TfL Ref: 2379-23254
Thank you for your request received by Transport for London (TfL) on 2 October 2023 asking for information about the DVLA database and the ULEZ scheme, following your previous request for information, TfL reference: 1688-2324 and subsequent request for an Internal Review.
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. You asked about the following:
TfL Access to DVLA Data Base. You state in your 26 September 2023 response that: ‘TfL does not receive copies of any letters sent to the registered keepers of the vehicles nor does the DVLA retain copies of the letters sent’. However, your response also states that ‘The total number of letters issued via the DVLA on TfL’s behalf to non-compliant vehicle owners for the purpose of raising awareness of the compliance status in advance of the Ultra Low Emission Zone expansion was 1,040,280’.
Therefore, if DVLA can determine from its database this 1,040,280 total, by the same token DVLA should be able to determine the total number of the ‘DN10’ letters it sent (accepting that DVLA has not kept copies of each letter). On this basis, I would now ask that you advise me as to the total number of ‘DN10’ letters that DVLA has issued on behalf of TfL.
As mentioned in our previous reply: ‘TfL have issued 1,040,280 letters via the DVLA to the registered keepers of non-compliant vehicles identified driving within the forthcoming expansion area. No further letters of this nature are due to be sent via the DVLA ahead of the expansion of the ULEZ across all London boroughs.
The DVLA is a national database which is not owned by TfL. TfL has access to the data for the purpose of vehicle checking to understand whether a vehicle meets the ULEZ standards. For this purpose, TfL does not access any fields that identify addresses so we are unable to advise how many of those vehicles are registered to an outer London address, or specifically to the County of Gloucestershire, as requested’.
Hence, Transport for London does not receive copies of these letters, nor does the DVLA retain them. Therefore, TfL cannot determine how may letters were issued to the DN10 postcode specifically, as we only hold the total number of letters sent as a whole - which is recorded - but we do not record where they were sent to.
Formulation of ‘DN10’ Letter. You also state in your 26 September 2023 response that: ‘the [DN10] letters sent to non-compliant vehicle owners with the Transport for London letterhead and sub-headed Transport for London Road User Charging were written by TfL but were printed and sent by the DVLA on TfL’s behalf’. Given that TfL formulated the letter in question, I request that TfL provide copies of those TfL internal written communication’s, drafts and proposals that lead to TfL providing DVLA with the final version of this letter.
Unfortunately, to provide the information you have requested would exceed the ‘appropriate limit’ of £450 set by the Freedom of Information (Appropriate Limit and Fees) Regulations 2004. Under section 12 of the FOI Act, we are not obliged to comply with a request if we estimate that the cost of determining whether we hold the information, locating and retrieving it and extracting it from other information would exceed the appropriate limit. This is calculated at £25 per hour for every hour spent on the activities described.
We have estimated that it would cost over £450 to fulfil this part of your request. This is because it is estimated that it would take in excess of 18 working hours to retrieve and compile the information you have requested. We have implemented an initial search for emails of various personnel in the Road User Charging Team, together with ‘DVLA’ as a keyword in an effort to retrieve copies of the communications you are seeking. A search against half of these individuals, to limit duplication and for expediency purposes, produced over 1,600 hits and if we broadened the search this would increase the volume further.
We would also have to manually trawl through a significant amount of emails to locate those that fall within the parameters of your request and compile accordingly. As these areas of interest are not something that we directly report upon, it would require a considerable amount of time and resources to retrieve, identify and review such subject matter, which would then need to be suitably formatted for the purposes of public disclosure.
To help bring the cost of responding to your request within the £450 limit, you may wish to narrow its scope by asking for specific information or data so that we can more easily locate, retrieve and extract the information you are seeking. 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 on whether the cost limit might apply, the burden created by non-specific requests for emails is significant and this should be borne in mind before submitting requests of this nature.
Please note that we will not be taking further action until we receive your revised request.
In the meantime, if you have any queries or would like to discuss your request, please do not hesitate to contact me.
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
