Contact: Alan Inder, ext 6759

1. Summary

1.1 Public consultation on the draft outline River Hamble Moorings Plan was carried out between mid-September and early November 2002. Over 300 written responses were received, many of them containing lengthy comments demonstrating a great deal of interest in the subject. The majority of respondents commented on detailed aspects of what is, at this stage, a set of principles. Although many people were opposed to change and felt that the benefits were overstated, it is reassuring that nearly one quarter of the responses expressed support for the principles of the Plan.

1.2 As the consultation process has only just been completed it will not be possible to draw any firm conclusions. Each of the issues raised needs to be carefully assessed and a response prepared. In these circumstances it is impossible to respond fully and quickly. The first priority is to produce a fair and balanced summary of the consultation responses and make that summary available on the Harbour Authority's website. The next priority is for those responsible for managing the river to discuss issues of principle with representatives of those organisations who have responded to the consultation, supported by specialists who advise on technical issues such as safety and hydrology. This will enable the authorities to prepare a considered response which will be reported to the next cycle of the River Hamble Harbour Advisory and Management Committees.

2. Introduction

2.1 In June 2002 the River Hamble Harbour Advisory and Management Committees considered the draft outline River Hamble Moorings Plan and in September a period of formal public consultation commenced. A manned exhibition outlining the Plan was displayed at the Southampton Boat Show and subsequently at venues in Hamble, Swanwick and Warsash.

2.2 A leaflet entitled `Towards a River Hamble Moorings Plan - We Welcome Your Views' was produced to explain the need for the Plan, its aim and objectives, and the basic concept. A total of 7,000 copies were handed out to visitors to the exhibition, posted to individual mooring holders and distributed to local residents (via free newspapers), marinas, clubs and boatyards on the river. People were invited to make their views known by writing to the Harbour Master by 4 November.

2.3 More than 300 individual letters, e-mails or consultation forms have been received. Due to the high number of responses and the detailed nature of the comments, it has not been possible to reply fully to individuals. However, an acknowledgement has been sent to all respondents, assuring them that their comments will be taken fully into account when decisions are made about progressing the Plan, and informing them that a summary of consultation responses will be put on the Harbour Authority's website. This Summary Report is attached as an appendix. A full set of the original e-mails and letters is held in the Environment Department, and another in the Harbour Office. Due to the Data Protection Act it has not been possible to publish the list of names of those who have responded, However a list can be inspected to ensure that all those who did respond have had their response recorded.

3. Overview of Responses

3.1 Of the 301 comments submitted, 94 were from local residents and 140 from boat owners, of which 105 were public mooring holders. A total of 63 comments were unattributed (ie no name or address given).

3.2 A total of 68 submissions contained statements of support. A total of 121 submissions contained issues and concerns, 60 of which included no indication of support for the principles set out in the consultation.

4. Comments on Specific Topics

4.1 Comments were made on a wide range of topics or issues, many of which were contrary to the perceived problems that the Plan was aiming to tackle or to the stated objectives. The main topics were:

(i) safety;

(ii) mooring charges;

(iii) range of moorings;

(iv) access, traffic and parking;

(v) visual appearance; and

(vi) nature conservation.

There were also many comments made about the consultation process, including publicity. A relatively small number of comments were made about the particular zones indicated on the outline Plan.

4.2 The remainder of this section summarises comments made in relation to each of the main topics or issues. However, it is necessary to read the Summary Report, to gain a better understanding of the full range of comments made.

Safety

4.3 Safety considerations form one of the main drivers for the Plan. The harbour authority has identified, through a risk assessment undertaken by independent consultants, a number of safety issues - including crowded and congested channels, and the relatively high use of tenders - which the plan proposes to address by such measures as widening the main channel, relocating mid-stream moorings to walk-ashore pontoons, and creating open areas for dinghy sailing.

4.4 These principles proved to be highly contentious, and generated a large number of comments, the majority of which were negative. Despite the risk assessment, many respondents are far from convinced that there are any significant safety issues relating to the use of the river. Furthermore, they contend that the Plan's proposals would increase safety risks because:

(i) widening the channel would allow large and powerful boats to travel faster;

(ii) the perceived removal of secondary channels would force small boats to use the main channel;

(iii) extending marinas towards the centre of the river would bring manoeuvring boats into conflict with those using the main channel; and

(iv) the proposed open areas for dinghy sailing would be accessible to larger, faster boats.

4.5 Clearly, therefore, the consultation exercise has highlighted the polarisation of views on safety issues between those responsible for managing the river (as advised by independent consultants) and those who use it.

Mooring Charges

4.6 A large number of representations expressed the view that the Plan would be expensive to implement and that the costs would inevitably be passed on to public mooring holders. As the draft Plan is conceptual, no information was available on this issue. However, the Harbour Master's calculations indicate that the capital costs of providing pontoon systems would be extremely cost-effective compared to the costs of replacing existing piled moorings.

4.7 A closely related issue is the degree to which mooring holders would have to pay increased charges to reflect the improved accessibility and convenience of the new moorings, and access to facilities such as car parking, toilets/showers and waste disposal/recycling, etc. The Harbour Authority is aware that a significant number of mooring holders currently pay for car parking. In principle, a relocated mooring holder need only pay a basic charge for the pontoon berth but would have to pay extra charges for use of associated facilities, so the degree of increase would depend on the choice made by the mooring holder.

4.8 Nevertheless, there is the very strong perception that mooring charges will rise substantially for all, and that as a consequence many current mooring holders will be forced to give up boating. There are accusations of `social engineering', ie that the County Council and Crown Estate are planning to force lower income people off the river so that the Hamble will become exclusively the preserve of the wealthy, despite the Crown Estate's stated assurance of maintaining a supply of affordable moorings.

Range of Moorings

4.9 The plan aims to offer a choice of mooring types and locations. However, despite assurances to the contrary, many respondents felt that the Plan would significantly reduce choice by removing from the river most, if not all, the pile and swinging moorings, and by forcing mooring holders to move to walk-ashore pontoons, many of which would be next to marinas or boatyards. A significant number expressed the strong desire to remain on mid-stream moorings and to avoid `marina style' moorings at all cost. There are concerns not only about increased charges but also increased potential for vandalism and theft which the objectors associate with walk-ashore pontoons compared with mid-stream moorings.

Access, Traffic and Parking

4.10 It is evident from the consultation that road access, and in particular car parking, are major issues. Furthermore, there is a strong feeling that although mooring numbers would not be increased, the relocation of about one-third of the current moorings would inevitably have significant implications for access and car parking. Many respondents felt that existing public car parks and those within marinas and boatyards are already at capacity, and that the scope to improve parking provision without breaching environmental constraints is very limited.

4.11 The draft Plan contained no proposals for road access and parking, primarily because it is conceptual at this stage; such issues would be addressed when a proper environmental assessment is undertaken. The County Council is currently doing traffic and parking assessments in the area.

4.12 The Plan offers the possibility of a river bus service linking access points with mooring areas, marinas and boatyards, as well as providing an effective link between riverside communities for residents and tourists (linking points along the `Strawberry Trail'). Whilst many people think this is a good idea that is worth exploring, there is a great deal of scepticism as to whether a frequent, reliable and inexpensive service could be provided without heavy subsidisation.

Visual Appearance

4.13 By relocating a substantial number of mid-stream moorings, the Plan proposes to create some open sections of river which would become free of moored boats, thus restoring the natural beauty of the river in those areas. Again this proved to be contentious.

4.14 Firstly, few respondents regarded the almost continual lines of moorings along the lower half of the river as having a detrimental effect on its visual appearance; indeed, several remarked that pile and swinging moorings make a positive contribution to the river's character. There is a strong feeling that the regimented pontoons of berths in marinas adversely affect the visual appearance of the river, and that the Plan would worsen the situation by relocating pile and swinging moorings to clusters of pontoons, some of which would extend the visual impact of marinas along the river.

Nature Conservation

4.15 The Plan aims to benefit nature conservation by reducing the impact of piled and swinging moorings on the river bed, opening up flight paths for birds and reducing disturbance to wildlife and fisheries.

4.16 This generated numerous comments, the vast majority of which were negative. Firstly, few people accept that swinging moorings (which are comparatively few in number) could have a detrimental effect on nature conservation or that continuous lines of pile moorings could adversely affect the flight paths of birds. Secondly, it is considered that the Plan would be detrimental to nature conservation by removing lines of pile moorings that protect the inter-tidal areas from wash. Thirdly, the perception that locating pontoon clusters adjacent to inter-tidal areas, especially by Hacketts Marsh, would cause disturbance to birds.

Dredging

4.17 The Plan aims to minimise the requirement for dredging in marinas. The public moorings would be relocated to appropriate areas with a minimum depth of water of one metre below chart datum.

4.18 However, those who commented on this matter assumed that the Plan's proposals would lead to more dredging rather than less, because the existing lines of piled moorings are not dredged. This was supported by the observation that many marinas require regular maintenance dredging to maintain effective depth of water closer inshore in those areas initially created by capital dredging.

Consultation Process

4.19 There were also numerous adverse comments about the consultation process. The wide distribution of the leaflet and the exhibition of the outline Plan at the Boat Show and venues near the river have been outlined in the Introduction. Nevertheless, there have been various criticisms, the most significant of which concern the costs of visiting the Boat Show, the late distribution of the leaflet and the absence of public meetings. Unfortunately, the impression gained was of an unwillingness to consult, which was far from the intention. Little can be done to rectify the situation now, though an explanation of the consultation arrangements is included in the Summary Report.

5. The Views of Statutory Authorities

5.1 During this consultation exercise, the statutory authorities were consulted to obtain their initial reaction to the concept and, in particular, to find out what they regarded as significant issues and what information they would require if formal consents were to be sought. Officers of the authorities have generally indicated their support for improving the moorings layout and for the objectives and principles of the consultative document, However, within their responses a number of detailed matters have been raised which will be addressed in the various assessments that will be required. These matters are summarised below.

5.2 Fareham and Eastleigh Borough Councils have noted the possible impacts the Plan's proposals might have on landscape and nature conservation, and the implications for access and car parking. They considered that much more information was needed in order to properly address these issues, and that a full appraisal of the Plan's costs and benefits (including an assessment of the effects on all sectors and interests) was required. They felt that there ought to be a further stage of public consultation on the more detailed proposals as the project progresses.

5.3 Fareham Borough Council also considers that the Plan's proposals may represent a departure from its current Local Plan, and that the draft Moorings Plan ought to be considered for inclusion at the next review.

5.4 The Environment Agency would need to consider the effects of the Plan's proposals on hydrology and sediment dynamics (including possible disturbance to contaminated sediments, and possible requirements for dredging), on all fish species including shellfish (especially during construction phases), and on the areas designated of national and international importance for nature conservation. The need for long-term monitoring would be vital.

5.5 English Nature would need to consider the impacts on important nature conservation sites and their dependent wildlife (especially birds), in particular the effects of piling, dredging, disposal of dredgings, removal of moorings, etc. On balance, there must be no net loss to nature conservation.

5.6 All the statutory authorities consider that an Environmental Impact Assessment (EIA) would be needed, as would an Appropriate Assessment (AA) - to assess the effects on the Special Protection Area and candidate Special Area of Conservation. The cumulative and in-combination effects of other proposals, including the proposed port at Dibden Bay, would have to be considered.

5.7 The Department for Transport confirmed that it is content with the outline Plan and the suggested approach, but could not determine yet to what extent it would delegate or devolve its functions. No response has been received from the Department for the Environment, Food and Rural Affairs.

5.8 Trinity House confirms that, as a part of the development of the proposals, there will be a requirement to review and re-mark the main and secondary navigation channels and structures. Any changes would be subject to Trinity House's approval.

6. Conclusions

6.1 The draft Plan was published to consult river users, local residents and the general public on ideas for rationalising and reorganising public moorings on the river. Although the Harbour Authority and Crown Estate realised that the proposed concept was bold, radical and imaginative, they have not been surprised by the volume and range of comments resulting from the consultation nor by the strength of feelings expressed.

6.2 To some extent, the reaction can be explained by misunderstandings. Firstly, the Plan was perceived by many respondents to be a `fait accompli', even though it was presented as a series of objectives and a conceptual layout. Ironically, the conceptual presentation was criticised by others for lacking information. This in turn led to misunderstandings on certain issues because, for example, there was insufficient information about such matters as the role of the marinas, the feasibility of the river bus, the costs of implementing the Plan, and so on.

6.3 Basically, most people who responded negatively consider that the stated problems that the Plan is trying to solve are exaggerated and the benefits overstated. Many feel that the river is fine as it is, and should be left alone.

6.4 There are obvious differences of opinion between the authorities and many respondents on a number of key technical matters such as safety, hydrology and dredging. It is to be hoped that meetings with representatives of objectors, involving specialist advisers, will clarify these issues.

6.5 According to the comments received the main motive and benefits of the plan are perceived to be commercial.

6.6 A fundamental issue concerns the costs of implementing the Plan and who will pay. It is the belief of the Harbour Master that the construction costs of the proposed public boat havens will be cost-effective. It is difficult to convince mooring holders that the annual charges for occupying a basic new pontoon berth (ie with no facilities) would not be vastly greater than current charges for a pile mooring. Consequently, it is widely believed that mooring charges will increase dramatically and that many mooring holders would be forced to give up boating. If reliable information cannot be provided to prove these fears unfounded, the accusation of `social engineering' by the County Council and Crown Estate will persist.

6.7 Some important conclusions can be drawn from the responses from the statutory authorities. Firstly, a great deal of work needs to be done to provide sufficient information to enable them to address properly those issues over which they have regulatory control. Secondly, it is inevitable that major formal assessments (EIA and AA) would need to be undertaken; however, it is suggested that a Strategic Environmental Assessment into the broad principles may be a way forward in the first instance as the more detailed assessments would be very costly. Thirdly, there ought to be further consultation on the Plan before any submissions for formal consents are made. Fourthly, the fact that the Borough Councils consider the draft Moorings Plan to represent a departure from their Local Plans implies a lengthy Plan preparation and approval process.

Recommendation

That the River Hamble Harbour Management Committee be advised that this Committee requests that:

(i) the report summarising consultation responses, attached as an appendix, be made publicly available, including on the Harbour Authority's website;

(ii) a meeting be held between representatives of the authorities, river users and specialist advisers to discuss technical issues, including safety and hydrology;

(iii) the authorities undertake a full appraisal of the consultation responses and report the results to the next cycle of Advisory and Management Committee meetings; and

(iv) a Strategic Environmental Assessment be undertaken to address the issues raised.

7617/AI

APPENDIX

DRAFT RIVER HAMBLE MOORINGS PLAN

SUMMARY OF CONSULTATION RESPONSES

First version - 6/11/02

1) INTRODUCTION

[summary of consultation process, leaflet, exhibition, publicity; number and range of responses, etc]

2) HEADLINE DATA

CORRELATION OF CONSULTATION DATA

(as at 11^th November 2002- to be updated)

HEADLINE DATA (out of 303 unless stated)

Number of comments received: 303

Number of respondents: 285*

Number received from Hamble-le-Rice residents: 38 (33 respondents)

Number received from Bursledon residents: 16 (14 respondents)

Number received from Lower Swanwick residents: 5 (4 respondents)

Number received from Sarisbury residents: 9 (8 respondents)

Number received from Warsash residents: 26 (25 respondents)

Number received indicating email address: 95

Number received from boat owners: 35**

Number received from mooring holders: 105***

Number received from [not stated]: 65

Number including support and concerns: 128 (out of 132)

Number received with statements of support: 68

Number received with only statements of support: 7

Number received with issues and concerns: 121

Number received with only issues and concerns: 60

*includes feedback from HCC employees who helped out at the Boat Show.

N. B. Sixteen people have submitted more than one set of (different) comments, two of these have written in three separate times

**some of these could also be mooring holders

***some of those at the AGM could have been mooring holders or boat owners

Comments about specific issues (out of 132)

Visual appearance 51 (46 to 5 negative) 90%

Safety 88 (61 to 27 negative) 69%

Range of moorings 69 (52 to 14 negative, 3 other) 75%

Access, Traffic and Parking 63 (52 to 11 negative) 82%

Security 21 (21 to 0 negative) 100%

New facilities 30 (15 to 15 equal) 50%

Nature conservation 48 (45 to 3 negative) 94%

Dredging 28 (28 to 0 negative) 100%

River bus 45 (31 to 14 negative) 69%

Mooring charges 76 (72 to 4 negative) 95%

Marinas, relationship with 37 (37 to 0 negative) 100%

Role of different groups involved 36 (35 to 1 negative) 97%

Consultation process 58 (48 to 9 negative, 1 other) 83%

Related local planning policy (6 to 0 negative) 100%

Zone specific issues/enquiries 18 (15 to 3 negative) 83%

Questions and general queries 42

3) SUMMARY OF RESPONSES, BY TOPIC

The responses, both positive and negative, have been grouped according to topic or issue and are summarised in this section. The format is to explain briefly what the Plan proposed, followed by a summary of the comments, and then the response of the County Council as harbour authority and the Crown Estate.

Safety

Safety considerations form one of the main drivers for the draft Plan. For example, the leaflet says that "crowded and congested channels endanger navigational safety" and "the use of so many tenders (often overloaded) is a significant contributor to safety risks".

These safety issues proved to be particularly contentious. Many respondents who have used the river for years say that they do not believe that either the existing navigational channels or the use of tenders present any dangers to safety. A significant number consider that there is no evidence to support the authorities' claims about safety issues.

The main safety risk is considered by consultees to be from large and powerful boats. The Plan's proposal to widen the main channel will worsen the safety risk by allowing such boats to travel faster, thus endangering small boats. The argument goes that relatively narrow and congested channels keep speed down and reduce the risk of collision; some people draw comparisons with the width of roads and the speed of traffic. By contrast, a small number of respondents consider that widening the channel would improve safety.

Some respondents complain that the Plan would remove the secondary channels which are used by smaller boats to navigate safely up and down the river.

It is also felt that extending marinas towards the main channel will endanger safety, firstly because it creates berths in faster flowing water (which makes berthing more difficult) and secondly because boats exiting marinas will come into more direct conflict with boats using the main channel.

Some people commented that the existing fairway is clearly defined by lines of pile moorings, and that by removing such moorings the fairway would be less well demarcated and would need navigation markers.

The Plan intends to "create open areas for safe dinghy sailing". Several respondents feel that although giving encouragement to dinghy sailing is a worthy aim, the Plan's proposals would not achieve it and, indeed, might work against it. They consider that existing areas for dinghy sailing (i.e. around relatively scattered moorings out of the main channel, are both safe and adequate to meet needs. They also consider that the areas proposed in the Plan would be less safe because they are easily accessible to large and powerful boats, and they are more open to wave generation. By contrast a small number of respondents applaud the intention to open up parts of the river.

The Plan's claims about tenders being a safety risk attracted several objections. People consider it to be a low risk activity and want to see the evidence of safety risks. It was considered unfair to use the issue as a justification for moving mid-stream moorings to walk-ashore pontoons. If there is any problem it should be tackled by education and encouraging safer use.

Range of Moorings

One of the objectives of the Plan is "to offer a choice of mooring types, locations and charges" and (in the sub-text) to "cater for the full range of consumer preferences".

Many respondents felt strongly that the range and choice of moorings would actually be significantly reduced, because:

· All public pile and swinging moorings will be removed, to be replaced by walk-ashore public pontoons, as a result of which the vast majority of the moorings on the river will be on pontoons (mostly within or adjacent to marinas or boatyards);

· Affordable, low cost moorings will be removed from the river, as a result of which many boat owners will be forced off the river.

Associated with these comments are concerns about the trend towards uniformity and standardisation, and accusations of social engineering by the authorities (see later section).

Many people choose to have pile or swinging moorings because they are private, quieter, less vulnerable to crime, and they often offer good views. Such people want to remain on them, and do not want to be forced on to walk-ashore pontoons, which they regard as marina-style berths.

In contrast, a number of people favour pontoon berths compared with pile moorings, and like the idea of walk-ashore berths because they offer more convenience and better/easier access. There is an indication that some mooring holders would be willing to move to the proposed moorings areas, providing they are affordable.

Security

Related to the comparison of pile/swinging moorings versus pontoon berths is the issue of security.

The plan claims that moving boats on to walk-ashore pontoons adjacent to marinas, boatyards or public access areas will give increased security, because of better surveillance (including use of CCTV) and on-site management.

Many respondents doubt that the Plan's proposals will improve security, as they feel that mid-stream moorings are relatively secure compared with walk-ashore pontoons which are easily accessible from land and therefore more vulnerable to vandalism, theft and other forms of crime. Doubts were expressed about whether monitoring by CCTV would be continuous and would cover al relocated moorings.

There were no positive comments under this heading.

Facilities

In addition to better security the Plan "would also open up possibilities for facilities such as car parking, toilets, waste collection and recycling for the benefit of all". (The subject of car parking is dealt with under the Access, Traffic and Parking heading)

The balance of those who commented on this topic were fairly evenly balanced between those for and against. Some people would welcome better access to a wider range of facilities and would be prepared to pay for using them, providing the charges were reasonable and affordable. On the other hand, many mooring holders said that they did not need or even want better facilities and therefore would not be prepared to pay for them. Access to such facilities raises issues concerning the role of marinas in the new Plan, which is considered in the next sub-section.

Relationship with Marinas

There were a significant number of comments relating to marinas, their involvement, and their effects on the Plan (or vice versa). As the Plan leaflet presented an outline concept, no information was given on these matters. Unfortunately this lack of clarity led to misunderstandings, and gave the impression that the relocated berths would be under the control of, or managed by, the marina operators (which is not the intention). Also, some people thought that the marinas would be allowed to expand as a `quid pro quo' for accommodating public pontoons; again, this is not the case.

The views expressed on these issues must be seen in the context of widespread concern about their strong, adverse visual impact on the river, their high charges, and the near monopoly situation that has developed. Some people viewed the Plan as an attempt to `marina-ise' the river, turn it into a "vast complex of marinas" or a huge "boat park". Some felt that marinas would be the main beneficiaries of the Plan.

As indicated above, the fact that several of the proposed public pontoon areas would be located adjacent to marinas caused many people to think that they would become completely under the control of marinas and subject to their charges and management regimes. Consultees were not convinced that the new mooring areas could be managed independently from marinas and at lower charges, even through "packages" priced according to the range of facilities made available. Some pointed out that marina berth holders would not tolerate a situation whereby public mooring holders on adjacent pontoons paid substantially less for the same facilities.

Access, Traffic, Parking and the River Bus

These topics cover those matters associated with gaining access from land to the new mooring areas.

Objective 4 of the Plan is "to balance access arrangements by combining appropriate car parking provision with a river bus service".

It is evident from the comments received that car parking is considered to be a major issue that has not been addressed by the Plan. There is concern about the lack of information about where those who are relocated to the new mooring areas will park, at what cost, and with what security. It is felt that although the number of moorings on the river is to remain the same, it is inevitable that the major relocation of around one-third of the moorings on the river will have significant and possibly serious implications for car parking.

It is pointed out by many that the existing car parking areas close to the river - whether in the villages, marinas or boatyards - are already at capacity, and there are particular problems at peak times resulting in fly-parking and so on. It is noted that access for many relocated mooring areas is likely to be via marinas and boatyards, where there is no spare capacity for parking and where charges will be high. Access and parking for many relocated mooring holders would be made more difficult rather than less. The perception is that the Plan will exacerbate the major car parking problems around the river, and that there are no suitable sites for new car parking.

On the other hand, a small number of respondents welcome the greater accessibility of walk ashore moorings.

There were roughly equal numbers of positive and negative comments about the river bus proposal. Many welcomed the idea, and say that it is imaginative and worth exploring. Some think it sounds good in theory but have reservation about its practical application. Several people remarked that the Plan provided insufficient information to judge the feasibility of the idea.

Many felt that the river bus would have to operate all year round, 24 hours a day, seven days a week, and that the service would have to be frequent, convenient and inexpensive in order for people to use it. However, such a service would be very expensive to operate and would require heavy subsidy. Some expressed serious doubts about its viability.

A few consider the river bus likely to reduce the use of tenders, but many who currently use tenders thought they would continue to do so, even if a river bus service was provided.

Implementation Costs and Mooring Charges

The Plan was strongly criticised for saying very little about these matters, which were considered to be big issues. They attracted a lot of comments, the vast majority of which were negative.

The general feeling was that the Plan will be expensive to implement. The relocation of pile moorings to concentrations of walk ashore pontoons will be considerably more expensive than straightforward replacement of existing piles.

It is strongly felt that the costs of implementation will be passed on to mooring holders and, therefore, that mooring charges will be substantially increased. There is resentment that mooring holders will end up paying for changes that most consider unnecessary. The Plan will cause affordable moorings to disappear from the river, and many mooring holders on lower incomes will be forced to give up boating. Furthermore, young people and other first-time boaters will be deterred from using the river.

On the positive side, a few people said that they would be prepared to pay higher charges if they were able to benefit from improved facilities.

Environmental Aspects: Visual Appearance

One of the problems stated in the draft Plan concerns "the proliferation of masts" which "produces seas of masts, which many people feel detract from the natural beauty of the river". This is based on remarks made over many years to harbour authority officials and planners.

Many respondents commented that the proliferation of boats on pile and swinging moorings is a positive feature of the river's character, adding to its attractiveness and appeal to visitors. However, it is considered that the dense conglomerations of boats moored in marinas spoil the character of the river.

Because the Plan proposes to relocate large numbers of pile and swinging moorings to `walk-ashore' pontoons, visually akin to marinas, it is strongly felt that the overall effect of the Plan will be to detract from, and not improve, the character of the river. Only three respondents felt that the Plan would improve the appearance of the river by opening up parts and making it less cluttered.

Environmental Aspects: Nature Conservation

The Plan aimed to "benefit nature conservation by reducing the impact of swinging moorings on the river bed, opening up flight paths for birds and reducing disturbance to wildlife and fisheries".

Several respondents said they did not believe that swinging moorings could be detrimental to nature conservation, and called for evidence. Many expressed the view that pile and swinging moorings were less detrimental than other forms of mooring, especially pontoons.

The main adverse effect of boating on wildlife is considered to be the possible erosion of inter-tidal areas by wash generated by large, speeding boats. The Plan's proposed removal of lines of pile moorings is expected to increase the effects of wash.

Some commented that the proposed concentrations of pontoons along the edge of the Hacketts Marsh nature reserve would cause adverse effects on wildlife, especially through disturbance.

There was one positive comment, that the Plan would achieve a balance between nature conservation and river use.

Environmental aspects: Hydrology and Dredging

The Plan says that one effect of the increase in the average length size of boats in recent years has been the requirement for more dredging to increase channel depths. Respondents felt there was no evidence to support this, and pointed out that because fore-and-aft moorings are aligned along the main and secondary channels they never require dredging. Many said that the only dredging on the river in recent years had been in marinas. They consider that the proposed concentrations of walk ashore pontoons will require dredging, because they are to be laid out like marinas berths. The general impression was that the Plan would lead to more dredging rather than less.

Role of organisations

Many respondents were sceptical about the role of the County Council and the Crown Estate, and considered that the main motive behind the Plan is financial; it is seen as a cynical attempt to raise income through higher mooring charges. There were also suggestions of connivance with marina and boatyard operators. There are suspicions about a hidden agenda. Concern was expressed that the decision to proceed with the Plan will be made by HCC and CE, who both have vested interests. Some felt that the way decision making has been organised by HCC because of the modernisation agenda means that the power of decision making is in the hands of very few people.

Consultation

There were some criticisms about the consultation process, in particular:

· Consultation was limited, selective and inadequate;

· The leaflet distorts the truth, and is misleading;

· There was insufficient information about the Plan to enable aspects of it to be properly assessed;

· Many people perceive the draft Plan to be a `fait accompli' and do not trust HCC and CE to give serious consideration to public comments.

General Points

There are some misunderstandings about the Plan's proposals that, with hindsight, could have been avoided.

The problems that the Plan attempts to solve are considered to be either fictitious or exaggerated, and the need for the Plan is strongly questioned. Also, the alleged benefits of the Plan are considered by many to be over-stated..

The Plan was criticised for not including a proper assessment of costs and benefits; the general perception of many respondents was that the Plan will incur huge costs for very little benefit.

There was no evaluation of alternative plans, in particular no assessment of the alternative of replacing existing piles.

The Plan is perceived to be detrimental to river users and the environment, and beneficial only to commercial interests.

Alan Inder

Coastal Manager

6 November 2002