Request ID: FOI-2552-2122 Date published: 18 February 2022
You asked
Under the provisions of the Freedom of Information Act, please provide me with a map of cameras for the ULEZ extension zone.
You are obviously aware that you have already published the following quote:
“We appreciate the need for openness and transparency in the operation of our business, and the fact that you have requested the information is in itself an argument for release. However, in this instance we believe that the balance of overall public interest rests in ensuring compliance with the ULEZ scheme in order to ensure its objectives can be met”
This is your belief and not governed by this act. You are withholding this information which I am legally allowed to have, therefore please forward by return email.
If you refuse to supply the information and I believe you will based on your belief that it would be in the “public’s interest” not to, I am not aware of any publications by you, supporting this belief. Please therefore provide evidence of this, with facts, figures, surveys you may have taken with the public to support this.
We answered
TfL Ref: EIR-2552-2122
Thank you for your request received by Transport for London (TfL) on 5th February 2022 asking for information about the Ultra Low Emission Zone ULEZ).
Your request has been considered in accordance with the requirements of the Environmental Information Regulations (EIR) and our information access policy.
Specifically you asked:
“Under the provisions of the Freedom of Information Act, please provide me with a map of cameras for the ULEZ extension zone.
You are obviously aware that you have already published the following quote:
“We appreciate the need for openness and transparency in the operation of our business, and the fact that you have requested the information is in itself an argument for release. However, in this instance we believe that the balance of overall public interest rests in ensuring compliance with the ULEZ scheme in order to ensure its objectives can be met”
This is your belief and not governed by this act. You are withholding this information which I am legally allowed to have, therefore please forward by return email.
If you refuse to supply the information and I believe you will based on your belief that it would be in the “public’s interest” not to, I am not aware of any publications by you, supporting this belief. Please therefore provide evidence of this, with facts, figures, surveys you may have taken with the public to support this.
I can confirm that we hold the information you require. However, the information is excepted from disclosure under Regulation12(5)(g) of the EIR, the exception that can apply where release of information would have an adverse impact on the environment. The rationale for this is explained in the previous responses which you have obviously already seen. To summarise, given the size of the extended zone it is not possible to have cameras throughout the zone or on every single entry and exit point at its boundary. If we were to release the location of the cameras outside of the central zone it would enable those who wish to avoid paying the charge to enter or drive within the zone without being detected, defeating the purpose of the scheme. If vehicle owners know they can avoid the charge by avoiding the cameras, it removes the incentive to adapt their vehicle, or reduce its use, in line with the scheme’s objectives. This in turn will affect the level of improvement in air quality, to the disbenefit of the general public. The locations of the cameras outside the central London zone are therefore excepted from disclosure.
Given that all of the information the public need to comply with the scheme is published online (see the following page of our website which includes maps of the zone, a postcode checker, and details of how to pay charges: https://tfl.gov.uk/modes/driving/ultra-low-emission-zone) we do not see any reason why it would be in the public interest to release the locations of the cameras themselves.
The decision to except this information from release is based on the explanation given above and on our understanding of the Environmental Information Regulations, which allow information to be withheld where there is a sound justification for doing so and where it is in the public interest. More information on the application of Regulation 12(5)(g) can be found on the Information Commissioner’s website here:
For data and evidence supporting the need for the ULEZ expansion I would refer you to the FOI response published here, which provides links to a number of relevant studies:
