The beleaguered CCs point out that C&RT can be hard-nosed in situations where common-sense should allow leniency - for example in the event of illness, mechanical/ maintenance issues and bad weather (I have recently heard from a very diligent and law-abiding CC served with a notice for overstaying, despite being iced in!), and that safe, affordable moorings can be impossible to find in some areas, particularly around London.
I'm not going to referee that fight here, but to draw attention to something that may seriously complicate the life of the less prosperous CC and increase the risk that they will fall foul of C&RT's 'get tough' policy; the new 'Universal Credit' benefit.
Let's look first at an unemployed boater. S/he is already going to struggle to continuously cruise. A few years ago it would have been relatively easy to combine a claim for Jobseeker's Allowance and the conditions of a job-seekers agreement with doing so. You would need to 'sign on' fortnightly at your chosen Jobcentre, but could easily actively seek work on-line in the evening and at points along your travels.
Today, such an unconventional way of life could make you a target for weekly or daily 'signing on' or a 'Work Programme' placement - unpaid, but requiring you to stay put close to the Jobcentre or training centre. JSA claimants also complain of very short notice to attend unscheduled extra appointments. Find yourself too far from public transport, and you can expect a sanction for missing one of those, with benefit suspended for at least four weeks, thirteen for a second 'failure' and up to 156 (three years) for a more serious glitch. Hardship payments are just 60% of the usual basic benefit rate and aren't usually paid for the first couple of weeks. No money = no fuel, so even if you aren't having to hover handy to the foodbank in order to keep body and soul together, you're going to have to limit your mileage.
It's not much better for boaters with long-term health problems. Employment and Support Allowance for the 'work-related activity group' of claimants - theoretically expected to recover enough to return to work in due course - also requires attendance at regular Jobcentre interviews and, increasingly, Work Programme referrals - once again limiting the CC claimant's ability to move.
It isn't just non-working CCs who need to look closely at the Universal Credit regulations. If you are in work and earning enough for most of the bills in a good month, but topping this up with a claim for Working Tax Credit or some Housing Benefit towards your boat licence, things are going to get more complicated too. At present, as long as you devote sufficient hours to your work, your Tax Credit award is safe and Housing Benefit cares only that your income is too little to pay your accommodation costs.
But both Working Tax Credit and Housing Benefit are due to be incorporated into Universal Credit. Universal Credit takes a different approach; if your work earns you less than the minimum wage for 35 hours, you run into 'in-work conditionality' - a requirement to be 'available for' and 'actively seeking' work rather as a jobless claimant would. Self-employed people face another catch - after allowing a setting up period of 12 months, regardless of your actual earnings from self-employment, you will be assumed to be earning the equivalent of the national minimum wage for 35 hours work per week, and your benefit calculated accordingly - even if you haven't earned a penny that month or the previous.
In practice, this will mean some people with part-time, seasonal or low-profit self-employment having to 'sign on' (and stay put to do so), and others receiving much less support than they actually need to live on during lean months, restricting mobility by limiting funds for fuel. If C&RT don't take a lenient approach to people caught by these conditions, many small traders, artists and craftspeople will face great personal and financial hardship, and may lose their homes and livelihoods. If they are forced onto permanent moorings, the cost to the 'public purse' stands to rise, as their mooring fees then also have to be claimed as housing costs for Universal Credit. If they are forced ashore, the costs of housing them on land are likely to be far higher than a small subsidy towards a boat licence.
I also wonder how much in the way of additional resources C&RT intend to spend on enforcement officers and action, and how much new money they realistically expect to bring in as a result? Perhaps they should look at how local authorities have struggled, post April 2013, to collect Council Tax from residents forced to make a payment for the first time from falling or static wages and benefits.
It hasn't been going well...
