K&A mooring consultation: only three weeks until deadline

Responses to the consultation on the Towpath Mooring Plan for the K&A west of Devizes have to be in by 29th November. The proposals will affect all boaters using the K&A between Bath and Devizes. If you haven’t filled in a consultation questionnaire, please do so now. Below is an example consultation response with some explanatory notes to help you gather your thoughts.

Copies of the Towpath Mooring Plan (to read) and the Consultation Questionnaire (to take away, fill in and send back) are available from the Raft Cafe boat in Bathampton; theLock Inn below Bradford lock; the K&A Trust cafe at Caen Hill; the K&A Trust shop at Devizes Wharf; the K&A Trust cafe in the Stone Building, Newbury and the K&A Trust cafe in Aldermaston just east of the lift bridge. A few copies are also available at the Waterfront, Pewsey Wharf; the Barge Inn, Honey Street and the Bridge Inn, Horton. There may also be some at the Three Magpies, Sells Green.

Example consultation response: notes marked in bold

Download the example consultation response here K&A Mooring Plan consultation example response
Consultation on Towpath Mooring Plan for The Kennet & Avon Canal west of Devizes
30 August – 29 November 2013

Introduction

The Canal & River Trust and Kennet and Avon (K&A) Waterways Partnership are seeking the views of K&A boaters, other K&A users, local residents, parish, district and county councils and canal side businesses on the proposed Towpath Mooring Plan for The Kennet & Avon Canal west of Devizes to Bath (not including the River Avon after Bath). The pilot local guidance for boaters on the K&A canal aims to establish fair and equitable sharing of the canal.

The proposed local guidance has been developed by a K&A Waterways Partnership working group1. Agreement for wider consultation on the proposal has been supported by the Trusts K&A Waterways Partnership and the Trusts Navigation Advisory Group.

This consultation runs from Friday 30 August to Friday 29 November 2013. Subject to any changes in the plan as a result of the consultation, the Canal & River Trust and the K&A Waterways Partnership will undertake a 12 month pilot of the K&A Towpath Mooring Plan beginning as early as feasible in 2014.

The Kennet & Avon Waterways Partnership Working Group ‘Towpath Mooring Plan for the Kennet & Avon Canal west of Devizes’ report can be viewed online here: https://canalrivertrust.org.uk/media/library/4082.pdf

Responses to the consultation survey must be received by Friday 29 November.

Send your response to:
Matthew Symonds, Boater Liaison Manager, Canal & River Trust, The Dock Office, Commercial Rd, GLOUCESTER GL1 2EB

For paper copies of the survey or for further information about the survey please contact, Matthew Symonds, Boater Liaison Manger by email matthew.symonds@canalrivertrust.org.uk or phone 07825 227951.

About you

Firstly about you – please complete this section to help us fully evaluate responses to this consultation

What is your primary interest in the K&A?

a. Boating X
b. Cycling
c. Walking
d. Fishing
e. Wildlife
f. Other (please state)

Do you own a boat licensed with the Canal & River Trust? (if no move to Q1a)

a. Yes   ( X )
b. No   (  )

This question excludes those who live on a boat that they don’t own. Many people live on boats that belong to the parent or partner that they live with. Others live on boats that belong to non-resident parents, other family members or friends.

Is the boat your primary residence?

a. Yes X
b. No

Which type of license do you have?

a. Home Mooring
b. Continuous Cruising X

There is no such thing as a continuous cruising licence. Relevant licence types are the Standard Canal and River licence or the Rivers Only licence. On top of that a boat may have a mooring, and if it has a residential mooring it may have a houseboat certificate.

K&A Waterways Partnership working groups Towpath Mooring Plan

Please give us your response to each of the consultation questions to help us gather your views on the proposals in the Towpath Mooring Plan. Please choose one option (strongly agree, agree, neither agree or disagree, disagree, strongly disagree) to say how you feel about that proposal. There is a space at the end of this consultation survey for you to write any other comments.

1. Local guidance, communication and compliance

The proposal recommends that a voluntary agreement and a suite of very clear local guidelines are produced in order to provide boaters with the confidence that they are using the K&A waterway on a fair and equitable basis that will not attract enforcement action. The voluntary agreement and guidelines would include:

a. Boaters agreeing to move to a new place every 14 days, unless it is reasonable in the circumstances to stay longer.

Strongly agree X
Agree
Neither agree or disagree
Disagree
Strongly disagree

This is what we are required to do by s.17 3 c ii of the 1995 British Waterways Act.

b. Where appropriate, cases of concern which the Trust staff feel are not clearly ‘reasonable in the circumstances’ will be referred to a partnership sub group for review and may be subject to challenge.

Strongly agree X
Agree
Neither agree or disagree
Disagree
Strongly disagree

This sub-group of the Local Waterway Partnership is intended to act as a buffer between boaters and the enforcement officers, and may even have members who are local liveaboard boaters who understand the reasons that boaters have for needing to stay longer.

c. Boaters agreeing to vary the places they select to moor, and each time they move they agree not to move back to the place they have just come from (unless they are reversing the direction of travel or momentarily accessing essential services).

Strongly agree
Agree X
Neither agree or disagree
Disagree
Strongly disagree

Fair enough as long as it is recognised firstly that there is limited choice of where to go to use water, refuse and sanitary facilities, which may mean turning back frequently, and secondly that there are limited places where you can wind a full-length boat so boats may have to turn back at particular places.

d. Boaters agreeing not to ‘Bridge Hop’ (the term used to describe when a boat moves from one place to another adjacent to it and then back to the same place).

Strongly agree
Agree X
Neither agree or disagree
Disagree
Strongly disagree

e. A map of local Places will be published that reflects the local geography and the places determined in a consistent fashion. The places will reflect the advice provided by Canal & River Trust in the local guidance. A map of places has been produced by the working group (see appendix 1), it is proposed that these are used during the 12 month pilot and then reviewed. The Towpath Mooring Plan will reflect the map of places.

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

The list of places provided is both incomplete and inaccurate (and some of the place names are spelled incorrectly). To penalise boaters for mooring at places that exist and are marked on the map would be unjust.

2. Range of movement

The proposal includes a range of movement that, when implemented alongside the other proposals, could help encourage new navigation habits by boaters.

a. Boaters would agree that over the period spanning a boat’s annual licence to achieve a range of movement that exceeds 20 km.

Strongly agree
Agree
Neither agree or disagree X
Disagree
Strongly disagree

While it would be helpful to have a minimum distance that would guarantee that boaters would not be subjected to enforcement, there is no minimum distance set out in s.17 3 c ii of the 1995 British Waterways Act. Although most liveaboard boaters probably travel 20km or more in a year, there are some who cannot. These are most often people who have children, who are disabled or who are elderly. These people are protected by the 2010 Equality Act from the application of procedures that would put them at a substantial disadvantage compared to a person who is not disabled, not elderly or is not responsible for children. Given that the consequences of enforcement mean that ultimately the boater can lose their home, that is a substantial disadvantage. Other people who cannot travel this distance are those who are temporarily unwell but not to the extent of being disabled; those who need to be in a particular area to get access to continuing medical treatment; those who are having mechanical problems and need to be in a particular location for repairs so that the engineer can have access, and those with deep draughted boats whose movement is limited either by the depth of water on the day (the water level on parts of the K&A fluctuates a lot) or that cannot navigate beyond particular shallow points (such as Limpley Stoke bridge and Stowell park). It would be unjust to penalise those people for circumstances beyond their control and prevent boaters who need it from getting the healthcare that they are entitled to. People in these situations are entitled to stay longer than 14 days in one place and many do exercise this right, but if they do move their boats in a limited way in an attempt to comply with the law they are frequently penalised by enforcement that is entirely unjustified given their circumstances.

3. Compliance

To effectively implement the 12 month pilot the following measures to apply;

a. C&RT would undertake regular, consistent and fair enforcement of the 14 day mooring rule, applied firmly and fairly to all boats, whether they are lived-on or empty.

Strongly agree X
Agree
Neither agree or disagree
Disagree
Strongly disagree

If CRT enforced the 14-day rule in this way, instead of enforcing an unlawful minimum distance as they do at present, most of the problems that the Towpath Mooring Plan purports to be intended to solve would disappear. The vast majority of boaters do move on if they receive an accurate, correct notice saying they have overstayed. This would leave a small number which would be a manageable caseload for the enforcement team. However CRT needs to improve its procedures so that the number of days a boat has stayed is recorded accurately and all such enforcement notices are correct.

b. C&RT would take enforcement action against boats that have been shown to have persistently disregarded Local Guidelines.

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

The local guidelines are presented in the Towpath Mooring Plan as a voluntary agreement. Any local guidelines that are not in line with the 1995 British Waterways Act are unlawful and cannot be enforced. The Towpath Mooring Plan presents this as a voluntary agreement which if followed will act as a guarantee that enforcement action will not be taken. This proposal turns that guarantee on its head; it does not reflect what is actually in the Towpath Mooring Plan presented by the Local Waterway Partnership.

4. Communications

A widely published local consensus could carry an authority of its own and encourage boaters to observe all such locally-approved guidance.

a. Updated signage, boundary markers (existing structures would be used wherever possible) and a towpath mooring map and information leaflets would be published to explain the local guidance.

Strongly agree
Agree
Neither agree or disagree X
Disagree
Strongly disagree

Any such information must reflect the fact that this is a voluntary agreement and following it is a guarantee that enforcement action will not be taken. Such information must not state that enforcement action will be taken against boats that do not follow local guidelines. Any signs must not spoil the look of heritage structures or clutter the waterway with prescriptive, bossy signs that would stop waterway users from enjoying the waterways, giving the impression to visitors that CRT is a draconian organisation that harasses and bullies boaters.

b. Boaters would be encouraged to self-declare their intentions with notices posted on their boats; for example an anticipated next move date (“next move before….”).

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

This proposal is not a true reflection of the discussions within the Local Mooring Strategy Steering Group that preceded the Local Waterway Partnership’s Towpath Mooring Plan. This type of “next move date” notice was proposed only for those boats that were exercising their right to stay longer than 14 days in one place if reasonable in the circumstances, to re-assure the public that boats were not overstaying in contravention of s.17 3 c ii. To require all boats to display these notices is firstly onerous and secondly would put those boats at risk of being burgled.

c. A summary of anonymous cruising records should be publicly available to show how boats are moving on the K&A in line with the guidance.

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

Although a well-meaning proposal, to make anonymised records publicly available would firstly run the risk of individual boats being identified by their travel pattern and secondly amount to a collective invasion of the privacy of the liveaboard boating community, contrary to our right to respect for our private lives conferred by Article 8 of the European Convention on Human Rights.

d. Individual boaters would be able to access their own navigation records held by C&RT

Strongly agree
Agree X
Neither agree or disagree
Disagree
Strongly disagree

We have the right to obtain any information that CRT holds about us anyway under the Data Protection Act. If this would enable us to access these records faster it would be useful. However, there has to be a facility for boaters to correct inaccurate or incomplete recording by CRT of their boat movements. So far CRT/ BW have refused to correct or add to their boat sighting records and boaters have been the victim of enforcement action when their boat movements have complied with the law, due to incomplete boat sightings.

e. To effectively evaluate the 12 month pilot, and to determine whether it is appropriate to consider revision of the guidelines, the C&RT will work with the K&A Waterways Partnership to agree key measures that will be reported regularly to the partnership.

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

We do not want CRT to keep moving the goalposts. It is bad enough to be told under threat of removal of our homes that we have to follow local guidelines that go above and beyond the requirements set out in the 1995 British Waterways Act. It would be unjust to keep reviewing and changing a set of local guidelines that will have been established with extensive consultation and as a result will have a broad acceptance among the boating community. Ongoing revision would allow CRT to progressively erode the rights of boaters to use the waterways without a home mooring, which would be unlawful.

5. Accommodating boaters’ existing lifestyles

The proposal recommends that boaters’ chosen lifestyles will be best preserved and protected through the clarification and consistent implementation of local guidance.

The Waterways Partnership rejects Community Moorings on the Kennet & Avon Canal. The Partnership believes that Community Moorings would deny the majority of boaters and anglers access to large tracts of the towpath and is contrary to CRT Policy on the prioritisation in the development of off-line moorings over on-line moorings. Community Moorings could increase congestion and may also be a source of conflict across the boating community.

a. Community Moorings should be rejected as an option on the Kennet & Avon Canal.

Strongly agree X
Agree
Neither agree or disagree
Disagree
Strongly disagree

We support the Local Waterway Partnership’s rejection of so-called Community Moorings. These would not benefit the community. Boaters already have the right to stay in one place longer than 14 days if a longer stay is reasonable. To set aside stretches of waterway where no-one else can moor would prevent other boaters from using large areas of the canal. There are already too many places where boats cannot moor due to lack of dredging and lack of bank maintenance. Community Moorings are an attempt by CRT to force boaters to pay twice for doing what they are entitled to do by virtue of s.17 3 c ii of the 1995 British Waterways Act. This is extortion.

b. The Canal & River Trust should continue to assess the merits of exceptional situations of need, on a case by case basis.

Strongly agree
Agree X
Neither agree or disagree
Disagree
Strongly disagree

We already have the right under s.17 3 c ii of the 1995 British Waterways Act to stay longer than 14 days if it is reasonable in the circumstances. Boaters who have children, are elderly or have disabilities are protected by the 2010 Equality Act. It is not for CRT to assess the merits of these rights but simply to uphold them. For those in “exceptional situations of need” who do not enjoy these rights, it is only just, right and proper that CRT uses its discretion in a humane and equitable way.

6. Visitor Moorings

a. Visitor moorings should remain free for the first 48 hours, but there should be an Extended Stay Charge for any K&A visitor mooring for more than 2 days at a time (the purpose of this would be to encourage more use by tourists visiting by boat).

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

The proposed extended stay charges are not lawful. Firstly, no specific authority has been granted by Parliament to CRT to impose either a charge or a penalty for a violation or extension of the time limits on visitor moorings. Secondly, the level of the charge at £25 per day bears no relationship to any proper charge for the use of the waterways  nor to the actual loss or costs associated with overstaying. It is therefore in the nature of a fine or penalty. The Towpath Mooring Plan does not explain how the £25 per day extended stay charge has been arrived at.The fixed daily element is inconsistent with this because the costs of enforcement cannot increase in this way and cannot realistically be considered to do so. The charge is fixed at a level to make it impossible to stay for any extended period. It amounts to £9,125 per annum compared to an average annual mooring fee of around £2,000. This makes it a fine and not a charge, and BW conceded in 2009 (for example in an email from Sally Ash to Keith Rossiter of Bathampton Parish Council) that it does not have the power to levy fines for overstaying. It is therefore outside the powers in s.43 of the 1962 Transport Act and any inclusion in the terms and conditions of the boat licence of a requirement to pay such charges does not bring these charges within the powers available to CRT under s.43 of the 1962 Transport Act.

The 1962 Act allows for charges to be made for services and facilities and this is clearly intended to cover reasonable remuneration for those services. However, the charge must relate to the value of what is provided or other associated costs incurred by CRT. As regards the use of land the value is the value of the occupation or the consequential damages (see the judgement in MOD v Ashman [1993] 25 HLR 513).

In some road traffic cases, local authorities have been permitted to apply excess parking charges (see for example Crossland v Chichester DC [1984] RTR 181) but the statutory power there was different and conferred a general power in relation to use rather than a power to charge for services and facilities.  A charge of that kind is still subject to the requirement that it be reasonable.

CRT and BW have in the past asserted that they may levy such charges simply by virtue of their rights as landowner. This is misleading because a body exercising statutory powers cannot rely on the common law rights of a landowner to empower it to levy such charges (see for example the judgement in Swan Hill Developments v British Waterways Board [1997] EWCA Civ 1089). However, in such cases, the charging regime is a matter of contract between CRT and a licence holder. The overstaying charge is a liquidated sum payable in the event of breach of contract and the amount amount must be a genuine pre-estimate of loss (see for example the judgement in The Paragon [2009] 1 CLC 379).

In the 1990 Bill that became the 1995 British Waterways Act, BW sought powers to impose fines for a breach of a mooring restriction. BW also sought powers in the 1990 Bill to erect signs designating mooring restrictions. Parliament forbade BW to impose fines for violation of a mooring restriction. As a result of this, BW withdrew the wording relating to the erection of signs designating mooring restrictions. BW had previously presented evidence that stated that its signs for mooring restrictions were advisory in nature. BW also withdrew the wording relating to the designation of mooring restrictions. Therefore, signs denoting visitor mooring time limits remain advisory to this day and not compulsory. The only mooring time limit that CRT has the statutory power to enforce is the 14-day limit applying to boats without home moorings in s.17 3 c ii of the 1995 British Waterways Act.

b. All boats (except those registered for hire) should be limited to spending no more than four days in any calendar month at a particular visitor mooring.

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

The Commons Select Committee also rejected any “no return within” restrictions (House of Commons Select Committee on the British Waterways Bill, 1993-94). As a consequence this means that any “no return within” or “maximum days in any period” restrictions also remain advisory and not compulsory. This restriction is completely impractical; some boaters need to use a particular visitor mooring more often than that, for example if they or their visitors are elderly or disabled. In any event, in the context of a voluntary agreement, CRT cannot restrict stays at visitor moorings in this way. However, all signatories to the K&A Boaters Code of Conduct have agreed to avoid visitor moorings in the summer wherever possible. As a voluntary agreement this is acceptable. It is not acceptable to have any such restrictions in winter when there are virtually no hire boats and when liveaboard boaters need hard-standing and good towpath access for loading coal and wood.

c. Debts accruing through extended stay charges should be collected via C&RT’s normal consumer debt collection process.

Strongly agree
Agree X
Neither agree or disagree
Disagree
Strongly disagree

The normal process for any organisation to recover debts of small sums of money is to make a claim in the County Court Small Claims track. Any other method of debt recovery would be unlawful.

d. During the 12 month trial the renewal of a boat licence would not be subject to settlement of overstay debts.

Strongly agree
Agree X
Neither agree or disagree
Disagree
Strongly disagree

It is simply not legal to make the renewal of a boat licence subject to the payment of other debts that are not arrears of licence fees. The 1995 British Waterways Act sets out the conditions under which a licence is granted, renewed or refused. These conditions do not permit CRT to refuse to renew a licence because of debts owed for another purpose. In any case, it is not legal to take money paid for one purpose and apply it to an existing debt to the same organisation that is owed for a different purpose.

e. No special provision is proposed for roving traders who must comply with the terms and conditions of their specific licences).

Strongly agree
Agree
Neither agree or disagree X
Disagree
Strongly disagree

f. To assist boat checking all hire/hotel boats under hire will be requested to display an “under-hire” notice or symbol.

Strongly agree
Agree
Neither agree or disagree X
Disagree
Strongly disagree

g. It would be a good idea for the location and lengths of all visitor mooring sites on the canal to be reviewed and updated to meet changing demand.  Boating communities and other interested parties would be invited to contribute to this review which would take place during 2014”

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

As stated above, all visitor mooring signs are advisory, not compulsory. There are already enough visitor moorings on the K&A. We do not need any further restrictions in the length of 14-day mooring space, which is already limited due to the condition of the canal. This would serve to further erode the right to use a boat without a home mooring. What is badly needed is not more visitor moorings, but dredging and maintenance that would free up more space on the waterway where boats could moor to the bank for 14 days. This would ease any pressure on the existing visitor moorings because hired, liveaboard and leisure boats would find it easier to moor on the towpath. This would also free up the purpose-built visitor moorings for those who really need them: disabled boaters and those with temporary mobility difficulties.

7. The needs of anglers

It is recommended that the requirements of anglers are incorporated into the local guidance and any voluntary code of conduct for boaters. This practice would fit with the emerging need for boaters to leave a fire break between boats in the interest of boat safety. The following guidance is recommended;

a. The need for pegging space (including for matches) for anglers should be included in any local guidance.

Strongly agree X
Agree
Neither agree or disagree
Disagree
Strongly disagree

b. The need for boaters to leave space (e.g. 3-5 metres) between boats to accommodate anglers is included in local guidance (as well as for reasons of fire safety).

Strongly agree
Agree
Neither agree or disagree
Disagree X
Strongly disagree

It would be helpful for boaters to better understand the needs of anglers. However, always leaving a 3-5 metre gap between boats is completely impractical. How would this be enforced? If a boat that has left a gap as advised then moves, and another boat moors and does not leave a gap, how does the enforcement team know which boat is to blame? What if a boat leaves a gap then moves, and a longer boat moors in the same space? What if a longer deep-draughted boat moves into the space because it is the only place deep enough for it to moor? This will require time-consuming enquiries,  administration and enforcement that is not worth while. In many parts of the K&A, there are long stretches of waterway where it is not possible to moor to the bank at all, and occasional areas where there is space for a few boats to moor against the bank. The anglers will be able to use all the space that is too shallow for boats to moor to the bank. Do the boats really still need to leave a gap in places like that?

8. Other recommendations

The K&A Waterways Partnership working group made a number of recommendations that are not proposed to be part of the initial 12 month pilot; however we would still like your views on these.

a. Pre-payment options, for extended stay on visitor moorings, including pay and display or phone payment systems, should be introduced as a priority.

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

As stated above, CRT has no powers to collect such extended stay charges or fines. Pay by mobile would not work due to the extremely patchy mobile network coverage on the K&A; it would be unjust to penalise people for the lack of mobile signal. In addition, not everyone has a phone or a bank account that can make such payments. It would be unfair to penalise them. In any case, most pay and display systems are set up for small amounts of up to £5.00. Even if it worked properly, which many machines that take notes do not, a machine that was known to contain multiples of £25.00 would be a target for thieves.

b. When reviewed and updated national C&RT enforcement documentation and published guidance should be amended to accommodate the existence of local guidance.

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

The Towpath Mooring Plan presents the local guidance as a voluntary agreement which if followed will act as a guarantee that enforcement action will not be taken. This proposal turns that guarantee on its head; it does not reflect what is actually in the Towpath Mooring Plan presented by the Local Waterway Partnership. Any local guidelines that are not in line with the 1995 British Waterways Act are unlawful and cannot be enforced.

c. When reviewed and updated C&RT licence renewal forms should be amended to incorporate a tick box that records the boater’s commitment to read and understand any local guidance that may apply to them over the forthcoming licence period.

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

The Towpath Mooring Plan presents the local guidance as a voluntary agreement which if followed will act as a guarantee that enforcement action will not be taken. This proposal turns that guarantee on its head; it does not reflect what is actually in the Towpath Mooring Plan presented by the Local Waterway Partnership. Any local guidelines that are not in line with the 1995 British Waterways Act are unlawful and cannot be enforced.

d. When reviewed and updated C&RT licence renewal forms should be amended to incorporate an additional tick box that enables the boater to confirm that “I understand that it is quite possible that my boat movements may attract enforcement action if I do not adhere to any local guidelines”.

Strongly agree
Agree
Neither agree or disagree
Disagree
Strongly disagree X

The Towpath Mooring Plan presents the local guidance as a voluntary agreement which if followed will act as a guarantee that enforcement action will not be taken. This proposal turns that guarantee on its head; it does not reflect what is actually in the Towpath Mooring Plan presented by the Local Waterway Partnership. Any local guidelines that are not in line with the 1995 British Waterways Act are unlawful and cannot be enforced.

e. The UK Driving license points system is a widely accepted and understood concept. A points system based on this concept should be introduced to provide certainty for boaters of when enforcement action might be taken against them and could enable boaters to recover from an occasional lapse and assist C&RT to firmly and fairly enforce rules.

Strongly agree
Agree
Neither agree or disagree X
Disagree
Strongly disagree

This is a helpful proposal, but it would be better if the enforcement process included a requirement for CRT to make it clear when a boat was no longer in the enforcement procedure, by sending a letter cancelling the enforcement notices and stating that the boater was now complying with s.17 3 c ii. At present the enforcement process lacks any provision to notify the boater that they are no longer the subject of enforcement. This is unjust and is a violation of the rights of all citizens to be able to tell when their actions are unlawful and their rights to a fair trial under Article 6 of the European Convention on Human Rights.

9. Any other comments

Do you have any other comments on the proposed Towpath Mooring Plan for The Kennet & Avon Canal west of Devizes which could improve its implementation?

What happens next?

Following the consultation a summary of consultation responses will be published on the C&RT website and also communicated to boaters on the K&A. The findings of the consultation will be discussed by the K&A Waterways Partnership at the January meeting. Subject to further changes following the consultation a 12 month pilot of the Towpath Mooring Plan will begin as early as feasible in 2014.

Keep informed.

If you would like to be kept informed directly please provide you name and contact email/address

Name
Email
Address (if no email available)
Mobile Phone (if you prefer updates by text message)

Appendix 1

Place
Western limit
Eastern limit
Eastern Bath: Bath Top Lock (Lock 13) to Candys Bridge (Br.184)
Bathampton: Candys Bridge (Br.184)to Bathampton Swing Bridge (Br.182)
Claverton: Bathampton Swing Bridge (Br.182)to Millbrook Swing Bridge (Br. 178)
Dundas: Millbrook Swing Bridge (Br. 178) to Limpley Stoke Bridge (Br. 175)
Muirhill: Limpley Stoke Bridge (Br. 175) to Elbow Bridge (Br. 174)
Avoncliffe: Elbow Bridge (Br. 174) to Meadows Bridge (Br.173a)
Bradford on Avon: Meadows Bridge (Br.173a) to Beehive Bridge (Br. 170)
Widbrook: Beehive Bridge (Br. 170) to Widbrook Bridge (Br.169)
Hilperton: Widbrook Bridge (Br.169) to Staverton Bridge (Br. 166)
Whaddon: Staverton Bridge (Br. 166) to Semington Swing Bridge (Br. 161)
Semington: Semington Swing Bridge (Br. 161) to Seend Park Foot Swing Bridge (Br. 155)
Seend Cleeve: Send Park Farm Swing Bridge (Br. 155) to Seend Top Lock (152)
Sells Green: Seend Top Lock (152) to Martinslade Bridge (Br 148)
Foxhangers: Martinslade Bridge (148) to Sir Hugh Stockwell Lock (Lock 44)

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