Active Bus Stands that are currently not used for scheduled journeys
Dear Transport for London,
Please would you prove me a list, in whatever form is easiest, that shows currently active and available bus stands that are not currently used for regular scheduled trips. - eg. not used at all or only used for curtailments.
Yours faithfully,
Brian Wharf
Dear Mr Wharf
TfL Ref: 2214-2122
Thank you for your request received by Transport for London (TfL) on 28
December 2021 asking for information about Active Bus Stands that are
currently not used for scheduled journeys.
Your request will be processed in accordance with the requirements of the
Freedom of Information Act and our information access policy.
A response will be sent to you by 27 January 2022. We publish a
substantial range of information on our website on subjects including
operational performance, contracts, expenditure, journey data, governance
and our financial performance. This includes data which is frequently
asked for in FOI requests or other public queries. Please check
[1]http://www.tfl.gov.uk/corporate/transpar... to see if this helps you.
We will publish anonymised versions of requests and responses on the
[2]www.tfl.gov.uk website. We will not publish your name and we will send
a copy of the response to you before it is published on our website.
In the meantime, if you would like to discuss this matter further, please
do not hesitate to contact me.
Yours sincerely
Sara Thomas
FOI Case Management Team
General Counsel
Transport for London
Dear Mr Wharf
TfL Ref: 2214-2122
Thank you for your request received by Transport for London (TfL) on 28
December 2021 asking for information about our bus stands that are
currently not used for scheduled journeys.
Your request has been considered in accordance with the requirements of
the Freedom of Information Act and our information access policy. I can
confirm that we hold the information you require. You asked: Please would
you prove me a list, in whatever form is easiest, that shows currently
active and available bus stands that are not currently used for regular
scheduled trips. - eg. not used at all or only used for curtailments.
Please find attached which lists our currently withdrawn bus stands as
requested.
Please note that in accordance with TfL’s obligations under Data
Protection legislation some personal data has been removed, as required by
section 40(2) of the FOI Act. This is because disclosure of this personal
data would be a breach of the legislation, specifically the first
principle which requires all processing of personal data to be fair and
lawful. It would not be fair to disclose this personal information when
the individuals have no expectation it would be disclosed and TfL has not
satisfied one of the conditions which would make the processing ‘fair’.
If this is not the information you are looking for, or if you are unable
to access it for any reason, please do not hesitate to contact me.
Please see the attached information sheet for details of your right to
appeal as well as information on copyright and what to do if you would
like to re-use any of the information we have disclosed.
Yours sincerely
Sara Thomas
FOI Case Management Team
General Counsel
Transport for London
From: FOI
Sent: 31 December 2021 11:14
To: 'Brian Wharf' <[1][FOI #818566 email]>
Subject: RE: new foi ref 2214-2122 CRM:0138442
Dear Mr Wharf
TfL Ref: 2214-2122
Thank you for your request received by Transport for London (TfL) on 28
December 2021 asking for information about Active Bus Stands that are
currently not used for scheduled journeys.
Your request will be processed in accordance with the requirements of the
Freedom of Information Act and our information access policy.
A response will be sent to you by 27 January 2022. We publish a
substantial range of information on our website on subjects including
operational performance, contracts, expenditure, journey data, governance
and our financial performance. This includes data which is frequently
asked for in FOI requests or other public queries. Please check
[2]http://www.tfl.gov.uk/corporate/transpar... to see if this helps you.
We will publish anonymised versions of requests and responses on the
[3]www.tfl.gov.uk website. We will not publish your name and we will send
a copy of the response to you before it is published on our website.
In the meantime, if you would like to discuss this matter further, please
do not hesitate to contact me.
Yours sincerely
Sara Thomas
FOI Case Management Team
General Counsel
Transport for London
Dear Transport for London,
Thank you for the information sent but unfortunately it looks as if my question was not understood. You have sent me a list that contains mainly withdrawn stands.
My request was for a list of Active stands not currently used for regular scheduled journeys.
As an example picking 2 'towns' Downham, Shroffold Road, Downham, Cinderford Way the 2 stands at Downham itself on either side of Old Bromley Road, Welling Vaugh Road, Welling Nag's Head Lane, Welling Churchfield Road etc...these are currently used for unscheduled curtailments but not as a main ultimate destination of a scheduled bus route.
Although the list sent through contains the odd one here and there, as a quick scan through, the above examples are not.
Many thanks in anticipation.
Yours faithfully,
Brian Wharf
TfL Ref: IRV-064-2122
Thank you for your email which was received by Transport for London (TfL) on 25 January 2022.
You have stated that you are dissatisfied with the handling of your request for information under the Freedom of Information Act.
A review will be conducted by an internal review panel in accordance with TfL’s Internal Review Procedure, which is available via the following URL:
https://tfl.gov.uk/corporate/transparenc...
Every effort will be made to provide you with a response by 22 February 2022. However, if the review will not be completed by this date, we will contact you and notify you of the revised response date as soon as possible.
In the meantime, if you would like to discuss this matter further, please feel free to contact me.
Yours sincerely
Emma Flint
Principal Information Access Adviser
FOI Case Management Team
Transport for London
Dear Mr Wharf
I am contacting you following your email of 25 January 2022 concerning the response provide to FOI-2214-2122.
Please accept our apologies that we mistook your request to be for withdrawn stands. Please see that attached spreadsheet which lists the stands that are still active but do not allow passengers to get on or disembark as far as we are able to ascertain. These stands are essentially there for the bus driver to have rest time or to catch up on the timetable so the stand is not part of a scheduled journey.
Please note that the list we hold is not exhaustive as the majority of stands are on borough roads. This means we have limited knowledge of whether they are all still used for regular scheduled journeys or not. Stands are usually identified by road markings and there are no freestanding assets involved as there is with bus stops and shelters.
Again please accept our apologies for any inconvenience caused.
I hope the above response has provided a better clarity regarding the information you seek, however if you are dissatisfied with the internal review actions to date please do not hesitate to contact me or alternately you can refer the matter to the independent authority responsible for enforcing the Freedom of Information Act, at the following address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
A complaint form is also available on the ICO’s website (www.ico.org.uk).
Yours sincerely
Emma Flint
Principal Information Access Adviser
FOI Case Management Team
Transport for London
[TfL request email]
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Dear FOI,
Both responses were not what I was asking for.
I asked for a list of Active stands that were not used as part of scheduled journies.
The first response gave me a lot of withdrawn stands that are inactive. The second response gave me a list of Private stands as to where the public are not allowed access including the likes of Euston station- which is definitely used!
Some examples of what I am after are Welling Nag's Head Lane, Welling Churchfield Road, Plumstead Common Warwick Terrace, Downham Cinderford Way....stands that buses may well use as a curtailment but don't generally speaking see regular use.
Buses are radioed constantly asking them to hold back as the stands that are in use are overflowing. This holding back is the complete opposite of what would make a bus anywhere near attractive to use - this is the reason for the FOI
This is now the fourth attempt to get the same information.
Yours sincerely,
Brian Wharf
Dear Mr Wharf,
TfL Ref: FOI-2752-2122
Thank you for your request received by Transport for London (TfL) on 24^th
February 2022 asking for information about bus stands.
Your request will be processed in accordance with the requirements of the
Freedom of Information Act and our information access policy.
A response will be sent to you by 24^th March 2022.
We will publish anonymised versions of requests and responses on the
[1]www.tfl.gov.uk website. We will not publish your name and we will send
a copy of the response to you before it is published on our website.
In the meantime, if you would like to discuss this matter further, please
do not hesitate to contact me.
Yours sincerely,
David Wells
FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London
Dear Mr Wharf,
TfL Ref: FOI-2752-2122
Thank you for your request received by Transport for London (TfL) on 24^th
February 2022 asking for information about bus stands.
Your request has been considered in accordance with the requirements of
the Freedom of Information Act and our information access policy.
Specifically you asked:
“I asked for a list of Active stands that were not used as part of
scheduled journies. The first response gave me a lot of withdrawn stands
that are inactive. The second response gave me a list of Private stands as
to where the public are not allowed access including the likes of Euston
station- which is definitely used!
Some examples of what I am after are Welling Nag's Head Lane, Welling
Churchfield Road, Plumstead Common Warwick Terrace, Downham Cinderford
Way....stands that buses may well use as a curtailment but don't generally
speaking see regular use.Buses are radioed constantly asking them to hold
back as the stands that are in use are overflowing.
This holding back is the complete opposite of what would make a bus
anywhere near attractive to use - this is the reason for the FOI.”
I can confirm that we hold the information you require. However, the
information has not been collated before and there is no way quick or
efficient way of doing so. Your request is therefore being refused under
section 12 of the Freedom of Information Act. Under section 12, TfL is not
reqeuired to provide information if it would cost more than £450 to
determine if that informtion is held, and to then locate, retrieve of
exract that infromation from elsewhere. This is calculated at a rate of
£25 per hour, equivalent to 18 hours work. In this case, the input of 27
different colleagues would be requried, each having to review the list of
bus stands in their boroughs and determine which are in regular use and
which are not. This is not feasible within the costs limit. We have
provided you with related information in our two previous responses, and
this the best approximation that can be provided within the costs limit.
If you have any more general points to make or questions to raise about
the issue then you can do so via our Customer Services team, though our
website here:
[1]https://tfl.gov.uk/help-and-contact/
Please see the attached information sheet for details of your right to
appeal.
Yours sincerely,
David Wells
FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London
Dear FOI,
As a former TfL employee, I don't accept your response as accurate.
The information used to be held in Busnet - it may still be - the incorrect CSV files you have sent me look as though they are using the same data that Busnet used. All that would need to happen is to correlate the end to end points of the bus routes to the Active Stands. - This could be done with the full CSV file in possibly an hour.
I have the full list but it is out of date by about 13 years and therefore an up-to-date list of stands would be required for it to accurately make the point I am trying to put across.
Yours sincerely,
Brian Wharf
TfL Ref: IRV-076-2122
Thank you for your email which was received by Transport for London (TfL) on 14 March 2022.
You have stated that you are dissatisfied with the handling of your request for information under the Freedom of Information Act.
A review will be conducted by an internal review panel in accordance with TfL’s Internal Review Procedure, which is available via the following URL:
https://tfl.gov.uk/corporate/transparenc...
Every effort will be made to provide you with a response by 11 April 2022. However, if the review will not be completed by this date, we will contact you and notify you of the revised response date as soon as possible.
In the meantime, if you would like to discuss this matter further, please feel free to contact me.
Yours sincerely
Emma Flint
Principal Information Access Adviser
FOI Case Management Team
Transport for London
Dear Mr Wharf
I am contacting you with regard to your email of 14 March 2022. Following
your email a review has been carried out by individuals who were not
involved in the handling of your request (the panel). You have disputed
the response which was provided to your request of the 24 February 2022
which advised that your request was being refused under section 12 of the
FOI Act due to the appropriate cost limit being exceeded (FOI-2752-2022)
Your request of the 24 February asked the following - “I asked for a list
of Active stands that were not used as part of scheduled journeys. The
first response gave me a lot of withdrawn stands that are inactive. The
second response gave me a list of Private stands as to where the public
are not allowed access including the likes of Euston station- which is
definitely used!
To provide you with a little more context with regards to your request for
information, section 12 of FOIA allows a public authority to refuse to
deal with a request where it estimates that it would exceed the
appropriate limit to-
(a) either comply with the request in its entirety or;
(b) confirm or deny whether the requested information is held.
The estimate must be reasonable in the circumstances of the case and where
we claim that section 12 is engaged, we should, where reasonable, provide
advice and assistance to help the requestor to refine the request so that
it can be dealt with under the appropriate limit. The relevant Regulations
which define the appropriate limit for section 12 purposes are The Freedom
of Information and Data Protection (Appropriate Limit and Fees)
Regulation.
Regulation 4(3) of the Fees Regulations states that a public authority can
only take into account the costs it reasonably expects to incur in
carrying out the following permitted activities in complying with the
request:
• determining whether the information is held;
• locating the information, or a document containing it;
• retrieving the information, or a document containing it; and
• extracting the information from a document containing it.
Additionally in such circumstances as may be prescribed, where two or more
requests for information are made to a public authority within a
consecutive 60 working day period-
(a) by one person, or
(b) by different persons who appear to the public authority to be acting
in concert or in pursuance of a campaign,
the estimated cost of complying with any of the requests is to be taken to
be the estimated total cost of complying with all of them. We do not have
to make a precise calculation of the costs of complying with a request(s);
instead only an estimate is required. However, it must be a reasonable
estimate.
We do not have to make a precise calculation of the costs of complying
with a request; instead only an estimate is required. However, it must be
a reasonable estimate.
A realistic estimate is one based on the time it would take to obtain the
requested information from the relevant records or files as they existed
at the time of the request, or up to the date for statutory compliance
with the request. We are not obliged to search for, or compile some of the
requested information before refusing a request that we estimate will
exceed the appropriate limit. Instead, we can rely on having cogent
arguments and/or evidence in support of the reasonableness of its
estimate. However, it is likely that we will sometimes carry out some
initial searches before deciding to claim section 12. This is because it
may only become apparent that section 12 is engaged once some work in
attempting to comply with the request has been undertaken. If we do start
to carry out some searches without an initial estimate, we can stop
searching as soon as we realise that it would exceed the appropriate limit
to fully comply with a request and we are not obliged to search up to the
appropriate limit.
When reviewing your request, the panel took into consideration advice
provided by the Executive Manager of TfL’s Bus Directorate regarding the
time and staff resource involved in identifying, locating and extracting
the information you seek.
As advised previously the information you require isn’t held in a single,
easily reportable format. Whilst you are correct that some of the data
would be held on Busnet, we would still need to manually determine what
information is held and then locate it on the system. Then we would have
to manually generate these reports and convert them into an editable
format. Additionally the extracted data would then need to be reviewed by
the appropriate individuals that are responsible for each area on the
network that the data covers to ensure it is up to date, accurate and to
rectify any anomalies that may arise.
All of this in conjunction with the time already spent providing data for
your previous FOI request and subsequent internal review, the panel are
satisfied that the 18 hour limit determined by s12 of the FOIA would be
exceeded.
Therefore given all the considerations above the panel are satisfied that
s12 has been correctly applied to your request in its entirety. Finally as
s12 of the Freedom of Information Act is not a qualified exemption it does
not require consideration of the public interest test.
We appreciate that the above response may come as a disappointment
therefore when considering this review response and the all explanations
provided to you the panel suggest that if you wish to make a new FOI
request, you either greatly narrow the scope of the correspondence you
seek (such as focusing on 1 or 2 specific areas of the network) and
consider what information is of a priority to you at this stage. It is a
far better use of the resources available to you under the FOI Act to be
as narrow and specific as you are able to allow a focused search for the
information you are interested in and allow us to assist you.
We encourage requesters to take into account the guidance and advice
provided by the Information Commissioners Office (ICO) such as the “dos
and don’ts” published on its website in order to make the best use of the
processing time available under the FOI Act. It can be far more productive
to request specific reports, documents or ask direct questions rather than
cast a wide email search as the burden created by these can often result
in consideration of an exemption on the basis of the time required to
complete.
The following link to the ICO website provides advice on how to make an
FOI request -
[1]https://ico.org.uk/your-data-matters/off...
I hope the above response has provided a better clarity regarding the
information you seek, however if you are dissatisfied with the internal
review actions to date please do not hesitate to contact me or alternately
you can refer the matter to the independent authority responsible for
enforcing the Freedom of Information Act, at the following address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
A complaint form is also available on the ICO’s website
([2]www.ico.org.uk).
Yours sincerely
Emma Flint
Principal Information Access Adviser
FOI Case Management Team
Transport for London
[3][TfL request email]
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Dear FOI,
This response speaks volumes.
The reason you have spent such an amount of time on this request is mainly down to the for active but unused stands was taken as being inactive and withdrawn stands the first time and as being private stands and most definitely used the second time.
The information IS there and it would take approximately an hour to gather. Your responses scream of an unwillingness to assist.
Rather than respond to this email, - I suggest you instead use the time getting on a bus (as an unannounced passenger) and see how unattractive you as the Authority that is supposed to be encouraging public transport use - have made bus travel.
Yours sincerely,
Brian Wharf
Dear Mr Wharf
Thank you for your response. To clarify, even if we didn’t take into account time spent providing data to your previous request and internal review, the panel are satisfied that your new request of 24 February would exceed the 18 hour limit prescribed by s12 of the FOIA on its own merit.
Kind regards
Emma Flint
Principal Information Access Adviser
FOI Case Management Team
Transport for London
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M Clary left an annotation ()
Two points which might be helpful.
Stands for scheduled journeys are visible in the bus working timetables available on the TfL site. Thus any identified stand can be checked to see whether they are used for scheduled journeys.
The route records included in the tender specifications include a complete list of stands available for the route and indicates whether they are only available on an unscheduled basis. An example is at
https://www.londonbuses.co.uk/route-reco....
I don't know whether these are there for every route or whether they are up-to-date.
Of course you have to do your own legwork!