Comment

Representation ID: 23109

Received: 11/10/2021

Respondent: Canal & River Trust

Moorings


Part 3 (a) of policy ENV7 opportunities for leisure, recreation and tourism activities. The provision of appropriate enhanced visitor
moorings supports this and we would welcome policy support for securing these on appropriately located development sites.

We welcome the fact that the draft plan includes policy (parts 6 and 7) on residential canal moorings. The provision of residential moorings can contribute to bringing activity to the canal network, enhancing its character and providing passive surveillance.

We suggest, however, that the policy position is overly restrictive in a number of aspects and does not reflect the reality of how residential moorings operate on the canal network. These are:

•The provision of the ‘necessary boating facilities’. We suggest that this is amended to state ‘the provision of appropriate boating facilities’ and the minimum requirement (of electrical power, a water supply and sanitary disposal) is removed. Depending on the location of a mooring relative to an existing pump out and/or elsan point it may not be necessary for a residential mooring to include sanitary disposal on site as it is often accepted that a short cruise to an appropriate facility on the canal network on a periodic basis is suitable and in some cases beneficial. The same can also be true of water points. The amended text that we have suggested would allow greater flexibility to consider which facilities are required on a site-by-site basis.
• The requirement for dedicated car parking provided within 500m of the moorings. We question why this is required, especially in locations where mooring sites are well connected to public transport and cycling and walking networks. At present, this section of the policy does not appear to be based on consideration of the issues identified in para 107 of the NPPF. We suggest that ENV7(6)(b) is removed and that parking and access requirements for moorings are assessed against other policies in the development plan.

We support the need for an adequate level of amenity for residential moorings (ENV7)(6)(d) and for residential moorings to not have an unacceptable impact on the amenities or activities of nearby uses (ENV7)(7) where planning applications for residential moorings are being considered. However, policy ENV7 should also safeguard the amenity of existing residential moorings where planning consent for development (including change of use) is sought on sites adjacent or in
close proximity to existing moorings. At present, this is lacking in policy ENV7. Such a change would be consistent with the ‘agent of change’ principle in para 187 of the NPPF