Daventry Town Council Objects to New Canal Arm
Posted: Wed, 11 Jan 2017 14:33 by Daventry Town Council
The revised scheme for the New Canal Arm in Daventry Town is to be considered by Daventry District Council Planning Committee tonight @ 6:15pm.
Daventry Town Council submitted the following objections and concerns in October 2011 and will also be submitting a further representation at tonight's meeting.
"Daventry Town Council is gravely concerned in relation to the apparent lack of research and assessments carried out to support and justify a planning application that has significant impact on the environment, economy and infrastructure of Daventry Town.
Visual and Construction Impact
Landscaping is a major concern, with the difference in level along the length of the canal, in terms of the current and possible uses of the adjacent land from mixed farming through to housing development. The development will cut across the established vista as it is in effect "Development in open countryside" (PPS7) and that is a resource in itself and will encroach onto valuable agricultural land.
The consultation process proclaimed that the canal would generate large numbers of visitors to the town; however the plans do not provide any facility or facilities to cater for the increase in visitor numbers. For example, to accommodate more visitors to the town, the town will need to provide an improved road structure, access from existing or future roads, car parking, toilets and facilities which will inevitably impinge on the overall scene of the canal development.
The construction process will have a major impact along the entire length of the proposed canal and beyond. Long term loss of natural habitats, the uprooting of hedgerows and trees, earthwork spoils, construction equipment, and scarring will take a long time to heal and return to maturity.
Currently the land identified is traversed with footpaths and designated open access headland, the introduction of a canal will compromise many of these paths, in particular the existing country park circular walk. We would also like to draw attention to the loss of facility for users of the Country Park, whereas the canal may offer a small amount of protection to the country park, it also creates a barrier restricting access to the park before, during and after construction.
It is important that existing links from the town and Southbrook estate are not lost where the current paths link with the underpasses to and from the Country Park. Bridging should be sympathetic to all residents needs. Tow paths should conform to British Waterways criteria, be wide enough for multi-purpose use i.e. cycle/walk and tow paths should never go over bridges at any point.
Any construction along and adjoining the length of the canal must be congenial to the character and appearance of the Canal Conservation Areas. It is vital that the obtrusive elements, bridges, locks, ponds, pump housing and canal walls are produced with the aesthetic in mind. Concrete block edifices and a concrete trench are not conducive to the environment and surrounding conservation area.
Conservation and Ecology
Daventry Town Council recognises that canals are in general viewed favorably in terms of acting as green corridors for wildlife, but it would like to draw attention to the fact that this predominantly relates to existing waterways. Existing canals are mature and enhance the environment. A new canal does not have that maturity, and as history shows it has taken over 100 years for canals to become attractive to the populace.
Daventry Town Council would like to highlight that canals are not comparable with rivers and have concerns in relation to water quality. Measurements assessments RE4 and RE5 under the River Water Classification scheme struggle to meet the required levels for the EU Water Directive because of their hydrology and usage (see "Management of canal systems….. Swanson, Lunn, Wallis Herot - Watt Uni 2004).
Canals sustain the "ordinary" in terms of wildlife and studies of canal development schemes throughout the country prove that claims that canals harbor otters, kingfishers and the more exotic species of English wildlife are ill-founded (Worcestershire Biodiversity Action Plan 2008, Greater Manchester Canals Habitat Action Plan 2003, River Trent to Cotgrave Green Infrastructure Study).
In fact, many other feasibility studies have highlighted the negative impact canals have on the environment and ecology apart from disturbance e,g rats feeding on fishing waste, overfeeding of wild fowl, introduction of invasive species, littering and pollution spills etc.
Daventry Town Council would question the purpose of creating a new canal when the Country Park already provides a major green link to the town. The Country Park reservoir provides an excellent habitat along with its surrounding wooded areas, adjacent farm land, feeder streams and ditches; there is also an existing 'run off' leading directly from the park which joins into the Grand Union canal providing and aquatic link. The existing canal by default is also in close proximity to this mature and natural green environment. On this basis a new canal will provide little extra habitat because that habitat is already there. The construction and possible extensive use with its human impact will in fact reduce the green link and the construction will undoubtedly have a massive impact on a mature and functioning eco landscape for years to come (PPS9, PPS7).
The canal is supposed to promote conservation and a greener environment, but with the predicted increase in visitors, and subsequent increase in cars, together with pumping equipment to maintain levels does this not contradict Daventry District Council's objective to reduce car use and reduce the carbon footprint?
There are no projections of visitor numbers or what enhancement it would bring to the town.
If the canal is approved and constructed it is essential there is an agreed regime in place for sympathetic maintenance programs to minimize disruption, tow path clearing pesticide/herbicide use), bank maintenance, and most importantly dredging and disposal of possible toxic material accumulated in the silt.
There also needs to be agreements and adequate systems in place to avoid taking excess water from the existing natural and made systems, along with flood prevention measures to ensure existing species are not compromised by drought or flood. It is also vital that pollution control measures are included. There is an obvious risk from spills and accidents in the basin to enter the canal, reservoir and surrounding waterways. The pumping system must be failsafe, over engineered and guaranteed into the future.
The Council is concerned that there appears to be no accessibility to the locks for maintenance and no parking near the locks for engineering work which would need to be undertaken at regular intervals and no indication of public parking for those wishing to walk along the canal.
Concerns have also been raised in respect to mooring on the canal. If there are to be moorings, what would be the limitations? This would also need monitoring to avoid long term, unauthorised mooring.
Water and Hydrology
The Environment Agency in the 'East Midlands State of Environment Report' states that good quality water is essential and East. Midlands ( Daventry inc) is amongst the driest in the country and the increasing population is putting ever greater pressure on resources. Our immediate area is already over licensed for abstractions which means pressure is already built in and we are advised that we should "use water wisely"
The soil, drainage, topography geotechnical study should be extensive and take into account worst case scenarios. It must be noted that this construction is in close proximity to current and future housing/business developments and the unexpected should be planned for. The proposed development is impinging on a reservoir and canal and hydrological testing should be extensive to avoid major flood or water loss scenarios including hydraulic gradient problems
The Town Council would like to highlight that restriction on canal use has been in place locally between Watford and Napton over the last few years and are extremely concerned that even if the proposed Daventry arm maintains levels without affecting other watercourses, this will negate its economic effect.
The proposed canal will inevitably have an effect on the water and general hydrology of the area. The canal will link into the British Waterways (BW) Grand Union - British Waterways state it is not a land drainage authority and that storm water discharges do not assist in dry periods but can cause severe problems in wet conditions. In carrying out research the Council would ask that the planning authority consider the development as a dead end navigation coming under the provisions of the Reservoirs Act 1975 and if so; only be built in accordance with those provisions.
In order to fill the canal, water has to be taken from either the Grand Union Canal or the reservoir. The reservoir is at an all time low currently and even heavy rain for a prolonged period will not address the problem, as water will need to be pumped out at regular intervals to keep the canal levels high.
Reduction of the level of water will have a great effect on the ecology of the reservoir and, once disturbed, it will not recover.
There has been no mention of who will pay for the water resource for the canal or the cost of the pumping required on a regular basis from the watersource to the proposed marina (waterspace). No calculation has been mentioned of how much water would be required to fill the canal and maintain the lock systems.
What is the cost of 'breaking into' the Grand Union Canal?
Should permission be granted for a large scale housing development to be built in close proximity to the canal, what preventative measures would be put into force to ensure this development would be safe from flooding if there were to be a breach in any part of the canal or lock systems?
Daventry Town Council are extremely concerned and deem it ESSENTIAL that the developer heeds the advice of British Waterways and follows the Surface Water Discharge – Guidance in accepting new discharges, and the Sustainable Urban Drainage (SUDS) CIRIA pub. C523 Best Practice Manual and also ref PPS25.
The council would like to draw attention to the 'Code of Practice for Works Affecting British Waterways and their advisory document 'Getting Started' together with other studies from canal regeneration projects. These reports carry out studies of usage and revenues emanating from specific projects. This information is not available and therefore makes it extremely difficult to consider and respond appropriately.
The Council would like assurances that plans are in place for the future finance of a resource to fix any problems caused both during and after construction is complete.
No mention has been made of how this project would be delivered. Funding does not appear to be available and the burden must not be put on the people of Daventry for years to come either on its construction or ongoing maintenance. A timescale is not in place and in a period of economic cutbacks one has to wonder if the project would ever be viable.
From the information available, the Council does not feel the canal is deliverable as a project, the lock system requires pumping and there are no pumps. The depth of the canal is specified at four foot, making it vulnerable to low water scenarios especially when un-dredged in the future.
The Council would like to question the lack of a robust study of viability. The Council does not consider a small informal survey at a visit to the Crick Boat Show the basis of a business plan based on canal usage.
The Council would also question the use of comparisons with Apsley in Hemel Hemstead, as a flagship for growth statement, the unsubstantiated 'opportunities' put forward by Niel Kemble of Hyder – B.W workshop 2007.
The Town Council is extremely concerned in relation to the funding of the canal. The developer has stated that taxpayers' money will not be used but goes on to imply S106 money will contribute to the project and sustainability of the project. The Town Council emphasizes that S106 is taxpayers money and the regeneration potential is minimal from this project and in view of the current economic climate, the project may no longer be feasible and in the public interest.
The Council are concerned that the draft S106 heads of terms for Middlemore sites 8 &9 west, would indicate a contribution of approximately £300k has been earmarked for the waterspace. Does this include the canal arm? And can Daventry Town Council influence the use of these S106 monies?
The Council would like to highlight the lack of funding detail and would suggest if S106 monies were withdrawn the only funding available would be minor waterways grants and/or private investment.
The Town Council would ask that full funding be verified to ensure the project is completed and can be sustained. It would be a planning disaster, to begin a project of this magnitude and not be able to complete of sustain it in the future.
The Town Council has concerns in relation to who is taking responsibility for the project and are concerned that there would appear to be no guarantee that if started it will be completed and if completed who will manage and maintain the facility in perpetuity.
The Town Council would like to highlight that British Waterways have, to date, shown no inclination
This is not an ordinary development, a canal is expensive to run and there is no revenue and an abandoned non functioning canal could be a disaster for Daventry and there are several questions regarding responsibility and funding – the canal itself, the towpaths, the water system, moorings, lock construction and maintenance, bridges.
The locks need to be constructed with high quality materials – who will decide on this quality and would it comply with British Waterways standards?
The pumping system must be maintained, a silt dredging program must be in place, the tow paths need constant work, the locks will need maintaining as will bank erosion, Failure on any of these factors could have massive impacts on the environs of the canal.
It is imperative that moorings are controlled to stop shanty towns developing , these not only block the waterway but can be unsightly, stop people using the tow path and can lead to litter and fowling of the locality.
The Town Council is of the opinion that the standard of the planning application is poor and the work on feasibility both in terms of the constructional and economic viability is lacking and gives consultees little to work with to make considered decisions.
The Council is extremely concerned that the funding streams are not available and the project will not be sustainable and the public should be consulted on the use of any public funds aimed at building this canal and likewise for the running of the canal.
The council would also like to comment on the quality and equitability of the consultation process and questions the interpretation of the results.
The consultation should have informed the public of possible negatives in cost benefit analysis format and also included questions of public funding. The consultation gave a vision and much of that vision has now changed. (There is now no iconic boatlift as per Daventry District Council website 2010 consultation - It is likely that there will be 7 locks over the length of the arm to accommodate a level difference of 20.5 metres, although a flight of 4 of the locks may be replaced by a boatlift that would be an opportunity to create a tourist attraction of regional and perhaps national importance. A boatlift would also reduce water usage on the canal allow
quicker transit along the canal arm for boaters and, as a tourist attraction and leisure destination, could provide further opportunities for employment. There are a number of design proposals for a Daventry boatlift.)
The consultation gave no evidence of economic regeneration, the green nature of the project was over emphasized and no data supplied to support the statements.
The emphasis of the consultation was on marketing and selling an idea. The canal was linked to the waterspace and infrastructure developments but in reality we have two separate planning applications, each reliant on the other to make the project feasible.
The consultation did not promote the generation of considered responses providing useful feedback into the planning process. The results of a parish poll were ignored and non-negative responses were presented as positive results. The results presented were only on the margin of public acceptance and note; documentation presented in the planning pack has a number of negative items in the positive column.
The consultation has a duty to be fair and reasonable and must be seen to be acted on.
Daventry Town Council has taken time to research and consider the planning application and asks that their comments are considered and concerns are responded to alleviate fears that this proposal has been ill-conceived and needs greater research and more assessments to support and justify the approval of this planning application."