Average speed cameras A40

william perrin made this Freedom of Information request to Transport for London

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was partially successful.

Dear Transport for London,

I welcome measures to improve road safety, am a regular car driver on the A40 and have been familiar with average speed cameras since one of the first national installations on the A43 in Northampton a decade ago.

TfL’s announcement of September 2014
https://tfl.gov.uk/info-for/media/press-...
based on the paper presented to the Finance and Policy committee on 27 November 2013
https://tfl.gov.uk/cdn/static/cms/docume...
described the A40 installation as ‘a trial’, apparently lasting for two years, as part of a 20 year programme. I should be grateful to receive under either the FOIA or EIR any information you hold in your records on the design of the trial. This might include some or all of:
information that led to this section of the A40 being used for a trial (the board paper mentions an evaluation)
success measures for the trial
failure measures for the trial
monitoring and assessment arrangements for the trial
governance of the trial
independent scrutiny of the trial
start and end dates of the trial
scientific guidance received in structuring the trial

The scale of the trials is substantial involving hundreds of thousands, possibly millions of people and as such there is a strong public interest in making this information available.

I would prefer to receive this information by electronic means through this service. Please don't hesitate to contact me if you require clarification in order to process this request. If you can only reply partially then please do so.

Yours faithfully,

william perrin

FOI, Transport for London

Dear Perrin

TfL Ref: FOI-0997-1516

Thank you for your email received by Transport for London (TfL) on 1 September 2015.

Your request will be processed in accordance with the requirements of the Freedom of Information Act and TfL’s information access policy.

A response will be provided to you by 29 September 2015. 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 http://www.tfl.gov.uk/corporate/transpar... to see if this helps you.

In the meantime, if you would like to discuss this matter further, please do not hesitate to contact me.

Yours sincerely

Ida Harris | FOI Case Officer
FOI Case Management Team
Transport for London

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FOI, Transport for London

Dear Mr Perrin

TfL Ref: FOI-0997-1516

Thank you for your email received by us on 1 September 2015 asking for information about average speed cameras A40

Your request his being considered in accordance with the requirements of the Freedom of Information (FOI) Act and our information access policy.

However, in accordance with Section 17 of the Freedom of Information Act this letter is a refusal notice as we are still considering the balance of the public interest in relation to qualified exemption that applies to the requested information and have not yet reached a conclusion. The exemption under consideration is s43(2). It is estimated that a decision will be reached by 26 October 2015 and I will write again to inform you of that decision.

Yours sincerely

Ida Harris | FOI Case Officer
FOI Case Management Team
Transport for London

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Dear FOI,

Thank you for your message of 29 September telling me that you are seeking a 20 day extension under Section 17 to consider the public interest issues. I have sought advice from the Campaign for Freedom of Information.

You say that this is a 'refusal' but i do not think from the context that you mean that you are refusing the whole request? But rather that you hope that by 26 October you will be in a position to reply having weighed up the balance of public interest versus prejudicing commercial interests. Could you please confirm? If you are refusing the whole request then i shall immediately submit a request for internal review which i suspect you and I could do without.

Also you are obliged to provide me information requested upon which you are not weighing up the issues.

For instance it cannot be the case that the start and end dates of the trial can prejudice anyone's commercial interests requiring 20 days to weigh it up.

I should remind you that DfT data reports in 2014 an annual average daily flow of 100,000 motor vehicles on the A40. This request pertains to a trial being carried out over a number of years that will affect each and every one of those vehicles, creating in aggregate a very substantial level of public interest . The prejudice to commercial interests suffered would have to be quite colossal to outweigh this and I am puzzled as to why you require extra time to weigh it up.

Yours sincerely,

william perrin

william perrin left an annotation ()

I have used the ICO's 'raise a concern' process to see if they can help expedite this issue. My covering email to the forms is below

>Hello

I spoke to your telephone line - they suggested i mark this as urgent. At the end of October, TFL will start a large trial involving huge quantities of personal movement data and are not responding promptly to my FOI requests about the nature of the trial nor what happens to the data arising. I have consulted with the CFOI who are as puzzled as I am.

The trial is due to start at the end of October, TfL are pleading S17 until 26 October.

This does not allow sufficient time for the traditional internal review and appeal route before this trial commences.

I should be grateful if you could expedite this with TfL

Details in attached.

Yours

William Perrin

FOI, Transport for London

4 Attachments

Dear Mr Perrin

 

TfL Ref: FOI-0997-1516

 

Thank you for your email received by us on 1 September 2015 asking for
information about average speed cameras on the A40.

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.

 

Q: TfL’s announcement of September 2014
([1]https://tfl.gov.uk/info-for/media/press-...)
based on the paper presented to the Finance and Policy committee on 27
November 2013
([2]https://tfl.gov.uk/cdn/static/cms/docume...)
described the A40 installation as ‘a trial’, apparently lasting for two
years, as part of a 20 year programme.  I should be grateful to receive
under either the FOIA or EIR any information you hold in your records on
the design of the trial.  This might include some or all of: information
that led to this section of the A40 being used for a trial (the board
paper mentions an evaluation) success measures for the trial, failure
measures for the trial, monitoring and assessment arrangements for the
trial, governance of the trial, independent scrutiny of the trial, start
and end dates of the trial, scientific guidance received in structuring
the trial

 

The camera enforcement will begin on 26 October 2015. I have attached
documents containing information about the A40 speed cameras trial.

 

In accordance with the FOI Act, we are not obliged to supply some of the
information in the business case document as it is subject to a statutory
exemption to the right of access to information under section 43(2). In
this instance the exemption has been applied as disclosure of the
financial information contained in the business case document would be
likely to prejudice our commercial interests. Disclosure of this
information would be likely to adversely affect our ability to obtain best
value from procurement, due to the creation of a benchmark price which
would be a disincentive to suppliers who might otherwise offer lower
quotations. 

 

The use of this exemption is subject to an assessment of the public
interest in relation to the disclosure of the information concerned. TfL
recognises the need for openness and transparency by public authorities
but in this instance the public interest in ensuring that TfL is able to
obtain the best value for public money outweighs the general public
interest in increasing transparency, which is in part mitigated by our
publication of all expenditure over £250.
[3]https://tfl.gov.uk/corporate/transparency/

 

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

 

 

Ida Harris | FOI Case Officer

FOI Case Management Team

Transport for London

 

 

 

 

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Dear Transport for London,

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

I am writing to request an internal review of Transport for London's handling of my FOI request 'Average speed cameras A40'.

1. Thank you for the information TfL provided in response to my FOI request about the A40 speed camera trial. I am supportive of averaging speed cameras as a significant road safety measure. The information you provided was helpful up to a point, but did not address the central thrust of my enquiry which i repeat here:

>success measures for the trial
failure measures for the trial
monitoring and assessment arrangements for the trial
governance of the trial
independent scrutiny of the trial
start and end dates of the trial
scientific guidance received in structuring the trial
>

TfL have been careful to describe the installation in public pronouncements as a trial - this may well be just an expedient political device to gloss over internal disagreements. But as TfL has described it that way, then TfL should follow through with this basic information i have requested. I should point out that you are carrying out a self-described trial with the personal data of people who make over 100,000 journeys a day on this road. so the public interest case for disclosure is very high indeed and increases rapidly as every day goes by and more people's information is drawn into the trial. Can i ask you please to provide me and the public in general with the information i request.

2. you have redacted the costs and benefits of the averaging cameras installation citing concerns that this would damage your commercial interests by establishing a guide price. This is nonsense.
Firstly It's been established in economic theory for over 40 years that lack of information about a transaction leads to 'adverse selection' - that is to say not knowing enough, people don't enter a market (see Stiglitz, Akerlof, Spence etc recent Nobel prize winners for their work). So in this case as there is no indication of price, rational companies might well chose not to compete as they can have no idea whether their costs will be covered in any winning price. This limits the choice for TfL ad increases TfL's own uncertainty.
Secondly - Blind auctions where no price is revealed are generally regarded as being suited only to commodity products or those where there is little variation or extremely well understood pricing. In complex bespoke projects such as installing and maintaining speed cameras a revealed price approach is likely to yield a far more efficient outcome. By revealing a price innovators can be persuaded to enter with alternative approaches at lower cost. Or the purchaser can use a multi-round approach to drive the price down among competing bidders.
Thirdly - you have redacted the amount of benefits to the public. And as such are saying that, the public will not benefit from knowing how much they will benefit. There is no public interest case for this. I should remind you again of the colossal amount of intimate private data you are processing about people's movements - that should outweigh any disbenefit.

I should be grateful if you could provide the information i have requested and also reveal the numbers you have chosen to redact.

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

Yours faithfully,

william perrin

FOI, Transport for London

Our ref: IRV-062-1516

Dear Mr Perrin

Request for internal review

Thank you for your request for an internal review which was received by Transport for London (TfL) on 6 November 2015.

You have stated that you are dissatisfied with the handling of your request for information under the Freedom of Information Act

The review will be conducted by an internal review panel in accordance with TfL’s Internal Review Procedure, which available via the following URL:

http://www.tfl.gov.uk/cdn/static/cms/doc...

Every effort will be made to provide you with a response by 4 January 2016. 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 do not hesitate to contact me on the number given below.

Yours sincerely

Emma Flint
Information Access Adviser
Transport for London
[TfL request email]

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william perrin left an annotation ()

Caroline Pidgeon GLAM has asked two questions of the Mayor on this topic

http://questions.london.gov.uk/QuestionS...
and
http://questions.london.gov.uk/QuestionS...

FOI, Transport for London

Dear Mr Perrin

I am contacting with regards to your internal review request of FOI-0997-1516. Unfortunately we will not be able to provide our final outcome by the date of 4 January as advised. We endeavour to provide a full response by 18 January 2016.

We understand that this delay maybe frustrating for you and apologise for any inconvenience caused.

Your sincerely
Emma Flint
Information Access Adviser
Transport for London

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william perrin

Dear Transport for London,

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

I am writing to request an internal review of Transport for London's handling of my FOI request 'Average speed cameras A40'.

You wrote to me in January 2016 explaining that you would not meet your target for a reply. It is now 9 May 2016 and I have not heard anything since. I note that in the opening words of his speech on being sworn in the new Mayor said that: 'I am determined to lead the most transparent, engaged and accessible administration London has ever seen’.

I should be grateful if you could swiftly respond to my request with the information I have requested in the spirit of the new Mayor's approach.

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

Yours faithfully,

william perrin

Dear FOI,

re my request above - you said you hoped to respond by 12 january and i still await a response. over two months have elapsed since my request for an internal review. I should be grateful for a full response within ten working days (ie by 10 August) or i shall escalate this to the ICO as you are firmly in breach of normal practice here. And i shall also raise it with the Mayor's office given his new commitment to transparency.

Yours sincerely,

william perrin

FOI, Transport for London

Dear Mr Perrin,

I am very sorry for the delay in processing your request for an internal review. We are preparing our response and we intend to reply in full as soon as we complete this piece of work. We note your requirement for a response by 10 August 2016 at the latest and we will endeavour to meet it.

Yours Sincerely

Simon Guild
Information Access Manager
Transport for London

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FOI, Transport for London

3 Attachments

Dear Mr Perrin

 

As part of the internal review process we have reviewed the redactions
made in relation to the attached documents and concluded that some of the
previously redacted material could be disclosed without there being
sufficient harm to our commercial interests. Please accept my apologies
for the delay in concluding this process. Therefore, please find attached
revised versions of the documents previosuly disclosed to you.

 

Additionally, we have revisited your original FOI request looking into
each of the specific aspects that you referred to. I can confirm that we
do not hold any specific documentation in relation to each of your
questions, however we have provided some explanatory information for each.

 

Information that led to this section of the A40 being used for a trial

The A40 was included in a short list of strategic roads in London that
were considered by TfL to be suitable for an average speed camera
corridor. The suitability of the corridors was firstly influenced by the
road layout, with proposed routes being roads with segregated lanes with
the fewest junctions or roundabouts. This identified certain roads that
would need fewer camera installations to cover the length of the route.
These eight corridors then had their Killed and Seriously Injured (KSI)
collision history extracted and the numbers compared to the estimated cost
of an average speed camera corridor installation. The A40 was one of the
four corridors decided to be progressed following a review of its likely
cost to install and the value of the predicted collision savings.

 

Success/failure measures for the trial

We are subject to a pan London target to reduce the number of people
killed or seriously injured by  50 per cent by 2020. A range of initatives
are underway to secure these reductions, including the delivery of the
average speed camera trials. The locations will be monitored to identify
the impact of the average speed cameras and to respond as necessary. There
is not a specific locational target for such reductions, as it is very
much dependent on local circumstances.

 

Monitoring and assessment arrangements for the trial, Start and end dates
of the trial

The average speed camera system on the A40 will be evaluated by
investigating the changes in numbers of KSIs on the route, changes in mean
speeds, journey time reliability, air quality and public acceptability.
Monitoring is ongoing and the initial findings into the public
acceptability of the A40 average speed camera corridor will be received in
late 2017, two years after camera enforcement began on 26 October 2015. It
is at this point that TfL will review the effectiveness of the scheme.  
    

 

TfL receives collision data from the Police with an approximate six month
time lag, leading to a delay in terms of monitoring the number of
collisions on London’s roads. Collision data is recorded by TfL’s accident
diary system and to date in the four full months of operation of the A40
average speed camera system for which data is available there have been 24
collisions (1 fatal, 1 serious and 22 slight injury collisions) compared
to the 46 in the seasonally matched before period (1 fatal, 2 serious and
43 slight injury collisions).  

 

This reduction in the four months of operation for which data is available
is not yet sufficient to draw any conclusions on the success of the trial.

 

Independent scrutiny of the trial or scientific guidance received in
structuring the trial

We have not received any independent scrutiny or other
scientific/specialist guidance on structuring the trial of these average
speed cameras along the four corridors.

 

If this is not the information you are looking for, or if you are unable
to access it for some 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

 

Lee Hill

Senior FOI Case Officer

 

FOI Case Management Team

General Counsel

Transport for London

 

 

Dear Transport for London,

 

I welcome measures to improve road safety, am a regular car driver on the
A40 and have been familiar with average speed cameras since one of the
first national installations on the A43 in Northampton a decade ago.

 

TfL’s announcement of September 2014

[1]https://tfl.gov.uk/info-for/media/press-...

based on the paper presented to the Finance and Policy committee on 27
November 2013
[2]https://tfl.gov.uk/cdn/static/cms/docume...

described the A40 installation as ‘a trial’, apparently lasting for two
years, as part of a 20 year programme. I should be grateful to receive
under either the FOIA or EIR any information you hold in your records on
the design of the trial. This might include some or all of:

information that led to this section of the A40 being used for a trial
(the board paper mentions an evaluation) success measures for the trial
failure measures for the trial monitoring and assessment arrangements for
the trial governance of the trial independent scrutiny of the trial start
and end dates of the trial scientific guidance received in structuring the
trial

 

The scale of the trials is substantial involving hundreds of thousands,
possibly millions of people and as such there is a strong public interest
in making this information available.

 

I would prefer to receive this information by electronic means through
this service. Please don't hesitate to contact me if you require
clarification in order to process this request. If you can only reply
partially then please do so.

 

Yours faithfully,

 

william perrin

 

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References

Visible links
1. https://tfl.gov.uk/info-for/media/press-...
2. https://tfl.gov.uk/cdn/static/cms/docume...
3. http://www.tfl.gov.uk/corporate/about-tfl/