Direct Communications Unit
2 Marsham Street, London SW1P 4DF
Switchboard 020 7035 4848 Fax: 020 7035 4745 Textphone: 020 7035 4742
E-mail: xxxxxx.xxxxxxxxx@xxxxxxxxxx.xxx.xxx.xx Website: www.homeoffice.gov.uk
27 June 2011
Freedom of Information Request Number 18834
xxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx
Dear Mr Peers,
I am writing further to Karen Sawyer’s e-mail of 2nd June 2011, regarding your
request for details on the Ultralyte LTI 20-20 1000 laser speedmeter. Your request
has been handled as a request for information under the Freedom of Information Act
2000.
The Home Office does not require tests of laser speedmeters at specified distances.
Nevertheless the police in their evaluations of the Ultralyte 1000 speedmeter did
measure the speed of vehicles at distances over 300 m. I attach all these
measurements. The data includes the distance from the Ultralyte 1000 speedmeter
to the target, the speed measured by the Ultralyte 1000 speedmeter, and the speed
measured by a reference system. This data is produced by the police for police
purposes and are not precision measurements.
The Home Office does hold the Bil of Materials for the Ultralyte 1000, but after
careful consideration, we have decided that this information is exempt from
disclosure by virtue of Sections 41 and 43 (2) of the Freedom of Information Act.
Please see the attached annex for details as to how we have reached this
decision.
The Home Office has not measured and is not aware of any measurements of the
peak optical power of the laser. The laser has received class 1 laser certification.
See the attached summary of tests against the Speedmeter Handbook v4.
The Home Office has not measured and is not aware of any measurements of beam
divergence. The nominal beam divergence is 3 mrad.
The Ultralyte 1000 has been tested against the sections of the Speedmeter
Handbook v4 that deal with temperature storage and performance (§7.1 and §7.2). I
attach a copy of the test results summary and the handbook.
The firmware in the Ultralyte 1000 has not changed since it was type approved. The
version number is v3.03e.
We have not conducted and we do not hold the results of any tests of the detector
sensitivity.
We presume you are asking about the peak forward current of the transmitting or
receiving diodes. We do not hold any information about the peak forward current of
either diode.
The pulse width of the transmitting laser is about 18 ns.
The duty cycle of the transmitting laser is about 2.25 x 10-6 (from pulse width of 18ns
and pulse repetition frequency of 125Hz).
It’s unclear what latency you are seeking. We presume you are asking for the time
lag between the receipt of the final laser pulse and the speed appearing on the
display. We don’t hold information about these processing times.
We don’t hold information about the rise and fall times of the laser pulse.
In keeping with the Freedom of Information Act, we assume that al information can
be released to the public unless it is exempt. In line with normal practice we are
therefore releasing the information which you requested via the Home Office website.
I hope that this information meets your requirements. I would like to assure you that
we have provided you with all relevant information that the Home Office holds.
If you are dissatisfied with this response you may request an independent internal
review of our handling of your request by submitting a complaint within two months to
the address below, quoting reference 18834. If you ask for an internal review, it
would be helpful if you could say why you are dissatisfied with the response.
Core Home Office, IPS and UK Border Agency cases:
Information Access Team
Home Office
Ground Floor, Seacole Building
2 Marsham Street
London SW1P 4DF
e-mail: xxxxxxxxxxx@xxxxxxxxxx.xxx.xxx.xx
As part of any internal review the Department's handling of your information request
wil be reassessed by staff who were not involved in providing you with this response.
If you remain dissatisfied after this internal review, you would have a right of
complaint to the Information Commissioner as established by section 50 of the
Freedom of Information Act.
Yours sincerely,
Rob Coleman OBE BEng Director
Centre for Applied Science and Technology
(Formerly HOSDB)
Annex
Freedom of Information request from S Peers (reference 18834
)
Reasons for withholding the Bill of Materials
We are not obliged to disclose these third party documents relating to the LTI 20.20
Ultralyte 1000 which were provided in confidence as a requirement of the type
approval process. After careful consideration, we have decided that this information
is exempt from disclosure by virtue of Section 43 (2) of the Freedom of Information
Act. This provides that information can be withheld where disclosure would likely to
prejudice the commercial interests of any person (including the public authority
holding it) and where the public interest fal s in favour of non-disclosure.
Exemption under Section 43 (2) - Commercial Interests
Section 43 (2) of the FOI Act provides that “Information is exempt information if:
its disclosure under this Act would, or would be likely to, prejudice the commercial
interests of any person (including the public authority holding it).
When the FOI Act came into force in January 2005, the Home Office wrote to
manufacturers of speedmeter devices explaining the implications of the FOI Act. We
asked for comments on the type of information that they would normally expect to be
exempt from disclosure. A number of replies were received. It might put my decision
in context if you are aware of some of these received comments. These are therefore
detailed below:
•
“We consider that ALL of the information submitted during the Type Approval
process is commercially sensitive and crucial y, that it was submitted on the
understanding that it would
remain confidential.
•
Clearly, releasing information about the specific implementation of our unique
system may enable competitors to copy our system. The fact that our product
remains unique in this field of enforcement technology 6 years later is testimony to
the creativity of our solution. Any release of information demonstrating how we
achieved Home Office Type Approval would be deeply injurious to our business and
is strictly against the undertaking of confidentiality expressed by CAST [HOSDB] at
the time the information was supplied.”
•
“… we would defend our right to protect the commercially sensitive secrets
that underpin out products.”
•
“…it does of course raise interesting questions about what information we can
now safely supply to CAST [HOSDB] for our new product which is about to be
submitted for approval.”
•
“..That documentation, which is of itself copyright, consists of Engineering
drawings………Much of this is subject to patents and commercial confidentiality. The
information was provided against undertakings, and indeed signed agreements, of
strict confidentiality and were that not the case we would have serious thoughts
about the viability of seeking Type Approvals in the UK. We would have concerns
about our commercial interests worldwide were the information to be freely available
worldwide. Where such information to be disclosed we would view that as a breach
of confidentiality leading potentially to severe commercial harm and would act
accordingly with actions both of Copyright and Breach of Confidentiality.”
•
“Al the information and data provided to you for the purpose of obtaining the
approval of our …. speedmeter has been and is given in confidence and therefore
should be treated as strictly secret and confidential information. “
•
“The concern that we have is that the types of information listed, disclosed
individually or in combination, could result in the intellectual property of our products
being disclosed to competitors.
•
“It is certainly within our knowledge that in a European country certain
commercially confidential information in respect of a speed measuring device was
obtained, probably il egally, from a test house and was used to manufacture a rival
device.”
As you wil see from the above comments, manufacturers of speedmeter devices
consider that the release of any of the information held by CAST as part of the Type
of Approval would be likely to prejudice their commercial interests. Disclosure of the
information would be likely to weaken their positions in a competitive environment by
revealing market-sensitive information or information of potential usefulness to its
competitors and in one evidenced case the information has been used in another
European country to manufacture a rival device.
Public Interest Test
Exemption 43 (2) is a qualified exemption where the public interest test has to be
applied. The industry is natural y wary of the consequences of sharing information
(even with CAST as part of the Type Approval process) as commercial advantage,
achieved at great expense, could be compromised.
However, through the proven integrity of CAST, a level of trust has been built up, the
manufacturers rely on CAST not to release the information, and the process
therefore works. It is in the public interest that the maintenance of safety on the roads
is carried out using the most effective equipment available. This can be ascertained
only through the Type Approval process.
Some manufacturers have already indicated in writing that they will withdraw from the
policing market if the Type Approval process is seen to be undermined. If we were to
have to release documents supplied to us in confidence for the Type Approval
process we would lose the co-operation of the manufacturers which would seriously
undermine the process and have wide ranging safety implications.
Against this background we considered that the factors outlined above weigh in
favour of the public interest in withholding the information because disclosure would
make it less likely that companies, or individuals would provide us with commercially
sensitive information in the future and consequently undermine the ability of CAST to
fulfil its role in type approving speedmeter devices.