Mooring Guidelines Consultation 2016
Below is our response to the PLA Moorings Guidelines Consultation
OPLAC/iWash Response to the PLA consultation on their Houseboat Mooring Guidance
1. We are concerned that this document has been referred to by the PLA both as 'guidance' and as 'a code of practice.' Also the documents refers to "the requirements of this guidance"; It is not clear if the guidance is advisory or mandatory. We believe the PLA should urgently clarify whether the guidance will, if it is not already, ever become a code, with the ensuing inspections, certifications and enforcement, possibly resulting in the removal of River Works Licences from residential houseboats. It is also unclear if wash complaints will be discarded or treated differently depending on whether the complainants are thought to be in compliance with the guidelines or not. Failure to clarify the above points will encourage the view that this is, at worst, a cynical exercise to clear a 'super highway' for clippers along the river, free of troublesome houseboats. We also note that the document itself introduces meeting the guidance as being a pre-requisite for obtaining new River Works Licences.
2. Related to this we are concerned that your guidelines/code may become retrospective - affecting houseboats that have been happily moored in their locations for decades without wash problems. We would like the PLA to acknowledge that houseboat moorings that predate the Clipper wash issue are in an entirely different category to new houseboat developments.
3. We think that whilst guidance and advice for the victims of wash is welcome, the PLA's main aim should be directed to ensuring that the perpetrators do not create the inconsiderate wash in the first place. Or that if they do, they know they will be prosecuted. It is inappropriate speed that causes wash issues and this must be your primary focus of operations management for the safety and comfort of all river users.
4. We would like to see a companion and comprehensive set of PLA guidelines to be published for vessel operators including for timetable setting, acceleration and deceleration and maximum speeds according to location. Such guidelines should also include the type of vessels that are suitable for high speed or high wash operation, with research undertaken by the PLA into this if necessary and not done already.
In particular, on a strongly tidal river where flows can reach 8 knots in places, we would like all vessels to have a means of measuring their speed through-the-water. It is astonishing to us that this is not a mandatory requirement for the speed limit exempt vessels such as the Clippers and even more astonishing that none of the Clippers have this basic equipment. Any companion set of guidelines to vessel operators should remind them of the PLA’s longstanding bylaw 57 on wash:
57. WASH AND DRAW-OFF
Except in an emergency, the master of a power-driven vessel must, at all
times when underway on the Thames, ensure that the vessel is navigated at
a speed and in a manner such that any wash or draw-off created by the
vessel must not compromise:
a) the safety of others using the Thames, the foreshore, adjacent piers,
moorings, berths, jetties or other facilities; or
b) the integrity of the foreshore.
We also note that the Clipper operators, by omitting through-the-water speed measuring devices from their craft, appear to be in breach of the PLA's existing short guidance on wash section (a) below:
PLA GUIDANCE ON WASH AND DRAW OFF
This guidance on Wash and Draw off is produced in support of Byelaw 57.
Master of a power-driven vessel, in determining safe speed in respect of wash or draw-off, should take a number of factors into account, including but not limited to:
a) the speed of the vessel through the water;
b) whether the vessel is accelerating or decelerating;
c) the hull form and wash and/or draw-off characteristics of the vessel;
d) the manoeuvring characteristics of the vessel;
e) the charted depth and height of tide;
f) the strength and direction of the wind;
g) other marine related activities underway on the Thames, the foreshore and/or adjacent berths, moorings and facilities where the safety of persons may be compromised by unacceptable wash or draw-off;
h) the content of current navigational information broadcasts made by London VTS in respect of locations and activities where vessels are requested to proceed with caution or at slow speed; and
i) the density and type of vessel traffic in the area and the potential for the build-up of a cumulative wash and/or draw-off effect.
We believe such comprehensive guidelines are even more essential given that the PLA specifically licence the Clippers and other vessels to breach the 12 knot speed limits and reach speeds of 25 and 30 knots.
5. We have found some of the guidelines rather ill-thought through. For example, 6 lines, doubled, of minimum 40mm polyprop has a breaking strain of 1.7 mega Newtons - the same as 6 Jumbo jets taxiing at full thrust. Furthermore the guidelines do not differentiate between:
· locations along the tidal Thames
· the size of vessels
· the layout of vessels within groups of vessels
· the site specific factors at particular moorings such as river bed or mooring infrastructure.
We do not believe that any existing boat on the tidal Thames complies with the minimum guidelines. Because of all this we suggest the PLA urgently apply their guidelines themselves to some volunteer houseboats so as to get real world and practical experience. It would be a small cost for the PLA to supply and fit their recommended ropes and fenders. We think this exercise would be much more valuable for all of us than a paper consultation and ideally should precede such a consultation in any event.
6. Re. "The waterway is defined as Category C waters by the Maritime Coastguard Agency". As you know OPLAC do not believe that the entire tidal and semi tidal Thames should be 'Cat C'. We doubt there have ever been naturally occurring waves of 1.2 metres anywhere above Wapping. It is disingenuous to use this existing (and we believe erroneous) categorisation to justify excessive, inconsiderate and dangerous man-made wash on the tidal Thames. This paragraph should be removed from the guidance. In any case wash is very different to natural waves and can be much more destructive at lower wave heights. On the tidal Thames wash has regularly caused damage to houseboats, natural waves never have as far as we are aware.
7. Some consideration needs to be given for the need to move vessels quickly in the event of an emergency, e.g. fire or an adjacent vessel sinking. 12 lines of 40mm+ polyprop per boat would not make this easy.
8. Driftwood mixed with wash at moorings can be a dangerous combination. 'Driftwood' can include gas bottles and long tree trunks which inevitably penetrate between vessels and their moorings no matter what mooring equipment is used. Inconsiderate wash can make this dangerous. We suggest the PLA urgently direct attention to removing more driftwood from the river near residential moorings where there is known to be a wash issue.
9. We think it is important that the PLA are seen to be independent guardians of the river. Therefore particular care need to be taken to be even handed when publishing guidance or codes of practice. This is especially so when the matters concern individuals living on the river counterpoised to large profit making organisations. To use an analogy, it is not acceptable for the police to tell victims of burglary that they have to fit security shutters and double locks whilst allowing burglars to continue unheeded. In fact we go further - even handed cannot mean treating victims and perpetrators evenly. We would like to see the PLA pursuing the wash perpetrators more than the wash victims.
OPLAC Organisation of PLA Customers