Request ID: FOI-3586-2324 Date published: 24 January 2024
You asked
Dear Transport for London,
Request ID: FOI-0099-2324
Date published: 10 May 2023
In your reply to this FOI, you state as below.
> Question 25: If a vehicle enters the zone, please provide a time scale/procedure as to when the driver can contact you to find out if they have entered the zone or not? For example a person who isn't sure if they entered the zone, how/when can they contact you to find out if they did or didn't enter the zone.
> Answer: The ULEZ operates using Automatic Number Plate Recognition technology. Each entry point to, and exit from the zone is clearly signed and as a vehicle either enters, leaves or drives within the zone its registration is recorded along with an image of the vehicle.
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A1 – Please provide JPG files to show the ways that “Each entry point to …. the zone is clearly signed”.
That includes the various types of advance warning sign, and where each type is used.
A2 - Please provide JPG files to show the ways that “Each … exit from the zone is clearly signed”.
A3 – “as a vehicle either enters, leaves or drives within the zone its registration is recorded along with an image of the vehicle”
Is this actually true – ie that an image is recorded of every vehicle and its registration number every time at the point it enters or leaves the zone?
If it is not true, then please explain.
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You say:
> At the end of the third charging day after the journey, when the payment period has expired, the list of vehicles observed in the zone is compared against the vehicles for which a charge has been paid, those which are exempt from the charge or those listed on an Autopay account. Where a match is found the image and record of the vehicle is deleted. If no match is found the details are retained for enforcement purposes.
A4 – Is this actually true?
It is believed that in fact, where there is a match between a vehicle observed in the zone is listed on an Autopay account, the image and record of the vehicle are not deleted.
Instead they are kept for several months, so that the diver can challenge the Autopay charge.
A5 – Is this instead correct?
A6 – Why the inconsistency between the facts and the FOI answer?
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In 2015, the government announced an end to hard-to-see enforcement cameras.
https://www.gov.uk/government/news/end-of-the-road-for-grey-speed-cameras
> move follows a review of cameras to ensure they are visible and
> motorists are not unfairly penalised This latest move will ensure maximum visibility of the cameras themselves.
The minister said: “We are on the side of honest motorists. I’ve always been clear that cameras should be visible and get used for safety rather than revenue raising”
> The government has also taken action at a local level.
The guidance went beyond just speed cameras – to include red light cameras and other enforcement cameras.
The police put up ANPR warning signs in advance of their ANPR cameras – which are painted yellow - for example on the A23 Brighton Road approaching Purley Cross.
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In Sept 2023, the government announced new measures to be fair to drivers.
https://www.gov.uk/government/news/government-announces-new-long-term-plan-to-back-drivers
> Transport Secretary Mark Harper has today (29 September 2023) set out plans to protect drivers from over-zealous traffic enforcement, as part of a long-term government plan to back drivers.
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The purpose of the above is to ensure that drivers can adjust their behaviour, rather than get caught out.
TFL ULEZ cameras and poles are painted black, making them as unobtrusive as possible.
A7 – Given clear government guidance that enforcement cameras should be painted yellow, so they are clear and obvious to the public, why does TFL defy this guidance by painting ULEZ cameras and poles in black?
A7.1 – Given the above, will TFL now review its policy and practice in this regard.
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The government also announced changes to national guidance to address the following.
> options to restrict the ability of local authorities to generate revenue surpluses from traffic offences and over-zealous traffic enforcement, such as yellow-box junctions.
A8 – How is TFL changing its enforcement practices to comply with this?
A9 – It is believed that TFL has no evidence that its enforcement of yellow-box junctions has improved traffic flow.
Instead the evidence is in fact that it has made traffic flow worse.
What evidence does TFL have on the impact of its enforcement of yellow-box junctions?
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> To make life easier for drivers and help traffic flow better, the Department for Transport will strengthen guidance to make sure bus lanes only operate when necessary and a consultation will be launched on motorcycles using bus lanes.
A10 – How is TFL responding to the government requirement “to make sure bus lanes only operate when necessary” – for example by reviewing and then removing most 24-7 bus lanes, and those applying every day of the week, and restricting them to, for example MF 7-10 and 4-7, or Mon-Sat 8am-12pm, or Mon-Fri 7-10 northbound and 4-7 southbound?
A10.1 – Will TFL now actively promote the use of bus lanes by motor cycles – as this will not impede bus movement, and should improve overall traffic flow?
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> reviewing guidance on 20mph speed limits in England to prevent their blanket use in areas where it’s not appropriate and amending guidance on low traffic neighbourhoods to focus on local consent.
A11 - How is TFL responding to this government requirement – for example by making sure 20mph speed limits and LTN’s are really supported across the general public who are impacted by them.
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> In the continued drive to tackle potholes, the government will support councils to introduce more lane rental schemes, where utility companies are required to pay to dig up the busiest roads at peak times.
A12 - How is TFL responding to this government requirement – as far too often key busy main roads are disrupted for days on end, while work only happens for around 40 hours out of the 168 in each week?
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In terms of ULEZ signage, there are many side roads in the ULEZ off a road which is outside it.
Many of these roads do not have advance warning signs in each direction on the boundary road.
A13 – How does TFL expect drivers in these circumstances to avoid turning into a side road, and then finding they need to reverse out?
A14 – Will TFL review all entry points to ensure there are advance signs to warn where the ULEZ is?
Many of these roads have only one ULEZ entry sign, pointing directly ahead.
This sign is often not easily visible when turning in – and sometimes not really visible at all.
An obvious way forward would be to ensure that there are two signs, one on each side of the road, tilted towards the opposite side, so incoming traffic has a sign facing it as it runs in.
This is widely done with NO ENTRY signs, for example.
A15 – Will TFL now review the ULEZ entry signs at each site, to ensure that all properly visible to vehicles turning into the roads?
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
