IWA Responds to Canal & River Trust Business Licence Consultation
Issue date: 9th August 2013
IWA has called upon Canal & River Trust (CRT) to reconsider its proposals to reform its business boat licensing fees.
IWA is concerned that, if implemented, the proposals will cause serious financial difficulty for some business licence holders.
In principle, IWA does not object to revisiting the formula of how licence fees are levied for business users, but considers that the proposals should be subject to much wider consultation and that any significant changes should be phased in over a longer period of time.
IWA is opposed to any increases that are in excess of the 4.6% agreed in CRT’s press release of 15th October 2012 when it was stated that “Trustees of the Canal & River Trust have decided to limit boat licence fee increases, for three years from 2014, to inflation only. Their decision was made at the same time as endorsing the third and final year of British Waterways’ planned licence prices which will see licence fees rise from 1 April 2013 by 4.6% (2% above inflation).” IWA considers that this principle should apply to both business and private licence holders.
Among the points put to CRT in IWA’s response to the consultation, are:
- IWA considers that the significant increase proposed for day boat licences may lead to many operators deciding to cease operating day boats. This will result in less people being able to discover the inland waterways and subsequently hire or own boats. IWA agrees with the proposal to remove the discount relating to use of locks, but considers that the overall increase would be too much for operators to bear.
- The overall increase for some holiday hire boats is also excessive, particularly for longer boats. Many hire firms will be hit by this, as two families (or an extended family) often choose a longer boat to make for a more affordable holiday. Again, if those people are not introduced to the waterways because they cannot afford a week’s hire, they will not go on to become further involved with the waterways.
- IWA considers CRT’s proposed overall increase in income as a result of these proposals to be excessive when the bulk of the increase (£106,000) is anticipated to come from day hire and holiday hire. It is likely that the income that CRT actually receives will be considerably less than this as a result of hire companies going out of business, by choosing to cease hiring out boats as part of a wider business or reducing their vessel numbers. For the future good of the waterways CRT should encourage more people to take part in affordable holidays, and to do this CRT must support the hire industry or there will be far fewer hire boats available on the system.
- The consultation document states that the review “did not set out to increase overall revenue from business boats” yet the proposals result in an anticipated increase of £120,000. CRT acknowledge that this is an insignificant amount in the overall running of Canal & River Trust, but it is substantial to the affected business licence holders who will have to bear this increase.
- The proposals for skippered passenger boats will hit the smaller operators hard, which could result in some passenger boats going out of business. Passenger boats often add life to under-used sections of waterway and as such should be encouraged. There has been a decline in the number of trip boats in recent years, and these proposals are likely to discourage new operators. IWA agrees that the flat fee for boats carrying over 100 passengers was too low, but is concerned that the proposed new fee structure will disadvantage some passenger boat operators and may force them out of business.
- IWA does not agree that the Disconnected Waterway discount should be withdrawn. It should remain as an incentive to businesses (and waterway societies) to operate on disconnected stretches of waterway, which otherwise would see little or no activity. Holiday hire boats based on disconnected waterways need to be able to compete with companies based on waterways where there is a choice of routes and longer routes available. IWA is concerned at the impact the proposals will have on waterway societies that operate trip boats where all the funds raised go towards further restoration of their canal project.
- While welcoming the proposed “community boat” category of licence, IWA remains concerned at the withdrawal of the “charitable discount” that previously applied. There are some community organisations who operate boats for holidays or day trips for disabled or disadvantaged children that will be affected by this, particularly where they currently raise funds through occasional private trips that enable them to offer free or subsidised outings to those the charity is aimed at benefitting. IWA considers that waterway societies operating trip boats where all the funds go towards waterway restoration, and charities raising funds in order to run a community boat, should be eligible for the new community boat licence.
- Even the proposed transitional rate which will cap increases at 15% next year may be enough to force some operators and charities out of business, and the full increase by 2015 may be the last straw for many others. IWA considers that CRT should not increase its income from this exercise, and that any price increases should be in line with CRT’s previous commitment of inflation only for the three years from April 2014.
IWA is also concerned by the consultation process that CRT used for obtaining views on its proposals. IWA, and other national bodies who represent business licence holders, were not consulted, and the consultation was not available on CRT’s website. Existing holders of CRT business licences were consulted, although it is understood that several business licence holders did not receive the consultation documents, and were unaware of the proposals until after the deadline for comments had passed. IWA is also concerned about the short duration of the consultation, and its timing at the busiest time of year for the hire boat trade.
Paul Roper said “IWA is very concerned that the CRT proposals, whilst only raising small amounts of additional income for CRT, will have a significant impact on the viability of some operators. This will result in the public having less opportunity to get afloat on our inland waterways. CRT should maintain their promise not increase boat licence fees by more than inflation for the next three years.”
Canal & River Trust has said that it will consider everyone's views before making any decisions to introduce changes.
A copy of IWA's full submission to Canal & River Trust is available here.