Kennet and Avon Boating Community Website

Canal & River Trust’s consultation on future boat licence pricing proposes to impose higher fees for boats without a home mooring. Please oppose this attack on our community by rejecting it in the consultation questionnaire! The consultation runs until 4pm on Thursday 6th April 2023.

This is at least the fourth time that BW/CRT has proposed to increase fees for boats without a home mooring. British Waterways, the predecessor to CRT, attempted to do so in 2002, 2005, 2008 and 2017. Each time before it was defeated due to strong opposition. We need to make sure it is defeated again. We believe it would be unlawful for CRT to do this, because Section 17 of the British Waterways Act 1995 makes it clear that there is one licence or “relevant consent” that can be held either with or without a home mooring. In the consultation, CRT also proposes to increase the widebeam surcharge. You will probably have received a link to complete the consultation questionnaire online. It is possible to complete the questionnaire by phone. You can contact CRT to do this on 0303 040 4040.

When responding to the consultation please pick the following option at Question 9:

Retaining the current licence fee structure based on the length of the boat and the current surcharge based on boat width. An increase would be applied evenly to all licences at a rate above annual inflation (CPI) each year for a period of ten years (from 2023 – 2032).

This question is repeated several times but the above option is always the last one on the page. This is the question that proposes raising fees for boats without a home mooring and widebeams, and also proposes moving to charging fees by total boat area in square metres rather than length with a width surcharge.

When answering questions 11 to 13, please say that increasing the licence fees for boats without a home mooring and widebeams is “Much less reasonable”.

There is what looks like unlimited space to explain the reasons for your answers in other questions. So you have plenty of opportunity to challenge the spurious reasons that CRT gives for increasing fees for boats without a home mooring and widebeams. Such as:

• It was CRT that changed its enforcement policy against boats without a home mooring in 2014-15 resulting in increased costs of enforcement and of supporting boaters without a home mooring
• It is CRT’s legal duty under the Equality Act that requires it to support boaters, rather than it being the boaters’ fault
• Hire boats and lack of maintenance do the most damage to the network
• The lack of use of the waterways during the Covid lockdowns resulted in siltation and equipment failure so boats constantly moving around is a benefit to CRT
• For CRT to try to recoup expenditure on making reservoirs safe by increasing our licence fees is blatantly unfair given that we are not responsible for the neglect and failure of Toddbrook Reservoir or for the Reservoirs Act
• Challenging the proposal that licence fees have to rise at all over 10 years, given that over the past year we have already seen two inflation increases totalling about 10%
• Challenging the proposal that licence fees have to rise over such a long period instead of a smaller one-off increase
• Challenging the basis of the consultation because CRT has not provided any evidence or figures to support its proposals or its allegations about boats without a home mooring

The FAQs for the consultation on future boat licence pricing state:

“Why are you considering applying a higher price to boats that continuously cruise?

Boats without a home mooring are expected, as per legislation, to move every 14 days to meet their licence terms. It costs us more to support boaters without home moorings, in addition to monitoring and enforcing compliance with the licence terms and conditions. A higher licence fee would reflect their more extensive use of our network.”

See https://canalrivertrust.org.uk/national-consultations/consultation-on-future-boat-licence-pricing-faqs

Some of you will remember the threat to increase licences without a home mooring in CRT’s 2020-21 consultation on boat licence terms and conditions.

One of the most insidious and significant changes made to the Terms and Conditions, which was not even included in the consultation, is that on Page 1, the new Terms and Conditions separate the Standard Canal and River Licence, which should apply to boats licensed both with and without a home mooring, into two new categories: “Pleasure Boat Licence” (also referred to as a “standard boat licence”) which must have a home mooring, and “Continuous Cruiser Licence”. This is contrary to the definitions in Section 17 of the British Waterways Act 1995, which simply defines a ‘relevant consent’ as a Pleasure Boat Certificate, a Licence or a Houseboat Certificate; and in Sections 17(3) (c) (i) and (ii) stipulates that a Pleasure Boat Certificate and a Licence (referred to in the Act as a “Relevant Consent”), can be obtained either with or without a home mooring.

It was obvious where CRT was going with this sweeping reclassification: the separation of the Standard Canal and River Licence into two categories would make it easier for CRT to charge a higher fee for a so-called “Continuous Cruiser Licence”, something which was threatened and consulted on several times by British Waterways, most recently in 2008, but was dropped each time following opposition.

Tags: boat licence fees, consultation, continuous cruising, cost of living, inflation, liveaboards, Waterways Act 1995, widebeams

This entry was posted on Wednesday, March 1st, 2023 at 2:12 pm and is filed under News. You can follow any responses to this entry through the RSS 2.0 feed. You can skip to the end and leave a response. Pinging is currently not allowed.