NABO has written today to CRT asking them to delay the introduction of the revised terms (for private boat licences), until they have been consulted.
The letter reads:
NABO is naturally disappointed that in the six months since our submission to CRT the Trust has made no effort to respond to the detailed points raised by NABO. Our submission reflected not just the views of NABO’s Council but was prepared after consulting our membership. We are forced to conclude that the Trust finds it easier to ignore a group of its customers than engage with them.
We note that the revised terms and conditions are materially different than the 2015 terms as well as those that were consulted upon. The fact that these revised terms have not been consulted upon and were introduced with six days’ notice is insulting to boaters.
The announcement of the revised terms offers no explanation of the legal basis of some of the more controversial changes. In particular NABO remains concerned over the Trust’s continued attempt to give itself powers not granted to it by the 1995 Act and yet boaters have no choice but to agree to them.
The 95 Act makes clear the responsibilities of boats with or without home moorings. The Trust’s revisions would appear to agree with only one aspect of this with no clear explanation as to why the Act should not apply in its entirety.
The 95 Act refers to one licence yet the Trust has now created two distinct licences dependent upon whether you have a home mooring or not. This has many potential implications but was not consulted upon nor fully explained. Could you confirm whether any of the boating associations or the Navigation Advisory Group was consulted and that they agreed with these new licences and the potential implications? Your commentary accompanying the implementation of the revised terms suggests that this was the case.
In conclusion NABO is disappointed that the Trust has chosen not to respond to our original comments and ask that it now do so promptly. We cannot support the introduction of the amended revised terms until the Trust has explained the legal basis for them. In the meantime we would urge a delay in their introduction until the Trust has consulted upon them.