NBTA response to Licence Review survey

Marcus Trower

National Bargee Travellers Association

Response to ‘Findings of an engagement survey of Canal and River Trust waterway users: Report for the Commission of the Trust’ (June 2025)

September 2025

Executive summary

This document presents the response of the National Bargee Travellers Association (NBTA) to a report commissioned by the Canal and River Trust (CRT), carried out through an online survey by Campbell Tickell Ltd. in March and April 2025 and published in June 2025 (Report). The Report was carried out in conjunction with the CRT’s Future of Boat Licensing Commission (Commission), which first met in January 2025. The NBTA has previously published its response to the Commissions’ Terms of Reference here.

In sum:

  1. Findings relating to itinerant boaters reflect concerns that NBTA has voiced repeatedly to CRT
  2. The Report demonstrates clear dissatisfaction with CRT’s management of the waterways across stakeholder groups
  3. The findings of the Report suggest that CRT’s Commission has been misguided in its focus on boat numbers and potential legislative change
  4. The data-gathering exercise reflects the failure of the Commission more broadly to engage productively with itinerant boaters, the group most likely to be impacted by change.

1. Findings relating to itinerant boaters

A quarter (494, 24%) of respondents who identified licensing as an issue raised specific issues facing “continuous cruisers” (p.10). These included:

  • Increased licence costs and additional charges applied to licences for boaters without a home mooring
  • Stress and uncertainty relating to lack of clarity and CRT’s “constant pressure” and “aggressive enforcement”
  • Barriers to accessing statutory services such as healthcare and education

These concerns mirror ones voiced repeatedly by the NBTA over several years, which have been largely ignored or met with defensiveness by CRT. For example:

  • NBTA has campaigned repeatedly against increases to the licence costs, the “surcharge” on boats without a home mooring, and the implementation of chargeable moorings, voicing its concerns to CRT, MPs, local governance bodies and others.
  • NBTA has provided casework support for boaters facing enforcement – including eviction – at the hands of CRT, and has emphasised the detrimental effects of unclear and aggressive enforcement, such as to boaters’ mental health.
  • NBTA has provided casework support for boater families attempting to access education, and voiced concerns about barriers to essential services created by CRT’s increasing and unlawful requirements regarding cruising range, distance and patterns of travel.

The Report confirms the relevance of NBTA’s campaigns, and suggests that a more collaborative approach to engaging with key waterways stakeholders may have resulted in better outcomes.

2. Dissatisfaction with CRT’s management

The Report provides irrefutable evidence that diverse waterway users across the UK are dissatisfied with CRT’s management of the waterways, and that CRT are failing on what Report refers to as “getting the basics right”.

  • More than 8 in 10 respondents (3,939, 84%) were frustrated with the day-to-day operational management of the waterways (p.20).
  • Over 60% of respondents raised the most frequent issue in the report: maintenance (p.21). This included effective maintenance of locks, towpaths and banks, management of water supply and a lack of investment in infrastructure.
  • It is notable that the number of CRT employees paid over £60,000 p.a. doubled between 2013/14 to 2023/24. In the same period, CRT invested in only two drinking water taps and no new sanitation facilities. And yet in only three years (2020-2023) CRT permanently shut down 21 sewage or rubbish disposal facilities.
  • These facts confirm the survey respondents’ perceptions of a decline in facilities and waterways management, and the suggestion that expenditure on senior staff salaries has become a priority to the detriment of CRT’s maintenance of the waterways and fulfilment of its charitable objects (p.22).

3. Misguided focus of the Commission

The Commission’s Terms of Reference state that itinerant boaters have “created challenges for the Trust both from an operational, financial and reputational perspective”. They point to a “steadily increasing number of boaters licensed as continuous cruisers and use of vessels for full time residential purposes” as a cause for reviewing the licensing framework, and they anticipate legislative change as a solution.

However:

  • The Report shows that boat numbers are not a significant problem for waterway users, with only 1 in 20 (210, 5%) seeing overcrowding on the waterways as an issue (p.14).
  • Almost half of the total number of survey respondents (2,253, 48%) mentioned issues pertaining to the fairness of the licensing framework (p.8). However, the solutions proposed were not legislative: almost half (45%) of those who identified this issue considered pricing and economic incentives as a possible solution, with less than a quarter (24%) suggesting legislative change (p.8).
  • This amounts to 540 respondents of the total survey respondents, showing that 9 out of 10 respondents were not in favour of legislative change.

The report notes that: “There was an overall sense that the licensing model lacks the nuance necessary to accommodate all user types” (p.8). We would like to point out that Section 17 3 c ii of the British Waterways Act 1995 was drawn widely precisely to provide that nuance and to accommodate all user types. This was previously pointed out in NBTA’s response to the Commission’s Terms of Reference.

4. Shortcomings and public engagement

In a meeting with the Licensing Review Commission on 16th May 2025, the NBTA requested the anonymised raw data of the survey, but this has not been provided. In an email dated 12th September 2025 the NBTA requested a second meeting with the Licensing Review Commissioners and this was refused.

Open communication, accountability and respect for research stakeholders are pillars of research integrity in the UK (as laid out in the Concordate to Support Research Integrity; see especially pp.3-4). In its lack of consultation with itinerant boaters in the construction of the data-gathering exercise – and in the work of the Commission more broadly – Campbell Tickell and CRT are missing an opportunity for productive engagement with a key stakeholder group, as well as ignoring established norms of research practice. Further, they have failed to share data openly with the communities it was extracted from. As NBTA previously noted in its response to the Commission’s Terms of Reference, exclusion of the most affected group contradicts a globally recognised policy-making principle: “nothing about us without us.”

In addition, we set out here some of the most evident shortcomings of the report:

  • The categorisation of responses at times failed to adequately differentiate within categories, leading to significant and problematic ambiguities. For example, reported concerns about “enforcement” were not split clearly enough into concerns that CRT enforcement is too strict, versus concerns that CRT enforcement is not strict enough. There is a similar inadequacy of differentiation regarding the fairness of licensing options. The same applies to solutions proposed by respondents, such as non-legislative “changes to Trust policy and guidance” – it is not made clear in which direction respondents think CRT policy and guidance should change.
  • The survey asked questions for which a narrative answer was invited, but very little qualitative analysis of the responses was carried out.
  • In paragraph 3.20, CT reveals a fundamental misunderstanding of boat licensing law by referring to a “continuous cruising licence”, which does not exist. The licence is a boat licence that can be held either with or without a mooring. This misunderstanding is compounded by the failure to differentiate between the “continuous cruising licence” and CRT’s interpretation and enforcement of the law regarding boats without a home mooring. It leads to the conclusion that the “continuous cruising licence” is inflexible; however, in law, the license encompasses a wide range of different patterns of boat use, including by families with children at school.