Argyll & Bute Council Harbour Charges Survey

Argyll and Bute Council are conducting a consultation on harbour charges.
You can assist the effort to have a vehicle ferry service reinstated in Dunoon by completing the survey which can be found here
www.argyll-bute.gov.uk/consultations/fees-and-charges-piers-and-harbours
There are only 9 Yes/No questions so it is quick to complete, most important though is the comments box at the end. The deadline is Monday 13th February 2017. Please submit your response as a private individual.
Although quick to complete the consultation is not particularly clear so the model answers below shows the responses which it is felt will best serve the cause of a vehicle ferry service.

Model Answers

Do you agree that the council should invest in its piers and harbours to secure their long-term future? YES
[The problem is that in the past the Council has probably not been keeping the facilities in good order and we must ensure that commercial operators are not asked to pay for past neglect. ]
Do you agree it is fair to consider the cost for major works in the overall charging scheme for Category A piers and harbours? NO
[ To attract commercial operators to Dunoon it is important that they are not charged for facilities at other ports. Dunoon is being classed as a Category A facility even though it has run at a loss since the Streaker service ceased. ]
Do you agree that it is fair to standardise the charging scheme for additional services? NO
[ It is unclear exactly what this means. We wish Ferry Operators to be charged the cost of the services they use in Dunoon, plus a small profit, not a standard charge across all the harbours. ]
Do you believe that it would be sensible to have a flat rate annual charge for ferries? NO
[ A flat rate across all harbours would mean a commercial vehicle ferry operator in Dunoon being asked to subsidise other ports which they do not use. ]
Do you agree that it would be sensible to have a Council staff presence at Craignure and Port Askaig facilities (NOTE – there are already CalMac staff at these piers) to assist with effective operations of these facilities and, more widely, with the collection of dues on Islay/Jura and Mull/Iona’? YES/NO
[ Choose either answer or leave blank ]
Do you agree that it would be fair to end the summer and winter fees split for unregistered commercial vessels? YES/NO
[ Choose either answer or leave blank ]
Do you agree that it would be fair to charge berthed vessels separately for electricity? YES/NO
[ Choose either answer or leave blank ]
Do you agree that it would be sensible to install CCTV at unmanned facilities to try and maximise the recovery of berthing dues? YES/NO
[ Choose either answer or leave blank ]
Do you agree that it would be sensible to work with local communities to try and maximise the recovery of berthing dues? YES/NO
[ Choose either answer or leave blank ]
Do you have any comments on any of the questions or proposals?

The survey identifies Dunoon as one of six category A piers and harbours and states that these are “income generating principal facilities”. However the Marine Operations Manager at Argyll and Bute Council wrote; “It may interest you to know that the income, generated by ferry charges at Dunoon Pier, is generally about half that of the actual expenditure incurred in operating this facility”.
Dunoon is clearly not presently Category A and so the survey is confusing and misleading.
The survey also suggest that income from the 6 Category A facilities would be used to cover the costs of all 39 of the Council’s piers and harbours plus a contribution to central funds which will be used to pay for all major works.
This it totally unacceptable it would render the objective of having a vehicle ferry operating from Dunoon unachievable and even put at risk the existence of a passenger only service.
A COMMERCIAL FERRY SERVICE RUNNING FROM DUNOON CANNOT BE EXPECTED TO PAY FOR THE UPKEEP OF FACILITIES IT DOES NOT USE AT OTHER LOCATIONS!
The costs of running a harbour are largely fixed. The survey acknowledges that passenger and vehicle numbers have little impact on the cost of running a harbour. However it fails to acknowledge that gross tonnage and frequency with which vessels dock also have very little impact on the costs.
The present charging scheme uses the gross tonnage of vessel and how often they dock. The result is that the present passenger only service in Dunoon is grossly undercharged but a vehicle service using larger vessels would be grossly overcharged.
There is nothing wrong with moving to a flat rate annual charge for ferries but that charge must be based on the cost of providing the services actually used by the ferry operator at the port in question, plus a small profit. In other words the charges levied on a passenger only service operating from Dunoon should not be much less than those levied on a vehicle and passenger service and those charges should reflect the cost of providing the services used in Dunoon, and should be adequate for the Council to generate a small profit.
The charge should include annual depreciation of the assets being used in Dunoon over their 20-40 year lifetime but should not include any costs associated with undertaking and funding works such as interest charges.
The MVA report produced for the Scottish Government in June 2013 stated; “Argyll and Bute Council has noted that harbour dues are a significant part of the cost of the vehicle ferry service and consequently they would seek to minimise such charges and would be willing to review the basis upon which harbour dues at Dunoon are set in the context of the introduction of a new service”.
How can a commercial ferry operator tender for a vehicle service when the bulk of the costs are unknown? A passenger only service will receive a subsidy but the Scottish Government has already allocated funds for the new service so the uncertainty over costs also puts at risk the passenger only service.
It is truly shocking that in 2017 four years after the MVA report and just months before a new service is to come onto the route the Council still have not defined the charges.