Memorandum submitted by the British Marine
Federation (DFWMB 30)
I am delighted to submit the following memorandum
in response to your call for comment on the inquiry, Draft
Flood and Water Management Bill. We welcome the publication of
the draft Bill and its proposed measures to decrease the future
risk of flooding in the UK.
INTRODUCTION
The British Marine Federation is the trade association
for the leisure boating industry, representing around 1,500 member
companies. Our members provide the boats, equipment, facilities
and services that enables 3.2 million adults to enjoy their
recreation afloat on the coast and inland waterways of our country.
The BMF also operates the London and Southampton International
Boat Shows via its subsidiary National Boat Shows.
Our industry is comprised of small and medium-sized
enterprises, with over 98% of companies employing less than 50 people.
In total, the UK leisure marine sector directly employs over 35,200 FTE
and generates an annual revenue of £3.1 billion, of
which 35.4% represents export sales. Over recent years the leisure
marine sector has been recognised by Government as a manufacturing
success story and a growing and valuable contributor to the UK
economy.
The BMF considers the free navigation of coastal
and inland waterways as a key component of the financial success
of its members and our goal is to ensure that any measures proposed
in the River Basin Management Plans are proportional and have
little or no negative impact on marine businesses, in addition
to ensuring the environmental sustainability of the UK's waterways.
FLOODS 2007—
HOW THE
LEISURE MARINE
INDUSTRY WAS
AFFECTED
While flooding can have a devastating effect
on any business, the risks for those operating in the marine sector
are significantly higher due to their proximity to the water.
Whether a business operates a waterside boatyard, marina or hire
boat fleet, all these business models can be destroyed by large-scale
flooding. Not only can factory floors be washed away but vital
seasonal trade can also be destroyed when tidal forces prevent
navigation on the waterways and depress the tourism market.
Many of our members experienced this first hand,
during the devastating floods of 2007 where the expected
income of hire boat fleets was reduced by 70% or more with countless
other manufacturing facilities suffering severe damage.
The BMF is committed to supporting DEFRA in
its efforts to prevent flooding of such a scale occurring again
and broadly supports the recommendations of the Pitt review. However,
we are also conscious of the need for a balance between not only
preserving the ecological status of the waterways but the best
possible business conditions for our member companies. We therefore
advocate a Bill that adequately takes into account the needs of
the Leisure Marine Industry and implements a policy approach that
has as little negative impact on our members as possible.
Has the Government analysed the effects of
the draft bill adequately, and has it taken sufficient account
of consultation?
As we have mentioned, large scale flooding has
the potential to cause significant damage to marine business,
both in terms of their infrastructure and their business model.
Expand on these two strands?
The BMF notes with interest the lack of impact
analysis contained within the Bill's accompanying consultation
document that is pertinent to marine businesses. This is particularly
concerning as the explanatory material makes no reference to any
potential impacts on both waterside businesses (other than protecting
them from flooding) or the leisure marine sector, despite their
increased exposure to risk. Areas, such as water morphology, are
mentioned as areas where improvement to water ecology and security
can be made (where water flow and ecological status can be improved
by removing artificial alterations as defined by the draft bill).
However, the supplied impact assessment makes no mention of the
fact that many artificial alterations to waterways serve the purposes
of supporting navigation on the waterway and their removal would
result in making many areas inaccessible to larger craft and,
in turn, undermine the business models of many inland hire boat
fleet operators. Water straightening as well as marinas would
all be subject to such measures as they are artificial modifications
to waterways.
We would like to highlight to the committee
that while the Bill incorporates much needed reforms to the United
Kingdom's outdated policies in this area, there is insufficient
recognition or understanding of how the proposed provisions will
affect our members and all inland leisure marine businesses. It
should be noted that these businesses provide crucial employment
for local people as well as generate tax revenue from an annual
turnover of over £3 billion
Additionally, we have noted the inclusions of
increased enforcement powers to tackle the problem of misconnections.
While the consultation document rightly identifies that the vast
majority of properties that affect such discharges are residential,
it does not consider the effect that the proposed remedial regulation
will have on business premises.
"…Those causing misconnections
are currently either unaware of the misconnection and-or have
no incentive to remedy the misconnection. The problems caused
by their misconnections impose a cost on the general public in
terms of water pollution and an increase in water company bills."
(I will reference this appropriately before submission)
This observation, within the impact assessment,
is key to understanding the possible difficulties businesses will
face if stricter enforcement of misconnection repairs is to be
more strictly enforced. The BMF is well aware of the ecological
impact misconnections can have and our Environmental Code of Practice
identifies and suggest ways in which such issues can be corrected.
However, it is right to say that, much like home owners, business
proprietors are frequently unaware of misconnections on their
premises - but act quickly to correct them once identified.
However, given the unprecedented market conditions
that many of our businesses are now being forced to endure, an
unexpected expense such as drainage repair may result in significant
financial hardship, particularly for very small businesses. The
BMF strongly believes that the Government must support business
with a package of financial measures and grants to defer the cost
of such work. This would permit businesses to work with the proposed
enforcement powers rather than simply being given an obligation
of compliance that they cannot meet. We believe that it is highly
desirable to avoid the unnecessary draconian steps of criminalizing
a business wherever cooperation can yield more positive results
for both the owner and the Government.
The BMF also believes that by expending funding
on incentivising business property owners to comply with regulations,
rather than incentivising local authorities to pursue prosecutions
for non-compliance (as is mooted in the consultation material),
the positive effect on the environment will be far greater.
Next Steps
The BMF would be delighted to provide any further
evidence to committee, should you require it, and is also available
for oral evidence. We look forward to further involvement in your
inquiry.
British Marine Federation
June 2009
| 
