RBOA Response to BW’s Licence Fee Consultation Review

Having considered the Proposals, RBOA wishes to make the following response.  When considering this, it should be borne in mind that our Association represents a mixed membership with differing situations, so it is not always possible to speak for them all.  However, we have encouraged our members to make their own individual responses to the Consultation, in addition to our Corporate Response.

Not to change our method of calculating the inflation factor to apply to licence fees to reflect increases in BW’s costs.  The inflation factor to be applied for 2008 fees will therefore be 3.3%.

RBOA: This would obviously be best for boaters, but does not in any way alleviate the funding shortfall.

BW should continue to investigate the possibility of obtaining funding from those local councils who have a waterway passing through their area, as BW is in fact providing them with a linear park.  RBOA believes that for this to be achieved, there would need to be primary legislation from Government, forcing councils to make a contribution.

Whilst appreciating that anglers make up only a small proportion of users of the waterways, is there any planned increase in their fees?

We would also support BW in obtaining any income from casual visitors to the waterways (e.g. Parking charges which are currently being applied at honeypot sites such as Foxton could be extended to  include more locations).  BW might consider a “Supporters of the Waterways” club at an annual charge for information and certain benefits.  (We have been surprised at how many people join TWT at events, in exchange for not much more than a cuddly toy!).

To reduce the prompt payment discount on licence and mooring fees to 5% for all licence and mooring fees with effect from April 2009.  In summer 2010 we will consult further to determine whether the discount should be eliminated altogether from 2011.

RBOA: Reducing/eventually removing the prompt payment discount is penalising those who pay on time.  The present situation only normally allows BW to seek interest and costs when a boater is taken to court for non-payment of licence.  Could BW investigate the possibility of amending the licence conditions, imposing an additional charge on late payers?

To increase the price of a Leisure Business Licence by 3.3% in April 2008 and by the relevant cost inflation factor in 2009 and 2010.

RBOA: Acceptable.

To maintain the full fee for a boat Shop, Store or Workshop licence at the same level as the leisure business licence so that it increases by cost inflation only.

RBOA: Agree with retaining the discounted rate for Low Intensity Traders, as it encourages commercial use of the waterways, and adds interest for visitors.

We assume that the growing number of those with canalside properties, and who currently trade from those properties to passing boaters, pay BW some sort of licence/fee to BW for doing so.  If not, this could be investigated?

To maintain the Cargo Carrying licence fee at the same level as the private licence fee.

RBOA: Acceptable.

To increase the fee for Trade Plate and Workboat licences by same percentage as the fee for the private boat licence.

RBOA: There is a fairly strong feeling amongst users that Trade Plates appear to be being abused by some people.  In some cases it appears that they are not being used in the spirit in which we believe they were intended – To allow boatbuilders to work on craft on the water, move craft in the course of their business, etc.  There are instances of trade plates on scruffy boats which do not cruise, and whose state of repair does not appear to improve.  There is possibly a need to be more restrictive with the issue of trade plates, and review their limitations.  This could lead to an increase in the number of craft requiring a full BW Leisure Licence.

To increase Private boat licence fees increase by 9% - 9.2% per annum in real terms over the period April 2008 - April 2010.

This headline increase could be reduced to 7% by adopting  Proposal 2.  In this case, customers currently benefiting from the prompt payment discount would face a 12.9% real increase in April 2009.

RBOA: This could result in a large number of people, particularly pensioners, having to sell their boats. In some cases this could result in them becoming homeless. Although not specifically relevant to this Consultation, the general increase which has occurred in the cost of boating (moorings, diesel, compliance, etc), coupled with increased licence fees, could lead to a reduction in the number of boaters, and therefore to a serious reduction in income.  With the current financial uncertainties, boating as a leisure activity may well not be affordable.  With the possibility of this scenario becoming a real possibility, RBOA would urge BW to recognise the long-term commitment to the waterways of those who have chosen live on their boats, and who could be a stabilising factor in BW income stream.

There is a view that hardship could be alleviated if BW introduced a blanket discount for all those retired and therefore in receipt of a Pension, which would be easy to prove.  Many branches of government service give discounts for retired/near retired citizens (e.g. Rail Card for Over 60s, winter fuel payments, etc – all of which are non means tested).

To review gross income performance from boat licensing in summer 2008 and summer 2009 and consider whether to adjust the proposed increases for 2009 and 2010 in the light of performance.  We will publish our conclusions on this but they will not be subject to formal consultation.

RBOA: The review seems to be reasonable, but the lack of consultation less so.  It seems to allow for BW to be able to make an additional increase over the 9% if the projected income is not realised, e.g. If the licence increase were to result in a reduction in boat numbers, BW would be able to make further increases to make up the short-fall, ad infinitum.  RBOA believes that consultation is essential.

As they are not mentioned specifically, we assume that the rates for Houseboat Certificate will  remain in line with Leisure Licences, as at present.

We are aware that there has been a suggestion put forward that those residential boaters who are Continuous Cruisers should pay a higher licence fee than a normal pleasure boat licence, on the basis that they use the system more than other boaters.  Whilst this may be true in some cases, there are many owners of Private Pleasure Craft who cruise throughout the summer, many covering considerable areas of the waterway at peak periods when demand is greatest.  Also, anyone paying for a licence has the right to navigate all year round (working around stoppages), so it does not seem right that they should be expected to pay more for what they are already entitled to do.  The fact that quite a large percentage of boaters move their craft only rarely does not alter the fact that they could move it every day of the year if they so wished.