The future of paddle boarding, kayaking or canoeing in Exmouth is at risk!
Important documents and templates at the bottom of this article.
The Exe estuary is one of Devon’s best-loved places to get on the water. On any given weekend you’ll see paddleboards, canoes and kayaks making the most of the sheltered stretches between Exmouth, Topsham and the Exeter Ship Canal. But a proposed change to how the Port of Exeter is run could, for the first time, hand the harbour authority the power to charge people simply for launching a paddleboard. Here’s what the Port of Exeter Harbour Revision Order means for paddlers — and why it’s worth speaking up.
What is the Port of Exeter Harbour Revision Order?
Exeter City Council has applied to the Marine Management Organisation (MMO) for a Harbour Revision Order — reference HRO/2023/00006 — covering the Port of Exeter, which includes much of the Exe estuary and the approaches to Exmouth. A Harbour Revision Order (HRO) is a legal instrument that updates the powers a harbour authority holds.
Much of what the Order does is uncontroversial housekeeping: it consolidates a patchwork of Victorian-era local Acts into a single modern framework and brings the Port into line with national harbour law. The concern for paddlers isn’t modernisation in general. It’s one specific provision.
The problem: Article 10 and charges on paddleboards
Buried in the detail is Article 10, which would create a power to levy the equivalent of ship, passenger and goods dues on craft within the port limits that are not classed as “ships”. The Council’s own documents give examples of what that covers — and they expressly include paddleboards, alongside things like jet bikes and jack-up barges.
In plain terms: for the first time, human-powered craft such as paddleboards, canoes and kayaks could be brought within a charging regime on the Exe estuary. That’s a significant shift from the way the estuary has always been used.
“But the Council says it has no plans to charge”
That’s true, and it’s worth acknowledging. The Council has stated it has no current plans to introduce paddleboard charges. But the objection isn’t about today’s intentions — it’s about the power itself. Once a charging power over paddlecraft is written into the Order, it can be used at any point in the future, and it would not need to go through the same public consultation again.
There’s a second point worth understanding. In correspondence, the Council has argued that many port users could already be charged under section 26 of the Harbours Act 1964. But section 26 applies to ships — and a paddleboard, canoe or kayak is not a ship. It is Article 10, not section 26, that would extend charging to human-powered craft. So the “you could already be charged” argument doesn’t answer the paddling concern; if anything, it underlines it.
Why paddlers should be concerned
There are strong, practical reasons to object to charges on human-powered craft on the Exe estuary:
- It would be disproportionate. A paddleboard needs no berth, burns no fuel, and makes almost no call on dredging, navigation aids or harbour patrols. Charging it the equivalent of commercial dues is out of all proportion to any cost it creates.
- It would be a barrier to access, health and wellbeing. Paddlesports are one of the cheapest, most accessible ways for people to get outdoors and active. A charge — or even the hassle of one — would put people off, especially casual, occasional and younger paddlers.
- It would be hard to administer economically. Recreational paddlecraft are unregistered, transient, and launched from dozens of informal spots around the estuary. The cost of identifying, billing and enforcing dues against them could easily outstrip any money raised.
- It raises a safety concern. Charging to launch could push paddlers towards unmanaged, less safe access points, or discourage them from engaging with the harbour authority at all — the opposite of what a safety-focused Order should want.
- It sits badly with the estuary’s protected status. The Exe estuary is designated as an SSSI, SPA and Ramsar site. Low-impact paddling is exactly the kind of use that should be encouraged, not financially discouraged.
If you’ve had a letter asking you to withdraw
People who objected to the Order during the consultation are now receiving letters from the Council’s solicitors, Ashfords LLP, inviting them to withdraw their objection. These letters typically give you six weeks to respond, after which your correspondence is passed to the MMO.
You do not have to withdraw. Withdrawing means your objection is no longer counted when the MMO decides whether objections are substantive. If you’re happy with your original representation, the simplest thing to do is reply confirming that you maintain it, quoting reference HRO/2023/00006, and copy the MMO at harbourorders@marinemanagement.org.uk. If nobody replies, the objection risks quietly falling away — a short, clear “my representation stands” keeps it on the record.
What you can do now
- If you objected, hold firm. Reply to the letter to confirm you’re not withdrawing, and say briefly how you personally use the estuary — a reply in your own words carries far more weight than a form response.
- Spread the word. Share this with other paddlers, clubs and local watersports groups so the strength of feeling is visible.
- Contact your local councillors. Let your ward councillors know that access to the Exe estuary matters to residents.
Where substantive objections remain unresolved, the MMO can be asked to make a determination, or a public inquiry may be held. In other words, objections that stay on the record genuinely count.
Keeping the Exe free to paddle
Nobody is arguing against a well-run, safe, properly maintained harbour. The issue is narrow and specific: whether a paddleboard, canoe or kayak — quiet, clean, human-powered craft that have always been part of the fabric of the Exe — should be brought within a power to charge harbour dues. Public policy should be making it easier for people to enjoy the water, not building in a mechanism to charge them for it.
If you paddle the Exe estuary, this is your water too. It’s worth a few minutes to make sure your voice is on the record.
Useful links: the MMO guidance on objections and representations, the MMO harbour orders public register, and Exeter City Council’s Harbour Revision Order page.
Documents
Consultation response letter (PDF Document)
Response letter template, email template pack & instructions (PDF Document)