Request ID: FOI-0656-2223 Date published: 29 June 2022
You asked
Good morning,
I was just having a look at the bus lane camera request (FOI-2452-1617 ) and wanted to download the file but it doesn't work for some reason.
Could I be assisted with this, please?
We answered
TfL Ref: 0656-2223
Thank you for your request received by us on 16 June 2022 asking for information about a published Freedom of Information request seeking the locations of bus lane cameras.
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. I can confirm that we hold the information you require. You asked for the following:
I was just having a look at the bus lane camera request (FOI-2452-1617 ) and wanted to download the file but it doesn't work for some reason.
Could I be assisted with this, please?
Whilst these locations have been disclosed previously, we can advise that in accordance with section 31 of the FOI Act, which relates to ‘law enforcement’, we are not obliged to supply information if it would, or would be likely to, prejudice the apprehension or prosecution of offenders or the exercise of functions for the purpose of ascertaining whether any person has failed to comply with the law.
In this instance the exemption has been applied as disclosure of the information would reveal which parts of the TfL road network are covered by such cameras. The purpose of these cameras is to assist with the safe and smooth flow of traffic on the TfL Road Network (TLRN), and TfL has the power to issue Penalty Charge Notices where drivers contravene a range of restrictions on the TLRN – the capital’s red routes. If drivers are aware of exactly where and, by extension, where not, these cameras are placed then it could, as a result, encourage non-compliance with traffic restrictions. This would adversely affect the flow of traffic, together with bus journey reliability times. Consequently, enforcement at those locations would need to be increased, which TfL currently does not have either the resources or infrastructure to undertake.
The use of this exemption is subject to an assessment of the public interest in relation to the disclosure of the information concerned. While we recognise the need for openness and transparency by public authorities, in this instance we feel that the greater public interest lies in favour of withholding the information requested in the interests of law enforcement and the daily operation of a busy road network, ensuring that we can effectively deter, monitor and enforce parking, bus lane and moving traffic contraventions across London.
The Commissioner is satisfied that the arguments presented by TfL outline how disclosure of the requested information would prejudice the applicable interests within the relevant exemption. Section 73 of the TMA 2004 outlines the contraventions under the act which are subject to civil enforcement, including bus lane contraventions. As previously discussed, TfL has a statutory duty to both ascertain if an individual has broken traffic regulations and apprehend and prosecute said offenders.
The Commissioner accepts TfL’s explanation that disclosure of the requested information, added to similar information already in the public domain, would allow motorists to determine where there is the least risk of receiving a PCN for failing to comply with bus lane controls. In turn, this would compromise the deterrent effect upon which TfL relies and increase the likelihood of such offences occurring, thus making it harder for TfL to carry out its statutory functions as outlined in section 16 of the TMA 2004. In its submission to the Commissioner, TfL has emphasised that expeditious movement of traffic throughout London relies on motorists obeying traffic regulations irrespective of whether a camera is present or operational. 27. Ultimately, the Commissioner concurs with TfL that it cannot afford to compromise the deterrent effect upon which it relies and which is sustained by the ignorance of motorists as to where enforcement action is less likely to take place. This deterrent effect maintains the expeditious movement of London’s traffic in place of the need for enforcement monitoring across the TLRN in its entirety at all times.
TfL has explained to the Commissioner that if this information were added to information already in the public domain, individuals would be able to build up a database of enforcement camera functionality in an effort to predict when cameras may or may not be operational or are operational only sporadically. This is what is commonly known as the ‘mosaic effect’. TfL has explained disclosure of this narrowed information into the public domain would be likely to lead to further continued requests concerning other specific camera enforcement locations in an effort to enhance this database.
The Commissioner accepts TfL’s explanation that disclosure of the requested information, added to similar information already in the public domain, would allow motorists to determine where there is the least risk of receiving a PCN for failing to comply with bus lane controls. In turn, this would compromise the deterrent effect upon which TfL relies and increase the likelihood of such offences occurring, thus making it harder for TfL to carry out its statutory functions as outlined in section 16 of the TMA 2004. In its submission to the Commissioner, TfL has emphasised that expeditious movement of traffic throughout London relies on motorists obeying traffic regulations irrespective of whether a camera is present or operational.
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 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
Jasmine Howard FOI Case Officer FOI Case Management Team General Counsel Transport for London
