Supplementary memorandum submitted by
the National Association of Boat Owners (NABO) (BW 14a)
1. BOAT SAFETY
SCHEME (BSS)
NABO has representatives on both the BSS Advisory
and BSS Technical Committees who have both contributed greatly
to the evolution of the Scheme. For this reason we feel we can
speak with some authority on the effects that withdrawal of navigation
authority funding seems to be having on the BSS, and its relevance
to "Current users of the waterway network and their relationships
with British Waterways".
Primarily the BSS was set up through the navigation
authorities' duty of care to minimise the risks to third parties
through fire, explosion and pollution. It was also, with our encouragement,
trying to promote education in boat safety, as there seemed to
be little statistical evidence that an inspection on one day in
every four years had any measurable effect on the risk factors
the scheme was intended to reduce.
In 2006, the BSS said it was aiming to be self
financing by around 2011, but now funding has been suddenly withdrawn
from both the EA and BW. As a consequence of this and the adoption
of the scheme by the Broads Authority causing extra workload,
it appears that its good intentions are under threat and the scheme
is in danger of reverting to only fulfilling its obligations to
the navigation authorities yet being financed only by boaters.
It may even have to economise on its support committees whose
input has been invaluable to its evolution.
Even with these savings, the BSS has still to
find extra funding. The BSS charges boat owners indirectly through
selling certificate blanks to those who inspect the boats. These
examiners and surveyors are not in the direct employment of the
scheme: their inspections of boats are run as independent businesses
and the certificate costs are passed on in their charges. From
1 April 2007 the BSS intends to raise the charge for each certificate
by over 110% from £13.22 including VAT to £28.20 at
trade price. Examiners say the outlay required to buy pads of
30 certificates at the new price in advance may, with mark-up,
mean charging their customers up to £50 extra on an examination
that costs now between £80 and £140.
NABO's concern is that boaters will refuse to
finance a scheme which seems only to benefit the navigation authorities'
protection against litigation, as they are not convinced that
the scheme significantly reduces the risk of boat fires or that
the benefits of the scheme have much respect from boat insurers.
Other users could argue that BW is being forced by GiA cuts to
skimp on its duty of care to its customers.
NABO is keen to explore alternative measures
to promote boat safety and would ask the Committee to consider
including a recommendation in its report to set up a Government
sponsored INLAND waterways safety executive which can draw on
the considerable experience of inland navigation users as well
as professionals. We would recommend the body be independent of
the MCA, either standing alone or maybe under IWAC or AINA, with
a remit to promote operational as well as construction safety
education on boats in addition to applying minimum mandatory construction
standards as required by UK and EU regulations.
2. SINGLE NAVIGATION
AUTHORITY
NABO has read the "uncorrected oral evidence"
given by the Inland Waterways Association and wishes to point
out to the Committee that not all users, even boaters, are in
agreement that there should be one navigation authority based
on British Waterways.
In fact amongst our Council there is a body
of opinion that the transfers of navigation responsibilities in
the reverse direction might be desirable, namely that major rivers
like the Trent below Nottingham and the River Severn should be
transferred to the EA navigation department where they can be
better integrated with flood control and general river management.
NABO is in support of a unified boat licensing
system but does not believe it is necessary to merge the navigation
authorities to achieve that.
3. REDUCED STANDEDGE
TUNNEL TRANSITS
This is further evidence of potential cuts in
the services offered by BW that have come to light since the closing
date for main submissions.
The cost of passages through the Standedge Tunnel,
the Anderton Lift and the Ribble Link is borne by all BW craft
licence holders through an agreed 2% surcharge on annual licences.
When that agreement was made there were five tow convoys each
week through the tunnel.
Last year it was down to three and BW Yorkshire
propose to further reduce it to two a week. Not only will this
act as a further restriction on the freedom of boaters, but it
will act as another deterrent to what is now a "Seen it,
done it, got the T-shirt but won't do it again" canal and
further devalues the benefits promised to the local community
from the Huddersfield Narrow Canal restoration.
Talks are being held with local interested parties
but NABO is concerned on behalf of its many members to whom the
route is as an exceptionally scenic alternative link between the
Midlands and the Yorkshire waterways avoiding the tidal River
Trent. We are also concerned about damage to boats through having
too many boats in each "train".
The National Association of Boat Owners (NABO)
March 2007
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