The National Association of Boat Owners (NABO) is a voluntary membership organisation, principally consisting of private boat owners based on the inland waterways of England and Wales. NABO exists to represent the interests of its members with navigation authorities and government organisations and to promote responsible ownership and use of inland boats. I am writing in response to the current HMRC Consultation for Diesel Fuel used in Private Leisure Craft.
The craft in question, as represented by our membership, are typically privately owned narrowboats, canal and river cruisers and small barges. The dimensions and capacity of the network mean that these craft are usually less than 21 m in length and less than 4 m beam (width).
For a more detailed description of the situation of boaters from our constituency in Greater London please see “Moor or Less – Moorings on London’s Waterways” led by Jenny Jones, (now Baroness Jones of Moulsecoomb).
The nature of these craft, and the fact that they are mobile, means that they rely on self-contained systems for heating, domestic electrical power and propulsion, and such systems are designed as their primary energy systems.
For propulsion, craft rely almost exclusively on diesel engines. It should be noted that there is no obvious viable alternative to diesel engines for propulsion. Petrol engines are highly discouraged because of the fire and explosion risk from the fuel.
Our main areas of interest are around the potential adverse impacts that private boat owners might experience in the event of insensitive regulation of:
A) The use of diesel for navigational propulsion.
The government intends to abolish the scheme introduced in 2008 that allowed users of diesel powered private pleasure craft (e.g. motorised yachts, canal boats and motorboats) to purchase red diesel and pay the duty differential between red and white diesel on the fuel used for propulsion. It intends to remove the right of operators of such craft to use red diesel for propulsion and mandate the use of white diesel. Users will be allowed to continue to use red diesel for on-board non-propulsion use where they have a separate fuel tank for this purpose. This means that craft with only one tank will pay more tax than they currently do as they will have to purchase fuel taxed at the higher white diesel duty rate for both propulsion and non-propulsion uses, and pay the standard rate of VAT as white diesel is not eligible for the reduced rate of VAT. Red diesel is currently taxed at 11.14 pence per litre instead of 57.95 pence per litre for unmarked (white) diesel.
b). Non-propulsion use of diesel
When in navigational use, the diesel engines, almost without exception, provide low-voltage electricity generation for both domestic and locomotive use, typically stored in lead acid battery banks, (typically 12v or 24v low energy systems).
In most cases, hot water is also generated by linking engine cooling water to simple calorifier systems, which use engine coolant to heat an immersion style water tank.
It is therefore also apparent why it is necessary for boat owners who are stationary on temporary/visiting moorings and long-term moorings to frequently run their navigational engine at least every few days to recharge domestic batteries and produce hot water while the boat is occupied.
It is noted that only boats moored permanently on residential moorings, which have Council Tax applicable, will be able to use red diesel. Many of our members use their boat for leisure purposes only and the use of white diesel will mean that the running costs for their leisure craft will increase. The introduction of the need to use white diesel will also affect their ability to source the correct type of diesel as most marinas and boats that sell fuel will only stock either one or the other
Once red diesel is in a fuel tank the dye remains, so Customs authorities will not be able to accurately check whether there is red or white diesel in a tank.
We, therefore, urge HMRC to carefully implement these changes as having separate tanks fitted will be beyond the scope for most boat owners due to insufficient space for two tanks.
Boating is a major source of tourism income as our members travel the country and, if implemented, this proposal will have an adverse impact on the communities who rely on canal tourism.
Stella Ridgway on behalf of the National Association of Boat Owners