Mr. Derek Whelan:

The RCAG welcomes the new revisions made to the by-laws as a result of our submission and the submissions of other interested parties. The consultation process has been extensive and the decision by Waterways Ireland to extend it further was worthwhile. I hope that the outstanding issues can be resolved within a short period and we have a set of conditions and rules with which all concerned with the future of our waterways can live.

The proposal on construction and safety measures on boats is a new one not mentioned in earlier drafts and requires all boats using shore power - 220 V to 110 V - to fit a marine isolation transformer. As this will involve a substantial investment by boat owners, we request that a phase-in period of two years be granted before implementation. Toilet systems are required to prevent polluting matter passing into the navigation. We agree that this is a necessary condition to protect our waterways. Waterways Ireland needs to provide more facilities to assist boat owners in complying with this vital requirement. There is currently no pump-out facility for boats' holding tanks on the Royal Canal between Dublin and Mullingar, which is a distance of 80 km.

There are good reasons to allow activities that are traditionally held on our waterways to be exempted from seeking permission for every event. We note that three named organisations are listed in the new draft. As a group, we have held events on the Royal Canal for almost 50 years and we are surprised that we are not listed. The intention of the rule is clearly to cut down on unnecessary administration, but is it necessary to seem to favour some organisations over others?

Waterways Ireland is proposing that inspection reports by qualified marine surveyors be carried out on boats every five years. Boat owners are already required to submit such boat survey reports by their insurers every ten years, but we feel that this new requirement needs a phase-in period of two years.

While the proposal to drop general speed limits on towpaths and greenways is welcome, there are good reasons to retain the power to impose limits in local areas. In urban areas, there is now widespread use of electric bikes and scooters along our waterways and many of these are capable of speeds of 30 km/h or more.

In the interest of public safety, there should be some control exercised in areas designated as being at risk. While legislation is planned to place control on scooters and ebikes, this may apply to use on public roads only and not to towpaths, greenways, etc., which could be seen as exempt. It is important that Waterways Ireland retains the power to enforce controls in some local areas as needed.