CRT’s is pressing ahead with plans that will affect liveaboard boaters without a home mooring, mostly by making the lives of our community more difficult. Firstly CRT is developing plans that were announced in its 2017-18 Review of Boat Licensing. The Licensing Futures Final Decision Report of 6th March 2018 stated:
“…the Trust does not propose to introduce a different licence fee for boats without a home mooring. Our intention is to take forward a further stage of work to look at options that would address the growing use of canals in London and other areas by boats without a home mooring and how to develop a fair [sic] means of reflecting the significant benefit gained by such use”. In response to a recent Freedom of Information request, CRT stated that:
“During our last public consultation into the changes to boat licences the Trust committed itself to reviewing those areas facing particularly high demand and welcomed customer views on this issue. We have since set up a mooring sub group as a forum to discuss such issues. It is our intention to proactively publish information and consult with customers and their representatives appropriately. The issue of managing these areas was discussed at the mooring sub group meeting on 23rd May and these minutes will be published on our website when they have been agreed by the sub group following their next meeting in July”. No specific evidence has been published that demonstrates where and why these areas of so-called high demand exist.
Whatever CRT decides to do, it is likely to mean further restrictions for boaters without a home mooring – unless CRT accepts that the best way to respond to the alleged high demand is to agree that a busy waterway is a successful waterway, provide more boater facilities and open up more areas that can be used for mooring with bank repairs, dredging and the installation of mooring rings where these are needed.
This does not look likely however, and we are increasingly seeing the concept of “fairness” being applied to justify restrictions against boaters without a home mooring in favour of people who use the waterways for leisure, despite the fact that those who live on their boats are entitled to greater protection due to their rights for respect to their homes under Article 8 of the European Convention on Human Rights.
The Outputs from the Communities on the Western Kennet & Avon Canal Strategic Study Day on 29th April 2019 under the heading “Share the Space” include the following intended actions:
“Licencing process and requirements under review”. This looks extremely ominous, especially given that there was a comprehensive review of CRT boat licensing in 2017-18. This suggests that CRT plans to introduce yet more unlawful licence terms and conditions that will have a disproportionate adverse impact on those who live aboard without a home mooring.
CRT is also in the process of revising the Boat Safety Scheme regulations “to address habitation and sanitation”. The Boat Safety Scheme is owned jointly by CRT and the Environment Agency (EA), the UK’s two biggest inland navigation authorities. In response to a request for the revised regulations under the Freedom of Information Act and the Environmental Information Regulations, CRT stated on 23rd July 2019 that “unfortunately there has been a delay in providing a response to your request for information and we will not be able to respond within the 20 working days”. While new BSS criteria may result in better fire and CO2 safety on boats, inevitably new BSS regulations will involve remedial works that will be unaffordable for some liveaboards, many of whom are on very low incomes or rely on intermittent low-paid work.
CRT is also carrying out a waste review across its network to develop criteria for what is to be provided, where it can be accessed by boaters and how to ensure it canotn be abused, and is also looking at installing more dry mixed recycling facilities. This is welcome, and better rubbish disposal facilities will undoubtedly make life easier for liveaboards if they are implemented, but they will not compensate for increased restrictions on mooring and even more draconian and unlawful licence terms and conditions, which will increase the risk of homelessness and Section 8 action for our community.
Tags: Boat Licence Terms and Conditions, Boat Safety Scheme, consultation, continuous cruising, CRT continuous cruising policy, CRT review of boat licensing, enforcement, FOI requests, liveaboards, mooring policy, recycling, refuse facilities