Memorandum from The Royal Yachting Association
1. THE ROYAL
YACHTING ASSOCIATION
(RYA)
The RYA is the national body for all forms of
recreational and competitive boating. It represents dinghy and
yacht racing, motor and sail cruising, RIBs and sportsboats, powerboat
racing, windsurfing, inland cruising and personal watercraft.
The RYA is recognised by all government offices
as being the negotiating body for the activities it represents.
It currently has over 100,000 personal members, the majority of
whom choose to go afloat for purely recreational non-competitive
pleasure on coastal and inland waters. There are an estimated
further 500,000 boat owners nationally who are members of over
1,500 RYA affiliated clubs and class associations.
The RYA also sets and maintains a recognised
standard for recreational boat training through a network of over
2,200 RYA Recognised Training Centres in 20 countries. On average,
approximately 150,000 people per year complete RYA training courses.
2. RYA AND THE
MARINE BILL
The general boating public wants to enjoy our
sport in a manner that is respectful and considerate to the natural
environment. The RYA therefore promotes responsible boating and
actively engages with the recreational boating community to provide
practical advice and guidance on how best to achieve a peaceful
and considerate co-existence of recreational boating activity
and the marine environment.
The RYA's guiding principles for its environmental
and planning work are:
— Promotion of recreational boating
opportunities for all.
— Promotion of the sustainable use
of the coastal zone and inland waters.
The RYA has shown its commitment to promoting
sustainable development of boating and the associated facilities
through a series of high profile projects and publications, which
are:
— "The Green Blue", a major
environmental project part-funded by Defra which promotes sustainable
boating practices to both the recreational boating industry and
to users.
— "The Environmental Code of Practice",
produced in association with the British Marine Federation (BMF)
and the Environment Agency.
— "The Port Waste Reception Facilities
Guide", produced in association with the BMF.
— "The Scottish Marine Wildlife
Watching Code", produced by Scottish Natural Heritage with
input from the RYA.
It therefore shares the Government's vision
for a marine environment that is clean, healthy, safe, and which
promotes biologically diverse oceans and seas (as set out in the
Government's publication "Safeguarding Our Seas" (May
2002)).
The RYA acknowledges that the Marine Bill could
significantly improve existing regimes and processes, but is also
aware that measures may be proposed which, if accepted, could
have an adverse impact on private recreational boating.
The RYA's comments at this stage of the Consultation
focus on the broad principles rather than the detail, and they
are:
3. PLANNING AND
LICENSING REGIMES
The RYA is in general agreement with the proposals
to reduce the complexity, cost and bureaucracy of existing planning
and licensing regimes and to clarify any overlap in responsibilities
and jurisdiction. It believes that a prime objective should be
to reduce costs and bureaucracy, and therefore care should be
taken not to make the situation worse by imposing additional burdens.
4. LICENSING
OF ACTIVITIES
AND THE
PUBLIC RIGHT
OF NAVIGATION
The RYA is particularly interested in those
aspects of the Bill that may affect or could have an impact upon
recreational boating activities. While it welcomes the intention
to streamline and improve policies relating to marine activities
in coastal and offshore water and to marine natural resource protection,
the RYA is keen to ensure that recreational boating activities
are not adversely affected or prejudiced by the proposed Bill.
It is not clear from the Consultation Paper
whether DEFRA has assessed the contribution made by recreational
boating activities, which include social benefits, participation
in physical activities and economic benefits to coastal communities,
including remote and rural economies.
The RYA therefore seeks assurances from Government
that recreational boating activities, and the social and economic
benefits they provide, will be fully taken into account by the
Bill team to ensure any impacts on the sport will be identified
and analysed, and the affects mitigated. The RYA believes that
the Bill should clarify what is meant by "unlicensed activities"
to enable the scope and effect of the Bill to be fully assessed.
The RYA is particularly concerned about any
interferences with the public right of navigation and the potential
to licence recreational boating activities. It notes that para
10.93 of the Consultation mentions concerns expressed by some
environmental organisations that "unlicensed activities are
causing disturbance to marine wildlife" and the view has
been expressed that leisure activities "such as|the intensive
use of recreational craft in sensitive areas are of most concern".
The RYA is aware that some environmental organisations
refer to anecdotal evidence claiming that recreational boating
is harmful to the environment. Notwithstanding that there is an
impact, by any reasonable measure the level of impact is low and
does not justify additional regulatory or licensing controls.
What impact there is can best be managed through practical and
sensible education, not by further regulation. Research is currently
being commissioned by the RYA to help identify additional measures
to further reduce any environmental impact of the sport.
With regard to licensing, the RYA believes that
any attempt to impose a licensing regime which will affect private
recreational boaters will introduce an unnecessary and costly
layer of bureaucracy which in practice will achieve very little.
The RYA promotes the policy of "education
not legislation". The UK currently has one of the best recreational
boating safety records of all maritime nations, and this success
is due in part to the responsible and self-regulating attitude
prevalent among recreational boaters. Any incidents are closely
examined by the RYA and the Maritime and Coastguard Agency (MCA)
and such investigations may sometimes result in sensible non-mandatory
recommendations to prevent recurrence. The Government agrees with
the RYA that further regulatory controls, including licensing,
are unnecessary.
Consequently the RYA would welcome a statement
from Government that the Bill will not seek to impose additional
regulatory burdens or controls on private recreational boaters,
and in particular will not seek to licence recreational boating
activities.
5. FISHERIES
Although comments on fisheries are not invited
at this stage, the RYA would like to request that it is consulted
on proposals that could affect any extension of inshore fisheries
management to recreational boaters who may fish or have lines
on board.
The RYA would also like confirmation that the
definition of "recreational sea angling" (para 7.26)
will not include the practice carried out by some cruising boaters
of trailing a fishing line while underway, or at anchor. Many
cruising boats carry a fishing line on board which may, or may
not, be put over the side while on passage and this is very distinct
from "recreational sea angling" where the primary purpose
is to catch fish. Similarly, the RYA would expect that recreational
boaters will also be exempt from any "bag limits" that
may be introduced.
6. CREATION OF
AN MMO
The RYA is currently neutral on whether or not
an MMO should be created. If the objectives of the Bill, once
agreed, can be achieved through, and by, existing organisations
then the Government should not create another body or layer of
bureaucracy without compelling evidence to show it is necessary
to achieve the objectives.
June 2006
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