Request for Cost of DVLA Mail to Drivers on behalf of TfL
Request ID: FOI-0614-2324 Date published: 23 June 2023
You asked
Request for details of costs from public funds for the DVLA ULEZ Mail Programme to Drivers on behalf of TfL.
What is the anticipated cost of the above?
What determines if a letter is sent to a driver?
What has been the response from members of the public receiving these letters?
How much support is there from members of the public for this exercise?
Was Cost/Benefit Analysis undertaken by TfL regarding the cost of this exercise?
Please provide details of any analysis.
We answered
Our Ref: FOI-0614-2324
Thank you for your request received on 30 May 2023 asking for information about the letter regarding the Ultra Low Emission Zone (ULEZ).
Your request has been considered in accordance with the requirements of the Freedom of Information (FOI) Act and our information access policy. I can confirm that we hold some of the information you require.
TfL is writing to the registered keepers of non-compliant vehicles owners whose vehicle we have seen being driven in outer London in what will be the expanded ULEZ area from 29 August 2023. Having identified the vehicles likely to be affected by this change, TfL has asked the DVLA to send letters to their registered keepers on our behalf. The letters help provide information in advance of the expansion on the vehicle’s compliance status, the options available including the scrappage scheme, grace periods and how the scheme operates including how to pay. The DVLA do not share registered keeper data with TfL or any third party for this purpose, and TfL does not know where these letters have been sent.
The letters form part of a large-scale multi-channel information campaign to raise awareness and to encourage vehicle checking with messaging running on TV, video on demand, radio, local and pan-London press, national specialist press e.g. What Van and What Car, and national press, a radio and local newspaper content partnership, digital display, messaging on Waze, a wayfinding app, social, roadside posters and petrol pump nozzle advertising. Emails are also being sent to customers registered to TfL’s database and leaflets are being distributed via a door drop and face to face leafleting in high footfall locations such as high streets, in the outer London boroughs.
You asked:
• What is the anticipated cost of the above?
In accordance with the FOI Act, we are not obliged to supply the information regarding the amount paid to the DVLA as it is subject to a statutory exemption to the right of access to information under section 43(2).
In this instance the section 43(2) exemption has been applied as disclosure would be likely to prejudice the commercial interests of the DVLA. Prejudice would be likely to occur when the DVLA carry out similar mail campaigns in the future, as their competitive edge would be prejudiced by disclosure of the price we have paid.
The use of this exemption is subject to an assessment of the public interest in relation to the disclosure of the information concerned. We recognise the need for openness and transparency by public authorities but in this instance the public interest in ensuring that the DVLA’s ability to procure the best deal in future campaigns and are not prejudiced in any way outweighs the general public interest in increasing transparency of our processes.
• What determines if a letter is sent to a driver?
Letters are sent based on identifying non-compliant vehicle registration marks (VRMs) seen driving by our Automatic Number Plate Recognition (ANPR) cameras within the ULEZ expansion area. The criteria for whether a VRM is included in the mailings to date, as of 5 June 2023, is that the vehicle had to be detected three or more times, either on the same day or across multiple days, between 1 December 2022 to 25 January 2023. These criteria may change for any future mailings.
TfL then de-duplicates the VRM captures and identifies which are non-compliant with the ULEZ scheme using the existing TfL database used for the existing ULEZ. Those VRMs that are non-compliant are then checked against TfL’s existing Road User Charging customers and if they are an existing customer with an associated email address (e.g. Auto Pay Customers who get monthly statements) then they will be contacted directly by TfL.
As stated above, a record of the remaining non-compliant VRMs is then provided to the DVLA who send an agreed letter to the registered keeper, where they have details in their database. The registered keeper details for these vehicles are not shared by the DVLA with TfL.
• What has been the response from members of the public receiving these letters? How much support is there from members of the public for this exercise?
TfL is not measuring the response from members of the public receiving these letters, nor is TfL measuring support for sending out letters to non-compliant vehicle owners via the DVLA.
TfL has previously carried out mailings via the DVLA for the implementation of the central ULEZ scheme and again when the ULEZ expanded to inner London in Oct 2021, as part of a multi-channel information campaign to prepare drivers.
As part of the consultation during the development of the ULEZ expansion policy in May 2022, TfL did advise that it intended to send letters via the DVLA to registered keepers of non-compliant vehicles seen in the expanded zone as detailed in pages 11-12 of the draft Data Protection Impact Assessment in the event the Mayor decided to go forward with the proposals, as he has now done). https://content.tfl.gov.uk/london-wide-ulez-draft-data-protection-impact-assessment.pdf
This was repeated in the final Data Protection Impact Assessment produced after the consultation and Mayor’s decision to expand the ULEZ, and has also been communicated via the ULEZ Privacy pages within the section ‘London wide ULEZ expansion mail-outs'
• Was Cost/Benefit Analysis undertaken by TfL regarding the cost of this exercise?
No cost/benefit analysis was undertaken by TfL as the DVLA are the only holders of registered keeper data for vehicles in the UK meaning there is no other means of directly contacting non-compliant vehicle owners identified within the expansion area. There are no third-party commercial databases that contain information on both the registered keeper linked to a specific vehicle and the vehicle compliance status with the ULEZ. If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me.
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
