I am writing to request the following information under the Freedom of Information Act 2000: 1) Since 9 May 2016 I would like to know which roads licensed London Black taxis been excluded from driving along or have no access to, which they could previously operate on? 2) Which roads are TfL planning to ban licensed London Black Taxis from driving on? 3) What regard in the decision making and design of any and all of the policy decisions to ban licensed London Black taxis from certain roads since 9 May 2016 was made to the Public Sector Equality Duty to advance equality? 4) Is there evidence that the Reasonable Adjustments Act been taken into consideration when designing the road closures and exclusions pertaining to the Streetspace initiative 5) How are the policies to ban licensed London Black Taxis from certain roads since 9 May 2016 being kept under review to consider the cumulative impact of these policies on disabled people. 6) Has there been any impact assessment on the licensed London Black taxi industry in relation to the Streetspace initiative and the road closures pertaining to its inception. (Please disregard previous request as question 6 was partially omitted in error)

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TfL Ref: EIR-0593-2021

Thank you for your request of 10^th July 2020 asking for information about black taxis being banned from certain roads.

Your request has been considered in accordance with the requirements of the Environmental Information Regulations Act and our information access policy.

Your questions are answered in turn below:

1) Since 9 May 2016 I would like to know which roads licensed London Black taxis been excluded from driving along or have no access to, which they could previously operate on?

TfL is the Highway Authority for the Transport for London Road Network (TLRN) only and, as such, this response is only in relation to the TLRN (which makes up around 5% of the road network) and not all roads within London.

The detail regarding restrictions on types of traffic using our roads is contained within the text of individual Traffic Regulation Orders (TRO). We can confirm that since 9 May 2016 we have not made any permanent TROs which exclude London Black Taxis from driving on TLRN roads. However, there are a small number of sections of bus lanes where taxis - along with other road vehicles - have been excluded along the TLRN. This information is contained within each specific TRO. To collate the information on exactly where such restrictions exist would require us to search each individual order and determine whether it contains information on taxis. To do this would require an inordinate amount of work - a conservative estimate would be that it would take one person in excess of 3-4 weeks of manual effort to complete this task. The request is therefore refused under regulation 12(4)(b) of the EIR on the grounds that it would be “manifestly unreasonable” to comply. The guidance on the use of this exception from the Information Commissioner’s Office (ICO) states that it can apply when the cost of compliance with the request would be too great, and that:

“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”.

While we appreciate the need for transparency and accountability from public bodies in the conduct of their business, and the expectation under EIR that requested information will be released, in this instance we believe that the balance of public interest falls in favour of the exception applying given the amount of resource that would be required to be expended in meeting the request, which would represent a disproportionate burden and unjustified level of disruption, requiring the allocation of limited resources which would more beneficially be spent elsewhere.

Permanent traffic orders are made available to view at our Palestra offices, and the offices of the relevant local authority, in line with the national regulations. They also appear in a paper available in the relevant local area and the London Gazette. There is no requirement for temporary traffic orders to be held on deposit as there is with permanent orders. However, the notice of intent and notice of making are published in a local paper. In all cases, copies of the orders and public notices affecting taxis are sent to the Licenced Taxi Drivers Association during the statutory process, both at the intent and making stage.

As part of our Streetspace plans and in response to the coronavirus pandemic, we are temporarily making Bishopsgate a bus / walk / cycle only corridor in order to facilitate cycling and walking in the interests of social distancing. All traffic including taxis will continue to be able to access properties on and adjacent to Bishopsgate which will be retained from side road entry, even though access through each end of the corridor will not be permitted for any motor vehicles between 7am and 7pm, Monday to Friday. The operation of the scheme will be kept under review.

2) Which roads are TfL planning to ban licensed London Black Taxis from driving on?

No decisions have been taken on permanently banning London Black Taxis on any TfL roads to date. We continue to develop our Streetspace Plan in partnership with the London boroughs who are responsible for the non-TLRN road network and any potential changes that involve full road closure or prohibition of certain vehicles will be consulted on with the trade where appropriate.

3) What regard in the decision making and design of any and all of the policy decisions to ban licensed London Black taxis from certain roads since 9 May 2016 was made to the Public Sector Equality Duty to advance equality?

We have not taken any decisions to permanently ban London Black Taxis from any TLRN roads since 9 May 2016 other than some small sections of bus lanes as referred to above. An Equality Impact Assessment (EQiA) has been undertaken on the Bishopsgate proposals in line with our public sector equality duty. Future Streetspace schemes will also be subject to Equality Impact Assessments.

4) Is there evidence that the Reasonable Adjustments Act been taken into consideration when designing the road closures and exclusions pertaining to the Streetspace initiative

Under the Equality Act 2010, TfL is required, in broad terms, to have ‘due regard’ to the need to eliminate discrimination, advance equality of opportunity and foster good relations when making decisions and developing and implementing policies.

5) How are the policies to ban licensed London Black Taxis from certain roads since 9 May 2016 being kept under review to consider the cumulative impact of these policies on disabled people.

An EQiA has been undertaken for the Streetspace programme and this will be kept updated as the programme develops. This impact assessment considers the potential short, medium and long term impacts of these changes related to all protected characteristics as defined by the Equality Act 2010 and this includes those people with disabilities.

6) Has there been any impact assessment on the licensed London Black taxi industry in relation to the Streetspace initiative and the road closures pertaining to its inception.

No specific impact assessment has been undertaken on the licensed London Black taxi industry in relation to our Streetspace programme however a number of strategic traffic modelling studies are ongoing. These studies focus on providing a better understanding of the combined impact of a variety of initiatives that have either been implemented or proposed to assist the restart of activity in and around the city. This encompasses both TLRN and London Borough streetscape proposals.

On a more general matter, please note that the impact of current circumstances on TfL’s resources means we are not able to answer FOI requests readily and we ask that you please do not make a request to us at present.

Answering FOI requests will require the use of limited resources and the attention of staff who could be supporting other essential activity. In any event, please note that our response time will be affected by the current situation.

Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.

Yours sincerely,

David Wells

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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