NBTA CHALLENGES EA PRICE HIKE POLICY
August 2018 - The first boater organisation – and so far the only one – to challenge the Environment Agency’s plans to hike boat registration fees by between 10 per cent and 5.7 per cent per year for three years is the National Bargee Travellers Association (NBTA), as Alec Wood reports
The Environment Agency (EA) is consulting on proposals for increases massively above inflation in 2019 to 2020 and 2020 to 2021 and NBTA’s chair, Pamela Smith is urging members to respond by post, email or online before it closes at the end of August.
The EA has already increased registration fees (the equivalent of Canal & River Trust licences) for 2018-2019 on the River Thames by 5.7%; on the Anglian Waterways by 7.5% on the Upper Medway by 10%. The proposed increases mean that for three years running from 2018 to 2020, boaters will see registration fees rise by 5.7% each year on the Thames; 7.5% each year on the Anglian Waterways; and 10% on the Upper Medway.
The NBTA says it opposes all boat registration and licence fee increases except those genuinely in line with inflation, claiming that, if these increases are implemented they will ‘result in more boat dwellers struggling to pay the registration fee, more boats becoming unregistered and more people losing their homes’.
The NBTA says it will publish its full response to the consultation but points out to members that liveaboards are not even mentioned in the consultation. “It seems the EA has not considered the impact of the steep increases on people whose boats are their homes,” says Pamela Smith.
An EA lock on the Thames
“The use of boats for leisure is declining and there is a corresponding growth in residential use of boats. An estimated 35% of inland waterway boats are now used as the owner's only, primary, secondary or temporary home.
She goes on to say “Boat dwellers will suffer the greatest negative impact of these proposed fee increases, because they depend on the waterways for their home and unlike a leisure boater cannot simply decide to give up a hobby.
“The fee rises will have a disproportionate adverse impact on the most vulnerable boat dwellers, putting them at greater risk of losing their homes through an inability to pay the higher registration fees.
“The majority of boat dwellers are working people on low incomes and retired people on modest, fixed incomes. If they cannot afford the increased fees, the majority will not be able to afford to move off their boats into bricks and mortar, whether rented or bought. Most will end up living in caravans, vehicles, sofa-surfing or on the streets.”
The NBTA chair urges that the EA should employ a Welfare Officer on a similar basis to the CRT Welfare Officer to mitigate the impact of the fee increases on the most financially vulnerable boaters who depend on the EA waterways for their home.
She says: “The fee increases will be counter-productive, leading to more unregistered boats and more loss of income as boaters, especially liveaboards, find the increased fees progressively harder to afford over the three years of implementation.
“To keep costs down the EA should restrict its enforcement activities to ensuring that boats are registered.
Pamela Smith goes on to point out that the EA may well be in breach of equalities legislation: “No Equality Impact Assessment has been carried out on these proposals. The EA is a public body that exercises statutory functions as a navigation authority. In respect of these statutory functions, which include boat registration, it is subject to the General Public Sector Equality under Section 149(1) of the Equality Act 2010 to:
a) eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under this Act;
b) advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it; and
c) foster good relations between persons who share a relevant protected characteristic and persons who do not share it."
“The EA has not demonstrated in the consultation how the proposals meet the requirements of the General Public Sector Equality Duty and it has not carried out an assessment of the impact of these proposals on people with the protected characteristics defined in the Equality Act. The EA is
therefore in breach of the Equality Act.”
The NBTA also points out that the consultation may be pointless saying: “The charging proposals the EA is “consulting” on have already been in preparation for 6 months and have already been approved by the EA Board; the Treasury; Waterways Minister Thérèse Coffey; and by Michael Gove, Secretary of State for Environment, Food and Rural Affairs.
“The consultation document also states that the increases “reflect the significant gap between existing levels of income from boat registration charges on each waterway and the cost of providing the services which these charges pay for”.
You can take part in the consultation here: EA Consultation on charges
Photos: (1st) The consultation document, (2nd) Moored on the Thames, (3rd) An EA lock on the Thames.