Freedom of Information request - ULEZ WARNING SIGNS for Start – Decision Letter Dates
Request ID: FOI-0093-2425 Date published: 03 May 2024
You asked
Dear Transport for London,
Where and when were the signs shown below installed?
http://webdefence.global.blackspider.com/urlwrap/?q=AXicY3BmUGFmYAgUZWQoyqk0NM7SKy4q08tNzMxJzs8rKcrP0UvOz2UwMbbwDQ1OMTEwNDUxM2dIy890KEnL0UvPL9MrzWbIKCkpKLbS108uLSnRy6nULyg3yU5KNy1gYGDQ0mFgAABwwRyF&Z
http://webdefence.global.blackspider.com/urlwrap/?q=AXicY3BmUGFmYAgUZWQoyqk0NM7SKy4q08tNzMxJzs8rKcrP0UvOz2UwMbbwDQ1OMTEwNDUxM2dIy890KEnL0UvPL9MrzWbIKCkpKLbS108uLSnRy6nUNyo3yS4zzMhlYGDQ0mFgAABtkhxV&Z
Please provide a copy of the TFL Policy Decision in respect of this.
Then a general description of locations where the signs were installed.
How many in total of each type were installed – and over what time period – dates please.
Was there any policy on removal – if so please provide this.
Please also provide a list of 30 precise locations where these signs were installed.
This is to be an illustrative sample.
Please include the dates of installation of each of these signs, along with the dates when any were removed.
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The Decision to go ahead with the ULEZ expansion to outer London is said to have been taken in November 2022.
Please provide a copy of that Decision Letter.
Four months earlier on 20 July 2022, the government Secretary of State issued a Decision Letter authorising TFL’s proposed new ULEZ signs.
Clearly this was made following an application by TFL or the Mayor to the Secretary of State for approval of those designs.
Please provide a copy of that application letter.
Please also provide copies of any further letters between TFL / Mayor and the government / DFT during 2022 or 2023 relating to or covering ULEZ.
Does TFL have an explanation for asking for permission for its proposed signs over four months before the Decision to implement the scheme was made?
Thank you for your request received by Transport for London (TfL) on 18th April 2024 asking for information about the A23 Brighton Road.
Your request has been considered in accordance with the requirements of the Environmental Information Regulations (EIR) and our information access policy.
I can confirm that we hold the information you require.
We have noted that this latest request follows a very similar tone, style and format to a number of other requests we have received via the What Do They Know website recently, including case references EIR-0069-2425 and EIR-0093-2425 which are both currently open, as well as a number of other cases received over recent weeks which have already been processed and are closed. These cases share a number of obvious similarities beyond the use of What Do They Know, including the following:
Similar subject matters and similar information being requested;
A tendency to mix requests for recorded information (which are rightly covered by FOI and EIR law) with requests for explanation (which are not covered by the FOI Act or EIR) and general comments and statements;
A large number of questions and large amount of information being requested, split into different sections using a single “ - “;
The use of identical wording in parts
All of this leads us to believe that these requests have been submitted by individuals acting in concert with each other or, more likely, a single person using different pseudonyms.
Whether the requests have been submitted by individuals acting together or by one individual acting alone, they nonetheless represent a sustained and cumulative burden and cost which we do not believe is proportionate to their value. The three requests referenced above are therefore being refused under Regulation 12(4)(b) of the EIR on the basis that they are ‘manifestly unreasonable’. In reaching this conclusion we have taken account of the Information Commissioner’s guidance on the use of Regulation 12(4)(b), which can be seen online here:
As you can see, the guidance includes the following:
“This exception can be used:
when the request is vexatious; or
when the cost of compliance with the request would be too great.”
“The purpose of the exception is to protect public authorities from exposure to a disproportionate burden or an unjustified level of distress, disruption or irritation, in handling information requests.”
“In assessing whether the cost or burden of dealing with a request is “too great”, public authorities will need to consider the proportionality of the burden or costs involved and decide whether they are clearly or obviously unreasonable.
This will mean taking into account all the circumstances of the case including:
- the context in which the request is made, which may include the burden of responding to other requests on the same subject from the same requester.”
“... there may be occasions where it permissible to consider a number of EIR requests together when deciding if they are manifestly unreasonable on the grounds of cost. This is in line with the approach to requests considered manifestly unreasonable on the grounds that they are vexatious, where the context in which they are made can be taken into account.”
The cumulative effect of these requests is that it ultimately creates a disruption and sustained burden to our colleagues across the organisation whose principal function is the running of transport services, or the support services required to make that happen, which ultimately comes at a cost to the public purse. Providing input to respond to information requests requires the re-allocation and diversion of their resources and places a burden on a small number of personnel. All of this leads us to believe that answering this latest series of requests, further to those already answered, is not a justified and proportionate use of our time, and that there is no wider public interest in doing so. A significant volume of information on all of the subjects that feature within your requests can be found on our published responses at the following link: https://tfl.gov.uk/corporate/transparency/freedom-of-information/search
Where you have questions or concerns that require the provision of advice, explanation or opinion we would encourage you to submit them to the relevant area of TfL by using the following contact pages: https://tfl.gov.uk/help-and-contact/
Please see the attached information sheet for details of your right to appeal.
Yours sincerely,
David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London
