Although many will make use of a friend or relative's land address, this residency qualification can pose problems for the canal-boat dweller, particularly those without a permanent residential mooring. It appears that it also perplexes some local authorities if this extract from a discussion forum for local government transport officers is anything to go by.
A Lancashire council officer asked:
We sometimes receive applications for ENCTS* passes from people who reside on canal boats, caravans etc. They probably live on the boat/caravan all year round but may move from site to site when one is closed for a period of time. They very often do not pay council tax. Is someone who resides like this entitled to an ENCTS pass or not. Of course the guidance is not as clear as we would like as it relates to "sole or principal residence" and it could be said that the boat is their sole residence and they are located within our county "most of the time".
I would be grateful for any information as to how you deal with this type of application. The one we have at present has provided proof of address (a marina) via his bank statement but does not pay any council tax and cannot stay in the same marina all year as it shuts down for a period of time.
*ENCTS - English National Concessionary Travel Scheme
The questioner, however, goes on to largely answer his own question by quoting from the guidance to the Act
1.18 The Concessionary Bus Travel Act 2007 specifies that TCAs must issue a travel
concession permit to an eligible person whose sole or principal residence is in
the authority's area.
1.21 Eligible persons who reside in more than one residence in England, Wales,
Scotland or Northern Ireland should apply for a travel concession permit only with
the TCA (Travel Concession Authority i.e. council) that they reside in most of the time.
1.22 Good practice would indicate that a signed declaration from an applicant is one
way to assist fair application of the 'sole or principle residence criteria'.
Boaters on the Kennet & Avon may be particularly interested in the response from Wiltshire County Council.
In Wiltshire we have the Kennet and Avon Canal, which goes through several counties. (incidentally a good choice for a spring or summer holiday). People do live on the boats permanently and we deal with that by accepting a mooring licence for a mooring in Wiltshire. We don’t accept bank statements as proof of residence as banks will send them anywhere – bank accounts are not linked to a particular address in the same way as a land line phone bill or council tax.
Note that nowhere in the Guidance does it state that payment of Council Tax is a prerequisite for obtaining a bus pass, although obviously whether you are happy to take the benefit without making the contribution is a matter for your own conscience. Also, it doesn't really matter who issues the pass as it is the local council is whose area the bus journey starts that pays the bus company, not the council that issued the pass.
Quite where this leaves the continuous cruiser (or even the "continuous moorer" without a mooring permit) I'm not sure; perhaps those who book into a marina for part or all of the winter should take care to apply for their bus pass at that time!