Peter Stockdale wrote:

> It could be argued that driver of the average narrowboat over 
> 23ft in length, travelling on the average narrow canal would  
> not be affected on the grounds that speed of travel would be 
> reasonably expected to be less than seven knots.

It could indeed be argued, but it would be wrong.  See
http://www.dft.gov.uk/consultations/open/exceptionfromalcohol/annexa-dra
ftshippingalcoho1.pdf 

The exemption would apply if the ship (as the regulations term it) has
(a) a length overall less than 7 metres; and
(b) a maximum design speed not exceeding 7 knots

So to be exempted you have to meet BOTH criteria - i.e. be less than 7 m
long and a design speed less than or equal to 7 knots. If you meet one
criterion but not the other, you are not exempted from the limit. You
may or may not think that is reasonable, but that is what the proposed
regulations say!

Also, concepts of the average narrow canal and actual speed of travel
are irrelevant. As drafted the regulations would apply in all waters.
The speed criterion is the design speed of the craft, not of the
waterway it is used on. Design speed is a rather imprecise concept for a
typical narrowboat, but I imagine some of the overengined craft we see
on the cut these days could probably manage a good 7 knots given some
open water.

David Mack

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