THE NATIONAL ASSOCIATION OF BOAT OWNERS

Monday, October 23, 2017

Current Consultations

Mark Tizard has read the 44-page report …. so that you don’t have to!

CRT is investing a considerable amount of time and expense in reviewing boat licensing. At the outset, it said it wanted the review to cover all aspects of licensing and that the outcome was intended to be revenue neutral and to simplify the current process. CRT has just published the Stage 2 report from the recent workshops, which is the main focus of this article. To recap, using an external consultancy, Involve, the review is a three-stage process that is intended to operate as follows:

Stage 1: interviews to get the views of boating organisations, who will understand the views of many of their constituent members. Following Stage 1, the Trust will develop a set of scenarios based on the views that have come out of the interviews;

Stage 2: nine regional workshops with boat owners, which will look at the scenarios, develop them further and, across the nine workshops, develop a set of draft options (probably three) to take to a full consultation. Workshops to take place in mid-late April and early May. Following Stage 2, CRT will work up the options further, drawing on the views of people in Stages 1 and 2.

Stage 3: an online consultation, open to all boat owners, will seek their views on the options presented - for example, their strengths and weaknesses, how they might be further improved and which option they prefer and why. This will take place over the summer and into late September. Between each stage, Involve will draft a summary report of the findings and, at the end of the project, it will draft a full report that draws everything together.

The Stage 1 report can be found at https://canalrivertrust.org.uk/media/original/32167-licensing-consultation-phase-1-report-2017.pdf. From the report, it would appear that there was broad agreement in four areas as follows:

  1. There should be a single licence, as exists currently.
  2. There was wide support for licensing by boat area.
  3. Congestion or lack of movement should be best dealt with by enforcement and mooring charges.
  4. Discounts should be retained where justified.

NABO Council agrees with all four of the areas above and advanced these views during our interview in the Stage 1 part of the process.

CRT has now published its Stage 2 report, which can be found at https://canalrivertrust.org.uk/refresh/media/thumbnail/33550-licensing-futures-stage-2.pdf

In summary, 988 people applied for 135 places in nine workshops at Leeds, Newark, Hatton, Northwich, Gloucester, London, Birmingham, Milton Keynes and Devizes. 186 boaters confirmed their intention to attend a workshop, but in all workshops, except Milton Keynes, many did not attend on the day and the number of people was considerably lower than aimed for (e.g. Leeds, 6 people from 15 invited; Newark, 6 from 20; Northwich, 8 from 25; London, 8 from 15; and Devizes 9 from 14 invited). In all, 81 people attended.

The workshops lasted for three hours and were guided by a semi-structured process plan, designed to ensure a focus on the issues of importance to CRT and informed by views expressed in Stage 1, while also allowing time for participants to raise other topics. The three main themes for discussion were:

  • Size: licensing by length; length x breadth; single flat fee; or other options suggested by participants.
  • Other factors relevant to licensing: for example, extent of access to the network; zoning; regional pricing.

I have summarised the main findings as follows:

  • Boaters were adamant that the licensing system should not be used to penalise specific types of boating or set different types of boater against each other.
  • Any changes to the system should be transitional (3-5 years was suggested) and not retrospective.
  • Participants identified a number of principles they felt should underpin any licensing system. These include fairness, intelligibility, simplicity and ease of enforcement.
  • There was broad support for licensing by area of boat (length x width), although this view was not unanimous ‒ a substantial proportion of participants argued for retention of the current system.
  • In addition to the size of a vessel, participants discussed three main factors that they felt had relevance to the licensing system. These were regional pricing or zoning, the use of technology and the level of use of a boat. There was no widespread support for these options.
  • With the exception of the prompt payment discount, responses to the different discounts were affected by the small numbers of boaters claiming each one. Most discounts received some support, although the rationale for some was questioned. The charity boat discount was widely supported and participants felt it should be increased. The electric boat discount was discussed at most length and many participants felt it should be removed.
  • Congestion on the waterways was raised frequently during workshops and participants defined it as a problem for both mooring and navigation, as well as a safety concern. Congestion is seen as localised but spreading.
  • There was a strongly and widely held view that congestion is a problem of mooring and enforcement,and not something for the licensing system to resolve, although there were a few voices who did see a role for licensing in managing capacity. Enforcement is seen as important but poorly managed.Some participants feel it is applied unfairly or aggressively.
  • The quality of the Trust’s communication and information provision was raised in a number of workshops and many participants felt there was room for improvement.

From the Stage 2 findings, you can see that the outcome is very like the Stage 1 report (an interesting conclusion which shows that the boating organisations are broadly in tune with their members). 

CRT is shortly to contact all boaters who have email for their views in Stage 3. Going back to the original aims ‒ which were 1) a complete review of licensing, designed to be broadly revenue-neutral, and 2) simplification of the current process, and also accepting that a substantial number of attendees apparently queried the need for any change ‒ the only broad agreement for change was that CRT should move to charging by boat area. Table 1 below, produced from information in Involve’s report, highlighted the pros and cons of this change.

 

Basis for licence fee

Pros

Cons

Length alone

The current system is ‘not broken’, simple and fair. Changes are likely to increase, rather than reduce, complexity. It provides a low-cost entry point for new boaters with shorter boats. The width of a boat does not bear any relation to its cost to CRT.

Even if larger boats cause more damage on certain canals, this should not be addressed through the licensing system. Instead, CRT should impose maximum dimensions for vessels using canals.

The underlying logic of the current system is unclear. Length-based licensing does not reflect what each boat costs the Trust and an area-based system is fairer.

 

Length x beam

Wide-beam boats occupy more space, use more water and cause more damage, adding to the cost of waterway upkeep. This type of licence has the potential to discourage purchase of wide-beam boats, which some felt add to congestion and impact on other boaters (they can require tunnels to be closed; cannot share a lock and they can be harder to pass). EA licences are already area-based (on the Thames - see Table 2). Arguing against the point that wide-beams can access only part of the network, participants noted buying a 70-foot boat also limits the cruising range.

 

Wide-beams are not able to access the entire network and should not have to pay for a system that they cannot use in its entirety. They have value to people who otherwise could not access the canals (e.g. people with some disabilities). Problems perceived as associated with wide-beam boats are better addressed through the mooring system, rather than through licensing. Wide-beams do not cause more damage than narrowboats: it is the boater, not the boat that is the problem.

 

Table 1. Pros and cons of length- and area-based licensing

 

Waterway area

Wide-beam (12’)

Narrowboat (6’10”)

Broads

 

860.95

488.30

CRT

 

991.30

991.30

EA

Thames

Gt. Ouse/Nene/

Stour etc.

1242.85

 

878.71

704.90

 

878.71

Scottish Canals*

 

198.12

198.12

 

Table 2. Licence fees for different waterway areas for 60-foot boats.

*The same fee for all powered boats, regardless of size or shape.

It is very interesting to note that the complexity of the current licensing process does not appear as a problem in any boaters’ views. This would appear therefore to be a function of the internal CRT procedures.

The views on changes to licence bands and navigable area support this. There are currently 18 different price points for a 12-month private pleasure licence. Some suggested increasing the width of the bands and decreasing their number. Those who disagreed argued that wider bands would penalise people on the thresholds, or make boats just over a threshold essentially worthless. Online renewal processes mitigate any apparent complexity with the current banding, and current increments are straightforward; most boaters would lose if this idea were implemented. Another view was that charging bands no longer make sense, as electronic systems can account for the true length (and width) of a boat, so a system could be based on cost per square metre.

The idea that patterns of use could play a role in determining the licence cost was widely discussed. There were two views: some felt that those who use the waterways infrequently (e.g. for a holiday or occasional weekend) pay disproportionately. However, these boaters should still be liable for the full licence fee, as they are paying for access to a network that needs year-round maintenance. A separate or increased licence fee for continuous cruisers received very little support and was rejected as it risked creating a ‘them and us’ culture. People who already evade payment or do not abide by their licence terms and conditions would find ways around such a system (e.g. by registering ‘ghost’ moorings).’

In conclusion, if CRT has taken on board the thoughts of the boating organisations and of the boaters who attended the workshops, the forthcoming questionnaire being sent to all boaters should be simple and clear (we live in hope!). We suggest four simple questions:

  1. Do you think the existing licensing arrangements need changing?
  2. Do you support a change to charging by boat area rather than length?
  3. Do you support the retention of the current range of discounts? If not which would you keep from the attached list.
  4. Would you support a reduction in the current 18 price points in a 12-month private leisure licence? If yes, how many price points would you suggest?

It’s important that members respond to CRT’s email when it is received to ensure that your voice is heard.