. The Conservancy should be at arms length from government in order to avoid the policy and
funding silo mentality amongst government departments with a key interest in waterways that
inevitably results when the waterways are controlled and funded by a single government
department. The eight policy themes identified in Waterways for Everyone are the natural
responsibility of a number of government departments and whilst government has recognised the
issue and set up the Inter Departmental Group, it is doubted that a single committee is sufficient
and more radical changes are needed.
8. In their 2020 vision, fleshed out more in Setting a New Course, BW has proposed that it
transitions itself into a not for profit organisation positioned within the third sector (possibly a
charitable trust). IWA believes that many of the arguments for this are sound but doubts that all
the claimed benefits can be fully realised by considering BW in isolation. A Conservancy
embracing a much greater proportion of inland waterways will be much more effective in realising
9. Expanding the user base of the waterways across the full spectrum of possibilities will be a key
role for the Conservancy. With success will come tensions between users and these will need to
be managed with a set of overarching national policies together with local initiatives, whilst also
retaining the desirable characteristics of individual waterways. IWA recognises and applauds the
efforts of the Association of Inland Navigation Authorities (AINA) in its attempts to create a single
voice on waterway management issues. However the nature and structure of this body is such
that it is not best placed to be fully effective in representing the interests of waterways nationwide
consistent with the ambitions that could be delivered by a Conservancy.
10. Development of the waterways is an opportunity that is widely recognised. There have been
notable successes over the years achieved within the current management arrangements such
as the transformation of the centre of Birmingham. However such developments require a
strategic approach dealing with Regional Development Agencies and other bodies. The
Conservancy would be well placed to take on this role taking due note of the need to conserve
both built heritage and also the natural environment.
11. One aspect of development is increasing the size of the navigable system by restoration of
derelict waterways and in some cases the creation of new ones. This has been a success story
over the years with IWA and the societies it represents playing a crucial role. There are many
derelict canals under active restoration but few will be completed with voluntary effort alone.
Strategic leadership is required to both justify and convince others of the projects‟ merits as well
as effecting the completion. BW used to do some of this but due to financial pressures has largely
withdrawn not only funding but leadership from a number of projects. IWA also notes that BW
expertise in the field of restoration has atrophied over the years. This has the further effect that a
number of projects when completed are likely to become separate navigation authorities
introducing more unwelcome fragmentation of the management of the system. The Conservancy
would take the lead in promoting restoration, making the business case, forming the partnerships,
fundraising, completing the restoration and eventually absorbing the new navigation within the
managing scope of the Conservancy.
12. The original Robert Aickman paper identified the need for a Conservancy to have an energetic
research department. IWA welcomed the transformation of the Inland Waterways Advisory
Council (IWAC) in 2007 and is impressed with the relevance, quality and content of the research
it has conducted. However IWAC is only an advisor to government which can accept what it likes
and quietly ignore what it doesn‟t. IWAC must continue to fulfil its valuable role. Options are that it
could sit either within, or responding to, the Conservancy where it will have an audience ready to
make the most effective use of its product.
13. It is evident from a variety of government publications that much greater consideration is being
given to the use of volunteers in society. This is also mentioned in both Waterways for Everyone
and also Setting a New Course. There is of course nothing new in the use of volunteers in
waterway activities and this has been promoted by IWA since its inception. However there have
been, and continue to be, tensions between voluntary organisations and navigation authorities,
principally BW and EA where the full contribution that volunteers can make is simply not being
captured. It is questionable whether these organisations, or modest reinventions of them, can
successfully jettison their background and culture to go through the necessary transformation to
fully embrace the opportunities that volunteers can bring. IWA believes that a Conservancy would
be better placed to achieve this from the start.
14. This paper does not set out to specify the detailed management arrangements for a
Conservancy. However IWA believes it to be essential that the board structure has appropriate
skills and suitably diverse stakeholder representation able to focus on the core mission without
undue distraction by other commercial interests unrelated to that mission. There would also need
to be strong governance arrangements to ensure appropriate use of public/charitable funds.
Arrangements will also need to be in place to reassure government that the funds it continues to
provide are being appropriately allocated to meet the public policy agenda (see para 23).
15. Similarly this paper does not set out the possible mechanics of a transition to a Conservancy.
However one point worth stressing is that these proposals are not just about expanding the scope
of an existing body such as transferring EA waters to BW or vice versa. Rather it is about the
creation of something completely new. As such it will probably be necessary to create a new
board and centralised corporate headquarters at the start in order to effect the new values and
16. Ideally IWA would like to see all navigable waterways within the scope of the Conservancy.
However the practical reality of the current disparate management arrangements means that not
all of this could or should be achieved and there may have to be a phased approach to
incorporation of the waterways of England and Wales into the Conservancy. Scotland is outside
the scope of this paper.
17. The publicly owned waterways on the connected system should form the initial tranche of the
Conservancy. These would be principally those waters managed by BW and EA.
18. Those waterways on the connected system currently run by charitable trusts, (Wey and Avon
navigations), would sit very well in the Conservancy and it is hoped that once the new
arrangements have settled down they would wish to transition their waterways into the
Conservancy. If the Wey is absorbed then the adjacent Basingstoke Canal, owned by two county
councils (and struggling under their stewardship), would be a good candidate to include.
19. There are a number of waterways in private ownership and some of these, like the Manchester
Ship Canal, are principally used for freight. Others include port areas and major tidal waters also
used for freight. It would be unrealistic and inappropriate to suggest that these be nationalised
then handed over to the Conservancy so these are best left alone. An exception could be the
Bridgewater Canal which is a key link in the connected leisure system and no longer has a freight
function; if a suitable deal could be struck with the owners to transfer this waterway to the
conservancy then this should be pursued.
20. There are a number of isolated waterways disconnected from the main system ranging in
character from fully engineered canals, river navigations through to unimproved tidal rivers for
which there are no navigation authorities. Many of these should be included in the Conservancy
but the future of these will need to be decided on a case by case basis.
21. Finally the Broads are worthy of note as a public body adopting a responsible attitude to
balancing conservation, acting somewhat like a National Park, and navigation. In many ways they
are already functioning as a Conservancy and could sit well within the larger body now
envisaged. However the Broads are a river-lake system isolated from the rest of the system and
with few navigation structures so are very different in character compared with the rest of the
system. As such the arguments for incorporation immediately within the Conservancy are weaker
but could be worthy of consideration at a later date.
22. Although this paper has focussed on broad vision some mention of funding must be made as that
will be a key to success of the Conservancy. First and foremost the Conservancy, once it has
settled down, will bring an economy of scale with a single headquarters, shared maintenance
equipment, increased purchasing power for outsourcing of services and a flexible workforce. The
use of volunteers, if suitably utilised can further reduce running costs. BW in its 2020 vision has
already identified that a move to the third sector will open up new funding possibilities - even
more so for a Conservancy with a larger role and scope.
23. It must be stressed that significant funding will still be required from government in recognition of
the broader role waterways play for the country. Much of the system could not survive without
this government finance to keep it functioning. Furthermore there needs to be better guarantees
of continuity of funding with perhaps a ten year plan to avoid the short term variations in funding
currently brought about by departmental fiscal cycles. However once the economies of scale and
other funding possibilities are realised it is likely that government funding could be on a declining
scale albeit never reducing to zero. Finally it will be worth revisiting the way in which government
funding is provided perhaps moving to a mix of central grant in aid together with some local
authority funding to reflect the considerable local public benefits and priorities.
24. The time is opportune to consider alternatives to the current disparate management
arrangements for the inland waterways of England and Wales. The IWA vision is of an Inland
Waterways Conservancy providing a single navigation authority for the majority of the inland
waterways together with a modern management system that would:
a. Focus on the core mission of safeguarding, conserving and developing the inland waterway
system, including its income streams, for public benefit including in particular navigation;
b. Provide a co-ordinated system with a single navigation licence, adopting best practice whilst
also realising the economies of scale;
c. Act as a focus for restoration;
d. Respond at a strategic level to relevant high level public policy initiatives such as adapting to
climate change, neighbourhood renewal, sustainable transport and healthy lifestyles;
e. Effectively harness the utilisation of voluntary effort;
f. Still rely on substantial government funding but potentially reduce the extent of the
dependence upon it;
g. Be a not for profit organisation able to seek additional funding from the third sector;
h. Keep at arms length from government potentially reducing funding vulnerability to the
departmental fiscal cycle;
i. Be responsive to customers needs and include stakeholder representation within the
management structure; and
j. Adopt strong governance and be suitably diligent in the use of public and charitable funds.