Following further discussions with interested parties including NABO, the Canal and River Trust has today launched its response to the recent consultation on the towpath mooring plan for the K&A Canal west of Devizes. This plan was produced by a sub-group of the Waterways Partnership, building upon work undertaken by an earlier and, unfortunately, abandoned working party in which most boating organisation were involved. NABO has always accepted that CRT has a problem inherited from BW to deal with on this highly congested stretch of the waterway.

Having recently rejected Roving Mooring Permits (consistently opposed by NABO) we believe that the proposed interim local mooring guidelines are a reasonable short term approach. NABO notes that these are guidelines only but given that they are generally locally supported, they will give all interested parties some breathing space to work out nationally agreed solutions.

See: http://canalrivertrust.org.uk/about-us/consultations/completed-consultations

In essence, the guidelines provide:

• A fair and consistent approach to handling applications for exceptional overstays.

• The adoption of a locally-agreed “neighbourhoods” schedule to clarify movement requirement after 14 days.

• Agreement (as legally required) to move every 14 days.

• Agreement to moor in different neighbourhoods with no bridge-hopping.

• A range of movement exceeding 20kms during the period of the license.

• Fair consistent enforcement of the 14 day rule.

NABO is however unhappy about the £25 overstay “charge” (which looks to us as a “fine”) and the proposed no-return rule, both applicable to Visitor Moorings. Besides the fact that our legal advisors confirm that both are non-enforceable legally (assuming the charge is in fact a penalty as there is no mechanism to pre-pay it), we can't see how they can work in practice.

Is it really sensible for CRT to monitor every visitor mooring on a daily basis – presumably to gather evidence?  How do you fine a hire boater?  And, presumably, if a private boater is happy to pay £75 for a week in Bath, CRT will be happy to take his money – many would see this as good value? Indeed, how will it be collected and how will boaters ask to stay an extra day?

We understand and support the need to share fairly and suggest that simply saying a maximum of 48 hours stay on a Visitor Mooring is enough – and after that boaters have to move on or action will be taken to move them on as they are obstructing others from using the mooring? We also need to point out that from our own members experience and NABO surveys, the issue of overstaying at Visitor Moorings is not largely caused by continuous cruisers. It is simply a congestion issue.

Besides the above reservations, NABO welcomes the introduction of this plan for an initial 12 months and hopes that it will be supported by the wider boating community. We are also pleased by CRT’s assurance recently given to us that they will look at our concerns raised above and related issues in full as part of a national review, in which we and other national bodies will be consulted.

13^th March 2014