British Waterways Licence Fee Petition

10 June 2011
Thank you to everyone who supported the petition. I cannot contact you all individually but wish to share the following response from BW received today. They have upheld the complaint & it looks as if they are now going to have to revisit their pricing policy & implementation practices.

Dear Mr Cutting

Further to our previous e mail correspondence I am now in a position to respond to your second
level complaint. Please accept mmy apologies for the delay in doing so but as I think you are aware I have had to consult with a number of colleagues, several of whom, myself included, have been away from the office for various reasons.

Your compplaint centres around what you consider to be an excessive increase in the 6 mmonth
licence feee of 49% as compared to last year.

In her first level response to you, my colleaggue Sally Ash confirmed that this increase efffectively returned the pricing structure for our shorter term licences to that which existed in 2003, and she explained that our costs in administering short term licences were proportionately higher.

She went on to explain a number of mitigation measures we were now proposing to reduce the
cost of a 6 month licence. She also described the favourable cost comparisons between the cost of
a BW licence and that of other navigation authorities.

You remained dissatisfied with her response and referred your complaint to be dealt with at the
second levvel under British Waterways (BW) internal complaints procedure.

In looking at your complaint I think it would be inappropriate for me to dictate what our pricing
policy for licences should be and how individual types of licence should be priced. This is best
done by others who are better qualified than I. I have passed a copy of the proposals suggested in your e mail to me dated 28th April to colleagues so that they are aware of your thoughts on pricing.

However I think it is right that I should look at the fairness of what BW are proposing by way of the increase in fees.

I do not think there is any dispute about the facts i.e. the effect of our revised scale of licence fees effective from 1st April 2011 is to increase the cost of a 6 month licence to you by 49%.

I am advised that the usual processes for notifying our customers of the proposed licence fee
increases was followed by BW and that you have no complaint about that, although in the
subsequent e mail correspondence with BW you have expressed dissatisfaction about how some
of the price mitigation measures that were introduced post consultation have been publicised. If
you would like me to deal with this issue as part of your complaint as well please let me know.

Turning to the substantive issue of the price increases I have had much discussion with colleagues about this, and also the subsequent measures already introduced by BW to mitigate the increase in costs which resulted from feedback to our consultation exercise.

As explained in Sally’s first level response BW have agreed to a 20% discount off the new higher
priced 3 and 6 month licences for people who can provide evidence that their boat has a home
mooring on a different navigation authority’s waters or that it is kept out of the water. In addition we have extended our instalment payment terms so that people can purchase an annual licence by spreading the cost over 12 months.

In my opinion these measures indicate that BW has listened to and recognised the concerns raised
by our customers in response to the consultation exercise on licence fees, and have reacted fairly and appropriately by introducing the changes described above.

However it does not seem to me that the BW response has been even handed in that it has not
been applied equally to all our customers affected by the changes to the price of a 6 month licence.

To this extent I am prepared to uphold your complaint by determining that the 20% reduction in the 6 month licence fee referred to above, currently limited to owners of vessels not on BW
navigations, should be extended to all our customers, wherever their boat is moored. This
concession would also be applied retrospectively to the very significant number of our customers
who have already accepted (and paid) the full amount for a 6 month licence based upon the
original price decision.

The consequence of this will, I know, present some challenges to our boat licensing department.
Achieving a fair balance of licence fees across different groups of boaters – all of whom depend on the waterways being available when they want to use them, regardless of whether this is for just a few months, or year round – is not easy. The decision to increase the fee ratios for 3 and 6 month licences to their 2003 levels was made to reflect this general availability, and it is consistent with the practice of other navigation authorities. Nevertheless, I feel that the speed with which the adjustment was made was unreasonable. As a result of your complaint and a number of others on the same subject, my colleagues responsible for boat licensing are now giving further thought to a wider consultation with boating organisations to re-visit the relative charges for licences for different groups of boaters. This will either endorse the original decision to return the three and six month ratios to 2003 levels from 2012 or 2013 onwards, or it will result in a different pricing formula.

If you would like to be kept informed about this work, please register for our monthly e-
newsletter for boaters published at www.waterscape.com/boatersupdates.

I hope this e mail sets out clearly how I have arrived at my conclusions, but if you are not satisfied then you are of course eligible to take your complaint further to the Waterways Ombudsman at any time within 6 months of the date of this letter. Details for the Waterway Ombudsman are

Hilary Bainbridge
The Waterways Ombudsman
PO Box 35
York
YO60 6WW
Tel 01347 879075
E Mail enquiries@waterways-ombudsman.org

Kind Regards,

Richard Curtis
Head of Property Development North