Request ID: FOI-0290-2324 Date published: 31 May 2023
You asked
1. Please let me have copies of all correspondence, including but not exclusively, emails, letters, notes of phone conversations, minutes or notes of meetings whether physical or virtual, with London Borough of Bromley, its officers or Councillors in relation to ULEZ expansion and implementation including but not specifically enforcement camera and warning sign erection and positioning for the period 1/4/22 to present date.
2. Please let me have copies of all correspondence, including but not exclusively, emails, letters, notes of phone conversations, minutes or notes of meetings whether physical or virtual, with Kent County Council, its officers or Councillors in relation to ULEZ expansion and implementation including but not specifically enforcement camera and warning sign erection and positioning for the period 1/4/22 to present date.
We answered
Our Ref: FOI-0290-2324
Thank you for your request received on 29 April 2023 asking for information about the Ultra Low Emission Zone (ULEZ) expansion. Your requests have been considered in accordance with the requirements of the Environmental Information Regulations (EIR) and our information access policy. I can confirm we do hold the information you require. Given the extent of the information you are looking for across both of your current requests, we are applying Regulation 12(4)(b) as we believe that the requests are ‘manifestly unreasonable’ because providing the information you have requested would impose unreasonable costs on us and require an unreasonable diversion of resources. When requests for email correspondence are received we are able to conduct a companywide email search using keywords, dates and email addresses. The more specific a requester can be as to what they are looking for, the more we can narrow the search and therefore stand a better chance of a more relevant or focused result. A search will then return an amount of ‘hits’ which potentially contain information relating to the search terms used. Each ‘hit’ is a single email, although that email will often consist of a chain of emails containing the search term at least once. We have done initial searches for all emails held by TfL sent/received to the London Borough of Bromley and separately to Kent County Council that contain the word ‘ULEZ’. This has returned over 7,000 hits. This search will include duplicates, as well as emails sent from third parties which TfL were copied into so are not caught by the request. However, we would still need to manually review all of the emails identified by the search in order to extract and collate the relevant emails. As we have only searched on the term ‘ULEZ’ there is potentially other relevant information that was not captured by these search terms so additional searches would have to be carried out. In addition to the time taken to search and review correspondence we would also need to identify and locate any letters, meeting minutes, or other documents. These will be held across several teams and would be very time consuming to identify and locate. You may wish to consider narrowing the scope of your request. For example, you may want to narrow your request by reducing the timeframe or providing additional keywords that you would like us to search against. Alternatively, rather than a blanket request for correspondence and documentation, if you have specific questions that you would like to ask this may be more helpful than a request for correspondence. Please note that by their nature, emails contain a significant amount of personal data such as phone numbers and email addresses and so, whilst this process of redaction does not feature as part of our considerations, the burden created by non-specific requests for emails is significant and this should be borne in mind before submitting requests of this nature. Although your request can take the form of a question, rather than a request for specific documents, we do not have to answer your question if it would require the creation of new information or the provision of a judgement, explanation, advice or opinion that was not already recorded at the time of your request. The use of this exception is subject to a public interest test, which requires us to consider whether the public interest in applying the exception outweighs the public interest in disclosure. We recognise that the release of information would promote accountability and transparency in public services and may help address your particular concerns about this issue. However, the time it would take to provide the information you have requested would divert a disproportionate amount of our resources from its core functions and as there is already a large amount of data already published on these matters, on balance we consider that the public interest currently favours the use of the exception. We will consider your request again, if you are able to narrow its scope so that we can more easily locate, retrieve and extract the information you are seeking. Please see the attached information sheet for details of your right to appeal.
Yours sincerely
Gemma Jacob Senior FOI Case Officer FOI Case Management Team General Counsel Transport for London
