Our Ref: FOI-2429-1617/IRV-002-1718
I am writing to you regarding the long outstanding request you submitted on 3 March 2017. You have requested an Internal Review of the handling of this request, and specifically our decision that the request was complex and required an extension to the normal time limit. This response comes significantly after that time limit and I apologise for the excessive delays you have experienced.
The extension to the deadline was because your request was both complex and voluminous. Following a significant number of internal enquiries, we have concluded that the searches required to determine what information is held, and to locate, retrieve and extract the requested information would be ‘manifestly unreasonable’, and therefore this request is refused under Regulation 12(4)(b) of the Environmental Information Regulations. Requests for ‘all correspondence and documents’ tend to be particularly time consuming as we hold emails from approximately 98,000 TfL accounts for up to seven years. We consider that in this instance the public interest in supplying the requested information is outweighed by the burden of identifying, retrieving and extracting all information falling under your request.
The Environmental Information regulations and the Freedom of Information Act provide a right to access recorded information. The parts of your email of 3 March that constitute requests for recorded information are repeated as bullet points below:
• any documents or correspondence relating to any consideration that has been given to the impact of the following planned regeneration schemes on traffic modelling for Cycle Enfield:
o The 4,000 plus new dwellings at Edmonton Heartlands Mayoral Housing Zone.
o The 10,000 plus new dwellings plus employment space and other mixed uses proposed at the Meridian Water Mayoral Housing Zone.
o The 10,000 plus new dwellings proposed for the Mayoral Housing Zones at White Hart Lane and Northumberland Park.
o The up to 5,000 new dwellings proposed for the Tottenham Hale Mayoral Housing Zone.
o The currently under construction Electric Quarter at Ponders End.
o The currently under construction regeneration of Alma Road Estate, Ponders End.
o The 63,000 seater stadium under construction at White Hart Lane.
o The extreme sports centre and associated hotel and commercial uses proposed at White Hart Lane.
o The impact between now and the 2030's of the 100,000 population increase projected for Enfield by the Office of National Statistics, much of which will be east of the A10 along the A1010 corridor.
• any documents or correspondence relating to assessments of the levels of traffic that will trigger junction saturation on the proposed highway interventions in relation to the above regeneration schemes
• assessments of the impact this would have on pollution and displacement of traffic onto alternative routes.
• any documents or correspondence relating the assessment of the number of buses that will need to be purchased and drivers that will have to be hired to maintain existing bus frequencies on the A1010 corridor and affected streets in light of the admitted journey time increases of up to 1.5minutes per mile.
• any documents or correspondence relating to the projected costs of additional bus resources and how they will be funded by whom, including associated need to invest in additional bus garage facilities.
• any documents or correspondence relating to the assessment of the lost revenue to TFL from reduced bus usage that will result from increased bus journey times.
• If additional resources are not being provided, please provide the same regarding the projected reduction of bus frequencies for all routes.
• I request a list of all the cycle schemes that have been rejected for lesser increases in journey times due to harmful impact on bus resources and income.
You also requested ‘If this work has not been carried out and incorporated, I request that it is carried out’. This is not a request for recorded information under either the Freedom of Information Act or the Environmental Information Regulations therefore it falls outside the scope of this response.
You have submitted eight information requests in 2017. Seven of the requests have now been answered, and your request about Overground and National Rail turn up and go standards will be answered shortly. You have also submitted three requests for internal review, and the first part of this email comprises the response to one of those. Regarding the two others, there is some overlap between the request received on 19 May and your most recent one (which also includes some new requests for information), received on 16 July – so we will be providing a single response and expect to send this to you by 5 August 2017.
The focus of your requests is transport planning, and because transport planning will usually have an environmental impact your requests should generally be considered under the Environmental Information Regulations (EIR), rather than the Freedom of Information Act (FOIA). Both the EIR and FOIA contain provision to mitigate the impact of burdensome requests on public authorities. The EIR allow the refusal of manifestly unreasonable requests whilst the FOIA places a limit on the cost of responding to requests which may be aggregated across requests which relate to any extent to the same or similar information received within 60 consecutive days.
We recognise that there is substantial public interest in the disclosure of information about transport planning. However, we are operating in a challenging financial environment and in future we may refuse requests for information if it would take more than 18 hours to locate, retrieve and extract the information required to answer any single request, or any series of similar requests received within a 60 working day period.
Since the FOIA and the EIR give a right to access recorded information, requests to undertake analysis, create new information or validate data fall outside this legislation. The Freedom of Information team will not consider such requests when providing responses to your FOI or EIR requests.
Information Access Advisor
FOI Case Management Team
Transport for London