Marina mooring and CC’ing - are the miles enough?

[Arthur Marshall]

12 minutes ago, GUMPY said:

The government are also going to give themselves access to pensioners bank accounts. Did you know pensions are classed as a benefit? This is a precursor to making the state pension means tested😱

You have been warned.

Seems fair enough to me. I can't see why some banker with a huge pension and millions in the bank should be given another couple of hundred quid a week by the state.

[GUMPY]

12 minutes ago, Arthur Marshall said:

Seems fair enough to me. I can't see why some banker with a huge pension and millions in the bank should be given another couple of hundred quid a week by the state.

It won't be that, it will be anyone with over £16k in savings* will lose out and anyone with a private pension will have that amount deducted from their state pension.

 

*Same as any other benefit.

[Arthur Marshall]

6 minutes ago, GUMPY said:

It won't be that, it will be anyone with over £16k in savings* will lose out and anyone with a private pension will have that amount deducted from their state pension.

 

*Same as any other benefit.

Well, it certainly won't be the Tories who bring that in, and I can't see Labour doing it on those figures, unless they whack the OAP up to a livable amount. Can't see either of them doing that, either. But if they cut immigration down as they seem to want to, there aren't going to be enough people in employment to sustain current levels. Who knows? What anyone says out of office tends to alter dramatically once they get into power.

[Higgs]

11 minutes ago, GUMPY said:

It won't be that, it will be anyone with over £16k in savings* will lose out and anyone with a private pension will have that amount deducted from their state pension.

 

*Same as any other benefit.

 

If you do not have the savings, you can, on top of your pension, claim rent and council tax. With the savings, you make do with the pension. As it currently stands. 

 

 

[___]

3 hours ago, David Mack said:

Under the 95 Act you are only required to notify CRT of your mooring status when you apply for a licence. You are not required to update them with subsequent changes  (although presumably your past behaviour could be a factor in 'satisfying the Board' when you apply to relicence as a CCer).

Boaters who frequently flip between having a home mooring and CCing are going to be an administrative pain in the neck for CRT once the differential licence cost comes in.

 

Presumably CRT can meet their legal requirements by issuing a licence (any licence) and are not duty bound to issue the lower rate licence for a boat with a home mooring simply because the applicant declares such?

 

Therefore if your past status or movement pattern suggests you do not make use of a permanent mooring then they can ask for evidence prior to issuing the licence.

 

I agree that us folk with transient mooring status may be a total PITA to CRT. Given I possibly make less use of CRT facilities as a boater without a home mooring than I did when I had a home mooring I shall have no problem with that.

 

Edited December 5, 2023 by Captain Pegg

[Momac]

4 hours ago, Captain Pegg said:

That’s suggesting the OP be less than totally honest about their true status. Why do that if you have a compliant cruising pattern?

Seems perfectly honest to  me since it sounds like  the boat will be in a  marina most of the time. Maybe not the same marina all year but what's to stop anyone declaring  home mooring and moving the home mooring from time to time? 

 

[Arthur Marshall]

15 minutes ago, MartynG said:

Seems perfectly honest to  me since it sounds like  the boat will be in a  marina most of the time. Maybe not the same marina all year but what's to stop anyone declaring  home mooring and moving the home mooring from time to time? 

 

Precisely. I've moved mooring three times, with a six week cruise in between, and I've never stopped being a home moorer even when I had no idea of the mooring I was going to get when I reached the new area. If your intention is to park the boat for most of the year in various marinas, you can't be a continuous cruiser because you're not, and have no intentions of, being on a continuous cruise for a while. Otherwise , a leisure boat would change its status every time it shoved off, which would be silly.

[Mike Todd]

It is unsurprising that the OP found CaRT staff unable to give clear answers as I do not believe that the Board have yet to decide how they are going to cope with the admin complexities of the new license scheme. (even if they have they have not told the rest of us!) Until now, it was technically necessary to advise CaRT whenever your mooring status changed but nothing much hung on that. Now it will be different.

 

Also, be aware that the new surcharges are not for CCing but for boaters without a home mooring so that, so far as liability to the surcharge is concerned, it does not matter what you do in between marina contracts, it is the lack of a mooring that matters. OTOH, given the processes around surrendering a licence mid term, I would not be surprised if the new arrangements mean that short periods of being without a home mooring will be relatively expensive. What is unclear is what CaRT will do to oversee the situation - it could well be that 'no home mooring' is the default and you have to submit formal documents for the periods when you do have one. That would be easier/cheaper for CaRT but even so is looking like being a source of confusion as any scheme beds in and even more complexities than we can now see, come to light.

[___]

1 hour ago, MartynG said:

Seems perfectly honest to  me since it sounds like  the boat will be in a  marina most of the time. Maybe not the same marina all year but what's to stop anyone declaring  home mooring and moving the home mooring from time to time? 

 

You can move as many times as you like but to legitimately claim the full lesser licence fee should each contract run absolutely consecutively with no gap?

 

I guess if you cruise directly between each within reason then you could argue it’s legitimate but you open yourself up to question.

 

Who knows what conversations take place between marinas and CRT regarding short term mooring holders?

 

I read it that the OP would like to retain a default position of not having a home mooring. Probably thinking about their long term status.

 

40 minutes ago, Arthur Marshall said:

Precisely. I've moved mooring three times, with a six week cruise in between, and I've never stopped being a home moorer even when I had no idea of the mooring I was going to get when I reached the new area. If your intention is to park the boat for most of the year in various marinas, you can't be a continuous cruiser because you're not, and have no intentions of, being on a continuous cruise for a while. Otherwise , a leisure boat would change its status every time it shoved off, which would be silly.

Clearly if you don’t hold a current mooring agreement and you are floating on CRT waters with a licence then you are a boater without a home mooring.

 

The key point is that up until now it’s been of no consequence as long as you keep moving. Hence there’s not really been any point in changing your declared status if it remains the same at the time of each licence renewal. That’s why I declare I’m a boater without a home mooring when in fact I spend the best part of half the licence period on a home mooring.

 

In future it will be of consequence so changing your status is arguably going to be necessary and the safe way of staying onside with CRT for transient moorers will be to default to not having a home mooring and work ‘back’ from there. Hopefully gaining credit on your licence account as you do.

The legal distinction as far as a home mooring is concerned isn’t where you are or what you’re doing but that you have a right of use to a mooring.

 

 

 

Edited December 5, 2023 by Captain Pegg

[Momac]

11 minutes ago, Captain Pegg said:

You can move as many times as you like but to legitimately claim the full lesser licence fee should each contract run absolutely consecutively with no gap?

 

That's a bit picky but I get your point.

I doubt C&RT care too much really. Looking at it with a dose of common sense the OPs proposed use pattern seems to me  a lot closer to a home moorer than it is to a continuous cruiser.

 

 

 

[___]

15 minutes ago, MartynG said:

That's a bit picky but I get your point.

I doubt C&RT care too much really. Looking at it with a dose of common sense the OPs proposed use pattern seems to me  a lot closer to a home moorer than it is to a continuous cruiser.

 

 

 

I’m wary of folk giving advice to the OP that although well intended and arguably pragmatic could lead the OP into conflict with CRT in the context of the proposed licence fee arrangements.

 

It really depends on the relative lengths of home mooring stints and the gaps between them and we don’t know that; and nor may the OP until the time comes.

 

I’m sure CRT care it’s just low on their radar today. That may change but you hope CRT have done adequate impact assessments on their new rules.

[beerbeerbeerbeerbeer]

I emailed CRT about this flipping from home mooring and no home mooring regards the surcharge and still await a reply. They’ve had their working week to reply, which is the time they promise to reply. 
 

There was a time for a few year when I’d be on and off different moorings in different counties and without moorings for short periods. I simply notified CRT (and my insurance) each time as they (CRT and insurance) requested. 
Til now it has always been the same leisure license so just a matter of them ticking a box. 

Very very simple. Almost sounded like a courtesy call from me. 

I’m interested to know whether the up coming surcharge will actually demand a different type of leisure license? If it does, then it will mean there will be the admin of cancelling one to issue another. 
Altering direct debit payments etc 🤷‍♀️
And as we know a license start on the 1st of the month. 
So no claiming back for half months or whatever. 
Which is all no big thing but..perhaps it will be a bigger PITA if some folk are changing their ‘status’ several times a year 🤷‍♀️.

 

The question from me; will it require a distinctly different type of leisure license now that there’ll be two different rates of charge, it’s  no longer just a simple tick box exercise?

[dmr]

3 hours ago, Arthur Marshall said:

Well, it certainly won't be the Tories who bring that in, and I can't see Labour doing it on those figures, unless they whack the OAP up to a livable amount. Can't see either of them doing that, either. But if they cut immigration down as they seem to want to, there aren't going to be enough people in employment to sustain current levels. Who knows? What anyone says out of office tends to alter dramatically once they get into power.

It doesn' matter who you vote  for, the government always gets in 😀

[junior]

Do what you want. Better to ask for forgiveness than for permission. 

[Momac]

2 hours ago, Captain Pegg said:

,,,,,,,,,,,,,,, you hope CRT have done adequate impact assessments on their new rules.

Their impact assessment is that they  have actioned what they were given approval to do via the majority after study of the results of a survey of license holders . Therefore the majority of license holders will be happy.

 

[Alan de Enfield]

3 hours ago, Captain Pegg said:

That may change but you hope CRT have done adequate impact assessments on their new rules.

 

 

They have - it is very detailed.

 

I have posted sections of it in various threads on the subject.

 

A couple of paragraphs from the 10 page asessment.

 

43% of all those who responded to the boat licence 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

 

 

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.

 

 

Conclusion : The potential equalities impacts relate to the additional costs burden on boaters with protected characteristics who may have lower incomes than boaters without those characteristics. In particular, the Trust has had due regard to the potential impacts on those boaters with disabilities who may require larger boats which attract larger licence fees, and who are less likely to be able to meet the additional costs. Mitigation is available to meet those costs, and reduce or remove the additional costs for protected groups. In so far as there may be some residual impacts on some protected individuals, those impacts are justified by the pressing need to fund essential work to the waterway network to ensure that it is viable and accessible to all boaters and users including those with protected characteristics. If the Trust was to maintain the status quo with regard to licence fees, it would no longer be possible to maintain parts of the network, which in turn would reduce accessibility to some groups. For that reason, the need to increase the licence fees is justified and outweighs the potential equalities impacts which we acknowledge

[___]

48 minutes ago, MartynG said:

Their impact assessment is that they  have actioned what they were given approval to do via the majority after study of the results of a survey of license holders . Therefore the majority of license holders will be happy.

 

 

20 minutes ago, Alan de Enfield said:

 

 

They have - it is very detailed.

 

I have posted sections of it in various threads on the subject.

 

A couple of paragraphs from the 10 page asessment.

 

43% of all those who responded to the boat licence 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

 

 

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.

 

 

Conclusion : The potential equalities impacts relate to the additional costs burden on boaters with protected characteristics who may have lower incomes than boaters without those characteristics. In particular, the Trust has had due regard to the potential impacts on those boaters with disabilities who may require larger boats which attract larger licence fees, and who are less likely to be able to meet the additional costs. Mitigation is available to meet those costs, and reduce or remove the additional costs for protected groups. In so far as there may be some residual impacts on some protected individuals, those impacts are justified by the pressing need to fund essential work to the waterway network to ensure that it is viable and accessible to all boaters and users including those with protected characteristics. If the Trust was to maintain the status quo with regard to licence fees, it would no longer be possible to maintain parts of the network, which in turn would reduce accessibility to some groups. For that reason, the need to increase the licence fees is justified and outweighs the potential equalities impacts which we acknowledge

 

What I meant was the operational impact on CRT.

 

For instance do they anticipate a higher proportion of boaters will declare a home mooring under the new system and if so what will their response be?

 

They must surely know how the scheme will work in respect of winter mooring permits and by extension other short term moorings?

[Alan de Enfield]

1 minute ago, Captain Pegg said:

What I meant was the operational impact on CRT.

 

Apologies - I thought you meant the impact and required mitigations on their customers

 

Purpose of EIA (Equalities Impact Assessment)

This EIA is intended to help us understand the possible impact of the proposed changes on our customers with additional needs (primarily those from equalities groups) and to ensure that any future decision about boat licence pricing is based on equalities evidence and is taken having due regard to any equalities impacts of that decision. This assessment helps us to identify any potential measures that might mitigate the negative impacts on equalities groups from the proposals and ensure that we do not discriminate against any protected group.

 

 

[cheesegas]

Thanks, plenty of advice but it doesn't seem to be very clear cut!

 

To answer a few questions - yep, I'm on a gold license as it's way cheaper than buying a visitor license for the Thames.

 

The Home Mooring declaration form doesn't seem to come attached with any restrictions as to the number of times I can submit it per year. I just don't want to get caught out when at the end of the year they look at how far I've moved and then I've only been spotted doing a handful of miles on CRT water.

 

I will of course be moving every 1-2 weeks as usual when out of the marinas, but that could be over the course of a month or just a week. I also may not go that far - sometimes I might end up going 10 miles or so out of the marina, then back in the same one again after a couple weeks which isn't navigation...it's not always going from marina A to marina B. Chances are the next marina mooring will be agreed, but as you all know this is usually only a phone call or text message to confirm it, not an official email etc.

 

9 hours ago, dmr said:

I suspect the CRT system has CC'ers and home moorers and does not really have a plan to cope with all those who are a bit of both, which is why they can not/will not answer your questions.

 

An option would be declare yourself as a home moorer each time you moor (if the marina is ok with this) and then declare as a CCer when you leave. Its very quick to change status online. Ideally you could arrange to be in a marina when you buy your licence 😀. This all feels a bit underhand and a way to avoid the new CC surcharge so CRT will have to come up with a policy before long. A big potential issue for CRT is that many CCers could take the same mooring short term just to get a licence, whilst in other cases it would be quite genuine.

This hasn't really answered your question but thats how the forum goes.😀

Some marinas don't want me to declare it as a home mooring, some do, some do but only if it's over a certain length of time, it varies a lot. I've just renewed my licence unfortunately - I'm currently away, boat in a marina but it's not declared as a home mooring.

[David Mack]

1 hour ago, cheesegas said:

I also may not go that far - sometimes I might end up going 10 miles or so out of the marina, then back in the same one again after a couple weeks which isn't navigation...

But it is exactly what many with a home mooring in a marina do, so you can't be faulted for that.

1 hour ago, cheesegas said:

Some marinas don't want me to declare it as a home mooring, some do, some do but only if it's over a certain length of time, it varies a lot.

I don't see that the marina has any say in the matter. If you pay for a mooring, and you have no other declared home mooring, then it is de facto your home mooring at that time. You can advise CRT of that, but I don't see that you have to tell the marina.

[___]

2 minutes ago, David Mack said:

But it is exactly what many with a home mooring in a marina do, so you can't be faulted for that.

I don't see that the marina has any say in the matter. If you pay for a mooring, and you have no other declared home mooring, then it is de facto your home mooring at that time. You can advise CRT of that, but I don't see that you have to tell the marina.

I thought exactly the same in respect of declaration of home mooring. I’ve never been asked whether I’m declaring a short term mooring as a home mooring. The marina doesn’t generally know my mooring status.
 

It did make me wonder if under the new rules marinas will become more bothered by it though. As you pointed out the only time you are required to declare your mooring status is when applying for a licence. Hence the possible temptation for folk to buy a short term mooring and declare it as a home mooring for licence renewal purposes. That potentially drags the marina into licence enforcement matters. Perhaps that’s already why some in the South East don’t wish to have short term moorers declare a change of status. They always have the option of refusing you a berth.

 

Otherwise it strikes me the OP is likely to be fine. I’d still keep good records though should the question get asked.

[Peanut]

If you are a boat without a home mooring, and pay to take a temporary winter mooring so that you have no need to move for that period, are you not still a boat without a home mooring, a continuous cruiser?

How would this differ if you took temporary moorings hear and there?  Would you not still be a without a home mooring?

Were it so, you would need to weigh up the benefits, cost and convenience, of staying in marinas, versus the additional cost of a licence with no home mooring? Where the surcharge isn't that large, but being unable to leave your boat in one place as you might like.

[___]

24 minutes ago, Peanut said:

If you are a boat without a home mooring, and pay to take a temporary winter mooring so that you have no need to move for that period, are you not still a boat without a home mooring, a continuous cruiser?

How would this differ if you took temporary moorings hear and there?  Would you not still be a without a home mooring?

Were it so, you would need to weigh up the benefits, cost and convenience, of staying in marinas, versus the additional cost of a licence with no home mooring? Where the surcharge isn't that large, but being unable to leave your boat in one place as you might like.

 

CRT's online information suggests that the descriptions "long-term mooring", "permanent mooring" and "home mooring" are interchangeable and that contract lengths vary from three months to three years. This latter information is perhaps based on their own Waterside Moorings contracts.

 

They use the term "short-term mooring" and "visitor mooring" interchangeably and with the key distinction that they are free (interesting in itself). That's certainly different from how I have used the phrase "short-term mooring" above.

 

I would certainly contend that my three month winter mooring constitutes a home mooring. How can it not if I don't have to move in that time?

 

Pragmatically it may seem sensible to have a minimum time for which a home mooring arrangement must apply but the law makes some distinct provisions that may tie CRT's hands. I think it may be hard to argue against the notion that if you have paid for the exclusive use of a berth then you have a home mooring, irrespective of duration. They will have to make some rules around that which I guess will stand until they are challenged in court and ruled to be unlawful (or CRT head that off by changing them). That may never happen, particularly if they come up with something sensible (like perhaps more than 14 days).

 

[LadyG]

3 hours ago, cheesegas said:

Thanks, plenty of advice but it doesn't seem to be very clear cut!

 

To answer a few questions - yep, I'm on a gold license as it's way cheaper than buying a visitor license for the Thames.

 

The Home Mooring declaration form doesn't seem to come attached with any restrictions as to the number of times I can submit it per year. I just don't want to get caught out when at the end of the year they look at how far I've moved and then I've only been spotted doing a handful of miles on CRT water.

 

I will of course be moving every 1-2 weeks as usual when out of the marinas, but that could be over the course of a month or just a week. I also may not go that far - sometimes I might end up going 10 miles or so out of the marina, then back in the same one again after a couple weeks which isn't navigation...it's not always going from marina A to marina B. Chances are the next marina mooring will be agreed, but as you all know this is usually only a phone call or text message to confirm it, not an official email etc.

 

Some marinas don't want me to declare it as a home mooring, some do, some do but only if it's over a certain length of time, it varies a lot. I've just renewed my licence unfortunately - I'm currently away, boat in a marina but it's not declared as a home mooring.

If you consider it to be a home mooring, I don't see why the marina have anything to do with it,  unkess your contract  with them, and if they have you signed up and you both agreed, in writing  that it is not to be declared, then you either accept that or you don't use that marina. Why do they they feel they need to interfere,

Is it confusion between leisure mooring and Residential Status. You are using the marina in a legitimate way IMHO. Many people will live on board in a marina occasionally. They have a house address and spend some time there .

I don't know why you discussed this with them,  did they raise the matter, try letting it drop!

 

 

 

Edited December 5, 2023 by LadyG

[Peanut]

It appears to be unclear what their definition might be, which could lead to a misunderstanding of what they had intended, and so they will have to clarify their thoughts before too long.