The article refers to “the rise in safety incidents since the ferries arrived”. This statement is incorrect. There has not been an increase in ferry related safety incidents. In fact the opposite is true.

All reported incidents are investigated by harbour staff which can be informed by statements taken from those involved, witnesses, and through viewing CCTV camera footage, including for ferry incidents, recordings from the ferry system. A record is kept of all findings and a summary report published on the LHC website and in our Annual Report (page 4).

The report classifies the findings under 17 categories. Those relevant to ferries are:

Collision with Ferry
2008 3
2009 0
Difference -3

Impede Ferry/Other craft
2008 23
2009 19
Difference -4

Near miss with Ferry
2008 8
2009 7
Difference -1

Wash Ferry
2008 5
2009 9
Difference +4

Total 1st Jan to 31 Dec
2008 39
2009 35
Difference -4

This is clear evidence of a reduction in incidents. In addition, a more detailed report has been presented to the annual meeting of the River Safety Group made up from representatives of the leisure users and Wightlink. This forum ensures that there can be a full debate of any issues arising and gives an opportunity for agreement on ways that safety may be further enhanced.

This process continues from year to year and is complimentary to the extensive risk assessment trials conducted by BMT Isis to ensure the safe introduction of the new ferries.

The above should make it clear to all concerned that the safety of all river users is a very high priority for the Commissioners and that we are working hard to maintain and increase the safety of navigation.

P.T. Griffiths

Chairman – LHC
23/2/2010

Wightlink have defied the will of all the regulators in deciding to introduce their new ferries before the environmental concerns have been resolved.

They have taken this action despite repeated requests from the LHC and their previous undertaking not to do so. They claim that they are justified because of the needs of the Isle of Wight, but the real problem that has lead to this situation is Wightlink’s determination to design and build ferries in advance of meaningful consultations with all the regulators. As a result, all subsequent consultations have taken place against the commercial necessity on the part of Wightlink to introduce ferries that had already been paid for.

We have once again requested Wightlink to desist from this action, and are contacting all the relevant Government Departments for support in preventing it.

The ruling concludes that Wightlink’s decision to introduce the A Class ferries on 25 February 2009 was unlawful, thereby fully vindicating our persistent requests for them not to do so. It now remains to be seen what action government will take to resolve the present unlawful situation.

Peter Griffiths

Chairman – LHC

16th February 2010

The mission of the Solent Protection Society is to ensure the ecological and environmental well-being and wise management of the Solent area, its natural beauty and amenities, so that these may continue to be enjoyed by present and future generations.

The Society considers that the proposals for reconfiguration of the inner harbour at Yarmouth, as currently formulated, do not reflect the objectives of the mission statement in many respects. The Society is concerned to ensure that all the proper procedures related to the environmental matters are being or will be carried out. There is also concern that some of the operational aspects of the new proposal will lead to a significant loss of amenity, both with respect to the general appearance of the Harbour, and to its wide availability for enjoyment by present and future generations.

Solent Protection Society’s response to the Yarmouth Harbour Board gives the Society’s view on the impact of designations, including Habitats Regulations; flood defence; aesthetics; capacity for yacht moorings; safety and alternatives to the proposals.

Solent Protection Society Mission statement

The mission of the Society is to ensure the ecological and environmental well-being and wise management of the Solent area, its natural beauty and amenities, so that these may continue to be enjoyed by present and future generations.

SPS interest

The Society considers that the project as currently formulated does not reflect the objectives of the mission statement in many respects. The Society is concerned to ensure that all the proper procedures related to the environmental matters are being or will be carried out. There is also concern that some of the operational aspects of the new proposal will lead to a significant loss of amenity, both with respect to the general appearance of the Harbour, and to its wide availability for enjoyment by present and future generations.

The Society seeks to support local communities: The Yarmouth & Thorley Community Plan states "The emphasis within Conservation Areas is on ensuring local character is strengthened, not diminished, by change. The area was designated in 1969 in recognition of the special architectural and historic importance of the town." While this constraint does not arise out of the Harbour Authority’s statutory powers and duties, it certainly gives a clear guide to the Authority.

Environment

Impact of designations

It is quite clear that the rearrangement of piling and pontoons within the Harbour constitutes a " plan or project" within the context of the Habitats Regulations. In the Society’s view, an Appropriate Assessment under the terms of habitats regulations would be required. To date we see no evidence that such an Assessment is planned.

A further requirement of the Habitats Regulations is that a plan or project is considered alone or in combination with other plans or projects. Inevitably there will be projects in the very near future relating to flood defence that will closely relate to the rearrangement of the Harbour. These will arise from the publication of the second shoreline management plan which is imminent. SPS believes that, as an absolute minimum, the Harbour rearrangement project should be considered in combination with these flood defence aspects. Indeed, redevelopment of the harbour may have considerable flood defence benefits to the local community if planned in an integrated way.

At a more general level, the harbour may be a separate legal entity but it is indivisible from the town on which any development in the harbour will necessarily impact directly . Therefore, the town and harbour should be seen as one unit. Unilateral activities in the harbour which could damage the overall atmosphere should be avoided.

It is clear from the description of the project that the commissioners envisage greater use of the upper Yar. This modification to the operations and activities must be considered within the terms of the scheme of management of the Solent European Marine Site. Evidence suggests that the upper Yar is one of the few places in the whole of the Solent where saltmarsh is accreting rather than retreating. It therefore represents an important ecological asset, and one that should not be put at risk as a result of increased activity without proper precautionary measures, including monitoring, being put into place.

There may also be constraints and procedures to be applied arising out of the AONB status, and Heritage considerations including the impact of any proposals on the setting of Yarmouth Castle.

Flood defence

Revisions to the shoreline management plan are due to be published shortly, and it seems inappropriate to proceed with a major reorganisation of the Harbour without taking the requirements of the shoreline management plan and associated impact on flood defences into account.

Aesthetics

A significant part of the charm and character of the Harbour is the wide mix of vessels that use it, particularly the more traditional types of vessel such as long keel gaff rigged boats with bowsprits. Such vessels find it much more difficult to operate within a marina environment, especially one where the tides can run strongly across the berths. Thus quite apart from the manoeuvring and safety aspects, on which the RYA and the Cruising Association are better qualified to comment, the proposed new Harbour layout will undoubtedly change the mix of visiting vessels with consequent effect on the general ambience of the harbour.

While purely commercial considerations are beyond the scope of SPS interest, a significant change in the balance of the charging structure (such as would be implied by the switch to all walk-ashore facilities) would significantly reduce the accessibility and affordability of this harbour to a wide range of the public using the Solent, in particular local residents who have permanent harbour moorings.

Whilst there is clearly a balance to be achieved between the needs of the local economy and the protection of this unique area, any threat to damage it by one organisation should be resisted unless it can be shown that the benefits outweigh the detriment to all other interests. The perceived benefit to a few yachtsmen who would prefer to walk ashore and the financial gain that this brings to the Harbour Commissioners clearly do not outweigh the loss of amenity to the greater number of residents and visitors.

The Society endorses the views expressed by Mr Ben Collins relating to the impact on Yarmouth’s heritage architecture.

Capacity

SPS is concerned about the general reduction of capacity for yacht moorings at destinations within the Solent area. Threats to capacity exist at Keyhaven Lymington Bembridge and Chichester (East Head). The Society therefore finds it disappointing that the proposed project contains no potential for capacity increase
To achieve a capacity increase without harming the ambience of the town is difficult, but the possibility of developing an outer harbour would locate such a development as far as possible from the current harbour, and may even allow the character of the existing harbour to be substantially unchanged,

Safety

SPS supports the comments of Mr. Granger in relation to compliance with the latest codes of practice for the construction of yacht harbours.
With regards to other operational safety aspects, the Cruising Association, Royal Yachting Association, and local yacht clubs are better placed to comment

Alternatives

Consideration should be given to the no-action alternative. It is probable that by one means or another revenue from the operation of the ferry could be returned to previous levels, and possibly increased. It could well be that the fear of long-term loss of revenue from ferry operation is overstated.

We are aware that an outer harbour project that encompasses the area of water currently occupied by the moorings outside the Harbour to the west of the pier and main entrance has been considered.

In the light of the various concerns expressed above, it would seem that solutions such as the outer harbour should be investigated further. Such a scheme could allow a significant increase in the capacity of the Harbour; address the manoeuvring aspects of the present Harbour and the current Harbour redevelopment proposal; and may integrate more easily with other plans or projects such as the need to enhance flood defence. Significantly, such a scheme could substantially protect the character of the present inner harbour, and could incorporate necessary remedial works on the existing breakwater.

While it is recognized that the cost of construction of a new mole would be high, the regeneration potential of a new Harbour facility and its contribution to the general economy of the Isle of Wight represent such an important consideration that such a project should be examined closely before proceeding with the present proposal, including an assessment of public support for such a radical proposal. It is, however, recognised that obtaining environmental consents for such a project would rest upon it being clearly demonstrated that such a project generated a net environmental gain.

Environment
There continues to be concern about the introduction of the new ‘W’ Class ferries and their potential effect on the protected local environment.
Over the summer and autumn period, Wightlink’s environmental consultant has been undertaking monitoring in the river to a methodology agreed with Natural England to identify if there have been any significant short term effects. It is currently understood that no significant short term effects have been identified. Long term impacts will be monitored through a Bathymetric survey programme.
At the time of writing it is understood that Wightlink have submitted a mitigation proposal for a habitat replenishment scheme to Natural England following discussion with Natural England, regulators and a number of other interested parties.
There also remains considerable uncertainty on whether due process has been followed under the Habitats Regulations. This is the subject of a Judicial Review
which has been brought by some local residents. The outcome is anticipated early in the New Year.

Peter Griffiths
Chairman – LHC
16th December 2009