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.

We are writing in response to the current consultation on the draft London Environment Strategy being undertaken by the Mayoral Group, in particular with reference to the issues around managing and reducing harmful emissions.

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 burning of fossil fuels and wood for domestic heating, and

b)The use of diesel engines for navigational propulsion.

The following comments are applicable across the piece, but are most directly relevant to Proposal 4.2.2a “The Mayor will work with government and relevant groups to reduce emissions from activity on London’s waterways” ^[1]. 

We welcome the commitment in the draft strategy to an “evidence based strategy” when considering policy in this area towards boats and watercraft and hope this submission will help introduce some of the “specific challenges for river and canal vessels” ^[2].

Our constituency

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” ^[3] 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 also be noted that, when in navigational use, the 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).

It should also be noted that there is no obvious viable alternative to diesel engines for propulsion. Petrol engines are highly discouraged because of the fire risk from the fuel.

In some 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 boat owners who are stationary on temporary/visiting moorings and long-term moorings frequently need to run their navigational engine at least every few days to recharge domestic batteries while the boat is occupied.

A few craft have secondary generators that replicate some or all of the above, but again these are almost exclusively either in-built diesel powered systems or portable petrol-fuelled generators.

Space heating is almost exclusively by solid fuel burners, burning coal, wood or in multi-fuel use, or less commonly, by diesel heating boilers. Some of these systems also contribute to hot water generation, depending on their type and configuration.

Bottled gas (Propane) is most commonly used for cooking and hot water production and, exceptionally, for heating (although the cost of this latter function is prohibitive for most owners).

Because of their actual and potential mobility, the use of ‘on-grid’ sources of power can only be a secondary option when a craft is moored long-term, and assuming that:

1. such a connection is available, and

2. the craft has suitable adaptations to ‘hook up’.

In the majority of cases, such access to the grid is not available.

Simply on the basis of this very short introduction, it should be clear to the reader that any global ban on the use of fossil fuels for heating and propulsion or of solid fuels for domestic heating of boats in the Mayoralty would potentially render most existing craft on the navigable canal and river network functionally redundant as their main systems for generating heat and power would be outlawed.  This applies whether the craft is lived on permanently or simply in temporary leisure use.

Of course the potential impact on long-term residential boaters is more severe and in the extreme could render residential boating in its present form impossible, making some boaters effectively homeless, as they will no longer be able to heat their boats or navigate.

National context

It should also be noted that London’s navigable waterways form part of a national network. Unlike London’s low-emission zones for road transport, the ‘vehicles’ (in this case boats) are largely leisure boats. It is therefore likely that restrictions on the use of diesel propulsion will mean that London becomes a no-go zone for many boaters not based in London, who would otherwise consider visiting the city, as the cost of converting or replacing propulsion and heating systems, simply in order to comply with any regional restrictions, will be considered uneconomic by many owners.

It is also likely that many existing boaters, especially those without long-term moorings, will look to leave London.

Conclusions

We therefore urge the Mayor and his advisory team to give careful consideration to the potential impact of restrictive changes in policy and/or legislation on our members and the wider private boating community, especially in respect of solid fuel heating and the use of diesel engines for navigation.

As stated above we welcome the indications in the draft strategy that the mayoralty will work with relevant parties on developing policy in this area. We are sympathetic to the aims of reducing air pollution in London and would suggest that a careful debate is undertaken to look at any potential mitigation measures. We would welcome further involvement as policy is developed and we would be happy to expand on the issues outlined in this submission.

As outlined above, boaters are largely dependent on the use of diesel engines for navigation and solid fuel for heating their boats and, in our view, must not be prohibited from continuing to use such systems, unless the aim is to effectively outlaw most existing private boats from London’s waterways.

The impact of the boating activities we represent is very marginal when compared to the impact, for example, of road traffic. The number of privately owned craft on London’s waterways is well under 10 000. The Canal and River Trust’s annual boat count shows that there were less than 5000 such craft in their London region as of March 2017 (Source: CRT press release reproduced at https://nabo.org.uk/files/National-boat-check-2017-FINAL.pdf ). (There are also other leisure craft base on the Port of London authority water and the non-tidal Thames (managed by the Environment Agency.)

In closing, we offer a few, and by no means comprehensive, suggestions that might help private boaters to reduce their emissions and wider environmental impacts. We would welcome further discussion of these and other potential practical contributions that the boating community can consider making towards improving London’s environment.

1. Improved access to electricity supplies for visiting boats at visitor moorings

• To reduce the need to run engines and generators for non-navigational purposes, especially for those craft that do not have solar arrays.
• To facilitate the increased use of electrical domestic systems, without the need for local generation of electrical power by running stationary engines and generators.

The capital costs of providing such schemes are, however, significant and beyond the Canal and River Trust’s means, and would require third-party funding.

2. Better research and information on the relative impacts of different solid fuels, with nudges towards the least harmful options. (For example, Canal and River Trust has encouraged the ‘coal boats’ it licenses (which commercially supply solid fuel to boaters) not to supply or stock fuels that do not comply with the current Clean Air Act regulations.) The Mayoralty might consider negotiating such an agreement with garages and other fuel suppliers.
3. All boaters’ organisations provide better information to ensure that existing propulsion and heating systems are well maintained.
4. Research into the potential application of catalytic converters, filters and other air cleaning technologies to reduce the impact of marine engine exhaust emissions.
5. Voluntary codes to minimise emissions from engines, generators and heating systems in the most sensitive areas. One such arrangement is already in existence at Noel Road in Islington, see; https://canalrivertrust.org.uk/news-and-views/news/new-plans-to-help-boaters-and-residents-get-along-in-islington)

Simon Robbins on behalf of the National Association of Boat Owners