Memorandum submitted by the United Kingdom
Major Ports Group (DMB 44)
The United Kingdom Major Ports Group is the
association which represents most of the major commercial ports
in the UK. Our nine members operate 41 ports which account for
some 70% of the cargo passing through UK ports. UK ports as a
whole handle 95% of the nation's international trade by volume
and therefore make an important contribution to the UK economy.
UKMPG welcomes the EFRA Committee's pre legislative
scrutiny of the coastal access provisions of the draft Marine
Bill and the opportunity to submit comments. Ports own and are
responsible for maintaining and operating a significant amount
of coastal land particularly on estuaries and therefore have a
considerable interest in the coastal access proposals in the draft
Bill.
UKMPG has no difficulties in principle with
the coastal access scheme set out in part 9 of the draft Marine
Bill and in the accompanying Natural England document. Port Authorities
already have a strong record of working closely with the relevant
authorities in planning and implementing good footpath provision
where this is appropriate and can be done without putting safety
and security at risk eg the work done by the Port of London Authority
(PLA) in negotiating access through terminals in Greater London
in connection with the extension of the Thames path national trail.
When Defra issued their original consultation
document last June UKMPG was concerned that that there was insufficient
recognition of the real practical problems involved in providing
access through operational port land. Allowing such access could
create significant operational, safety and security risks which
would greatly outweigh any benefits for walkers in being able
to take a coastal route through port areas. The security risk
is particularly relevant in the light of the additional measures
ports have recently had to introduce to strengthen security to
comply with new national and international requirements. We therefore
pressed strongly that in port areas the presumption should be
that harbour authorities would work with Natural England, local
highway authorities and others concerned to identify an appropriate
inland route round operational port land.
We are pleased to see that in the latest Natural
England document the special position of ports and other industrial
areas has been recognized and it is now proposed that the trail
will normally avoid operational land in the interests of safety
and security. Natural England say they will be working with site
managers in deciding the route of the coastal trail in the vicinity
of the port. The ports sector will participate constructively
in those discussions.
Our examination of the detailed provisions of
part 9 of the Marine Bill is still at an early stage but as far
as ports are concerned they appear to be consistent with Natural
England's approach described above. We shall want to be sure however
that the exemption provisions secured through the application
of schedule 1 of the Countryside and Rights of Way Act 2000 relate
not just to land which is in current operational use but also
to land which is being held for future port related development.
As was recognized in the Government's interim ports policy review
published last July and subsequently in the recently published
consultation paper on Port Master Plans, demand for port capacity
will grow over the next few years and this growth will require
a significant increase in capacity. Many ports have plans to expand
to meet this increased demand and it is important that the coastal
access provisions in the draft Marine Bill take sufficient account
of the need to safeguard future port development.
Richard Bird
Executive Director, United Kingdom Major Ports Group
May 2008
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