NABO today has written an open letter to Ian Rogers CRT's Head of Customer Services. This is in response to CRTs letter to boaters with boats with out a home mooring (CCers).
CRT's policy statement can be found here:
The text of CRT's letter to all CCers can be found here.
If you are affected and have comments to make, please let us know.
This is the NABO letter.
"We write to express our disappointment at the communications strategy of the Canal and River Trust around enforcement that has occurred in the short term following your appointment. We think this has been a PR disaster alienating many of our members who continuously cruise without a home mooring.
At the meeting with the associations on 19 January this year we were shown a presentation that indicated that CRT were planning a three step approach to enforcement this was broken down as follows :
Step 1. Refuse to license the 16% of boaters without a home mooring that move less than 5km
Step 2. Refuse to grant a full term license for the 50% of boaters without a home mooring that move more than 5kms but less than 20km until they show a pattern of movement that takes them into the third step.
Step 3. Those that move more than 20kms will not generally attract enforcement attention.
It was recognised that these percentages were being verified but that they were not expected to change materially. The associations were invited to approve this process.
NABO has long stated that it is for CRT to decide what constitutes ‘bona fide’ for navigation and to enforce on this basis and this could be challenged via the Courts as appropriate. NABO therefore supported this proposal on the basis there was a comprehensive strategy that CRT intended to follow and that enforcement was seen to be transparent, consistent and clear. The implication from the presentation given by Denise Yelland , head of enforcement, was that enforcement was to be focussed on those boaters on step 1 , thus the “towpath telegraph” would work and many of the boaters currently step 2 would move to step 3 without any need for further action.
However what has happened is that every boater without a home mooring has been sent a letter and email detailing out two vague definitions those that ‘hardly move’ and those that move more than ‘hardly move’ but still do not, in CRT’s opinion, move but not far enough. At the meeting of the associations it is minuted that Richard Parry and Denise Yelland were going to prepare a clear response to the question “how far should I travel to comply?” Regrettably this has not been the case .
This has had the effect of upsetting many of our members who fall within the 34% that do not and will not attract CRTs enforcement attention, these are boaters who in general are supportive of what CRT is trying to achieve.
A typical comment we have received is “I'm not against the rules for CCing or CRT trying to enforce them but they really do not have the information to make fair and reasonable decisions and there is a lot of assumption where there are gaps in the data. I suspect many people who are following the rules will end up with enforcement notices due to the enforcement attitude which appears to be guilty unless proven innocent. Like many boater we are now using the Android Cruising log ap as we do not think our blog would be considered a suitable evidence if we did find ourselves with an enforcement notice.
Seems to me that CRT are losing the support of lots of great boaters who previously donated to them and supported their activities with enthusiasm. “
Instead of focussing initial communications and enforcement activity on those boaters within step 1 we now have great unrest within the continuous cruiser fraternity with boaters asking for their movement records and in many cases discovering many discrepancies in the recording of their movements which has given rise to doubts coupled with many boaters emailing CRT to request confirmation how far they should travel to avoid enforcement attention. It has appeared that CRT did not have a strategy to respond to these queries. No doubt some will seek to use the inaccuracy of CRTs records with the lack of clarity from CRT on their movement as a defence.
In the end CRT have been forced to release a statement (we note now in miles as opposed to kilometres) giving a range of movement that boaters should follow as a guide to avoid enforcement activity.
From a PR perspective this does not reflect well on CRT at this blanket approach to communication and enforcement.
We hope that CRT will now pause and ensure that they have a clear strategy in place on their approach to enforcement. Our recommendation would be to focus on those boats within step 1 with a clear , consistent and transparent enforcement approach giving encouragement , guidance and support such that there is a pattern of movement that supports CRT’s interpretation of ‘bone fide’ navigation that they are comfortable in defending when challenged.
In the meantime from a PR and customer services perspective we would urge CRT to please treat boaters as customers that they wish to retain and encourage to be more involved in the waterways and not as a problem which is how many perceive that CRT see them."
NABO Vice Chair and Moorings