Cowley LTN evaluation report...evaluated roads selected

The request was refused by Oxfordshire County Council.

Dear Oxfordshire County Council,

The recent Cowley LTN evaluation report, presented to OCC cabinet on 19 July 2022, evaluated the impact of LTN by reference to a sample of specific roads, rather than an exhaustive evaluation of the whole area. The sampling of the roads evaluated therefore had a direct impact on the report's findings. For example, the finding that traffic volumes fell within the Cowley LTN was almost certainly influenced by the fact that two out of the three roads evaluated (Rymers Lane and Cowley Road north) has LTN planters installed directly on them, cutting off vehicular access to the traffic monitoring sensor for even some residents of that specific street.

Given the importance of initial sampling to eventual finding, I want to understand how the road sampling for the evaluation was made - over and above comments about data being available from those streets: data would also be available from other streets too, so some choices must have been made. I also want to understand whether the research team were aware of the consequences of their sampling to the eventual outcome of their evaluation - i.e. did they know that their LTN area road sampling had road blocks directly installed on them as part of the LTN trial, and were therefore unrepresentative of the wider LTN area? Did they care, if they did? Did they raise ethical questions about this choice?

In this incidence, I suggest the public interest is firmly in favour of disclosure on this point, because inputs lead directly to outputs. I would, therefore, suggest, that you do not attempt to refuse permission based on "safe space" considerations. We are also taking about an evaluation of a scheme, not the scheme itself. Safe space arguments are, therefore, arguably non-applicable to my request, which are not directly related to policy.

In light of the above, please therefore provide me with all correspondence between the report's authors and reviewers, and also other councillors / council staff, and any external stakeholders also engaged, regarding the specific issue of evaluation road sampling - i.e. which roads were selected for evaluation in this report. Because multiple versions of the reports were created (including one for the abandoned LTN decision meeting in February and another for July cabinet meeting), I would like the particular focus of your correspondence search to be in the run up to the completion of the first draft of the report, which was completed on 19 January 2022. It was during this period that when the sampling decisions were mostly likely to have been taken - the sampling did not change for the latter versions of the report. I would therefore suggest you initially concentrate your efforts in location correspondence for the four month period leading up to the completion of the report's first draft.

Yours faithfully,

Richard Parnham

FOI Team, Oxfordshire County Council

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Joint Commissioning FOI, Oxfordshire County Council

Our reference: 20271 EIR

 

Dear Mr Parnham,

Thank you for your request received on the 19 August 2022, in which you
asked for the following information:

The recent Cowley LTN evaluation report, presented to OCC cabinet on 19
July 2022, evaluated the impact of LTN by reference to a sample of
specific roads, rather than an exhaustive evaluation of the whole area.
The sampling of the roads evaluated therefore had a direct impact on the
report's findings. For example, the finding that traffic volumes fell
within the Cowley LTN was almost certainly influenced by the fact that two
out of the three roads evaluated (Rymers Lane and Cowley Road north) has
LTN planters installed directly on them, cutting off vehicular access to
the traffic monitoring sensor for even some residents of that specific
street.

 

Given the importance of initial sampling to eventual finding, I want to
understand how the road sampling for the evaluation was made - over and
above comments about data being available from those streets: data would
also be available from other streets too, so some choices must have been
made. I also want to understand whether the research team were aware of
the consequences of their sampling to the eventual outcome of their
evaluation - i.e. did they know that their LTN area road sampling had road
blocks directly installed on them as part of the LTN trial, and were
therefore unrepresentative of the wider LTN area? Did they care, if they
did? Did they raise ethical questions about this choice?

 

In light of the above, please therefore provide me with all
correspondence  between the report's authors and reviewers, and also other
councillors / council staff, and any external stakeholders also engaged,
regarding the specific issue of evaluation road sampling - i.e. which
roads were selected for evaluation in this report. Because multiple
versions of the reports were created (including one for the abandoned LTN
decision meeting in February and another for July cabinet meeting), I
would like the particular focus of your correspondence search to be in the
run up to the completion of the first draft of the report, which was
completed on 19 January 2022. It was during this period that when the
sampling decisions were mostly likely to have been taken - the sampling
did not change for the latter versions of the report. I would therefore
suggest you initially concentrate your efforts in location correspondence
for the four month period leading up to the completion of the report's
first draft.

 

 

Your request is being considered and you will receive the information
requested as soon as possible and in any event within the next 20 working
days in compliance with the Environmental Information Regulations
2004/Freedom of Information Act 2000, unless an exception applies. This
means that the council will respond to you by the end of 19 September 2022
at the latest.

 

If appropriate, the information requested can be made available in
alternative formats, including other languages, Braille, large print, and
audiocassette. If you require any of these formats then please let me
know.

 

Please contact me if you have any have further enquiries about your
request. I would be grateful if you could quote the reference number given
at the top of this email.

 

Kind regards,

Renata Malinowski

 

Freedom of Information Support Officer

 

Voice of the Customer Team

Customers and Organisational Development

 

Oxfordshire County Council

Email:  [1]jointcommissioning[Oxfordshire County Council request email]

[2]www.oxfordshire.gov.uk

 

 

 

 

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FOI - E&E, Oxfordshire County Council

1 Attachment

Dear Mr Parnham,

 

Please find attached our response to your Environmental Information
Request. 

 

Kind Regards

Renata

 

 

Renata Malinowski

Freedom of Information Support Officer

 

Voice of the Customer Team

Customers and Organisational Development

 

Oxfordshire County Council

Email:  [1]FOI-E&[email address]

[2]www.oxfordshire.gov.uk

 

 

 

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If you have received it in error, please notify the sender by reply and
delete it immediately. Views expressed by the sender may not be those of
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Information Act 2000. [3]email disclaimer. For information about how
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Dear Oxfordshire County Council,

Thank you for your email. I wish to take you up on your offer, and narrow the scope of my enquiry considerably. This should help slash the amount of information you need to review and redact.

I would, ideally, still prefer to view the contemporanious discussions regarding the selection of sample roads, because I want to learn about the reasons for their selection, over and above the availability of data (which has already been disclosed). However, I am happy for the focus of my enquiry to be tightened to include a fewer number of key evaluation roads, rather than all of them.

My initial enquiry would have bought a total of 14 roads in scope for enquiry:
• B480 (Cowley Rd) southeast of Marsh Road
• A4158 (Henley Ave) northwest of Church Cowley Road
• B4495 (Hollow Way) northeast of Oxford Road
• B4495 (Church Cowley Rd) at Rymers Lane
• A4158 (Rose Hill Rd) at Ashhurst Way
• A4165 (Banbury Road) south of Marston Ferry Road
• A4144 (Abingdon Rd) south of Weirs Lane
• A420 (London Road) east of Headley Way
• B4495 (Headley Way) at London Road
• A4165 (Banbury Rd) north of A40
• A4144 (Woodstock Rd) south of A40
• Rymers Lane at Church Cowley Road (Florence Park LTN)
• Cowley Rd north of Newman Road (Church Cowley LTN)
• Long Lane at Newman Road (Church Cowley LTN)

In fact, I am most interested in the three internal LTN Roads:
• Rymers Lane at Church Cowley Road (Florence Park LTN)
• Cowley Rd north of Newman Road (Church Cowley LTN)
• Long Lane at Newman Road (Church Cowley LTN)

I believe there is a public interest in disclosing the rationale for selecting these three evaluation roads specifically, because two of them (Rymers Lane and Cowley Rd) had LTN barriers installed on them as part of the trial. I would regard it as bad practice to evaluate traffic levels on roads that had barriers physically installed on them, making it impossible for some local traffic to travel along this road - potentially skewing the findings, unfairly. I want to know if concerns were raised about this sampling decision internally too, given that a reduction in traffic inside the LTNs was deemed to be a success metric for evaluating the entire scheme. The evaluation process has to be seen to be fair, and to actually be fair. This is what my enquiry seeks to establish.

Is this reduction in the scope of my enquiry acceptable to you? Three roads rather than 14? Please let me know.

Yours faithfully,

Richard Parnham

FOI - E&E, Oxfordshire County Council

Our reference: 20389 EIR

 

Dear Mr Parnham,

Thank you for your request received on the 20 September 2022, in which you
asked for the following information:

Thank you for your email. I wish to take you up on your offer, and narrow
the scope of my enquiry considerably. This should help slash the amount of
information you need to review and redact.

 

I would, ideally, still prefer to view the contemporanious discussions
regarding the selection of sample roads, because I want to learn about the
reasons for their selection, over and above the availability of data
(which has already been disclosed). However, I am happy for the focus of
my enquiry to be tightened to include a fewer number of key evaluation
roads, rather than all of them.

 

My initial enquiry would have bought a total of 14 roads in scope for
enquiry:

 

• B480 (Cowley Rd) southeast of Marsh Road

 

• A4158 (Henley Ave) northwest of Church Cowley Road

 

• B4495 (Hollow Way) northeast of Oxford Road

 

• B4495 (Church Cowley Rd) at Rymers Lane

 

• A4158 (Rose Hill Rd) at Ashhurst Way

 

• A4165 (Banbury Road) south of Marston Ferry Road

 

• A4144 (Abingdon Rd) south of Weirs Lane

 

• A420 (London Road) east of Headley Way

 

• B4495 (Headley Way) at London Road

 

• A4165 (Banbury Rd) north of A40

 

• A4144 (Woodstock Rd) south of A40

 

• Rymers Lane at Church Cowley Road (Florence Park LTN)

 

• Cowley Rd north of Newman Road (Church Cowley LTN)

 

• Long Lane at Newman Road (Church Cowley LTN)

 

In fact, I am most interested in the three internal LTN Roads:

 

• Rymers Lane at Church Cowley Road (Florence Park LTN)

 

• Cowley Rd north of Newman Road (Church Cowley LTN)

 

• Long Lane at Newman Road (Church Cowley LTN)

 

I believe there is a public interest in disclosing the rationale for
selecting these three evaluation roads specifically, because two of them
(Rymers Lane and Cowley Rd) had LTN barriers installed on them as part of
the trial. I would regard it as bad practice to evaluate traffic levels on
roads that had barriers physically installed on them, making it impossible
for some local traffic to travel along this road - potentially skewing the
findings, unfairly. I want to know if concerns were raised about this
sampling decision internally too, given that a reduction in traffic inside
the LTNs was deemed to be a success metric for evaluating the entire
scheme.  The evaluation process has to be seen to be fair, and to actually
be fair. This is what my enquiry seeks to establish.

 

Is this reduction in the scope of my enquiry acceptable to you? Three
roads rather than 14? Please let me know.

 

 

Your request is being considered and you will receive the information
requested as soon as possible and in any event within the next 20 working
days in compliance with the Environmental Information Regulations
2004/Freedom of Information Act 2000, unless an exception applies. This
means that the council will respond to you by the end of 19 October 2022
at the latest.

 

If appropriate, the information requested can be made available in
alternative formats, including other languages, Braille, large print, and
audiocassette. If you require any of these formats then please let me
know.

 

Please contact me if you have any have further enquiries about your
request. I would be grateful if you could quote the reference number given
at the top of this email.

 

Kind regards,

Renata

 

 

Renata Malinowski

Freedom of Information Support Officer

 

Voice of the Customer Team

Customers and Organisational Development

 

Oxfordshire County Council

Email:  [1]FOI-E&[email address]

[2]www.oxfordshire.gov.uk

 

 

 

 

 

 

 

This email, including attachments, may contain confidential information.
If you have received it in error, please notify the sender by reply and
delete it immediately. Views expressed by the sender may not be those of
Oxfordshire County Council. Council emails are subject to the Freedom of
Information Act 2000. [3]email disclaimer. For information about how
Oxfordshire County Council manages your personal information please see
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References

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FOI - E&E, Oxfordshire County Council

1 Attachment

Dear Mr Parnham,

 

Please find attached our response to your Environmental Information
Request. 

 

Kind Regards

Renata

 

 

Renata Malinowski

Freedom of Information Support Officer

 

Voice of the Customer Team

Customers and Organisational Development

 

Oxfordshire County Council

Email:  [1]FOI-E&[email address]

[2]www.oxfordshire.gov.uk

 

 

 

This email, including attachments, may contain confidential information.
If you have received it in error, please notify the sender by reply and
delete it immediately. Views expressed by the sender may not be those of
Oxfordshire County Council. Council emails are subject to the Freedom of
Information Act 2000. [3]email disclaimer. For information about how
Oxfordshire County Council manages your personal information please see
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References

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Dear Oxfordshire County Council,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Oxfordshire County Council's handling of my FOI request 'Cowley LTN evaluation report...evaluated roads selected'.

My basis of request is as follows.

The selection of roads evaluated within the Cowley LTN was central to the finding that traffic had been reduced within the Cowley LTNs. The roads selected for evaluation - just three roads (out of dozens possible) - two of which were blocked off during the trial with planters - was extremely questionable, in terms of sampling best practice. The outcome of this sampling clearly, and unambiguously, skewed the outcome of a key LTN evaluation metric, thereby indicating "success" where, in reality, that success was likely to be down to the sampling itself rather than wider traffic impacts within the LTN.

I therefore believe the public interest in discovering whether this unfair sampling was known, considered, and accepted in advance, outweighs the cost of discovering what was known. The council created this sampling problem of its own volition - and must now be subject to scrutiny about who knew what, when. That is the public interest associated with my enquiry, which sits IN ADDITION to the presumption in favour of disclosure.

Moreover, the council plans to deploy a very similar sampling approach in relation evaluating the East Oxford LTNs - evaluating roads blocked off by the trial itself rather than those that were not, and therefore take the diverted traffic within the LTN, (according to another FOI, which revealed their evaluation sampling methodology in advance). This separate sampling decision, I believe, further tips the public interest in favour of disclosure in relation to the Cowley LTN road sampling decisions. If the key decision makers were fully aware of the likely outcome of their questionable sampling in relation to the Cowley LTN, then it raises questions about why a similar similar sampling decision has been taken in relation to the East Oxford LTN evaluation.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/c...

Yours faithfully,

Richard Parnham

FOI Team, Oxfordshire County Council

Now logged as internal review of 20271 EIR.

Send date 25 November, return to Governance 18 November.

Renata Malinowski
Freedom of Information Support Officer

Voice of the Customer Team
Customer and Organisational Development

Oxfordshire County Council
Email: FOI-E&[email address]
www.oxfordshire.gov.uk

show quoted sections

FOI - E&E, Oxfordshire County Council

1 Attachment

Our reference: 20271 EIR IR

 

Dear Mr Parnham,

 

In accordance with the council's Freedom of Information policy, I will
arrange for an internal review of your request to be undertaken.

 

The review will be undertaken by a manager not involved in the original
handling of your request. In line with guidance from the Information
Commissioner’s Office, we will aim to provide a full response within 20
working days beginning the day your complaint was received. This means you
will receive a response by 25 November 2022.

 

Kind regards,

Renata

 

 

Renata Malinowski

Freedom of Information Support Officer

 

Voice of the Customer Team

Customers and Organisational Development

 

Oxfordshire County Council

Email:  [1]FOI-E&[email address]

[2]www.oxfordshire.gov.uk

 

 

 

 

 

 

 

Save money and paper - do you really need to print this email.

 

 

This email, including attachments, may contain confidential information.
If you have received it in error, please notify the sender by reply and
delete it immediately. Views expressed by the sender may not be those of
Oxfordshire County Council. Council emails are subject to the Freedom of
Information Act 2000. [3]email disclaimer. For information about how
Oxfordshire County Council manages your personal information please see
our [4]Privacy Notice.

References

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FOI - E&E, Oxfordshire County Council

1 Attachment

Our reference: 20271 EIR IR

Dear Mr Parnham,

Thank you for your email dated 29 October 2022. As you have indicated that you are not satisfied with the response made by the County Council, the issue has been referred to me to conduct an internal review.

My investigation

I have completed the internal review and have looked at the whole request afresh. I have also looked at how the original response was handled. On that latter point, I can see that we replied within the statutory timeframe.

On 19 August 2022 you requested the following information:

"all correspondence between the report's authors and reviewers, and also other councillors / council staff, and any external stakeholders also engaged, regarding the specific issue of evaluation road sampling - i.e., which roads were selected for evaluation in this report. Because multiple versions of the reports were created (including one for the abandoned LTN decision meeting in February and another for July cabinet meeting), I would like the particular focus of your correspondence search to be in the run up to the completion of the first draft of the report, which was completed on 19 January 2022. It was during this period that when the sampling decisions were mostly likely to have been taken - the sampling did not change for the latter versions of the report. I would therefore suggest you initially concentrate your efforts in location correspondence for the four-month period leading up to the completion of the report's first draft."

On 29 October 2022 you wrote to the Council expressing dissatisfaction with the Council's handling of your request in the following terms:

"The selection of roads evaluated within the Cowley LTN was central to the finding that traffic had been reduced within the Cowley LTNs. The roads selected for evaluation - just three roads (out of dozens possible) - two of which were blocked off during the trial with planters - was extremely questionable, in terms of sampling best practice. The outcome of this sampling clearly, and unambiguously, skewed the outcome of a key LTN evaluation metric, thereby indicating "success" where, in reality, that success was likely to be down to the sampling itself rather than wider traffic impacts within the LTN.

I therefore believe the public interest in discovering whether this unfair sampling was known, considered, and accepted in advance, outweighs the cost of discovering what was known. The council created this sampling problem of its own volition - and must now be subject to scrutiny about who knew what, when. That is the public interest associated with my enquiry, which sits IN ADDITION to the presumption in favour of disclosure.

Moreover, the council plans to deploy a very similar sampling approach in relation evaluating the East Oxford LTNs - evaluating roads blocked off by the trial itself rather than those that were not, and therefore take the diverted traffic within the LTN, (according to another FOI, which revealed their evaluation sampling methodology in advance). This separate sampling decision, I believe, further tips the public interest in favour of disclosure in relation to the Cowley LTN road sampling decisions. If the key decision makers were fully aware of the likely outcome of their questionable sampling in relation to the Cowley LTN, then it raises questions about why a similar sampling decision has been taken in relation to the East Oxford LTN evaluation."

I have discussed the matter with the relevant officers and reviewed the original response, and can confirm that I am satisfied that the Council correctly applied Regulation 12(4)(b) EIR 2004 to the information. The effort required to search and review all the information you require would represent a substantial and unreasonable burden on resources. I have also considered the arguments for and against disclosure and I uphold the public interest test and the finding that the balance of the public interest lies in non-disclosure. As detailed in our initial response, the Council calculates it will take approximately 41 hours to complete the request. Although this is an approximate, an informed estimate would suggest anywhere between 32-41 would be required to locate, retrieve and extract the relevant information.

The Council accepts that there is a public interest in transparency especially where the matter in question has a current and high level of public interest. However, the Council does not consider there to be an overriding or exceptional reason for disclosure in this instance.

As offered to you in our initial response, we are able to provide as an alternative an explanation of the process of sensory selection without reference to historic communications. Please now find attached. This sets out the location selection requirements and rationale.

The Information Commissioner

I trust that this information now satisfies your request. However, if you remain dissatisfied with the handling of your request or complaint, you have a right to appeal to the Information Commissioner at:

The Information Commissioner's Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire, SK9 5AF.
Telephone: 0303 123 1113
Website: https://ico.org.uk/

Yours sincerely,

Aron Wisdom
Programme Lead
Transport and Infrastructure
Oxfordshire County Council
Email: [email address]
www.oxfordshire.gov.uk

This email, including attachments, may contain confidential information. If you have received it in error, please notify the sender by reply and delete it immediately. Views expressed by the sender may not be those of Oxfordshire County Council. Council emails are subject to the Freedom of Information Act 2000. email disclaimer<https://www.oxfordshire.gov.uk/emaildisc...>. For information about how Oxfordshire County Council manages your personal information please see our Privacy Notice.<https://www.oxfordshire.gov.uk/council/a...>