Here we publish guidance from the NBTA for completing the CRT Licence Review Commission survey. You can also download it as a Word document here NBTA_Guidance_for_filling_in_CRT_Licence_Review_commission_surveyV3_Final
NBTA encourages you to complete the survey but recommends that you engage with it cautiously. CRT has initiated this Licence Review by falsely representing itinerant boaters and licensing legislation. You can find details of this in the Terms of Reference document. Whenever you answer a question in this survey, ask yourself, “Can my answer be used against the itinerant boating community?”
In order to maximise the effectiveness of this survey, we recommend only putting forward three primary issues that impact the boating community as a whole, such as the lack of accountability or oversight of CRT, the lack of maintenance of the waterways and facilities, and CRT’s persistent persecution of itinerant boaters through its discriminatory policies.
We know that if there are a number of identical survey responses, some organisations will treat them as only one response. We therefore recommend putting the suggested responses below into your own words.
While there are many individual concerns, such as the dumping of rubbish on the towpath, these grievances could be used against us to justify changes in the law, licensing alterations, or stricter enforcement policies. Therefore we have identified three key issues that we believe should be addressed in the survey. We encourage boaters to avoid divisive concerns that could divert attention from our shared interests and potentially result in significant changes that will make life difficult for all boaters.
The survey is online here https://www.smartsurvey.co.uk/s/CandRTrust/
With this in mind, we have gone through the survey to give guidance on answers to help collectively raise our concerns to this “independent” commission:
Question – Describe the primary nature of your relationship with the Canal & River Trust, or interest in this engagement:
If applicable, we suggest that you write down that you are a boater and include other user groups you are a part of, for example “towpath user (pedestrian/ cyclist)”.
Question – Which part of the canal and river network are you most engaged with? This could be via use, or proximity to where you live. Please tick all that apply.
We suggest you include as many waterways as you visit, or the Whole Trust Network, if applicable.
Question – What kind of licence do you have?
Most of us will have a “leisure” licence (either with or without a home mooring) as the other licence types are business and commercial.
Question – Please indicate how many issues you would like to tell us about – required.
Click 3 issues
Question – What is the issue?
CRT’s Lack of Accountability.
The Charity Commission, Waterways Ombudsman, local authorities, and DEFRA all lack the power to influence CRT’s policies. MPs report an inability to affect CRT’s executive decisions.
This creates a situation where no government body has operational oversight. The Waterways Ombudsman, funded by CRT, cannot be considered truly independent, undermining its ability to provide impartial redress. There is inadequate representation for customers, particularly itinerant boaters, whose needs are often overlooked. CRT enjoys free rein to implement policies without meaningful consultation or accountability, despite its reliance on public funds.
Question – Why is it an issue?
Currently, there are no mechanisms for the accountability of CRT. The current situation, where an organisation with significant public responsibilities and funding operates without effective checks and balances, is unsustainable and demands urgent reform.
Question – Whom does it affect?
All users and taxpayers.
Question – What changes do you think could be made to help resolve the issue you have identified?
Other (please specify)
[NB there is no word limit for this section so we don’t know how much you can write]
A truly independent, statutory Ombudsman, free from CRT funding and influence, is essential for objective, impartial dispute resolution. A designated government department must be granted clear authority to provide operational oversight and ensure CRT’s accountability. Improved representation for customers, particularly itinerant boat dwellers, is crucial for ensuring their voices are heard and their needs addressed. A full public inquiry into CRT’s governance, policies, and use of public funds is necessary to restore public trust and ensure accountability.
Question – Please add a comment to explain your response more, if you would like.
Write extra if you want.
Question – What is the issue?
Running down of facilities and waterways infrastructure.
A major area of concern is the continued erosion of services for customers. Basic maintenance is non-existent, which often leads to total and long-term collapse of critical waterway infrastructure. Lock bollards and mooring rings are not painted, causing trip hazards and other health and safety issues. Lock paddle gear is rarely greased, causing issues with lock use and injuries as a result. Grass at designated moorings is not cut. A complete cessation of regular dredging causes a reduction in depth, making navigation difficult everywhere and in some areas almost impossible.
Question – Why is it an issue?
CRT’s mismanagement.
Question – Whom does it affect?
Boaters and other people who use the waterways.
Question – What changes do you think could be made to help resolve the issue you have identified?
Other (please specify)
[NB there is no word limit for this section so we don’t know how much you can write]
Better management of the waterways. Stop selling off assets and wasting money.
Question – Please add a comment to explain your response more, if you would like:
Write extra if you want.
Question – What is the issue?
CRT’s anti-itinerant boat dweller policies.
Aggressive enforcement against boaters without a home mooring; the discriminatory escalating surcharge on their licence fees; chargeable moorings especially in London; and this review of boat licensing. In 2012 the Waterways Minister gave an undertaking to Parliament that the rights of boat dwellers would not be diminished by the transfer of BW to CRT. However, since then there has been ever-tightening micro-management of their cruising patterns and increasingly punitive enforcement that makes it difficult to carry on their daily lives. The threatened seizure of their homes is out of all proportion to any alleged non-compliance.
Question – Why is it an issue?
The surcharge is making the licence unaffordable. Whatever boaters’ cruising range or pattern, they are told it is non-compliant. Enforcement is increasingly opaque, with no coherent reasons given why licence renewals are restricted to 6 months or blocked altogether. It is hard to predict what cruising pattern will result in the renewal of a licence for 12 months. A small misjudgement in cruising pattern could cause homelessness. Chargeable moorings make it financially prohibitive to moor in central London, compromising their cruising patterns, licence renewals and access to employment. This review aims to prohibit their way of life with new laws.
Question – Whom does it affect?
Up to 15,000 boaters who own the 7,300 boats without a home mooring, and an unknown number who have been forced by CRT’s aggressive enforcement into taking moorings they either cannot afford, are not allowed to live on, or don’t want. CRT’s enforcement of Section 17(3)(c)(ii) of the British Waterways Act 1995 goes beyond its legal powers. Around 1,800 out of 7,300 boats (that’s more than 1,800 people) are under some form of enforcement, either a 6-month licence, renewal blocked without a mooring, or non-renewal leading to Section 8 and probable homelessness.
Question – What changes do you think could be made to help resolve the issue you have identified?
Other (please specify):
[NB there is no word limit for this section so we don’t know how much you can write]
Surcharge: drop the surcharge and raise the money by charging all boaters an equal fee increase; cutting top salaries; spending less on enforcement.
Enforcement: simply enforce the 14-day limit and no more. The 1995 Act does not empower CRT to enforce range or cruising pattern.
Drop the chargeable moorings; this costs CRT more than it raises.
Drop the licence review, as the issues relating to boaters without a home mooring were examined forensically in 1991-1994. The makeup of the itinerant boating community has not changed since. Any change will cause widespread homelessness.
Question – Please add a comment to explain your response more, if you would like:
CRT’s current enforcement policy from 2015 onwards is unlawful. This is because its interpretation of the law goes beyond the requirements placed on boats licensed under Section 17(3)(c)(ii) of the British Waterways Act 1995. No minimum range, distance, or cruising pattern is specified. Parliament defined bona fide navigation as compliance with the limit of 14 days in one place. The law was widely drawn to accommodate many different patterns of boat use in response to boat dwellers who had different circumstances, including employment in a fixed place and children attending school.
In 2015, thousands of boaters without a home mooring who had the same travel pattern for many years and whose licences had been renewed without any issue were suddenly told that their annual travel patterns no longer complied with the law. Since then, enforcement has become increasingly aggressive and opaque, with fewer cruising patterns deemed compliant and increasing numbers of people told their range of travel is not far enough. CRT does not have the legal power to keep moving the goalposts like this.
Itinerant boat dwellers should have rights to security of their home. This should include prohibiting CRT from: seizing, detaining or placing a lien or charge on their boat; banning or injuncting a boat dweller or their boat from their waterways; or recovering debts from a boat dweller other than via Civil Debt procedures. Boat licences should always be renewed for 12 months unless the boater requests otherwise. Sections 43(3) and 43(8) of the Transport Act 1962 should be repealed.
Question –
The future of boat licensing: additional comments –
Are there any issues you haven’t been able to cover? [this is at the end of the survey]
CRT’s aggressive attitude towards itinerant boat dwellers is causing many to suffer poor mental health. People are constantly worried about threats to their homes and lives. The non-renewal of a licence for the full 12 months causes fear, stress, anger, and a sense of injustice because it could mean the eventual loss of home. For a so-called charity claiming that “Life is Better by Water”, CRT’s behaviour exhibits the exact opposite.
Question – The Terms of Reference for the Commission set out that it should seek to apply the following principles in considering improvements and outcomes:
Fairness
Clarity
Sustainability
Effectiveness
Are these the right principles for evaluating the impact of any changes that result from this engagement?
We suggest clicking ‘Strongly disagree’ to all of the above principles.
We suggest you write the following in the ‘Other Outcome’ box:
[NB there is no word limit for this section so we don’t know how much you can put]
The four principles above are subjective, arbitrary and meaningless without context. The only context provided is CRT’s biased Terms of Reference which unfairly misrepresents itinerant boaters. Therefore I strongly disagree with all four principles. The outcomes I want are real stakeholder engagement and transparency. I want the broader social and economic impacts on the itinerant boating community to be central considerations in this review. I also want CRT to value and support the itinerant boating community and respect that there are many forms of itinerant boaters and that licensing legislation (Section 17(3) of the British Waterways Act 1995) is intended by Parliament to protect itinerant boating in its many forms. Principles that do not prioritise the interests and well-being of individuals and the wider boating community should not be used to evaluate the impact of any changes resulting from this survey.
Other questions
At the end of the survey there are some Equality and Diversity questions, these are optional.
See also