NABO joins chorus of protest as C&RT's licence 'consultation' becomes a farce

October 2017 - Having not got what it wanted from stage 1 and 2 of its licence consultation, C&RT seems hell bent on pressing on regardless – perhaps the reason it parted company with the 'independent charity', Involve, who it had engaged to run all three stages of the consultation. Involve has been replaced by TONIC, a non charitable organisation, often used by Government, with very different aims and ideals. Allan Richards investigates.

Since CEO, Richard Parry, abruptly broke off communication with boaters some years ago there has been little attempt by C&RT's Customer Service organisation at dialogue with individual boaters and when it finally asks for opinions it is transparently pursuing an agenda already rejected by boater representatives.

Back in January 2016, customer service and operations director, Ian Rogers, told his board of trustees 'The first boating management team live web chat with customers is planned for early 2016 giving boaters a chance to ask questions ‘real time’. It is hoped this will become a regular feature for boaters in 2016.'

What Mr Rogers failed to tell his board was that boaters had been told, via Boaters Update in December 2015, that a first live web chat would take place on 18 December 2015. He somehow forgot to tell his board why this web chat did not take place.

A Freedom of Information request confirmed that the 'early 2016' live web chat did not take placeeither. Indeed, C&RT confirmed that Mr Rogers failed to provide any 'web chats' whatsoever in 2016! Furthermore, C&RT have also confirmed that its customer service and operations director failed to provide trustees with an explanation as to why these 'web chats' did not take place.

So what has this to do with the licence consultation? Quite a lot.

C&RT's justification for the consultation (repeated again at stage 3) is as follows: 'The current licensing system has remained largely unchanged for more than two decades and is often cited by boat owners as being complex and out of date.'

If Mr Rogers had held his live web chat, he might have found out earlier what changes to licensing might command support from boaters. In the event, C&RT suffered the embarrassment of having to admit that they could produce no recorded information that would support the claim that boaters were telling them that the licensing system was complex and out of date.

To make it worse, the claim that the licensing system has remained largely unchanged for more than two decades is simply untrue. To give just some examples of changes within that timeframe. Licence fee structure changes were made in 2003 and again in 2007. Changes regarding multi user craft were made in 2007. Discount structure was given an overhauled as recently as 2010. Changes to houseboat licensing were made in 2013. Business Licences changed in 2011 and 2013 and another change was made whilst this current consultation was running (why was that last one not included in the current consultation?).

During this timeframe, consideration was also given to many different aspects of licensing and changes not made. For example, (and pertinent to the current consultation) proposals were made for surcharging wideboats and those without home moorings. These proposals were not carried through due to boater opposition.

Those that have read right the way through the stage 1, stage 2 and stage 3 documents will note with alarm that C&RT appear to be proposing premium price roving mooring permits again in stage 3.

Why is it that this is being again proposed when there is no indication that boaters support it in stage 1 and 2. Why is it again being proposed when it has previously rejected by C&RT itself a couple of years ago as being illegal?

It has to be said that stage 3 of the consultation has already attracted plenty of criticism. Some boaters have complained that they have not received email invitations to participate. In many cases, on advice from other boaters, they subsequently found the email in the spam folder.

However, a much greater concern is security of the online consultation survey. The problem is that personalised links have been emailed to eligible participants (e.g. http://www.smartsurvey.co.uk/s/CRT-Licensing-Consultation-2017/?m=26324743gtahn). This allows the participant to complete and submit a multi page survey .
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Once the form is submitted, the link can not be used to submit a subsequent another survey. As in the example link given above, an attempt to reuse the link gives a message 'You have already completed this survey'.​

However, it has been quickly pointed out that, by omitting the parameter at the end of the link (i.e. the ?m=26324743gtahn in the example above), anyone can complete the survey. ... and they can complete it as many times as they like!

As one boater put it 'Perhaps some of C&RT's 450,000,000 visitors might like a go'.

C&RT have acknowledged that the security problem exists and say they will check each response against a valid email address. This may come as something of a shock to boaters who believe that they are contributing anonymously.

It seems C&RT can and will tie responses to email addresses and tie email addresses to individual licence holders.

C&RT have also said that they have instructed TONIC to disable the truncated link that allows anyone to complete the survey multiple times. However, it is not known if it is possible to do so and, at the time of writing the link is still active.

To add to C&RT's discomfort, NBTA has been advising members, many of whom have not received email invitations to use the shortened link. How is C&RT going to differentiate between these responses and non genuine ones?

Perhaps the last word on this train crash of a consultation should be left to NABO. Vice chair Mark Tizard has just emailed its members:

Dear Member

Your Council met recently and felt that we should urgently communicate our views and recommendations with regard to CRT's latest consultation.

Canal and River Trust have spent considerable time and expense getting to this stage yet in our view have now effectively ignored the majority view. CRT have in this consultation posed questions intimating that these have the support of the two earlier stages and of the Navigation Advisory Group (NAG L&M) where boaters views were requested. This is not the case.

At the specially convened meeting of NAG and the boaters representatives (Mark Tizard and Alison Tuck from NABO attended) we were advised that after getting the views of the boating organisations (stage 1) and the boaters workshops (stage 2) the only common themes emerging were the approval to change the way licensing was charged from length to area and to review discounts generally (keeping the prompt payment discount).

We understood that this basically was likely to form the core of the questions to be asked. There was a majority view that there should just be one license charge (regardless of whether a boater had a home mooring or not) and it was agreed that licencing cost should not be used to address congestion but that this was the function of enforcement. Despite being rejected at stage 1&2 this was brought up again at the special NAG meeting and again rejected unanimously.

Despite this we note with dismay that CRT have chosen to be divisive and have included questions that suggest that the boaters should pay a different fee dependant upon whether they have a home mooring or not, see questions 24,25 and 26.

NABO's view is that there should be one license fee for use of the waterways under CRT's control and would urge members to vote accordingly. In addition we note that CRT in question 24 is suggesting a new license with increased fee (in our view potentially illegal unless there is a new act of parliament) for boats that wish to remain in one area. This
is in our view a function of creating a sustainable mix of towpath, short and long term moorings supported by enforcement.

We would URGE all members to respond to the consultation, if you have not received a copy contact customer services who will email or post one out to you.

NABO is planning to launch a wider campaign shortly whose aims are to ensure that CRT and EA put boating and boaters at the forefront of their thinking and actions when promoting the waterways. This will have the tag of ' As a boater are you feeling marginalised ?'

NABO Council

... Says it all really ...

Photos: (1st & 2nd) The CRT online survey, (3rd) Ian Rogers - not big on communicating with boaters.