Love it!

For the BBC to say "we would need to manually examine each individual address on our database to find the information you have requested" is, quite frankly, ridiculous. This is what computers are for! It would be a simply matter to construct a suitable query or series of queries which would distinguish a vehicle registration number from any other type of address. For example, a first step would be to eliminate all records carrying a postcode and this would take seconds. Subsequent operations would depend on the fields available in the records. As Sir Winston Churchill very nearly said - "Give me the tools and I will finish the job."

You know that, I know that, but apparently they do not. I have visions of TVL sending out reminders to "Motor Home ABC123X, Somewhere in the UK". The TVL web site is strangely silent about setting up a primary abode in anything other than a house on a street with a post code so I have asked them to clarify their procedures used when that is not the case.

An internal review of an internal review... sounding a bit like a Monty Python sketch!

Hmmm... but I'm not finished with this yet.

They refused my request.

Then they refused my request again following an internal review.

Then they apologise for being late with their reply.

Me neither.

Stick with it, brother. This is not a frivolous FoI request. In December 1997 I sold my house and began a nomadic life in a motorcaravan, which was my sole place of residence. This lasted until August 2000. Was I TV licensed? No - how could I be? Was I watching or recording TV programme service? The BBC will never know, as it does not know whether I'm doing so today.

The situation is real, and the BBC ought to tell the public what the licensing requirements are under these circumstances. If ignorance of the law is no defence, the public has a right to know what the law is. The BBC, as the TV Licensing Authority, should tell us.

Finally, a response from TVL:

******
I can confirm that it's possible to use the registration of a vehicle as a licensable address.

If somebody lives permanently on a canal boat or in a road vehicle, and they're watching live broadcasts on any device, they would require a TV Licence regardless of whether or not they're using mains electricity. If, however, they had a permanent residence which had a licence and they were using only the battery power of a laptop to watch live television, for example, whilst on their boat or in their vehicle, they would be covered the licence at their home address.

If a permanent address can't be supplied it's possible, if it's a road vehicle, to use the registration as the licensed address. Furthermore, as my colleague has stated in a previous email, it's possible to use TV Licensing's details as a holding address. If it's a licence for a canal boat and a permanent address can't be supplied we ask for the name of the boat, and the address and postcode of the mooring that it's registered to.

The licence holder can sign up to receive correspondence electronically. If, however, the customer would prefer to receive paper copies of their licence and renewal reminders and doesn't have a poste restante, all I can advise is that a forwarding address is provided, and we can redirect all correspondence to that address.
******

I have received another reply directly from BBC FOI:

Request for Information – RFI20140523 and RFI20140538

I write further to your email to TV Licensing Customer Relations on 27 March 2014. We have interpreted your query as a request under the Freedom of Information Act 2000 (‘the Act’) seeking the following information:

RFI20140523

“The BBC's Information Policy and Compliance department suggested that I contact you. In response to a FOI request concerning the holding of TV licences by people who live permanently in a mobile home (RFI20131619) the BBC has stated "a vehicle registration could be used as a licensable address". I queried this with yourselves some time ago and I was told that this is not possible and that a "bricks and mortar" street address with post code is needed to register a TV licence. I would be grateful if you would answer the following questions for me assuming that these apply to somebody who wishes to watch live TV lawfully:

1) Can a vehicle registration be used as a licensable address?

2) If somebody lives permanently in a road vehicle and has no access to mains electricity, do they need a TV licence?

3) If somebody lives permanently on a on a canal boat and has no access to mains electricity, do they need a TV licence?

4) How can a licence be registered to a vehicle or boat owner if they cannot or do not supply a street address with post code?

5) What procedures do TV Licensing have in place to prevent TV licence letters and documents from erroneously being sent by post to road vehicles.

6) What procedures are used by TV Licensing to send paper communications to the holders of licences registered to road vehicles and "continuous cruiser" boat owners who do not have a "poste restante" address?

I also note that you subsequently contacted the BBC directly on 3rd April 2014 with the following related request:

RFI20140538

“This FOI request has, presumably, been raised on my behalf by TV Licensing. Your email yesterday came as something of a surprise to me as I was expecting and hoping that TVL would answer my questions themselves as a previous FOI request (RFI20131804) had failed to provide the information I am seeking.

I would like to know, please, the name of the person at TV Licensing who raised this FOI request on my behalf.”

Please note that “TV Licensing” is a trade mark used by companies contracted by the BBC to administer the collection of television licence fees and enforcement of the television licensing system. The majority of the administration of TV Licensing is contracted to Capita Business Services Ltd (‘Capita’). Over-the-counter services are provided by PayPoint plc (‘PayPoint’) in the UK, and by the Post Office in the Isle of Man and Channel Islands. Marketing and printing services are contracted to Proximity London Ltd. Media services are contracted to Mediaedge:CIA International Limited ("MEC"). The BBC is a public authority in respect of its television licensing functions and retains overall responsibility.

Firstly, in response to your request RFI20140538, I note that the Internal Review Decision IR2014001 (in respect of your earlier request RFI20131804) suggested that you should contact TV Licensing directly for further guidance or clarification about TV Licensing. Please note that the web contact details provided directs individuals to TV Licensing Customer Relations which deals with general queries and/or complaints.

Please be advised that the Act gives a general right of access to all types of recorded information held by public authorities. As TV Licensing Customer Relations is managed by Capita, all requests for recorded information received by this department are automatically passed to the BBC to respond to. This is because Capita is not a public authority as defined in the Act. In retrospect, this could have been made clearer in the Internal Review Decision and I apologise for any inconvenience this may have caused.

Turning to your request RFI20140523, I shall address your questions in turn below.

1) Can a vehicle registration be used as a licensable address?

As explained in my response to RFI20141619 (on which your request RFI20131804 was predicated), anyone who watches or records television programmes at the same time as they are shown on TV will need a TV Licence. Motor vehicles do not require a separate licence provided a licence is held at the user's primary address. However, if a motor vehicle is the primary place of residence and you watch or record television programmes at the same time as they are shown on TV, you will need a TV Licence. In the latter case, the vehicle will constitute a licensable address.

Where a vehicle is the primary place of residence and that vehicle is static, such as a caravan situated in a caravan park; or has a semi-permanent location, such as a boat with a mooring address, TV Licensing will use that fixed site address to communicate with the licence holder. If the vehicle is mobile with no fixed correspondence address, TV Licensing will seek a forwarding address from the licence holder for the purpose of communicating with them. If the licence holder is unable to provide a forwarding address, TV Licensing will set up an e-licence until such time as one could be supplied.

2) If somebody lives permanently in a road vehicle and has no access to mains electricity, do they need a TV licence?

3) If somebody lives permanently on a on a canal boat and has no access to mains electricity, do they need a TV licence?

Please be advised that the Act gives a general right of access to all types of recorded information held by public authorities. As these are hypothetical questions they fall outside the scope of the Act. However, under our duty to advise and assist you under section 16 of the Act, I can tell you that a TV Licence is required in both scenarios if you watch or record television programmes at the same time as they are shown on TV.

4) How can a licence be registered to a vehicle or boat owner if they cannot or do not supply a street address with post code?

5) What procedures do TV Licensing have in place to prevent TV licence letters and documents from erroneously being sent by post to road vehicles.

6) What procedures are used by TV Licensing to send paper communications to the holders of licences

registered to road vehicles and "continuous cruiser" boat owners who do not have a "poste restante" address?

Please see my response to question 1 above.

Appeal Rights

If you are not satisfied that the BBC has complied with the Act in responding to your request you have the right to an internal review by a BBC senior manager or legal adviser. Please contact us at the address above, explaining what you would like us to review under the Act and including your reference number. If you are not satisfied with the internal review, you can appeal to the Information Commissioner. The contact details are: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow SK9 5AF. Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate) or see http://www.ico.gov.uk/.

Kind regards

Rupinder Panesar

Freedom of Information Advisor, TV Licensing Management Team

You vill pay come what may, ve have vays of sending out speedboats, that vill be a lot faster than your barge - you haf seen james bond, on your unlicenced TV? Ves, Ve have a vaster one ;)

Merry Xmas 2014 to all in this sparring contest!