After internal discussion within NABO Council and considering comments and suggestions from members, NABO has submitted its response to the 2011 Licence fee consultation document as follows:
National Association of Boat Owners
Consultation response concerning the Proposed changes to the licencing system in 2011.
Boat Licence Changes 2011
The National Association of Boatowners would like to make the following comments to the consultation document issued by British Waterways on 7.12.10.
Licence fees for 2010
NABO understands the realities of the present economic climate and the very real possibility of reductions in services that may have to be imposed. However, this has to be balanced by the effect that the impact on individual boaters is equally severe and large increases in the licence fees year on year may well be the deciding factor in some boaters deciding that they can no longer afford to use their boats. This will inevitably reduce the funding available to British waterways via the licence fees and drive up the fees in later years to those loyal customers who continue to run their boats. We urge BW to do all it can to keep the licence fees as low as possible by exploring alternative ways of generating income from the many millions who make use of the facilities and benefits of the inland waterways without contributing one penny. In the proposal to offset increases in future years by the use of extended stay charges and transient mooring permits BW is once again increasing the load on the boater which emphasises the need to spread the load more fairly to other, non-contributing waterway users.
NABO is pleased to note the longer term commitment regarding possible future licence fee increases in 2012 and 2013 and the indication that in future years there may be opportunities to further moderate any increases.
3 and 6 Months licences
NABO does not agree with the reasoning behind the proposal to revert to the 60% and 85% ratios from 1.4.11. We find that the proposed changes are disproportionate and unnecessary. One argument put forward is that BW are currently unable to generate automatic renewals for these shorter period and this may highlight yet another deficiency in the BW licence software which has been the subject of complaints during 2010. The trend to purchase shorter term licences is an indication that hard pressed boaters may find it easier to manage their cash flow by this method and BW should make all efforts to assist them. The proposal to revert to the higher percentages will just add one more obstacle to those boaters who are already hard pressed to keep boating.
Consideration should also be given to visiting boaters coming onto BW controlled waterways who would be unfairly penalised for wishing to stay for shorter periods which may discourage them from BW waters and hence lead to a loss of revenue.
Prompt Payment Arrangements
NABO disagrees with the proposed changes to these arrangements. BW acknowledges that the present arrangements have been effective in reducing late renewals but the argument to extend this fails to acknowledge the very real need for BW’s licence department to increase its own efficiency. It is our opinion that the process and systems need an urgent overhaul before any further changes are brought in, and more thought should be given to removing any elements of unfairness in the prompt payment arrangements.
C1 No comments
C2 Agree but otherwise no comment
C3 The principle of daily charges will be set out in the Local Mooring policy for each location and will need to be well defined and fair to avoid dispute and challenges.
C4 No comment
C5 No Comment
C6 NABO suggests rewording 6.1as follows:- “6.1The price of the licence is published on or before 01 Feb preceding the effective commencement date of those fees (01 April) and revised each year from 1st April and you agree to pay the amount due (including, where appropriate, any late payment and/or credit card charges)
C7 NABO Strongly believes that the principle of making a charge to move a boat in these circumstances is not in accordance with the 1983 BW act and therefore ultra vires. NABO has raised this point on a number of occasions with BW during our discussions regarding our legal complaint over the last year. In correspondence in 2010 BW have been unable to provide data which show that this requirement is a reasonable response to a problem area. In NABO’s view this does not justify amendment of the British Waterways Act 1983 with the use of the powers of the Transport Act 1962. We request deletion of this unnecessary requirement.
C8 No Comment
C9 No comment
C10 Agree but otherwise no comment
C11 No comment
C12 Add “The refund regime for Houseboat certificates is different and set out in statute – i.e. BW Act 1995, schedule One, Sections 8 and 9. Under this clause BW are obliged to refund the whole unused portion of the licence”
We welcome the opportunity to comment on the proposals set out in the consultation document and would be happy to contribute further in any discussion which may be necessary prior to reaching a final conclusion.