APPENDICES TO THE MINUTES OF EVIDENCE
Memorandum by Environment Agency (PPG
1.1 The Environment Agency
1.1.1 The Environment Agency welcomes this
further opportunity to comment on the draft PPG and to submit
evidence to the Sub-Committee.
1.1.2 The Environment Agency is a statutory
body created by the 1995 Environment Act. Within its very broad
remit, the Agency has specific recreation and navigation duties
including the general duty to promote the recreational use of
the water environment within the context of our overall remit
for sustainable development.
1.1.3 The Agency manages a number of waterside
sites for formal and informal recreation and is the harbour authority
for Rye Harbour and the navigation authority for 800 km of navigable
river including the River Thames.
1.2 Government Report: Waterways for Tomorrow
1.2.1 In the DETR report, Waterways for
Tomorrow, the Government recognises the value of inland waterways
and says that it wishes "to encourage people to make use
of inland waterways for leisure and recreation, tourism and sport".
1.2.2 The report also states that the Government
will support such development of the inland waterways through
the planning system. The Agency feels the draft PPG 17 has not
met this objective and as such needs to be considerably strengthened.
2. DRAFT PPG
2.1 The Water Environment
2.1.1 In its consultation response to DEFRA,
the Agency has already noted the recognition in the draft PPG
17 of the contribution rivers and canals may make in providing
green links between areas of open space. The draft PPG should
however recognise more fully the role of water and waterside land
in providing open space and places for sport and recreation in
urban and rural areas. This should be addressed at an early stage
in the PPG and the full extent of the resource that is the water
environment should be acknowledged.
2.1.2 Linear waters such as canal and river
navigations and non-navigable watercourses form part of this resource.
Natural lakes, man-made reservoirs and water-filled mineral sites
also provide opportunities for sport and recreation.
2.1.3 Policy guidance should recognise that
increased access and use of the water environment will have a
potential impact on wildlife. The need to protect biodiversity
must be taken into account and proposals should be assessed in
the light of proper environmental appraisals.
2.2 Regionally Important Water Space
2.2.1 The PPG should recognise that some
water space will be of regional and even national significance
for sport and recreation and as a tourism destination. The economic
contribution made by these water features and associated land
and facilities should be acknowledged and planning authorities
encouraged to provide policies and guidance to protect and enhance
2.3 Water and Urban Regeneration
2.3.1 There are many examples around the
country where previously derelict and neglected watercourses and
adjacent land and buildings have been restored and the water itself
used for recreation. These sites have played a significant role
in the urban regeneration of such areas and the potential for
other similar regeneration initiatives involving open space on
and near water should be highlighted in the PPG.
2.3.2 Previously under-utilised water spaces
are often rich in biodiversity and may be the habitat of Biodiversity
Action Plan species. Policy guidance should indicate the need
to take into account the protection of such species.
2.4 Water and Informal Recreation
2.4.1 Rivers, canals and lakes act as magnets
drawing people to the water's edge to watch boats go by or simply
admire the view. This "open space" experience needs
to be valued for the contribution it makes to a good quality of
life for locals and visitors. Planning Policy Guidance should
recognise and protect this experience through policies to preserve
access to the waterside via riverside footpaths and informal open
space adjacent to water. The visual contribution water makes to
the landscape or townscape should be similarly protected through
2.5 Sport and Formal Recreation on the Water
2.5.1 The PPG should take full account of
the existing and potential use of water for formal sport and recreational
activities such as angling, boating, canoeing and windsurfing.
These activities should be valued for the economic and quality
of life contributions they make to an area and strongly protected
from the detrimental impacts of any development.
2.5.2 Formal sport and recreation frequently
require the development of associated facilities. The PPG should
recognise the significance of slipways and launching sites in
providing access on to the water itself. Other facilities, from
marinas and boatyards at one end of the scale to fishing pegs
for angling at the other, are all vital components of a thriving
recreational water environment, for which planning policy must
make provision to protect existing facilities and allow appropriate
new development, where it will be sustainable.
2.6 Sustainability and Managing Conflict
2.6.1 The PPG needs to give more guidance
on managing conflict between different recreational activities
on land and water and between recreational uses and other interests.
Planning authorities may be tempted to create policies to exclude
"nuisance" sports and activities from their areas. The
House of Commons Environment Committee report, The Environmental
Impact of Leisure Activities (1995), notes that "the principle
of sustainability in recreation involves the provision of facilities
for all activities, not only for the aesthetically pleasing and
2.6.2 The Guidance should give consideration
to zoning and other management techniques to avoid conflict between
different interests. The Environment Agency has considerable experience
in managing competing interests on the water and is able to advise
planning authorities on management techniques and other measures.
2.7 Identification of Need and Opportunities
2.7.1 The PPG makes reference to the need
for local authorities to develop a full understanding of the available
resources for sport, open space and recreation in their areas
and also to assess demand for such resources. With regards to
water and water based recreation, the Environment Agency is able
to advise and guide local authorities on existing provision and
opportunities for development. Reference to this could be made
in a relevant section of the PPG.
2.7.2 A Memorandum of Understanding exists
between the Environment Agency, the Countryside Agency and Sport
England to enable these organisations to work together more effectively
to promote sustainable recreation in the water environment. These
practices may also contribute to planning authorities' assessment
of need and opportunity.
2.8 Environment Agency Strategies and Policies
2.8.1 The Environment Agency produces strategies
and policies relating to recreation in the water environment and
its sustainability in the long term. These should be used to advise
and inform local authority plans and strategies.