Fight the EA waterways registration fee increases: please respond to consultation by 30th August

Boaters on waterways managed by the Environment Agency (EA) are facing steep increases in boat registration fees well above inflation. The EA is consulting on proposals for increases in 2019 to 2020 and 2020 to 2021. The consultation ends on Thursday 30th August 2018. You can respond online here

You can download the consultation document here

The EA has already increased registration fees 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 are the same as the fee increases for this year. That means 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 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 EA says “We were going to consult on a new charging scheme and 5-year charging plan this year. However, this work is significantly more complex than we initially thought… Therefore, we now plan to consult on proposals to implement this year’s percentage increases for the next 2 years.”

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”.

The NBTA opposes all boat registration and licence fee increases except those genuinely in line with inflation. 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 will publish its full response to the consultation but in the mean time here are some key points:

  • 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. 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.
  • 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 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.
  • 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.
  • 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 Duty 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.