Location of Mid Tunnel Vent Shafts & Intervention Points

Robin Taylor 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 refused by Transport for London.

Dear Transport for London,

I'd be grateful if you would able to kindly list the locations of the Mid Tunnel Ventilation Shafts and Intervention Points on London Underground, including the name of the road where the Ventilation Head House or exit is located.

As an example Netherton Road is a known example of a ventilation shaft for the Victoria line.

Thanks for your help.

Yours faithfully,

Robin Taylor

Dear Transport for London,

I'd be grateful if you'd kindly let me know if you have received my request dated 17 October 2011 as I have not received an acknowledgement.

Thanks for your help.

Yours faithfully,

Robin Taylor

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 'Location of Mid Tunnel Vent Shafts & Intervention Points'.

There are two aspects that I have not been happy with:

1) The failure of the department to acknowledge receipt of the request made on the 17 October 2011 and of the follow up on the 21 October.

2) The department has failed to complete the request within the specified period and has given no reason for the delay.

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

Thank you for your help.

Yours faithfully,

Robin Taylor

Dear Transport for London,

I'm contacting you to establish the current position of my FOI request made via the What Do They Know website.

The request was made on the 17 October 2011 and a follow up sent to you on 21 October with a response expected by 14 November.

I have not received any acknowledgement of receipt of my request or been given an indication of when you will be able to respond.

I have requested an internal review of how this request has been handled, meanwhile I'd be grateful if you'd kindly inform me of the progress of this request, reason for the delay and when I can expect a response.

To assist you my request was :

I'd be grateful if you would able to kindly list the locations of
the Mid Tunnel Ventilation Shafts and Intervention Points on London
Underground, including the name of the road where the Ventilation
Head House or exit is located.

As an example Netherton Road is a known example of a ventilation
shaft for the Victoria line.

Thanks for your help.

Yours faithfully,

Robin Taylor

DPA, Transport for London

Dear Mr Taylor

Request for internal review

 

Our reference IRV-077-1112

 

Thank you for your request for an internal review which was received by
Transport for London (TfL) on 16 November 2011.

 

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 is available via the following
URL:

[1]http://www.tfl.gov.uk/assets/downloads/f...

 

Every effort will be made to provide you with a response by 14 December
2011. 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.

 

Ida Harris of behalf of

 

Peter Sloane

 

Senior Information Governance Adviser
Information Access & Compliance Team | General Counsel | Transport for
London
5th Floor, Windsor House, 42-50 Victoria Street, London SW1H 0TL
T: 020 7126 4912 auto 64912
F: 020 7126 3185
E: [2][email address]

 

TfL has recently adopted an ‘information security classification scheme’
to help protect its information assets. If you work for TfL or one of its
subsidiaries and want to find out how this affects you, see the new
[3]Quick Guide or visit [4]Source for more information.

 

 

 

References

Visible links
1. http://www.tfl.gov.uk/assets/downloads/f...
2. mailto:[email address]
3. http://source.tfl/pdfs/IA_QG1_Informatio...
4. http://source.tfl/OurCompany/Governance/...

Dear Transport for London,

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

I am writing to request an further internal review of Transport for London's handling of my FOI request 'Location of Mid Tunnel Vent Shafts & Intervention Points'.

This is the second request for a review as I have not received a response by the previous deadline of 14 December 2011. A response to the original FOI request has also not been provided.

Please advise on the progress of this matter and the reasons for the continued delay.

A compliant has registered with ICO regarding the handling of this request.

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

Thank you.

Yours faithfully,

Robin Taylor

Sloane Peter, Transport for London

5 January 2012

 

Our ref: IRV-077-1112

 

Dear Mr Taylor

 

The initial internal review of TfL’s response to your request for
information has been completed. As we have discussed, I am sorry that I
was not able to provide you with this outcome sooner.

 

You requested details of the location of mid-tunnel vent shafts and
ventilation points on London Underground. As constitutes information on
factors that are likely to affect the environment, your request has been
considered under the Environmental Information Regulations.

 

The review found that in failing to respond to your request within 20
working days, TfL contravened the requirements of Regulation 5(2). The
review also found that, in not considering whether it was reasonable to
extend the response time in accordance with Regulation 7(1) TfL further
failed to abide by requirements of the Regulations with regard to the time
for responses to be sent. The review found that this was a result of
failure by LUL Customer Services to issue the response once the relevant
business area had agreed the appropriate way to respond to you. On behalf
of TfL, please accept my apologies for the delays you have experienced in
the handling of your request and in receiving the outcome of this review.

 

In view of the problems you have encountered, the central TfL team that
handles requests for information has taken over this request and will be
issuing you with a formal response very shortly. As we have discussed,
while this email constitutes the outcome of your initially requested
internal review I would like to make it clear that, should you be unhappy
with the response that is shortly to be sent, we would still be prepared
to offer you a further internal review. We consider that it would not be
fair to you to refuse your right to an review of the quality of the
response simply because you have already exercised your right to a review
as a result of LUL’s failure to provide a timely response. Therefore, if
there are any other aspects of the response with which you are unhappy
once you receive it, please let me know.

 

The review also found that there were other shortcomings in how your
request was handled. The review noted that more should have been done to
keep you informed of the progress of your request, including acknowledging
receipt of it.

 

On behalf of TfL I apologise for the failings in how your request for
information was handled and for the delays that you have experienced. It
may interest you to know that, as part of TfL’s efforts to streamline the
FOI process, FOI requests made to London Underground will now be
co-ordinated by the TfL specialist FOI team.

 

If you are dissatisfied with the outcome of this internal review, 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 available on the ICO’s website ([1]www.ico.gov.uk).

 

Yours sincerely

 

Peter Sloane

 

Peter Sloane | Senior Information Governance Adviser (Enforcement and
Complaints)

Information Governance | General Counsel | Transport for London

Windsor House, 42-50 Victoria Street, London SW1H 0TL

T: 020 7126 4912 | E: [2][email address]

 

TfL has recently adopted an ‘information security classification scheme’
to help protect its information assets. If you work for TfL or one of its
subsidiaries and want to find out how this affects you, see the new
[3]Quick Guide or visit [4]Source for more information.

 

show quoted sections

 

References

Visible links
1. http://www.ico.gov.uk/
2. mailto:[email address]
3. http://source.tfl/pdfs/IA_QG1_Informatio...
4. http://source.tfl/OurCompany/Governance/...

FOI, Transport for London

1 Attachment

Dear Mr Taylor

 

Thank you for your e-mail received by Transport for London (TfL) on 17
October 2011 asking for information about the locations of the Mid Tunnel
Ventilation Shafts and Intervention Points on the London Underground.
Please accept my apologies for the delay in our response.

 

Your request has been considered in accordance with the requirements of
the Environmental Information Regulations (EIR) 2004 and TfL’s information
access policy. I can confirm that TfL holds the information you require. 

 

However, because of the extent of the information you have requested, we
are not able to provide it to you and are applying Regulation 12(4)(b) of
the EIR as we believe that your request, as it is currently framed, is
‘manifestly unreasonable.’  This is because providing all the information
you have requested would impose unreasonable costs on us and require an
unreasonable diversion of staff time and resources.

 

We do not have a definitive list of these assets available. Due to the
extensive history of the Underground’s development, information is simply
not available for many of the older lines.

 

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 transparency in public services;
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 on balance we consider that the public interest
currently favours the use of the exception.

 

We will consider your request again, if you are able to narrow its scope
so that we can more easily locate, retrieve and extract the information
you are seeking. If you have specific questions we will be happy to
consider those.

 

Please see the attached information sheet for details of your right to
appeal.

 

Yours sincerely

 

Gemma Jacob

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

 

[1][TfL request email]

 

Dear Transport for London,

I'd be grateful if you would able to kindly list the locations of
the Mid Tunnel Ventilation Shafts and Intervention Points on London
Underground, including the name of the road where the Ventilation
Head House or exit is located.

As an example Netherton Road is a known example of a ventilation
shaft for the Victoria line.

Thanks for your help.

Yours faithfully,

Robin Taylor

 

References

Visible links
1. mailto:[TfL request email]

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 'Location of Mid Tunnel Vent Shafts & Intervention Points'.

In your reply dated 6 January 2011 you state that "you and are applying Regulation 12(4)(b) of
the EIR as we believe that your request, as it is currently framed, is ‘manifestly unreasonable.’ This is because providing all the information you have requested would impose unreasonable costs on us and require an unreasonable diversion of staff time and resources." and "We do not have a definitive list of these assets available. Due to the extensive history of the Underground’s development, information is simply
not available for many of the older lines."

I do not accept that TfL would not know the location of its assets.
The location of many of the ventilation shafts have been made public as part of the cooling the Tube programme and this has been referred to in TFL Board Agendas.
http://www.tfl.gov.uk/assets/downloads/c... - page 14 for an example.

Also mentioned is that there are 160 ventilation shafts thoughout this system.

http://www.flaktwoods.com/newsarchive1/f...

Intervention point and ventilation point locations are also given as part of the Jubilee Line Act 1993
http://www.legislation.gov.uk/ukla/1993/...

Also 2.8 of http://7julyinquests.independent.gov.uk/...

These are examples of where the infomation is in the public domain. I also understand that these locations have an internal reference number.

The location of Colina Road was disclosed in a previous FOI asking for addresses of TFL locations.

http://www.google.co.uk/url?sa=t&rct...

There is also a map of Victoria line shafts at http://www.icevirtuallibrary.com/docserv...

To clarify my request, please provide a list of the 160 or so ventilation and intervention points on the London Underground system. I believe that this is a reasonable request that should not require an unreasonable amount of staff time to provide.

Thanks for your help.

Yours faithfully,

Robin Taylor

Information Governance, Transport for London

Dear Mr Taylor

 

Request for internal review

 

Our reference IRV-102-1112

 

Thank you for your request for an internal review which was received by
Transport for London (TfL) on 12 January 2012.

 

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 is available via the following
URL:

[1]http://www.tfl.gov.uk/assets/downloads/f...

 

Every effort will be made to provide you with a response by 09 February
2012. 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.

Ida Harris on behalf of

Peter Sloane

 

Senior Information Governance Adviser
Information Access & Compliance Team | General Counsel | Transport for
London
5th Floor, Windsor House, 42-50 Victoria Street, London SW1H 0TL
T: 020 7126 4912 auto 64912
F: 020 7126 3185
E: [2][email address]

 

TfL has recently adopted an ‘information security classification scheme’
to help protect its information assets. If you work for TfL or one of its
subsidiaries and want to find out how this affects you, see the new
[3]Quick Guide or visit [4]Source for more information.

 

 

 

show quoted sections

 

References

Visible links
1. http://www.tfl.gov.uk/assets/downloads/f...
2. mailto:[email address]
3. http://source.tfl/pdfs/IA_QG1_Informatio...
4. http://source.tfl/OurCompany/Governance/...

Felicity Groombridge (Account suspended) left an annotation ()

Just an observation - is it correct this is being dealt with under the EIR rather than a straight forward FOI request?

Robin Taylor left an annotation ()

I believe that TfL decided to classify the request under EIR, something that I believe they have done before with other FOI requests.

I don't quite understand the logic of this and this is maybe what is causing the ongoing delay and reviews.

Sloane Peter, Transport for London

16 March 2012

 

Our reference: IRV-102-1112

 

Dear Mr Taylor

 

I am contacting you further to your request for an internal review of the
response to your request for information under the Environmental
Information Regulations 2004 (EIR). I am sorry that we have not been able
to provide you with this response sooner.

 

As you are aware, you expressed your concern regarding the application of
Regulation 12(4)(b) of the EIRs (manifestly unreasonable) to your request
on the grounds that TfL does not currently hold a definitive list of all
the Mid Tunnel Vent Shafts and Intervention points on London Underground
(LU), and that compiling such a list would impose unreasonable costs on
TfL and require significant diversion of staff time and resources.

 

I can confirm that TfL will no longer be relying on the exception
contained in Regulation 12(4)(b). This is because we have confirmation
from one of the Infrastructure Protection Engineers that they do not
consider that compiling a list of the ventilation shafts and intervention
points would constitute an unreasonable amount of work. They also
acknowledged that a lot of information is in the public domain, though
while some of this has been released legitimately, some has been released
through unauthorised sources. They did also confirm that TfL does not
currently hold a single list of all these points and this is for security
reasons.

 

The review has therefore concluded that the information should have been
considered to be exempt from disclosure by virtue of the exception
contained in Regulation 12(5)(a), which provides that information can be
withheld when its disclosure would adversely affect international
relations, defence, national security or public safety. The panel also
wanted to note that this is in no way a reflection on you personally or
any use that you might intend to make of this information.

 

TfL considers that releasing a single list of all intervention and
mid-tunnel ventilation points would be prejudicial to national security
and public safety. The panel felt that it was important to stress that,
although some of this information is already publically available and that
some points can be identified above ground by those who know what they are
looking for, this is quite different from TfL knowingly and deliberately
making all this information available in a single list. It is an important
principle of FOI and EIR requests that disclosures are considered to be
made to the general public and not just to the person making the request.
It is recognised that there will always be a degree of natural ‘leakage’
of information about a rail system. However this should not be seen as a
justification to release additional information – which may be taken and
misused by third parties.

 

This information would be of considerable use to anyone planning terrorist
attacks on the underground network, which would have clear consequences
for public safety. In addition, publicising the location of intervention
points would further enable anyone planning such attacks to target further
attacks at emergency services seeking to provide assistance. It would
assist anyone with hostile intent in understanding LU’s ability to respond
to terrorist incidents and plan accordingly to maximise casualties or
increase the impact of physical damage to infrastructure. The risk of such
attacks is clearly not a hypothetical or remote possibility. There is a
real, significant and ongoing risk, particularly of terrorist attack, on
London Underground, and we must take reasonable steps to safeguard the
security of our staff and the travelling public.

 

The public, confined, economically critical and iconic nature of the
London Underground system means it will always be an attractive target for
those seeking publicity, economic damage or mass casualties. Whilst it is
not possible to always prevent such acts on an open transport system, it
is possible to plan and prepare to reduce the consequences and increase
the ability to rescue and recover casualties. The panel felt that it was
appropriate to take account of the heightened health and safety risks on
London Underground. Apart from the demonstrated risk of attacks, there are
particular difficulties posed on the Underground which make it even more
necessary to limit the release of information that could be used
maliciously. There are particular problems associated with evacuating
passengers, access of emergency services and the need to move trains out
of danger areas and prevent them backing up which are exacerbated in the
closed environment found on the Underground.

 

The Underground is a critical part of London’s infrastructure and its
smooth and effective functioning is essential to London’s social and
economic wellbeing. The consequences of attacks on the Underground are
therefore not limited to the health and safety implications for individual
customers using the Underground, but also the wider functioning of London
as a whole. The transport network must be considered to be part of the
critical national infrastructure and that therefore information that could
be used to facilitate an attack on the network must be considered
information that is necessary for safeguarding national security.

 

This is a qualified exception, which means that TfL must consider the
balance of the public interest. TfL recognises that there is a general
public interest in openness, but does not consider that there are any
other significant factors in favour of the release of this information. On
the other hand, there are significant public interest factors in favour of
limiting the amount of extra operational information that is made public –
as outlined above, this information would be of use in the planning and
execution of hostile acts on the Underground, which has already been the
subject of such attacks or attempted attacks on more than one occasion.
TfL considers that therefore there can be no sufficiently strong
countervailing public interest in the disclosure of information that would
override the need to safeguard the health and safety of the travelling
public or justify undermining national security by supplying information
that could be of material use in the planning and execution of terrorist
attacks

 

However, the panel also noted that, in failing to provide you with the
original response within 20 working days, and in failing to provide you
with this internal review outcome within 40 working days, TfL has breached
Regulations 5(2) and 11(4). On behalf of TfL, I apologise for these
shortcomings in the handling of your request.

 

If you are dissatisfied with the outcome of this internal review actions
you can refer the matter to the independent authority responsible for
enforcing the Environmental Information Regulations, at the following
address.

 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

 

A complaint form is available on the ICO’s website ([1]www.ico.gov.uk).

 

Yours sincerely

 

Peter Sloane

 

Peter Sloane | Senior Information Governance Adviser (Enforcement and
Complaints)

Information Governance | General Counsel | Transport for London

Windsor House, 42-50 Victoria Street, London SW1H 0TL

T: 020 7126 4912 | E: [2][email address]

 

TfL has recently adopted an ‘information security classification scheme’
to help protect its information assets. If you work for TfL or one of its
subsidiaries and want to find out how this affects you, see the new
[3]Quick Guide or visit [4]Source for more information.

 

show quoted sections

 

References

Visible links
1. http://www.ico.gov.uk/
2. mailto:[email address]
3. http://source.tfl/pdfs/IA_QG1_Informatio...
4. http://source.tfl/OurCompany/Governance/...

Paul Sladen left an annotation ()

Depending on your exact definition of "vent shaft" (MVS, sub-surface steam vents, fan shafts, sub-station headhouses, nominated escape facilities); then the following relationship (grouping) on OpenStreetMap may provide much of what you're looking for:

http://www.openstreetmap.org/?relation=2...

This covers most of the obvious ones, from North End, down to Somerleyton Road Shaft in the south, and from Old Ford Fan Shaft in the east, to the PiccEx Driver's Escape Shaft on the western edge of T5.