Alan de Enfield

Its not so much the chance of the Police 'getting you' as the possibility of having an accident, and be found moving without permission an unlicenced boat that does not have a safety certificate. It cost nothing to ask and they will not withold permission without good reason so why wouldn't you.

It was an IIMS member, (on the way back from doing a boat survey in the Netherlands) who failed my NB BSS as it did not have an RCD, when I pointed out an RCD was advisory only he said in his view it was a requirement and unless I fitted one he woould issue a 'fail. Complained to the BSS who simply said we will check if he needs further training, but refused to tell me the outcome of their investigation.

That is how Rolls Royce cars are (were?) built They used to be one of my customers and whenever we had VIPs from other group companies we'd do a RR factory tour for them. When we had an international meeting at one of our USA factories in Florida, they organised a team event of rescucing a live Aligator and us having to carry it about a mile thru the swamp - and, having to memorise a detailed message about its illness to give to the Vet at the other end. All I remember is that "Aligators have nictating eyelids and .............."

Many of them do both jobs - neither seem to be 'standalone' means of employment, but add another £200 for doing the BSS after/during the survey and it becomes a paying proposition.

But you are never more than 60nm from land - its not like you are 120nm from land. We reguarly did weekends in Dun Loghaire / Dublin from our moorings at Holyhead and it was 60 miles. Blue water sailing is totally different to 'confined waters' OK my misunderstanding - I thought Gas Safe was a trade organisation and only engineers registered with them were allowed to work on gas

That was the pieces of paper I mentioned .............

I too fill my own gas cylinders - decanting from a 47kg, or for the small 100g camping cartridge from a 500g cartridge. Calor Gas even supply a pipe for decanting form one to another. 'Experts' on here say that the hose has valves in it to stop its use as a decant hose, but having spoken to Calor they say it doesn't. No - the nearest I came would be when I was a civilan instructor in the RAF teaching cadets to fly at weekends, or maybe the years I spent writing 'standards' for the NCB As is the GSIUR legislation - the problem is how to prove you are competent, the only acceptable way currently seems to be that you are a member of a trade organisation and have 'a bit of paper' - maybe if you do your own work and it fails that proves that you are not as competent as you think.

following a meeing of the committe It is endorsed which means it is binding. In summary, endorsement is a straightforward yet significant action in legal documents. It transforms a piece of paper into a binding agreement

The RSG have been tasked by the European commission to act as an intemediary between the commision and the notified bodies. They are effectiveely the front line between the RCD/RCR and the users. RSG stands for Recreational Craft Sectoral Group, a group charged by the Commission to undertake technical interpretations of the Directive particularly those associated with compliance assessment. The RSG Guidelines have been drafted by the RSG with the objective of helping designers and builders ensure their product complies with, and may be satisfactorily assessed against the Directive. As drafted these Guidelines are the best tool available to assist with ensuring compliance. Part E reproduces the Essential Requirements of the Directive and gives interpretations of what the RSG consider to be the most appropriate method of achieving compliance. The Guidelines reproduce many parts of the Directive including the Annex I, the Essential Requirements to which boats must comply. The RSG gives binding decisons on questions regarding the implementation of the RCD/RCR Example : A notified body or builder aks them a question

As in the norm. You then either walk away (and just lose your survey cost) or try and negotiate a reduction for any work needed - but - do not have an expectation that the seller will reduce it as much as you want. Both parties are at liberty to walk away and the seller has lost nothing (cost wise) and another buyer will be along soon. You need to decide at what point you 'stop negotiations' and make a purchase - only you can make that decision. I had a 1998 NB with a 12mm base plate, it had never had the base plate painted, blacked or anything - it was raw steel. In 2015 I had the bottom thivkness measured whildt out for blacking - it varied between 12mm and 13mm which would be within the original manufacturing tolerances.

The seller could argue that he has already 'priced in' the cost of work needed. If the price asked is comparable with similar boats selling prices then "you can ask", but, he may take the stance that I normally take - " that is my price, there is maybe a little movement, but dont make 'cheeky offers'" You always have the choice of walking away - there are many more boats available.

Surely, anyone with a modicum of intelligence, wouldn't need the reason for the use of boot-lace ferrules explaining to them. How much dumbing down do we need ?

The owner probably claims he cannot move under the clause : "14 days or such longer period as is reasonable in the circumstances."

You do not need either a licence or a BSS to move a boat 'for repair' but you do need to inform C&RT and get their permission. You may need insurance but talk with C&RT Here is the actual wording in the legislation : (a)The refusal or withdrawal by the Board of a relevant consent in respect of any vessel on the grounds that the vessel does not comply with the standards applicable to that vessel shall not preclude the movement or use of the vessel with the consent of the Board (which shall not be unreasonably withheld) and subject to such reasonable conditions (if any) as they may determine. (b)Without prejudice to the generality of paragraph (a) above, the Board shall not withhold their consent under this subsection to the movement or use of a vessel for the purpose of taking it to a place where it may be repaired or modified so as to comply with the standards applicable to it, or for the purpose of taking the vessel to be destroyed, unless such movement or use would give rise to the risk of obstruction or danger to navigation or to persons or property.

This is from the RCD technical section (The RSG) 3. CONFORMITY OF THE PRODUCT Article 14: Presumption of conformity Products which are in conformity with harmonised standards or parts thereof the references of which have been published in the Official Journal of the European Union shall be presumed to be in conformity with the requirements covered by those standards or parts thereof, set out in Article 4(1) and Annex I. And : 4. CONFORMITY ASSESSMENT Article 19: Applicable conformity assessment procedures. The Recreational Craft Directive establishes procedures applying to the assessment of compliance with the Essential requirements. These procedures comply with Council Decision No Decision n. 768/2008/EC concerning the modules for the various phases of the conformity assessment procedures and the rules for the affixing of the CE conformity marking, which are intended to be used in the technical harmonization Directives.It is to be noted, amongst other points, from this Council Decision (in Annex), that: 1. The essential objective of a conformity assessment procedure is to enable the public authorities to ensure that products placed on the market conform to the requirements as expressed in the provisions of the Directives, in particular with regard to the health and safety of users and consumers, 2. Conformity assessment can be subdivided into modules, which relate to the design phase of products and to their production phase, 3.As a general rule a product must be subject to both phases before being able to be placed on the market if the results are positive. Notified bodies should be encouraged to apply the modules without unnecessary burden for the economic operators. The Commission, in cooperation with the Member States, must ensure that close cooperation is organized between the Notified Bodies in order to ensure consistent technical application of the modules, 4. Whenever Directives provide the Manufacturer with the possibility of using modules based on quality assurance techniques, the Manufacturer must also be able to have recourse to a combination of modules not using quality assurance, and vice versa, except where the compliance with the requirements laid down by the Directives requires the exclusive application of a certain procedure. 5. Whenever the NB subcontracts testing or verifies subcontracted testing, etc., it is the responsibility of the NB to ensure that the subcontractor has the facilities and meets the criteria for that function (Annex XIV). As written in the directive for module B, "applicants shall include a written application that they have not lodged an application with any other notified body". This declaration should be extended by a declaration that they have terminated any existing application with another NB for the same product and the same assessment module.

will the replacement of the old shit with the new shit affect the safety or stability of the boat ?

If adding solar or lithium batteries, or different means of propulsion to a post 1998 boat then you may find the law thinks differently. You could argue the chance of being caught is remote but that doesn't affect the legality of what you are doing.

A fairly detailed cut & paste but the figures are interesting. It shows that the majority of boaters are at the bottom end of the income scales with a large number being below the ONS figure of median household income. It shows that about half of liveaboad boaters have chosen a boat because it is a lower cost than the alternatives The March 2023 national boat count identified there were 35,814 boats on the Trusts waterway network (including private marinas), of these 27,388 were boats with a home mooring, and 7379 were boats without a home mooring (continuous cruisers). Other boats counted include those that are trailable (i.e. are kept out of the water) or where mooring status has not been declared yet. The 2022 boater census indicated that 23.4% of boaters with a home mooring were permanently living aboard and 79.9%% of boaters without a home mooring were permanently living aboard. Approximately half of liveaboard boaters responding to the boat licence consultation stated that reducing the cost of living was a motivation when they first started to boat, with liveaboard continuous cruisers even more likely than those with a home mooring to state this as a motivation. In the 2022 Boater census 33.7% of respondents stated that their day-to-day activities were affected by a disability or a long-term health condition (10.1% a lot, 23.6% a little). 17.5% of respondents to the boater census said that they faced challenges living on a boat due to a disability or a long-term health condition. Fifty-seven percent (57%) of disabled boaters responding to the consultation who stated that they either started boating or continue to boat as part of a more affordable lifestyle believed that introducing a surcharge for continuous cruisers was much less 'reasonable' than the current model. The 2022 boater census indicates that 74% of all boat licence holders are aged over 55 (43% over 65) and 19% of boaters without a home mooring were aged over 55 (8% over 65). 5.2% of boaters responding to the boater census stated that they had children living aboard. As part of the consultation, we asked for information about household income. 53% of boaters stated that their household income was below £40,000, 43% stated their household was income below £30,000, and just over a quarter (27%) stating their household income was below £20,000. It is clear that for a significant proportion of boaters, including those with protected characteristics, their boats serve as their main or only residence. We have considered average income information from the most recent UK census to see if any groups are more likely to have lower incomes and therefore may find the impact of any increase to boat fees greater than other groups. 43% of all those who responded to the consultation stated that their household income was below £30,000 per annum. The Office for National Statistics estimates that from the most recent data available, the median household income was £30,500.1 Although this suggests that the household income for a significant minority a boaters is below the median, the current average licence fee is also well below comparable costs for land-based accommodation. 27% of boaters responding to the consultation indicated their household income was below £20,000. The average annual boat licence fee as of October 2022 was £856.63, this would be equivalent to approximately 4.3% of a £20,000 annual household income. This is considerably lower than what households on median income on accommodation costs. The 2021 UK Census states that private renters on a median household income could expect to spend 26% of their income on a median-priced rented home in England compared with 23% in Wales in the financial year ending March 2021. London was the least affordable region with a median rent of £1430 being equivalent to 40% of median income. It is important to note that the cost of a boat licence is only part of the cost of owning and/or living on a boat. Maintenance costs, and mooring fees (for those with a home mooring) would all be additional costs. The cost of maintaining and running a boat will depend on different factors. For example, how a boat has been maintained, or the age of boat (older boats are likely to require more maintenance). Even taking these additional costs into account, accommodation costs for living on a boat are regarded as a much more affordable than land-based housing costs. A rise in the costs of the boat licence would increase the proportion of income liveaboard boaters spend on accommodation, this would impact most on those on lower or fixed income (see below). However, the boat licence increase would have to be very high before it impacted significantly on the affordability to live on a boat. Even if the average boat licence price were to double, therefore increasing the accommodation costs for living on a boat, the cost of living on a boat would still be well below that spent on accommodation costs by households on a median income in England and Wales, and less than a quarter of that spent by households on a median income in London. Boaters who continuously cruise do not pay a mooring fee, or for accessing water, Elsan, or refuse facilities provided by the Trust, so the cost of living on a boat would remain comparatively more affordable than median-priced rented homes on land. Although there is no income data available for all equality groups, the ONS state that income inequality for retired households remains consistently lower than that of nonretired households. The UK government also report that there is a disability pay gap with disabled persons earning 13.8% less than non-disabled persons. The UK government also report that there is a gender pay gap of 8.3%. The ONS state that the ethnicity pay gap differs across regions and is largest in London (23.8%) and smallest in Wales (1.4%) 4. Older people, those who are pregnant or disabled, can also be subject to reduced or fixed income due to personal circumstances or inability to work. Even where benefits are available to support certain groups, such as disabled people, these are to help cover the additional costs they experience as a disabled person, and not as additional unallocated income. Increases in the licence fee could be felt more acutely by these groups. The added cost of an increase in the boat licence could be a contributing factor in their ability to continue to boat or to continue to live aboard their boat. The increase would have a greater impact on those boaters living aboard their boat; for those who could no longer afford to live aboard their boat, this could lead to homelessness and the need to seek housing provision from their local council. Housing benefit/universal credit support is available for those who are on very low income. An increase in boat licence fees is likely to be covered by housing benefit/universal credit.

I think she/he was fed up of living in never-never land and having lost 2 years living with Walter Mitty said, "either a boat comes or I go"

Indeed they are not - but the various laws can state that compliance with an ISO specification is required. The adherence to the ISO standards is an automatic assumption of compliance to the RCR/RCD and means that the boat does not require inspection. If you chose to build without using the ISO standards then independant tests will be required to show that the perfomance is equivalent, or greater, than that required in the ISO standards. The ISO standards are considered to be best practice and should there be an 'incident', on a boat of any age, I'm sure there would be questions asked around the standard of build of the relevant part of the boat. From the RCD/RCR Other ways to comply with the essential requirements The application of harmonised standards is not the only means to demonstrate the conformity of a product. However, only harmonised standards, after publication of references in the Official Journal of the EU (OJEU), may provide an automatic presumption of conformity against essential requirements covered by such standards. With the exception of the Directive’s mandatory reference to some harmonised standards (see Point 3), the manufacturer can choose whether or not to apply and refer to harmonised standards. However, if the manufacturer chooses not to follow the harmonised standards, he has the obligation to demonstrate that his products are in conformity with essential requirements by the use of other means that provide for at least an equivalent level of safety or protection. These can be technical specifications such as national standards, European or international standards which are not harmonised, i.e. not published in the OJEU, rules of notified bodies or the manufacturer’s own specifications. In these cases the manufacturer does not benefit from the presumption of conformity, but has to demonstrate the conformity himself. This implies that he demonstrates, in the technical documentation of a relevant product, in a more detailed manner how the technical specifications he uses provide conformity with the essential requirements. Manufacturers are advised to stay informed about the developments in international standardisation. Even if the manufacturer has not used harmonised standards, a change in the relevant harmonised standard could mean a change in the state of the art that implies that his product may not be compliant.

On the recent boaters survey, over 50% of boaters in London said they could not afford a mooring at any price (if it was free they'd love to take it) as their disposable income/discretionary spend was around zero once boat bills and living bills had been paid.

I do not see how 'geographical area' based licence fees would work - after all boats are mobile ! So everyone licences their boat in the lowest cost region. (And either lies about its location or immediatly moves it to the high-cost region where they really want to be) That could only work if the boats have trackers fitted, or the boat owner is fitted with an electric shock collar which activates if he goes byond the licenced area boundary.

I think you will find that it does exist for a HMer (c)either— (i)the Board are satisfied that a mooring or other place where the vessel can reasonably be kept and may lawfully be left will be available for the vessel, whether on an inland waterway or elsewhere; or (ii)the applicant for the relevant consent satisfies the Board that the vessel to which the application relates will be used bona fide for navigation throughout the period for which the consent is valid without remaining continuously in any one place for more than 14 days or such longer period as is reasonable in the circumstances. Such a place could be a boatshaped/size of ground such as someones drive or gaarden. This was the argument from the Judge and the problem with one word and two meanings. For a CCer it is 'defined' as a parish etc (bona fide navigation), whilst for a HMer it is defined as a boat sized 'space'. Hence the comment that if a HMer is moored alongside the towpath, and the next day moves a 'boat length' he has moved to another place.