Comment

Representation ID: 23107

Received: 11/10/2021

Respondent: Canal & River Trust

Structural Integrity
Many of the Trust's assets and infrastructure are over 200 years old and were built using
techniques and materials contemporaneous with the time. Canals can be fragile assets and it is important to ensure that they are protected where new development takes place on, over, under, alongside or in close proximity to them. Not doing so causes a risk of harm to the canals themselves and, by extension, users
and local communities.


Waterway infrastructure (including waterway walls, cuttings, slopes and embankments) that supports the banks of our navigable waterways and our towpaths was not designed with the consideration of modern- day loadings. Additional loadings may be temporary or permanent and may include items such as buildings, embankments, scaffolding, construction plant & equipment, roadways and new foundations. Any lateral or vertical surcharge on waterway walls poses a risk to our navigations and surrounding land uses.

Canals are not water-tight and retain their water through a combination of waterway wall construction, clay lining and earth pressure. Excavation of the ground in the vicinity of our navigations can lead to the creation of leakage pathways not previously present, and in extreme cases lead to flooding. Leakage from our canals poses a risk to our navigations both in terms of water resources and potential collapse of supporting structures. Excavation in the vicinity of our navigations also poses a significant potential risk to our navigations through undermining and collapse.

Any ground vibrations may lead to accelerated degradation and potential collapse of waterway walls and embankments. Vibrations may be caused by a range of activities including piling, ground compaction and plant/vehicle movement.

Paragraph 174 of the NPPF requires that planning policies prevent new and existing development from being put at unacceptable risk from land instability. Paragraph 160 of the NPPF requires that strategic policies should manage flood risk from all sources. A failure of canal assets can result in land instability and/or flood risk. Whilst we welcome para 2(a) in the draft policy (all development proposals likely to affect the canal network must safeguard the continued operation of a navigable and functional waterway), we would like to see this wording amended as follows:

All development proposals likely to affect the canal network must demonstrate that they will not adversely affect the structural integrity of canal infrastructure to avoid increased flood risk, land instability and/or harm to the usability of the canal (including its towpath) as a green-blue infrastructure asset.

We suggest that this alternative wording better recognises the importance of protecting canals not just for their own sake but in the interests of surrounding communities and properties. It also relates the need to protect the canal to established planning issues in the NPPF.

We suggest that the following sentence is added to the supporting text:

Canal infrastructure includes (but is not limited to) waterway walls, embankments, cuttings, locks, culverts, weirs, aqueducts, tunnels and bridges