After a delay of around 15 months BW has finally coughed up some information about changes to its “continuous cruising” enforcement procedure. A Freedom of Information request was made in October 2010 after changes to the procedure were mentioned in a BW briefing for User Group meetings. The FOI request was refused; in June 2011 the boater referred the matter to the Information Commissioner after BW failed to respond to a request for a review of its refusal to provide the information. Below are the new Continuous Cruising Flowchart and Continuous Cruising Timeline. (The original FOI request is at the end of this article.) The main changes are the inclusion of the “Pre-CC1” letter and the blocking of any attempt to relicense a boat that has had its licence revoked. The other issue of note is that boat sightings over a period of 9 months are being used to judge whether or not a boater is complying with Section 17 3 c ii of the 1995 British Waterways Act. This is contrary to what Parliament intended – according to the evidence BW submitted to the Commons Select Committee that drafted the 1995 Act, boat movements were to be looked at when the licence was due for renewal, not 3 months before that date. Yet another aspect of the “Continuous Cruising” Procedure that is unlawful. The entire enforcement procedure is based on whether a boat’s movements comply with the Guidance for Boaters Without a Home Mooring, which sets movement requirements that are beyond what is specified in section 17 3 c ii.
Continuous Cruising Flow Chart 2011
Continuous Cruising Timeline 2011
The Information Commissioner decided that BW did not have to provide all the information requested. Below is the original FOI request, the Information Commissioner’s decision and the explanation that BW was ordered to provide. BW’s explanation contains several exaggerations of its legal powers, so read it with a large pinch of salt.
The original FOI request:
1. The minutes of all meetings during 2010 where these changes to the continuous cruising process were discussed;
2. all briefings, procedural guidance and instructions issued to staff during 2010 regarding these changes to the continuous cruising process.
3. the total number of boat sightings made by BW in 2009; the total number of boat sightings made by BW in 2010;
4. the dates and locations of these boat sightings in 2009, and the dates and locations of these boat sightings in 2010.
BW provided the total number of boat sightings and a supplementary request was made which was refused for:
A breakdown of the total of 548,218 boat sightings into the figures for 2009 and 2010 and the dates and locations of each of these boat sightings in the following format:
1. the date;
2. the name of the waterway;
3. the total number of sightings made on that date on that waterway,and
4. a breakdown of the sightings for each day on each waterway into continuously cruising boats, boats with home moorings, hire/share boats and trading boats.
This is BW’s final response after the Information Commissioner intervened:
I am writing further to your request for an internal review following our refusal to provide you with the information you requested on 13th October 2010.
Firstly I would like to apologise for the delay responding to your request for a review. This was
initially an oversight on our part, which happened during a change in responsibility for information requests when our previous Information Officer left British Waterways. This was then delayed further following your contact with the Information Commissioners Office because of holidays taken by both my colleagues and myself; I am sincerely sorry for any inconvenience caused by these delays.
I understand that the elements of your requests which you have not received a satisfactory
response to are as follows:
1. The minutes of all meetings during 2010 where these changes to the continuous
cruising process were discussed;
2. All briefings, procedural guidance and instructions issued to staff during 2010
regarding these changes to the continuous cruising process.
3. A break down the total of 548,218 boat sightings into the figures for 2009 and 2010.
4. Secondly, please could you tell me the dates and locations of each of these boat
sightings (for [3] above) in the following format:
1. the date;
2. the name of the waterway;
3. the total number of sightings made on that date on that waterway; and
4. a breakdown of the sightings for each day on each waterway into
continuously cruising boats, boats with home moorings, hire/share boats and
trading boats.
For clarity I will address each point in turn below.
Point 1:
The minutes of all meetings during 2010 where these changes to the continuous cruising
process were discussed
Having discussed this matter further with the members of the Steering Group I can confirm that
there are no minutes of meetings where changes to the ‘Continuous Cruising Process’ were
discussed. As they do not exist I am unable to provide you with any information in response to this request.
I also understand that the Freedom of Information Act 2000 (“FOIA”) does not require a public
authority to create records in order to reply to a request for information or to supply any other
information unless it is already on record.
Point 2:
All briefings, procedural guidance and instructions issued to staff during 2010 regarding
these changes to the continuous cruising process
In response to this request please find attached the following documents:
a. Continuous Cruiser Process Flowchart
b. Continuous Cruiser Standard enforcement letters, timeline and file cover sheet.
Point 3.
A break down the total of 548,218 boat sightings into the figures for 2009 and 2010
On 13 October you made a request to British Waterways (BW) for the following information:
“I would be grateful if you could first of all break down the total of 548,218 boat sightings into the
figures for 2009 and 2010.
Secondly, please could you tell me the dates and locations of each of these boat sightings in the
following format:
1. the date;
2. the name of the waterway;
3. the total number of sightings made on that date on that waterway
4. a breakdown of the sightings for each day on each waterway into continuously cruising
boats, boats with home moorings, hire/share boats and trading boats.”
The request dated 13 October followed a request you made to BW on 8th October for information
including:
3. the total number of boat sightings made by BW in 2009; the total number of boat sightings
made by BW in 2010
4. the dates and locations of these boat sightings in 2009, and the dates and locations of
these boat sightings in 2010.”
Within your request for this review you mention that Chris Gray, BW’s Information Officer at the
time, had written to you twice before our final response was made withholding the information.
From his correspondence you believed that the information would be disclosed to you. Having
reviewed the e-mails sent by Mr Gray on 12th October and 4th November I can understand why you
would have believed the information to have been forthcoming. Unfortunately, until the information had been extracted from the database, Mr Gray had not sought any advice from colleagues within the enforcement and legal teams. In attempting to be helpful and keep you updated on the progress of your request Chris had inadvertently given you the impression that you would receive the information in our response. For this I apologise.
However, having reviewed your request further, I am pleased to provide you with the total number
of sightings made by BW in 2009 and 2010 which are as follows:
1. Total number of sightings 2009 – 297,372
2. Total number of sightings 2010 – 304,737
The total number of sightings of 602,109 for 2009 and 2010 differs from the total of 548,218 given
in our response of 12th October 2010 because the year (2010) was not quite complete at that time.
Point 4.
Secondly, please could you tell me the dates and locations of each of these boat sightings
(for [3] above) in the following format:
1. the date;
2. the name of the waterway;
3. the total number of sightings made on that date on that waterway; and
4. a breakdown of the sightings for each day on each waterway into continuously cruising
boats, boats with home moorings, hire/share boats and trading boats.
Again your initial request for this information was received on 13th October when you said:
“Secondly, please could you tell me the dates and locations of each of these boat sightings in the
following format:
1. the date;
2. the name of the waterway (location);
3. the total number of sightings made on that date on that waterway
4. a breakdown of the sightings for each day on each waterway into continuously cruising
boats, boats with home moorings, hire/share boats and trading boats.”
On 8th October you had already requested:
3. the dates and locations of these boat sightings in 2009, and the dates and locations of
these boat sightings in 2010.”
Again I offer our apologies that you believed this information, as you had requested it, would be
forthcoming following the e-mails that you had received from our Information Officer, Chris Gray.
In fact our response of 15th November was one of non-disclosure under Section 31(1)(g) or (h),
Law Enforcement.
“I refer to your e-mail of 13 October and I am writing to let you know that we have considered this matter in detail.
As a result, we are not prepared to disclose the information requested as it is likely to prejudice one or more of the specified purposes under Section 31(1)(g) or (h) of the Freedom of Information Act 2000 (Law Enforcement) and the public interest in withholding this information outweighs the public interest in disclosing it. The information requested is therefore exempt from disclosure (Law Enforcement).”
Within your request for this internal review you have helpfully defined the reasons that you are
unsatisfied with our response to you. These are:
1. BW has not given a clear explanation of its reasons for refusing to release the information
but has just repeated the terms of the exemption. According to the Freedom of Information
Act, BW must give a clear reason for refusal; repeating the terms of the exemption is not
sufficient.
2. BW has not explained why that particular exemption applies.
3. BW has not explained how it has carried out the public interest balancing exercise which is
required under the Act to justify withholding the information I requested.
I will now respond to each point in turn for clarity.
1. Clear Explanation:
To assist our Enforcement Team to manage and collect the appropriate licence and mooring fees,
data gatherers and collectors collect data about the boats on our waterways; this includes their
movements. We also collect data about boaters’ movements to check and to ensure that boaters
are complying with their contractual and our legal requirements. If a person is not complying we
can take the appropriate action against them; this could include legal action. We do not publish the survey data that we collect because of the implications that this may have on our enforcement
activities. The only other use to which this survey data is put is to determine the levels of evasion nationally on our waterways.
We also believe that because of the richness of the information you have requested (i.e. all
sightings made over a two year period broken down into the date; the name of the waterway; the
total number of sightings made on that date on that waterway and a breakdown of the sightings for
each day on each waterway into continuously cruising boats, boats with home moorings, hire/share
boats and trading boats) it would undermine British Waterways’ ability to properly perform its duties if this information were to be supplied and therefore held in the public domain. Furthermore, the information requested would reveal significant levels of detail about our monitoring processes and activities, which could be used to assist people in avoiding our enforcement strategy.
2. Application of Exemption:
In explaining why we have relied upon the Section 31 exemption it is necessary to provide some
background on British Waterways’ powers and responsibilities first. British Waterways is a public body and the navigation authority for the majority of inland waterways of Great Britain. It was established as a statutory corporation by section 1 of the Transport Act 1962 and took over the inland waterway operations (and certain docks and harbours) of the former British Transport Commission which itself had assumed control of the inland waterways under the auspices of nationalisation of the main British transport infrastructure as reflected in the Transport
Act 1947. British Waterways now manages navigation on approximately 2200 miles of waterways (canals and rivers) of which about one third are navigable rivers (such as the Severn, the Trent, the Lee, the Witham and the Weaver). The powers of British Waterways to manage the waterways within its jurisdiction largely derive from the private Acts of Parliament, often called the “Enabling Acts” that authorised its various predecessors to build the various canals. These Acts have been considerably supplemented by later public and private legislation. In addition to the Enabling Acts and the various Transport Acts, in particular of 1962 and 1968, the principal statutes referable to British Waterways’ management of the waterways are:
1. The British Waterways Act 1971
2. The British Waterways Act 1975
3. The British Waterways Act 1983
4. The British Waterways Act 1995
In addition to the aforementioned Acts there are a number of important canal byelaws which
provide the framework in which British Waterways manages the inland waterways. Section 16 of
the British Transport Commission Act 1954 empowered the British Transport Commission “from
time to time to make byelaws for regulating the use of the canal and the conduct of all persons
(including the officers and servants of the Commission) who shall be on the canal …”. “Canal” is
defined as “any canal or inland navigation belonging to or under the control of the Commission…”. Those powers of the British Transport Commission were vested in British Waterways as its successor by section 32 of the Transport Act 1962 and Byelaws for the proper regulation and
management of the canals were made in 1965, which have subsequently been amended in 1966,
1972, 1975 and 1976. I attach a copy of these bye-laws for your information.
Licensing of vessels to use and moor on British Waterways managed inland waterways
Most canals built in the 18th and 19th centuries were built with private capital but using public
statutory powers. In return for those powers the private canal companies were obliged to make use
of the canals generally available to commercial traffic and thus a statutory public right of
navigation, subject to payment of tolls by reference to the cargoes carried, was the usual
arrangement. That statutory right of navigation did not extend to the keeping of pleasure boats or
houseboats on the canal. It was therefore routine for the canal proprietor to issue licences (on payment of a fee) for pleasure boats and houseboats to be kept and used on the canal.
British Waterways is given a wide discretion in determining the terms and conditions on which it
may give permission for vessels to be kept and used on the waterways it manages. Section 43(3)
and 43(8) of the Transport Act 1962 (as amended) provides:
“(3) Subject to this Act and to any such enactment as is mentioned in the last foregoing subsection, the Boards shall have power to demand, take and recover or waive charges for their services and facilities, and to make the use of those services and facilities subject to such terms and conditions, as they think fit.”
“(8) The services and facilities referred to in subsection (3) of this section include, in the case of the British Waterways Board, the use of any inland waterway owned or managed by them by any ship or boat”.
British Waterways is therefore entitled (i) to charge for the use by a ship or a boat of any inland waterway, which is British Waterways owned or managed; and (ii) to make the use of any inland waterway which is British Waterways owned or managed subject to such terms and conditions as it thinks fit.
During the second half of the 20th century, the nature of the use of canals in the rest of England
and Wales changed significantly. Significant commercial traffic had largely disappeared by the
mid-1960s and the Transport Act 1968 recognised in statutory terms for the first time that the
primary use of the core canal network had become one of amenity with boating being primarily a
leisure activity.
The Transport Act 1968 therefore reformed the basis on which use of the waterways by vessels
was regulated by abolishing all statutory private and public rights of navigation (section 105(5)
Transport Act 1968) and making the use of any British Waterways managed waterway by a vessel
conditional on the permission or licence of British Waterways.
Section 105(5) provides:
“(5) …; and any local enactment passed with respect to any such inland waterway, so far
as that enactment –
(a) Confers any public right of navigation over the waterway; or
(b) Imposes any duty to maintain that waterway for the purpose of navigation (including
any duty to supply, or maintain a supply of, water for the waterway for that purpose)
shall cease to have effect.”
In the context of the abolition of statutory rights of navigation, section 115 of the Transport Act 1968 provides that “references to any right of navigation over a waterway or canal include
references to any right to use or keep any vessel or craft on the waterway or canal”.
From the starting point of there being no entitlement to use or keep a vessel on British Waterways
owned or managed waterways other than with British Waterways’ consent, which consent is
subject to a charge on such terms and conditions as British Waterways considers fit, British
Waterways operates a system of licensing by which anyone can obtain the right to use the
waterways.
Licensing is a critical element of British Waterways funding, with nearly £1 of every £5 spent on
maintaining the network being derived from licensing. The type of licence required depends on the
nature of use for the vessel.
The starting point is therefore the British Waterways Act 1971. Section 13 of the Act states:
“(1) It shall not be lawful to moor, place, keep or maintain any houseboat in an inland
waterway … unless a certificate, in this Act referred to as a “houseboat certificate”, in
relation to it is then in force …”
This section proceeds to provide that if no certificate is in force then British Waterways has the
power to serve a notice requiring the remedy of an unlicensed vessel being on the waterway,
failing which remedy various powers are made available to British Waterways.
Section 14 of the 1971 Act provided for registration of houseboats and section 15 provided for
payment for registration and renewal of any houseboat certificate.
The British Waterways Act 1971 also refined the term “pleasure boat”, defined in section 3 and
introduced a system of registration for such vessels, including charging for such registration, but only in respect of “river waterways” which were identified in schedule 1 of the Act, but do not include canals.
The pleasure boat licensing requirement was subsequently extended to canals in the 1975 and
1976 Bye-Laws. That such a medium was permissible was reflected in section 16 of the British
Transport Commission Act 1954. The power was vested in British Waterways by reason of section
32 of the Transport Act 1962 referred to above.
The next relevant legislation is the British Waterways Act 1983. Section 4 of that Act provides:
“(1) Notwithstanding anything in the Act of 1971 or the Act of 1974 or in any other enactment
relating to the Board or their inland waterways, the Board may register pleasure boats and
houseboats under the Act of 1971 for such periods and on payment of such charges as they may
from time to time determine. …”
Section 8 of the British Waterways Act 1983 provides a further means by which British Waterways
can serve notices on vessels which are not licensed, being vessels which are left or moored
without lawful authority requiring the removal of the vessel failing which British Waterways are
authorised to remove it.
By the mid-1990s, with the growing popularity and use of the waterways further reform of the
regime for the giving of permission to use the waterways was found to be necessary and
provisions were included in the British Waterways Act 1995 that extended and enhanced the
powers of British Waterways in this regard. In particular, the 1995 Act introduced a provision that made it a requirement for the issue of any licence that a vessel either (a) has a long term “home” mooring or (b) be used for continuous cruising throughout the period of the licence.
Section 17(3) of the British Waterways Act 1995 states:-
“(3) Notwithstanding anything in any relevant enactment but subject to subsection (7) below, the
Board may refuse a relevant consent in respect of any vessel unless –
(a) The applicant for the relevant consent satisfies the Board that the vessel complies with
the standards applicable to that vessel;
(b) An insurance policy is in force in respect of the vessel and a copy of the policy or
evidence that it exists and is in force has been produced to the Board; and
(c) Either –
(i) The Board are satisfied that a mooring or other place where the vessel can
reasonably be kept and may lawfully be left will be available for the vessel
whether on an inland waterway or elsewhere; or
(ii) The applicant for the relevant consent satisfies the Board that the vessel to
which the application relates will be used bona fide for navigation throughout
the period for which the consent is valid without remaining continuously in
any one place for more than 14 days or such longer period as is reasonable
in the circumstances.”
The provision in section 17(c)(i) above is commonly referred to as the “home mooring” requirement
and the provision in section 17(c)(ii) above is commonly referred to as the “continuous cruising”
requirement.
Part III of the British Waterways Act 1995 expands on the provisions for registration of houseboats and pleasure craft and a “relevant consent” for the purpose of section 17 is defined as meaning “…a houseboat certificate, a licence or a pleasure boat certificate”, thereby encompassing both houseboats and pleasure craft as originally defined in the 1971 Act.
I shall return below to deal with both the terms and conditions upon which British Waterways grant
consent for vessels to use the inland waterways it owns and manages and also the issue of
continuous cruising.
Moorings
When it comes to allocating space for moorings British Waterways has regard to the competing
interests of all the boaters and a balance has to be struck between those who require visitor
moorings as they pass through an area and those who require home moorings in that area. This
will ultimately be a matter for the exercise of British Waterways’ management discretion having
regard specifically to local circumstances, but in the context of the national picture.
In addition to the various statutory provisions relied upon by British Waterways for charging for
moorings, British Waterways is also able to exercise its rights as a landowner. The terms and
conditions of British Waterways licence make it plain that the permission to be on the waterways
does not extend to an entitlement to moor, except for short periods, where permitted, whilst
cruising the waterways. Therefore outside of mooring temporarily in the course of cruising, if no specific mooring permit is granted for a specific boat, the boater will be trespassing on British Waterways’ property.
Growth in use of the Waterways
As I have already mentioned, leisure boating on the inland waterway network has increased very
significantly in recent decades. In 1990 there were estimated to be some 22,000 boats on the
British Waterways managed waterway network. Today that has increased to approximately 35,000
boats. This, of course, is on an essentially finite waterway space. Demand generally, and particularly for use of the waterways by full time residential vessels, is
growing rapidly. This is a significant problem for British Waterways given the finite space available. Some of those who choose to live on the inland waterways do not wish to stay in a particular location and they continuously move from one place to another. These boaters are commonly described, both by British Waterways and the boating community generally, as “continuous
cruisers”. Other people who live permanently on their vessels prefer to generally stay in the same place, which may be on the inland waterway itself or off the inland waterway in a marina or on another stretch of waterway which is not within the jurisdiction of British Waterways. These people will have a home mooring that is also a residential mooring with planning permission.
A third category of residential boaters seek to live within easy reach of a particular location, usually a town or city, but do not have a home mooring. They do not use the boat “bona fide for navigation” (continuous cruising) but tend to keep it in the same place or close to the same place for extended periods. This category of persons causes considerable difficulties for British Waterways’ management of the inland waterway network. Aside from not complying with their licence terms and conditions and the applicable statutory framework, their actions will often amount to a breach of planning law. Further significant issues for British Waterways include:
Creating obstructions for other users of the inland waterways and the towpaths, because,
for example, casual towpath moorings or designated visitor moorings are not available for
other users, which itself has consequential effects as those seeking a visitor mooring may
be tempted to moor in the wrong location.
Avoidance of paying for a home mooring. Not only does this deprive British Waterways of
much needed revenue (if the home mooring is on the inland waterways within British
Waterways’ jurisdiction) but it acts as a real irritation to those who have complied with the
rules and regulations and paid the appropriate sums.
Licences, charges and revenue protection
Licences are issued subject to standard terms and conditions, including navigation rules and
mooring guidance. I attach a copy of the standard term and conditions.
Because of the abolition by statute of any right of private or public rights of navigation, any boat present on the waterways owned and managed by British Waterways must have permission which
is subject to the grant of a licence and compliance with these terms and conditions.
Licensing is a critical element of British Waterways’ funding. At present the cost of maintaining the inland waterways is approximately £140 million per annum. Around £23 million per annum is raised from licence and mooring fees to put towards the cost of maintenance.
Where we feel able to do so, British Waterways does not take issue with disclosing information
about its activities on Britain’s waterways. However, we cannot be expected to do so where, as
here, this would have an adverse effect on British Waterways’ operations or its management of the
waterways within its control.
We have relied on Section 31(1)(g) and (h) of the FOIA as the basis for refusing to disclose the
information requested. British Waterways considers that it is exempt from providing the
information requested on the basis that disclosure would be likely to prejudice the proper exercise of our functions. The particular section 31 (2) FOIA purposes that we deem applicable are:
Ascertaining whether anyone has failed to comply with the law; and/or
Ascertaining whether any person is responsible for improper conduct. For these
purposes, we consider that using the waterways otherwise than in accordance with
granted licence conditions would be improper.
3. Public interest test:
We believe that release of the information requested, namely, the total number of boat
sightings made by BW in 2009 and 2010 broken down into:
1. the date;
2. the name of the waterway (location);
3. the total number of sightings made on that date on that waterway
4. a breakdown of the sightings for each day on each waterway into
continuously cruising boats, boats with home moorings, hire/share boats
and trading boats
would prejudice, or be likely to prejudice, the ability of our enforcement staff to undertake their duties. It remains a very real concern for British Waterways that the richness of the data would provide such a clear picture of British Waterways’ monitoring and enforcement activities that the purpose of those activities would be undermined. Furthermore we believe that this prejudice is certain and probable.
We therefore contend that the public interest in disclosing the information requested is outweighed by the public interest in non-disclosure.
I would like to apologise again for the delay in responding to your request for an internal review
and trust that we have now fully addressed your concerns.
Yours sincerely,
Sarina Young
Customer Services Co-Ordinator
This is the Information Commissioner’s decision:
Your FOIA complaint about British Waterways – an update
I am writing from the Information Commissioner’s Office about the complaint that you have made about British Waterways. I can confirm that I have been allocated this complaint as case officer and have already corresponded with British Waterways in order to ensure that it complied with its obligations in this case.
This email has two purposes. The first is to provide an update and the Commissioner’s preliminary view. The second is to provide your options about how this case will continue and ask you to choose one.
(1) An update about this case
The main problem that you reported was British Waterways’ failure to conduct an internal review in a reasonable time period and its failure to answer some of your requests at all.
I have now told British Waterways what it should have done and it has now issued an appropriate internal review. A copy of that review is attached for your ease of reference.
I consider the internal review response accords with what is expected and complies substantively with its obligations under the Act.
I can also confirm that my preliminary view is that it has applied section 31 appropriately to the information identified in part [4] of the request. Coincidentally, the Commissioner considered a case for subset of the information you requested in part [4] recently. He found that the exemption was applied appropriately by British Waterways. A link to a copy of that Decision Notice can be found below:
http://www.ico.gov.uk/~/media/documents/decisionnotices/2011/fs_50382936.ashx
For your information, British Waterways originally tried to apply section 31 to the information requests in part [3] and it changed its mind after my involvement. It also ensured that it provided the full figures for both years.
However, procedurally British Waterways have acted well below what is expected by the Commissioner. In particular, it has taken:
§ Far too long to issue an appropriate response to some parts of your request – particularly parts [1], [2] and [4];
§ Its refusal notice lacked appropriate detail – although this was remedied in its internal review; and
§ Far too long to conduct its internal review – although there is no statutory timescale to conduct an internal review.
I can confirm that I have referred these matters to our enforcement team and they will continue to monitor British Waterways. The enforcement team is concerned about patterns of non-compliance and do not correspond with individual complainants. However, I consider it important that they are aware of these problems to influence their future work.
(2) Your available options
There are three possible options that can be taken in this case. They are noted below:
1. Your first option is to choose to withdraw this complaint at this stage. You may decide in light of receiving the information you are entitled to that this particular case can be closed. If you choose this option, I will ensure that the procedural breaches are recorded on our system and that you receive a copy of the letter that I write to the British Waterways advising it to improve. If you choose to withdraw your complaint, you cannot appeal to the First Tier Tribunal (Information Rights);
2. Your second option is to ask for the Commissioner to come to a formal decision about the unacceptable delays you experienced in this case. The advantage of this would be that you would receive independent verification about where the British Waterways fell short and this would be a public document; or
3. You third option is to elect for a formal decision notice about both the delays and about British Waterways withholding the information under section 31. If so, I would appreciate that you provide your arguments about why you consider that the Decision Notice about similar information is not correct. I would like you to do this to ensure that I address any concerns that you have in the formal decision notice. This option will take more time than the first two.
Please choose one of these three options, as soon as possible, and by 20 January 2012. If I do not hear from you by 20 January 2012, I will proceed on the basis that you are prepared to take option one.
I hope this letter is clear and helpful. If you have any questions about your case please call me. I can be contacted on the telephone on 01625 545 547. This office is not open between 24 December 2011 and 3 January 2012.
I look forward to hearing from you. You can respond by replying by post:
The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tags: CC1, CC2, continuous cruising, enforcement team, FOI requests, Section 17, Waterways Act 1995