Movement requirements and congestion

Movement requirements and congestion from the commission report on the future of licensing.

Objectives of the licensing system

If they are to be effective, changes in the licensing system need to be based on clear objectives.
In our view the objectives should be:

i. To raise in a fair and equitable manner part of the revenue needed to allow the Trust to provide the services required or considered desirable for boaters, including the costs of enforcement, and to keep the waterways in good condition. The proviso about fairness and equity is important. Levels of licence fee evasion are likely to be greater if the size of fee is regarded as unreasonable and/or disproportionate. An issue for Trust waterways is that, of the millions of people who use them, it is only boaters and to some extent those who fish, paddle or row who pay for the privilege directly. Towpath walkers and cyclists pay nothing (though all taxpayers contribute indirectly through the Government grant paid to the Trust).
ii. To encourage good behaviour (i.e. broadly behaviour which enhances the waterways environment for other users) and discourage bad (i.e. behaviour which is detrimental to the enjoyment of others). Some positive behaviours are more easily supported by a licensing system than others. For example, the issue of a licence requires both a boat safety certificate and third-party insurance. These requirements provide some protection against the risks presented to other users or nearby property by boats kept in a dangerous condition. The arrangements provide little leverage, however, against poor boat handling and less than full assurance that a boat can float and navigate reliably and safely. There is nothing equivalent to the civil remedies available to local authorities to use against those who drive cars above the speed limits or park on double yellow lines.
iii. To support the Trust in its basic purposes of providing fair access to its waterways for navigation, recognising the great variety of usage patterns among those who enjoy them, and encouraging full use of the network. It is reasonable to expect, for example, that boaters should be able to find somewhere to moor (though not necessarily exactly where they want) and to access necessary services without too long a journey.25 Hire boat companies should be able to offer their customers reasonable certainty that they will find mooring spaces and to use the waterways with the same freedom as other users, without abuse. Paddlers ought to be able to enter and leave the waterways reasonably easily with their canoes, kayaks and paddle boards, including where portage is necessary around locks and weirs. Anglers ought to have reasonable access to stretches of the canal. Rowers ought to be able to enjoy their sport safely and with consideration from other users.
iv. To support the Trust in its other charitable objects. For example, by encouraging wider navigation of the entire waterways network, use of the towpath as a shared space generating considerable social value or protecting and enhancing water heritage and ecology.
v. To be based on clear, easily intelligible rules which are easy to understand and simple to enforce.

The recommendations in this report are intended to help meet these objectives. If implemented in full, we believe they would make the system fairer. They would help reduce licence fee evasion. They would work better than the current arrangements in encouraging good behaviour and discouraging bad. They are likely to improve fair access to the waterways; and they would make licence conditions clearer to understand and easier to enforce.

A key issue: movement requirements

A key issue for the Commission, on which a lot else depends, is the nature of the movement requirement placed on those without home moorings and on other boaters when cruising. As explained earlier, these boaters are required by the British Waterways Act 1995 to demonstrate “bona fide navigation”. The Trust has interpreted this as not staying in any place for more than 14 days and showing a pattern of continuous movement through the licence period. The requirement is one of the main causes of enforcement action (see paragraph 79 for details). It also underlies the poor relations between the Trust and many of its licence holders. It is intrinsically linked to the management of demand in popular areas, particularly in urban areas with housing shortages or disproportionately high housing costs.

Is there a need for any movement requirement?

In view of the difficulties it causes, we have asked ourselves whether it would still be necessary for the Trust to impose movement requirements for operational or other reasons if the legal requirement of bona fide navigation did not exist. Would it not be easier, and remove a great deal of potential aggravation, if boaters were allowed to moor where they like, and stay as long as they like, provided they moor safely?
Our conclusion is that there would be significant difficulties with an approach of this kind for the following reasons.

i. Practicality. Unless other measures were taken, the effects would be likely to include an even greater concentration of boats at key sites in urban locations, causing, among other things, increased difficulties for those looking for moorings when passing through.
ii. Fairness. It would be the opposite of creating fair access. It would give those who happen to be moored at desirable sites the ability to stay there for as long as they liked, blocking off those sites to other users – though permanent moorers would still have to move occasionally to access services like water and sanitation services, unless those were supplied on site or by roving traders, and to maintain their boats, for example to renew the blacking on their hulls.
iii. Charity law. If liveaboard boaters without a home mooring were permitted to reside for indefinite periods on the towpath, effectively living in a locality for the price of a boat licence, the Trust may have to raise boat licence fees for those boaters by a very considerable amount to reflect the benefit derived if it is to comply with its obligations under charity law. That would particularly be the case in areas where alternative accommodation on land is in high demand which is reflected in the cost of living in that location. The Trust would otherwise unlawfully be conferring a private benefit on the boaters concerned.
iv. Planning law. There is a distinction in planning law between leisure moorings (effectively moorings not used for permanent residence) and permanent residential and fixed-term commercial moorings. Temporary mooring of boats alongside the towpath is an established use associated with navigation. It is generally accepted that temporarily moored boats are not therefore a matter for planning control. Permanent long-term residential moorings, on the other hand, require planning permission, because they are not incidental to the primary use of the Trust’s water space. Permission is not always easily obtained, especially in areas of high usage or in legally protected areas like the green belt. The Lee Valley Regional Park Authority, for example, takes the view that residential use of the water is not one of the statutory purposes of land within the park. The point at which a mooring departs from being an incidental use of the waterways, thus requiring planning permission, depends on fact and degree. In practice, the distinction can be difficult to determine. There is no accepted planning definition of the length of overnight occupation possible under leisure use. The Trust’s belief is that the ability to demonstrate another permanent place of residence is an important relevant factor.
v. Attractiveness to boaters. A permanent mooring would bring additional costs to boaters, notably a likely requirement to pay Council Tax in addition to any mooring fees which the Trust was then required to charge. In some cases, particularly for those not receiving income support, this could make it significantly less attractive even to those boaters who wish to remain within a tight geographic area.26
vi. Effect on marina businesses. Unlimited free mooring would be likely to have a significant impact on the viability of many marina and hire businesses, with implications for the availability of moorings, for access to the waterways for those without their own boats, and for the Trust’s finances.
vii. Waterways heritage and operations. Removing any form of movement requirement would sit poorly with the heritage of the waterways, reduce the beneficial effects of boat movements in keeping channels clear and structures operating effectively, and would lessen interest for towpath users and other visitors.

Some of the effects of removing any need for movement could in principle be mitigated. The difficulty for boaters wishing to find temporary moorings when moving through congested areas, for example, could be addressed by increasing the availability of short-term visitor moorings, where this is practical. Significant changes in charity or planning law solely to address waterways issues, however, seem unlikely given the little attention waterways have received to date from planning authorities.
There may be some boaters without home moorings who would prefer for work or family reasons to be able to stay in the same place for longer. We have found, however, that most of those with whom we have engaged believe that the 14-day rule is broadly fair and acceptable. Any unhappiness is more with the requirements imposed once the 14 days elapses and/or with a perceived lack of flexibility in the way the Trust deals with minor infringements.
We do not therefore think the option of removing movement obligations entirely is worth further consideration. We recommend that the requirement for boaters without home moorings and other boaters when cruising to change their moorings at least every 14 days, or such longer period as is reasonable in the circumstances (for example to allow for unplanned navigation stoppages), should be retained.
We have encountered some confusion about what 14 days means in practice. We think it would be helpful to clear this up. A strict interpretation of 14 days moves back the day of the week on which a boater must move by a day every two weeks, which can unnecessarily disrupt working and family lives. To reflect better the rhythm of daily life, 14 days should in our view be interpreted as inclusive. In other words, if you moor at any time on day one, you must move no later than the end of day 15. So, if you moor on, for example, Saturday 1st of the month you must move on or before midnight on Saturday 15th. We recommend that the Trust should interpret 14 days as inclusive.

Alternative movement requirements

A 14-day time limit on mooring in any one place is meaningless without some definition of what the boater must do once that limit is reached.
In an ideal world, the movement requirement would be:

i. Easy to understand, to minimise compliance failures arising from misunderstandings.
ii. Straightforward to evidence, to minimise disputes.
iii. Generally regarded as fair and proportionate, so boaters feel positive about meeting the requirement and so Trust staff feel comfortable about enforcing it.
iv. For these and other reasons, easy to enforce.
v. Helpful in delivering the Trust’s charitable objects.
vi. Designed to ensure sufficient movement to facilitate fair access to the most desirable mooring sites.
vii. Recognising in a proportionate way the needs of some liveaboard boaters to access their places of employment or, if they have families27, schooling, and the needs of those with a disability. We have used the word “proportionate” to reflect the need to balance the desires of boaters in this situation with the importance of not endangering the charitable objects of the Trust in relation to keeping the waterways open.
viii. Encouraging to the wide use of the waterways network. ix. Compliant with the requirements of charity and planning law.

The present movement requirement28 falls short on all these ideals except the last. It is complex and difficult to enforce, requiring consideration not only of whether boaters have moved at all after 14 days but also how far they have moved and the pattern of movement they have shown over a period. There is dispute about whether, as interpreted by the Trust, it is consistent with the legislation, though the Trust insists that it has always acted on legal advice and its interpretation has never been successfully challenged in the Courts. There is a widespread perception that the rules are enforced in an unfair way – too robustly in some cases and not robustly enough in others. It does little to encourage wider use of the waterways network. Complaints about difficulties in mooring in congested areas are widespread, though contested; and the requirement is ill-matched with the way in which a significant number of licence holders wish to live their lives.
The last of these points needs to be kept in perspective. Many of those living on land have considerable distances to travel to their workplaces, involving both cost and inconvenience. Some of those living on boats will have chosen to do so because of the much lower cost compared to land-based accommodation, often with no Council Tax or water rates to pay. We have been told, for example, that some liveaboard boaters in London are doing so in part as a way of making savings to use as a deposit for house or flat purchase or to be close to work or to schools. It is not unreasonable for them to face some inconvenience as part of the financial and other trade-offs they are making.29
In view of its failure to measure up to what we believe should be its objectives, we do not think the current movement requirement is sustainable. We believe it should be redefined. We also believe it should be directed at fair access and the effective and efficient operation of the waterways rather than an outdated concept of bona fide navigation.
Designing a new movement requirement will necessitate a considerable shift in mindset for both the Trust and boaters. The notion of bona fide navigation is deeply engrained. Change will also require careful thought if the new requirement is not to become as complicated as the current set of arrangements. We are acutely conscious that designing it successfully will require much thought and detailed consultation with those directly affected and with others (like marina owners) whom it might impact indirectly. It may also require different arrangements in different areas where, for example, there are disconnected waterways or canals bounded by rivers. We have decided therefore not to attempt to make precise recommendations about the detail. In Annex 5 however, we have outlined one possible approach to illustrate what we have in mind.
We recommend that, after careful consultation with licence holders and others about the different options, the Trust should define a new, clearer movement requirement to replace the concept of bona fide navigation. The new requirement should be directed at finding an appropriate balance between the efficient and effective management of the waterways, including fair access, boater needs and the impact on others whose interests might be affected, and on encouraging the use of all the waterways.
We have considered the desirability of defining the new requirement in detail in a new law. That would avoid repeating the difficulties caused by the lack of definition in the existing legislation and put the legal legitimacy of the requirement beyond doubt. It would, however, also introduce an element of inflexibility should circumstances change or experience suggest that the requirement needs to be modified. It could also make for complex legislation if the requirement differed from area to area. On balance we do not think putting the detailed requirement into legislation would be desirable, at least until after the arrangements have been shown to be effective.
The term continuous cruiser is a misnomer. Despite its well-established use, we think it can lead to misunderstandings and, potentially, to stigmatisation. Using it to describe the whole category of boaters without home moorings misrepresents both how many of them use their boats and what the licence terms require of them. It is also a potential obstacle to the change in mindset we are recommending in relation to a new movement requirement – away from one requiring a view about what continuous cruising “ought” to mean to one firmly based on the Trust’s objectives and operational requirements. As part of any changes, we recommend that the Trust should cease to use the term “continuous cruiser” to describe leisure licence holders without home moorings and substitute a more accurate description.
We have noted that the Trust is not always consistent in the terms it uses to describe different categories of boaters. Changing the term used for continuous cruisers could provide an opportunity for the Trust to ensure greater consistency in all the nomenclature it uses.

Demand management and licence pricing

The changes we have recommended to the movement requirement would be unlikely to do much to relieve congestion issues in areas like parts of the London waterways, the west end of the Kennet and Avon Canal or, on a lesser scale, in some other urban locations which are already congested or could become congested in the future. They could make matters worse, by reducing the effect of one of the disadvantages of living on a boat.
We have encountered different views on the extent of the capacity problem in these areas.
Only five per cent of those responding to our survey mentioned congestion as an issue. Some of those with whom we have engaged directly have told us that they have not encountered undue difficulty in finding short-term moorings when they have moved through urban areas, including London. They have pointed to high vacancy rates for dedicated short stay moorings in, for example, Paddington Basin30. It has also been suggested that some of the complaints made by hire boaters about mooring difficulties may result from unrealistic expectations about being able to moor exactly where they want.
Others believe the need for radical action to be self-evident in view of the large number of boats moored in London and elsewhere and the extent to which licence conditions are perceived to be being breached by “continuous moorers” (as boaters without home moorings who do not move their boats every 14 days are sometimes called). The situation in London has been described by some as “out of control”. Some boaters are reluctant to cruise through London; and hire boat operators no longer operate there, citing mooring difficulties for their customers as one of the reasons. Hire boat operators have told us that their customers navigating through other congested areas can find the difficulty of mooring severely impairs their experience, particularly when they can reportedly also suffer abuse when attempting to moor. Some hotel boat operators have claimed that they find it difficult to keep to publicised itineraries because of mooring problems; and we have been told of space-related tension in some places between boaters, rowers, anglers and paddlers.
We have no doubt that some boat hirers do face difficulties and may face abuse31. We note, however, that boater satisfaction surveys consistently show higher levels of satisfaction among hire boat customers than among other boaters. In 2024, the most recent date for which data are available, overall satisfaction was 93 per cent for hire boaters compared with 46 per cent for other boaters. Nine in ten hire boaters would recommend hiring a boat to friends and family.32
We do not have sufficient data to give a confident opinion on whether congestion in certain areas has yet reached the point at which radical measures are necessary. The different interpretations of capacity are difficult to reconcile. Without a common understanding of the meaning of congestion, and a way of measuring it, it will be difficult to reach consensus on the extent to which it exists.
There is, however, at the very least a perception problem. It is also likely that problems will get worse as long as housing shortages continue and there remains a significant price differential between land and water-based accommodation in high-cost housing areas. Even if is true that the situation has not yet reached a critical point, unless something unexpected happens in the housing market, the Trust is likely soon to have to face up to the need to find some way to address congestion in some areas if its commitment to maintaining open waterways is not to be endangered. None of the possible remedies looks straightforward. So, the Trust would be wise, in our view, to begin discussion with those affected and with those other authorities whose policies impact on the issue. The problem is part of a wider societal issue. Responsibility for addressing it needs accordingly to be shared with others, not left to the Trust alone.
Many of the steps the Trust may wish to consider are outside our terms of reference and not directly related to the licensing system. They include:

i. Greater attention to the condition of towpath edges, vegetation cover, and the depth of water adjacent to the towpath on some stretches of the Kennet and Avon Canal and elsewhere.
ii. Greater provision of mooring rings on stretches of towpaths which have been upgraded to hard surfaces, making it difficult to insert mooring pins, where that is compatible with other towpath requirements.
iii. Provision of sufficient accessible moorings clearly marked, accompanied by further roll-out by the Trust of its new accessible mooring bollards and accessible mooring site design.
iv. Encouraging wider use of the entirety of the waterways network by finding ways of making less busy parts of the network more attractive to boaters currently without home moorings who might otherwise congregate in congested areas.
v. Increased provision of, and publicity for, short-term moorings, whether bookable or not, adequately monitored and enforced to prevent misuse.33
vi. Greater support for those attempting to obtain planning permission for permanent residential moorings.
vii. Continuation and reinforcement of the Trust’s efforts to influence changes to the planning system to make planning policies more supportive to the creation of new permanent moorings.34
viii. Encouragement of the use of water spaces without direct connection to the network to provide residential moorings for residential boat owners who prefer to be static.
ix. Better enforcement leading to removal of abandoned, sinking and sunken boats (on which see later).
x. Encouraging owners of leisure moorings in marinas or boat clubs to accommodate small numbers of residential boats. Residential boats can be used to accommodate caretakers to improve security. Changes in the status of moorings from long-term leisure use to residential use would require planning permission. We understand, however, that this has been successfully achieved in some marinas. Trust policy has so far been to encourage development of off-line (i.e. marina-based) rather than on-line (i.e. on the canal bank) moorings because that is better for the cruising experience. More on-line moorings in London might nevertheless be justified given the extent of demand there. They have, however, proved difficult to establish in practice.
xi. Monitoring the number of wide-beam boats in congested areas and, if necessary, taking steps to inhibit their use, because of the limitations they impose on double mooring.35

In our view a coherent strategy to address congestion issues requires the Trust to look carefully at all these possibilities.36 A major difficulty, however, is that, even if they could be afforded, implementation of many of the above ideas could result in increased demand responding to the increased supply of mooring space. If the Trust wishes to address mismatches between supply and demand in congested areas, it will therefore also need to consider the traditional means of addressing excessive demand – price and/or rationing. Neither would be straightforward.
Price differentiation would impact directly on demand in a way that few other measures could, except possibly measures intended to make life more difficult for boaters (which we would not recommend). It would be possible to design arrangements under which the licence cost of using a boat in highly used areas of the network was greater than in other areas. This could be through the use, for example, of congestion charging, roving mooring permits or local area licences. We understand all of these have been considered in the past.
Price differentiation in congested areas might be regarded as justified for a second reason. The existence of excess demand in these areas suggests that there is a product – mooring space in popular spots – for which the Trust could, if it wished, charge higher prices. As suggested earlier, by not doing so the Trust is arguably conferring a private benefit on those currently occupying these spaces. This would conflict with its duty to comply with charity law; and the requirement to remain financially viable. As the real value of its Government grant continues to reduce, the Trust needs to look to other sources to make up the difference so it can continue to deliver its charitable objects.
Price differentiation would, however, involve administrative complication in determining whom to charge; and in monitoring and enforcing compliance. It would also be highly resented by many of those who would be most affected. This is particularly likely to be the case since the cost difference in places like London and Bath between living on a boat and living on land is so great that small increases in the cost of owning and living on a boat may have only a limited effect on demand. The Trust has told us that lower fees for boats without home moorings combined with no Council Tax obligations means that total outgoings for liveaboard boaters in London without home moorings can be less than half that of a typical London property rent, without adjusting for higher value areas. If the Trust is to make a significant difference to congestion issues by encouraging movement out of popular areas, price increases for liveaboard boaters without a mooring might therefore need to be substantial (though see later on the possible effect of price sensitivity on the demand for moorings on the Lee Navigation).
There is also the point that increasing costs to boaters to provide a disincentive to mooring in those areas could reduce diversity. It could make boating in the relevant areas affordable only to the better off or to those on income support, and unaffordable to those on intermediate incomes, including many key workers – a situation which already exists in some areas of the land-based London housing market.
Rationing, i.e. limiting the number of licences made available in high demand areas, is another possible way of managing demand. It could, however, suppress demand rather than reduce it. It could be regarded as intrinsically unfair; and it could create operational difficulties and increase the amount of monitoring and enforcement required.
It is for the Trust to judge whether capacity issues in some urban areas have yet reached, or might soon reach, the point where radical measures like price differentiation or the rationing of new licences, or a combination of the two, are required. We do not have sufficient information to judge that for ourselves. We also believe that greater provision of paid-for short-term moorings to facilitate easier through movement in congested areas, as suggested earlier, is a necessary prior step. But we think it is highly desirable for the Trust to begin an open discussion with others, not just with licence holders but also with other relevant policy and decision makers, about the extent of the congestion problem and the practicality and desirability of different ways of addressing it. A discussion of this kind is bound to be difficult and will raise strong feelings. We do not, however, see how it can reasonably be avoided.
We recommend that the Trust should begin an open discussion about the meaning and measurement of the term “congestion” and about the desirability and practicality of introducing price differentials and/or rationing the issue of licences or other ways of addressing capacity issues in congested areas.
The Trust is unlikely to be given more than one opportunity of securing new legislation in the foreseeable future. We recommend that the Trust should seek to include the power to introduce price differentiation and/or rationing on a contingent basis in any legislation which is put to Parliament to implement our recommendations.
If the Trust does implement radical measures to address congestion, they are likely to prove more acceptable if they are introduced as part of a package and phased in over time with appropriate transitional arrangements. A package of this kind would include replacement of the bona fide navigation requirement with a simpler alternative, as we have suggested. It might also include abolition of the continuous cruiser surcharge outside congested areas and ring-fencing part or all of the additional revenue created to improve services and enforcement in the higher priced areas.37 The combination would go some way to address the complaint that it is unfair through the continuous cruiser surcharge to make those who do not boat in London pay for services provided to those who do. In effect the Trust would be creating a clear differentiation between licence holders in London (or some parts of it) and other areas with significant mooring difficulties and those on the rest of the network. To do this, the Trust would need to have the ability to designate the relevant areas, implying some way of defining congestion to assess whether the necessary threshold has been reached.38 We recommend that, if the Trust decides to introduce differentiated licence fees and/or rationing in congested areas, it should do so as part of a considered package, possibly including ring-fencing the additional revenue in whole or in part to improve services in those areas.
Using additional revenue to provide better services in return for higher charges may not be straightforward because of a shortage of suitable land areas on which to site new or improved services. Innovative thinking might therefore be required; for example, encouragement to water-borne private traders to provide water, waste and other services. We have been told by the Trust that it does try to encourage private operators to provide services, but that very few do so in areas of high demand. Some form of Trust-provided assistance to providers may therefore be necessary.

The Rivers Only discount

A direct way of addressing congestion problems is to remove any existing incentives for boaters to operate in heavily congested areas. The most obvious example is that boaters on the Lee Navigation receive a discount of 40 per cent on their licence fees. This discount is available to any boaters who confine themselves solely to river navigations. Assuming a typical 12-month licence fee of around £1,200, the discount is worth on average around £480 a year. This may have contributed to the heavy concentration of liveaboard boaters on the Lee Navigation, which might indicate a degree of price sensitivity to fee levels which would be relevant to consideration of price differentiation elsewhere.
There are currently just over 4,000 holders of Rivers Only licences, around 800 (c.20 per cent)39 of whom are moored on the Lee Navigation. Arguments in favour of the discount include the historic right to public navigation on rivers and the fact that there are, for example, some boats on the Lee Navigation which are too big to travel on most other Trust-owned waterways. The discount does, however, appear to us to be an anachronism. Its abolition would simplify licence terms and conditions, would facilitate more effective and consistent management of the waterways and would make it more straightforward to make future changes in the licence system. We have not seen any evidence that the Trust’s costs in maintaining river navigations are less than those for maintaining other waterways.
We recognise that removing the Rivers Only discount will be unpopular with those affected. But we do not think that to be sufficient justification for its continued existence, not least because any steps taken to relieve congestion elsewhere could put greater pressure on river navigations. We believe the Trust should remove the discount at the same time it is making the other changes in the licensing system we are recommending. Removal should be phased in over a three-year period to ease the financial impact. A longer transition would be undesirable because of the need to reduce pressure on some of these waterways. We recommend that the Rivers Only discount should be ended on all Trust rivers. The change should be phased over a period of three years to ease the financial impact on those affected. That would raise an obvious question as to whether a separate Rivers Only licence is needed at all.
We have been told by the Trust that there are a small number of waterways for which it is responsible but where, because of gaps in the legislation, it does not have the ability to charge licence fees. This is an anomaly which could lead to overconcentration of boats on those waterways. We recommend that any waterways where the Trust is the responsible navigation authority but where it currently has no power to issue licences should be brought within the scope of the licensing provisions.

25 The Trust has set out the standards of customer services it expects to offer, including distance between services, in its Customer Service Facilities (CSF): Policy Statement, available on its website.

26 Though we have been told that some liveaboard boaters without home moorings may regard it as fair to contribute to local authority and other services, particularly if payment of Council Tax was linked to easier access to those services.

27 Three per cent of respondents to the Trust’s 2025 Boater Survey reported children under 16 living aboard.

28 Guidance for boaters without a home mooring

29 Not forgetting that some people, particularly early in their careers, might see advantages in living on a boat, for example being able to move home if their place of employment changes. It is also relevant that public transport is good in areas around the canals in London, though not necessarily in some other urban areas with canals.

30 The Trust has told us that some of these moorings are relatively new and that usage can be expected to increase further as their availability becomes better known. Low usage may also be an effect of the price charged.

31 For their part, some liveaboard and leisure boaters complain about inconsiderate behaviour from hirers.

32 Hire Boat Survey 2024.

33 We note that active management of paid-for short-term moorings has resource implications for the Trust. It has told us that in parts of London management of short-term moorings has become so difficult, partly because of the inadequacy of enforcement powers, that some have had to be removed.

34 We do not underestimate the difficulties. The Trust believes there is a fundamental disconnect between housing needs policy and guidance published by the respective MHCLG planning and housing teams that needs to be addressed as a significant factor affecting the supply of residential moorings.

36 We understand that to some extent it is already doing so. It is, for example, investigating the capacity of London waterways to accommodate more moorings, including new residential moorings. We have been informed that some potential offside locations for moorings (i.e. locations on the opposite side of the canal to the towpath) have been identified, but that land availability, access issues and scope for providing facilities are proving challenging.

37 In the same way as the revenue from the London road traffic congestion charge is directed to improve roads and address other transport needs in the London area.

38 For example by a periodic assessment of the total length of available mooring space in a defined location, measured at sunset. The assessment would need to take account of the possibility of double mooring where the navigation is wide enough.

39 375 with home moorings, 438 without.

Section 3: Movement requirements and congestion