NABO respondss to EA licence increases

THE National Association of Boat Owners has responded to the proposed year on year hike of Environment Agency boat licence costs.

The response has been forwarded to us, and we re-produce below.  Boaters that use any of the Environmental Agency waters should also fill in its form to object to the increases, bearing in mind the opportunity closes at the end of this month.

NABO's response:

Submitted to Proposals for navigation boat registration charges 2019 to 2021
Submitted on 2018-08-13 15:10:40

3. About you
1 Please tell us if you are responding as an individual or on behalf of an organisation or group. Responding on behalf of an organisation or group Name of organisation or group you're responding on behalf of.:
National Association of Boat Owners

2 Please tell us on which waterway you or those you represent keep or use your/their boat/s most often. If you/they use more than one waterway please list them in the box provided. Other (please specify below)
Other waterways:
We have members who boat on or visit all the above waterways .

3 What is the main reason you or those you represent use your/their boat/s? Other (please specify below) Other (if you use your boat for residential purposes, you can tell us here):
Our members use their boats for private pleasure use as well as for residential purposes.

4 What type of boat/s do you own, operate or represent? Other (please specify below) Other:
Our members have a range of the above privately owned boats.

[5 & 6 concernered email address and data]

7 Please tell us how you found out about this consultation:
From the Environment Agency
Other:
4. Proposed increases for all our waterways

8 Do you agree with the need to increase Environment Agency boat registration charges in order to maintain the avigation service?
Strongly disagree
Please provide further information to support your answer. :
Whilst we accepted that the above-inflation increases introduced over the past year was acceptable (given that there had not been an increase for some years) we strongly believe that only a direct- inflation-based increase can be introduced across all EA waters. The proposal for continuing the differential figures for the 3 waterways is also not acceptable.
We also suggest that in your Table 2.2 all sources of income should be increased by the same amount and that the boat registration charges should not be expected to carry the load – this is simply wrong and unfair.
We would also like to see how your central costs compare to other similar government agencies. We are not convinced that your agency is working in the most cost-efficient way when compared to others

9a We are proposing to increase charges for the River Thames by 5.7%.
Strongly disagree
Please provide further information to support your answer. :
See above in section 8 – totally unacceptable.

9b We are proposing to increase charges for the Anglian Waterways by 7.5%.
Strongly disagree
Please provide further information to support your answer.:
See above in section 8 – totally unacceptable.

9c We are proposing to increase charges for the Upper Medway by 10%.
Strongly disagree
Please provide further information to support your answer.:
See above in section 8 – totally unacceptable.

9d We are proposing to increase charges for unpowered boats and those boats (powered or unpowered) which are part of joint registration agreements (British Rowing, British Canoeing, Canal & River Trust Gold Licence) by 7.7%. What is your opinion of this proposal?
Strongly disagree
Please provide further information to support your answer.:
But any increase must apply to all users!

10 To what extent do you agree that the boat registration charge is important in the overall cost of owning or operating your boat/s?
Agree

11 If introduced, would the proposed increases make you consider:
Leave or give up boating? - Leaving Environment Agency waterways?:
Yes
Leave or give up boating?? - Giving up boating?:
Yes
Please provide further information to support your answers. :
As registration charges increase they are becoming a significant proportion of the cost of owning a member’s boat. Most of our members are not gin-palace owners!
We are already observing a significant number of our members selling their boats as they cannot afford the costs being imposed on ownership. The proposed increases will result in more giving up and the result would be a decrease in income.

12 If we were not to increase charges, some services may have to reduce or stop. We would like to understand what’s important to you to help us prioritise the services we provide on our waterways.
Ranking or services - Assisted passage (staff to operate locks):
1
Ranking or services - Car parking:
13
Ranking or services - Canoe portage:
14
Ranking or services - Channel dredging:
2
Ranking or services - Compliance and enforcement checks:
3
Ranking or services - Drinking water supply:
8
Ranking or services - Electric hook up:
16
Ranking or services - Non-statutory/safety routine site maintenance (e.g grass cutting and garden maintenance, cosmetic painting):
12
Ranking or services - Permanent/base moorings:
7
Ranking or services - Pump out and chemical toilet disposal:
10
Ranking or services - Routine patrolling by river (e.g compliance checks, checking and marking the navigation channel, identifying issues or blockages):
4
Ranking or services - Showers and toilets:
11
Ranking or services - Short stay/overnight moorings:
6
Ranking or services - Slipways:
15
Ranking or services - Tree and vegetation clearance:
5
Ranking or services - Waste and recycling points:
9

13 Please tell us if you have any ideas on alternative or additional ways that we could/should fund the navigation service we provide.
Ideas on funding:
1. The Henley Regatta is a well-funded activity which has so far appeared to resist all attempts to pay their extensive policing/presence before, during and after the Regatta. The Regatta organisers should be held to account and required to contribute to the Thames’s funding.

2. With a modest capital investment at some locks, moorings can be substantially increased - and these would produce additional income.

14 Do you feel confident that the Environment Agency is working to secure a sustainable funding future for the waterways we manage?
Don't know
Please provide further information to support your answer. :
We strongly support the EA’s present investigations into the funding of their operations but cannot support a simple above-inflation increase in registration fees – there are many other sources of income that should be investigated.
We also strongly support EA resisting of attempts by CRT to take over their navigational responsibilities. CRT has enough funding problems of their own and has yet to prove that they are capable of managing their present responsibilities.

15 We really value your feedback on our proposals. Please tell us if you have any further comments and provide as much information as possible to support your answer.
Further comments:
See previous responses.
Your feedback on this online tool
How satisfied were you with the tool?
Neither satisfied nor dissatisfied
Please tell us if you have any suggestions on how we could improve the tool.:
Some questions require yes/no/no opinion/don't know indications - this does not allow for mixed responses ie partially agree.