[I] Please provide us (under FOI/EIR) with all available information that TfL is using or intends to use that is applicable/relevant with respect to the junction - both present and proposed. (Examples are Traffic flow studies (including pedestrians and cyclists; including volume, velocity etc.); Road Safety Audits (all stages) and Risk Assessments; EQIAs; team/consultants’ reports/briefs; Any applicable/relevant instructions, terms and conditions or agreements by TfL with other entities such as the local authority; drawings; projected cost breakdowns etc. etc.). [II] We take what is written in the media with all due caution, but note that the Aug/Sep press report in The Lewisham Ledger (p.8, Issue 8) covered the junction. Assuming that the report is relevantly correct (apologies if not) kindly clarify the quotes from an unstated TfL representative as follows (these have been embolded for clarity): (a) “..we are working... in agreement with Lewisham Council...”. We are confused by this as it is understood that TLRNs, including lead-ins from side-roads, lie entirely within TfL’s remit. Please let us know (a) in what respect that TfL finds it necessary to obtain agreement(s) with other authorities and (b) what regulations (codes, guidelines or rules etc.) if any that are applicable in the respect of obtaining permissions or agreements. (b) “...and will now work on concept designs before consulting.”. This is an uncomplicated junction. The relatively narrow footways do not lend themselves to any form of planned shared footway. Unless, following a line of thought here, there are (unmentioned) plans for A205 carriageway narrowing and cycle lane creation (hence specific cycle facilities) it is not apparent why after previous prompting, another half year is thought necessary to work on concepts. Please let us know the details of the said concept designs (that appear to be one of the causes of significant delay) and for what reason these cannot be ‘off the shelf’ generic? (c) “...we are proposing..... all arms of the junction...”. This is confusing since the next paragraph states “Our proposals are for three arms of the junction...”. No doubt this is likely to be the reporter’s error. Please let us know which is correct and if not all arms planned, the detailed reasons for this. (d) “...we plan to consult before next spring...”. We are more used to more substantial projects where the need to consult is fairly apparent, even if the conclusions not. In this case, it is difficult to imagine that any pedestrian user response would not be positive whilst any motorist would be against waiting time increase. We opinionate that this is a simple matter of Health & Safety. Please let us know what regulations (codes, guidelines or rules etc) you are following in the proposed consultation and the reasons for delay in taking this step (whether or not necessary) (e) “...and then for work to start the following year.”. From our point of view, the work will have to be carried out in a timely fashion and after slow steps (a)-(d).

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TfL Ref: FOI-2284-1920 / FOI-2445-1920 / FOI-2547-1920

Thank you for your requests received by Transport for London (TfL) on 11^th November, 15^th November and 20^th November 2019 asking for information about the Torridon Road Junction, air pollution mitigation, and bus stop bypasses. 

Your requests have been considered in accordance with the requirements of the Freedom of Information (FOI) Act, the  Environmental Information Regulations (EIR) and our information access policy.

We note that these requests are further to your eight other requests received since 11^th May 2019 (case references 0453-1920; 0454-1920; 0459-1920; 1277-1920; 1711-1920; 1916-1920; 1989-1920; and 2281-1920). Therefore, in the period 11^th May 2019 to 20^th November 2019, you have submitted eleven requests in total – a rate of more than 1.5 per month.

Your latest requests raise a large number of questions on a variety of different matters covering a large amount of information  – some of which fall under EIR, some under FOI, and some of which are not specific requests for recorded information (for example, in case ref FOI-2445-1920 you ask us to clarify statements attributed to TfL in a local press report).

Your requests are being refused on the basis that it would be manifestly unreasonably for TfL to source all of the information to enable us to respond to them. In reaching this judgement we have taken due regard to advice provided by the Information Commissioner’s Office (ICO), both in relation to the EIR “manifestly unreasonable” exception and to section 14 of the FOI Act. The ICO guidance on these provisions includes the following:

“The information Commissioner recognises that dealing with unreasonable requests can place a strain on resources and get in the way of delivering mainstream services …”;

And;

“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”.

The ICO  provides some specific indicators to help public authorities judge whether or not responding to a case or cases should be considered unreasonable. This includes the following:

“Burden on the authority: the effort required to meet the request will be so grossly oppressive in terms of the strain on time and resources, that the authority cannot reasonably be expected to comply, no matter how legitimate the subject matter or valid the intentions of the requester”;

“Frequent or overlapping requests: the requester submits frequent correspondence about the same issue or sends in new requests before the public authority has had an opportunity to address their earlier enquiries”.

Note that a request which would not normally be regarded as unreasonable in isolation may assume that quality once considered in context. The ICO states that:

“An example of this would be where an individual is placing a significant strain on an authority’s resources by submitting a long and frequent series of requests, and the most recent request…. is contributing to that aggregated burden”.

It is the frequency and complexity of your requests that leads us to judge that it is fair to consider that the aggregated burden of your requests is manifestly unreasonable, and that the balance of public interest lies in the exception applying (given that TfL is a publicly funded body and there is therefore a cost to the public purse in responding to such requests). However, please be assured that our refusal to respond does not reflect a conclusion that it has been your deliberate intention to place an undue burden on TfL, and we will consider any future request for information on its merits and in accordance with the requirements of the applicable legislation.

In making any future request I would ask that you consider carefully what information is of most importance to you, and to take account of the guidance and advice provided by the ICO on accessing information from public bodies published on its website here: https://ico.org.uk/your-data-matters/official-information/

You will note that the table of “dos and don’ts” halfway down that page includes the following advice to applicants:

Do….“Give the authority ample opportunity to address any previous requests you have made before submitting new ones”;

Don’t… “Disrupt a public authority by the sheer volume of information requested”;

Don’t…”Bury your request in amongst lengthy correspondence on other matters”, and;

Don’t…”Send ‘catch-all’ requests for information (such as ‘please provide me with everything you hold about x”)”.

Further, I note that in our response to your request of 25^th September 2019 (our ref FOI-1916-1920) we provided you with the contact details of various colleagues involved in the delivery of various schemes in the Lewisham area. While it is perfectly valid for you to engage in dialogue with these colleagues I would ask that you separate-out your more general correspondence/questions about such projects with any specific requests for recorded information (which, by law, we are required to consider under EIR/FOI legislation), in line with the ICO advice in the “dos and don’t’s” referenced above. For the avoidance of doubt, under FOI/EIR we are not obliged to provide advice, explanation or opinion that is not recorded at the time of a request.

Notwithstanding all of the above, I can provide you with the following general information in relation to case ref 2445-1920 (Torridon Road Junction). In 2018 there was an existing feasibility proposal along Brownhill Road that extended from Laleham Road to Verdant Lane. Due to the overall cost of the scheme it was decided it would be better broken down into smaller schemes in order that they could be funded from our Healthy Streets Local schemes (HSLS) budget. There is a scheme currently underway at Brownhill Road at its junction with Torridon Road to provide a pedestrian signal across three arms of the junction. We are unable to provide a pedestrian signal across the eastern arm of Brownhill Road due to the location of an established vehicular crossover. Recent traffic counts have shown that the largest number of pedestrians cross the western arm of Brownhill Road, so the crossing point is on the main pedestrian desire line to cross the A205 and both arms of Torridon Road. The scheme is currently at concept design. Concept design is not just layout design but includes investigations into the existing traffic signal equipment, ducting surveys to determine if there is spare capacity in the existing ducts to lay more cables, to ensure there are no blockages in the existing ducts, or if more ducts are required. Modelling is also required to ensure signal timings are adequate to allow pedestrians sufficient time to cross the road, in addition to ensuring bus journey times are maintained or mitigated given the traffic flows. Modelling has been completed and the Scheme Impact Review is now being produced.

Site investigations revealed that there were underground services that had to be avoided, given the narrow footways. Therefore the pedestrian crossings have had to be moved very slightly. Also, given the age of the existing traffic signals and the associated electronic equipment, the signals will need to be upgraded to work with latest signalling equipment to provide a pedestrian phase. The cost estimate will therefore need to be updated, and once we have confirmation of the revised costs the additional funding will need to be secured from the HSLS budgets. We are also waiting for a Road Safety Audit to be completed, and we still require feedback from the Equality and Inclusion Assessment that has been submitted. Once the ducting survey has been completed we will be able to undertaken an audit of the signals (this is separate from the Road Safety Audit). Risk assessments and a technical report will be undertaken as the concept design progresses. The scheme will go out for public engagement to notify the public of the proposals in early 2020 as part of TfL’s standard procedures.

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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