Request ID: FOI-3522-2324 Date published: 24 January 2024
You asked
Q1 - Please confirm the information provided by TFL to drivers who are registered for Auto-Pay when a charge is registered against their vehicle.
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It is claimed that there are 5 photos.
The first shows a black and white photo, with only the registration number possibly clearly visible.
This photo has no identifying date or location.
A registration number is printed below the photo – presumably obtained by ANPR – clearly not part of the photo.
Q2 - Is this correct – obtained by ANPR?
Q2.1 - What degree of accuracy does TFL claim for its ANPR?
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The first photo appears to be a close-up of the second photo.
Q3 - Is this correct?
Q3.1 - Why are the b/w photos black with only the numberplate and maybe a vehicle light visible?
Q3.2 - Are these genuine photos – a black and white photo would normally show shades of grey with much more detail visible?
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The second shows apparently the same black and white photo, with a code and a road name.
For example, U629-10-0151 Brighton Road.
Again this photo has no identifying date and time.
There is the same registration number printed below the photo – presumably obtained by ANPR.
The third, fourth and fifth photos appear to be successive colour photos of the vehicle.
Again there is no identifying date and time.
Q4 - The fourth photo is differently lit from the third and fifth – why is this?
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Q5 - Why do none of the photos have an identifying date and time – this is standard practice for photos where this information is important?
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Q6 - Without the identifying date and time, how is TFL able to establish that the date and time quoted in the Auto-Pay charge is correct?
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Q7 - What does the code signify – for example what do these codes mean?
U629-10-0151
U867-70-0757
0264-60-6056
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Q8 - Why is the location stated so vague? – Why is the postcode not shown?
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Q8.1 - For example, “Brighton Road” could be in many places, and some are inside and some outside the ULEZ.
Even Brighton Road Coulsdon is not sufficient, as parts of this road are in the Zone and parts outside it.
How many different locations are described by TFL as “Brighton Road”?
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Q8.2 - How is the driver suppose to verify and validate the claim without being told precisely where their vehicle was allegedly seen – and how can the driver check it was actually inside the ULEZ?
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Q9 - The photos are wide but very short.
It is generally not possible from the photo to recognise and identify the location from the photo – even where it is well-known to the driver.
Is the information in the photo provided to the driver the entirety of the photo which TFL has – or has it been cropped – and if so how much?
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Q10 - If TFL has more detail than shown to the driver, why does TFL conceal this from the driver?
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Q11 - Why is the definition in the first photo sometimes very different from that in the later photos?
For example, it is claimed that in one case, the first photo shows the registration plate clearly, while in the three colour photos it is indistinct and illegible.
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Q12 - Is the first b/w photo a computer-enhanced or otherwise altered photo?
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Q13 - Why may it happen that a charge is applied to a car with a different registration number to that identified below the photos?
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Q14 - How many cases have appeals been made on this basis?
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Q15 - What proportion of all the appeals does this represent?
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Q16 - In how many of these cases has TFL cancelled the charge?
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Q17 - Please provide a daily total of Auto-Pay charges applied for every day from August 1st 2023 to date.
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Q18 - Please link to each date the number of appeals made in respect of that charge to date.
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Q19 - Please state also how many of each appeal by day was allowed – to date.
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Q20 - What is the procedure if a driver wishes to appeal an Auto-Pay charge to PATAS or whoever if dissatisfied with the TFL response to their appeal.
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Q21 - How many appeals beyond TFL have been made in respect of Auto-Pay charges imposed during 2023?
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Q22 - How many of these appeals were successful?
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Q23 - What is the time interval between each of the three colour photos?
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Q24 - Why does the “camera” apparently have two lenses?
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Q25 - What are the around 20 small clear bulbs around and below the lenses?
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Q27 - Is this some kind of flash system?
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Q28 - What are the three blue spots?
Thank you for your emails received by Transport for London (TfL) on 22 December 2023 and 3 & 8 January 2024, asking for information relating to the Ultra Low Emission Zone (ULEZ), including payment and autopay, vehicle and traffic data, enforcement, ANPR cameras and signage.
Your requests have been considered in accordance with the requirements of the Environmental Information Regulations (EIRs) and our information access policy. I can confirm we hold some of the information you require.
You asked for a wide range of information concerning the ULEZ scheme and its operation, comprising of nearly 50 questions across your requests. Approximately half of them do not even constitute a valid EIR request. Although a request can take the form of a question, rather than a request for specific documents, the EIRs only apply to recorded information. We do not have to answer questions for unrecorded comments, advice and explanation or the provision of a judgement, that was not already recorded at the time of your request.
Furthermore, we have established that the requested information is likely to be spread across a number of documents and files in multiple locations. Therefore, to identify, locate, extract and review the requested information would require a wide-ranging search of electronic and physical files. Given the wide range and volume of information you are looking for, we are applying Regulation 12(4)(b) as we believe that the requests are ‘manifestly unreasonable’ because the cumulative effect of your requests would impose unreasonable costs on us and require an unreasonable diversion of resources.
After reviewing the above documents and a search of our recent responses, you may wish to consider narrowing and/or focussing the scope of your requests so that we can more easily locate and retrieve any additional information you are seeking that is not already provided in these documents. There are limits on the time that we are required to spend determining whether we hold the information you are requesting, and the time spent locating, retrieving and extracting it. Therefore, you should identify the information that you want as clearly and concisely as you can, specifying the types of documents that you are looking for.
Please be assured that our application of the exception 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 FOI Act/EIRs and the expectations of the ICO. However, in making any future request I would ask that you consider carefully what information is of most importance to you. Please refer to the guidance and advice provided by the ICO on how to request information from a public authority, published here: https://ico.org.uk/your-data-matters/official-information/.
The use of this exception is subject to a public interest test, which requires us to consider whether the public interest in applying the exception outweighs the public interest in disclosure. We recognise that the release of information would promote accountability and transparency in public services and also help address any concerns you have about the operation of the scheme. However, the time it would take to provide the information you have requested would divert a disproportionate amount of our resources from its core functions and, taking into account the information already published, on balance we consider that the public interest currently favours the use of the exception.
Please see the attached information sheet for details of your right to appeal.
Yours sincerely
Eva Hextall FOI Case Officer
FOI Case Management Team General Counsel Transport for London
