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Request for Chamberlayne Road Bus Review Report (Summer 2018)

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Dear Transport for London,

I am reliably informed that Transport for London undertook a comprehensive review of all the bus routes - 52, 187, 28, 452, 302, 6 and 316 serving Chamberlayne Road, Kensal Rise, NW10. I understand a number of factors were considered:

1) Passenger trips along this road
2) Bus frequencies for each route
3) Alternative route options

From this review, a decision was made to curtail the number of services for route 52; this done on the basis that passenger demand for this route along Chamberlayne had declined.

Grateful if you could provide me with the following information:

1) The full written copy of this review along with the passenger demand data relied on to inform the decisions made in respect of the 7 Chamberlayne Routes;
2) All written emails, minutes, and documents relating to the decision to reduce services on route 52 and not the other chronically underutilised routes - 452 and 28;
3) Loading profiles for each bus along and for each of the seven Chamberlayne bus routes. I want to understand the average passenger loads at each stop along each bus route - where passenger demand really occurs.

I look forward to hearing from you.

Yours faithfully,

Fiona Mulaisho

M Clary left an annotation ()

Fiona

Are you aware that the 452 was cut back last year from every 8 to 10 minutes? And the 28 was cut back in 2017 from every 7-8 to every 10 minutes?

Also worth bearing in mind that the usage of a route tends to thin out as it approaches any terminus that is not in itself a major traffic objective. Unless you go with the logic of Dr Beeching, curtailing the less well used sections risks undermining the rest of the route.

Fiona left an annotation ()

Thanks M Clary for your comment. I see that you also have tried to get an explanation from TfL on how it defines "excess capacity". I thought TfL's eventual response to your FOI request was an interesting one.

TfL’s response effectively said bus hourly provision by route is determined by the number of passengers on buses at the busiest point at the busiest times…."For example, if there are ten buses an hour, each of 90 capacity, we would plan to 90% of 90 x 10 = 810 capacity per hour".

The problem with this approach is that bus passenger demand peaks and falls. This approach fails to recognise that or consider the hours when capacity actually drops - the same number of buses per hour are still operated? This explains why there are so many ghost buses, or "under-utilised" buses as now TfL has finally conceded to describing them marauding the streets of London, travelling for miles more or less empty.

This is the problem that has been created for areas like Kensal Rise, as all the 12,000 buses coming weekly to Chamberlayne Road run on diesel, with devastating consequences for the local air quality environment.

TfL’s vast diesel bus operation is a significant contributor to the air quality public health crisis now being experienced. In fact, one of the schools where the diesel buses drive very close to is in the Mayor’s Air Quality Audit of schools as one of the 50 worst polluted schools on one of London’s most polluted roads, in this case Chamberlayne Road. Children are particularly vulnerable to the harms caused by air pollution, these being asthma, deformed lung formation, stunted lung growth etc.

Two of the seven routes – 452, 28 – operate as ghost routes, travelling more or less empty for miles to and from Kensal Rise because as TfL says: “Demand takes place several miles away from Chamberlayne Road”. If that’s the case, then why aren’t the buses turned around earlier so that they can better serve the areas where demand actually happens and so improving journey reliability?

Instead, hundreds of ghost 452 and 28 come to Chamberlayne Road simply to turnaround and in the meantime, contributing greatly to the chronic air pollution problem. There are lots of areas in London with very poor bus provision crying out for buses!

With the technology and information on passenger loadings that TfL has to hand, bus provision can and should be dynamic, this matched to passenger demand THROUGH THE DAY AND NIGHT!

However, TfL’s bus model is not about moving passengers. It’s about how many buses a bus operator can move by the minute for which the operator and senior TfL management are paid handsome taxpayer funded bonuses!

FOI, Transport for London

Dear Ms Mulaisho

 

TfL Ref: FOI-0292-1920

 

Thank you for your email which we received on 26 April 2019.

 

Your request has been considered in accordance with the requirements of
the Freedom of Information (FOI) Act and TfL’s information access policy. 

 

Unfortunately, from the description provided, we are unable to identify
the information you require. To enable us to assist with your request,
please clarify a time frame you want us to cover to search for emails and
minutes of meetings concerning the decision to reduce services on route
52. As for the passenger loads, can you also specify a time period or
particular dates which you are interested in?

 

Please note that the 20 working day deadline for responding to your
request will depend on when we receive satisfactory additional
information to help clarify your request.  

 

If we hear nothing further from you by 21 May your response will be
treated as a new request.

 

In the meantime, if you have any queries or would like to discuss your
request, please do not hesitate to contact me.

 

Yours sincerely

 

Eva Hextall

FOI Case Officer

 

FOI Case Management Team

General Counsel

Transport for London

 

 

 

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Dear FOI,

Thank you for your email asking me to clarify my ask for information and communications relating to the curtailment of services for route 52.

To provide some context, my FOI request is based on an email received from a TfL customer executive last week, and in which it was said that following a Chamberlayne's comprehensive bus review in 2017:

"We (TfL) have since identified a reduction in usage of route 52. On this basis, I am pleased to advise that we are planning to reduce the 52 service from nine buses per hour to seven buses per hour Monday to Saturday day times and evenings. Sunday frequencies are planned to reduce from six buses per hour to five buses per hour".

In view of the above, and to help tighten the time frame for my request, it would be helpful if TfL could tell me when and what work was undertaken to assess usage of route 52, this resulting in the abovementioned plans? When did this work start and end? What was the time frame for the loading profiles used to inform the decision / plan to curtail route 52 services?

When TfL has provided the above information, I will then be in a better position to specify the time frame for the search for emails and minutes of meetings concerning the decision to reduce services on route
52, and time frame for passenger loading data required.

Yours sincerely,

Fiona Mulaisho

FOI, Transport for London

Dear Ms Mulaisho

 

Thank you for your email.

 

Route 52 was reviewed as part of tranche 664 and the frequency reduction
was approved in late September 2018. The loadings data was taken from a
typical week in April 2018 and was also based on keypoint data from 2017
and 2018. The bulk of the work was done in August 2018.

 

I hope this helps you with specifying a timeframe for your request.

 

Yours sincerely

 

Eva Hextall

FOI Case Officer

 

 

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Dear FOI,
Thank you for your response . Please can you provide me with the loadings data for the following Chamberlayne Routes - 52, 6, 452, 28, 187 and 302 - and these should be based on the same "typical week in April 2018" that was used to assess the review undertaken for route 52, and should also be based on keypoint data from 2017 and 2018.

Yours sincerely,

Fiona Mulaisho

FOI, Transport for London

Dear Ms Mulaisho

 

Thank you for clarifying your request. A response will be provided to you
by 10 June 2019.

 

Yours sincerely

 

Eva Hextall

FOI Case Officer

 

 

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FOI, Transport for London

1 Attachment

Dear Ms Mulaisho

 

TfL Ref: FOI-0292-1920

 

Thank you again for your request asking for information about bus routes.

 

Your request is being considered in accordance with the requirements of
the Freedom of Information (FOI) Act and our information access policy. I
can confirm we do hold the information you require.

 

However, in accordance with Section 17 of the Freedom of Information Act
we are still considering the balance of the public interest in relation to
a qualified exemption that applies to some of the requested information
and have not yet reached a conclusion. The exemption under consideration
is section 43(2) – Commercial Interests. It is estimated that a decision
will be reached by 8 July 2019 and I will write again to inform you of
that decision.

 

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

 

Yours sincerely

 

Eva Hextall

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

 

 

 

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Dear FOI,

Section 10 of the FOIA sets out the timescales that a public authority has to respond to an FOIA request. I set out below the chronology of my request:

1. I made my initial request for the following information to you on 26 April:

a) The full written copy of this review along with the passenger demand data relied on to inform the decisions made in respect of the 7 Chamberlayne Routes;
b) All written emails, minutes, and documents relating to the decision to reduce services on route 52 and not the other chronically underutilised routes - 452 and 28;
c) Loading profiles for each bus along and for each of the seven Chamberlayne bus routes, including the average passenger loads at each stop along each bus route - where passenger demand really occurs.

2. You confirmed that the date of receipt of my request for was 30 April;
3. You asked for clarification of the request on 8 May (6 working days after the date of receipt);
4. I responded to you on 12 May providing you with further information on my request;
5. You acknowledged that the date of receipt of this further clarification information was 13 May.

In your latest email of 10 June ( 19 working days after the date of receipt of my further information), you have now confirmed that you have the information that I requested, but you require an additional period of time to consider whether the information should not be disclosed under one of the exemptions in the FOIA, specifically the exemption in Section 43(2).

You state that you will make a decision on this by 8 July. You are therefore stating that you will require an additional 20 working days to consider this request and consider further the exemption that you are seeking to apply and the public interest test.

Section 10 of the FOIA sets out the timescales that a public authority has to respond to an FOIA request. You are required to respond promptly to a request and this means that you should comply with the request as soon as reasonably practicable.

The ICO guidance on timescales for a response is very clear; authorities should regard the 20 working day limit as a ‘long stop’ and as you have indicated that you intend to make a decision by 8 July I will expect you to be able to account for and justify the length of time taken to comply with the request.

You also indicate that you are looking at the exemption under section 43(2) which exempts information whose disclosure would, or would be likely to, prejudice the commercial interests of any person (an individual, a company, the public authority itself or any other legal entity). This section 43 exemption is a qualified exemption, subject to the public interest test.

I would urge you to consider my request in the spirit of openness and transparency and the need to provide clarity around value for money and quality of service in bus routing and provision in London. Disclosure and provision of passenger loading information to potential new bidders for bus contracts should be a central part of the bidding process.

Further as a public authority, Transport for London is accountable for the spending of public money and the disclosure of the information I have asked for will provide better understanding to taxpayers and service users of how Transport for London spends public money.

Clear expressions of service levels, monitoring information and performance should be an integral part of a contract between the public sector and a commercial entity. This information should be readily available for public scrutiny and I look forward to receiving it.

Yours sincerely,

Fiona

FOI, Transport for London

Thank you for your request for an internal review which was received on 16 June 2019.

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:

http://content.tfl.gov.uk/internal-revie...

Every effort will be made to provide you with a response by 15 July 2019. 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.

Yours sincerely

Emma Flint
Principal Information Access Advisor
FOI Case Management Team
General Counsel

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FOI, Transport for London

Dear Ms Mulaisho

I am contacting you regarding your internal review request concerning the extension of a further 20 working days under the provisions of the Freedom of Information (FOI) Act. This review has been carried out following your e-mail of 16 June 2019.

Where a request is made under section 17 of the FOI Act and where a public authority is considering the use of a qualified exemption to the requested information, they may extend the period of 20 working days to consider the public interest test.

Whilst we understand that you are keen to receive the information you requested as soon as possible and your frustration at the ongoing request, some of the information you have requested has to be reviewed for any potentially commercially sensitive information. As part of this review we must also consider the public interest when applying the exemption. As we are still reviewing this information it was agreed by a manager that an extension under the provisions of the FOI Act was appropriate. This was clearly communicated to you in our email of 10 June 2019 with a new advised response date of 8 July 2019.

Please note that at this stage as a final response to FOI-0292-1920 has yet to be provided to you, I am unable to review any decisions made regarding the application of s43 of the FOI Act. Every effort will be made to provide you with a response by the 8 July however once a response is provided to your request we will offer you the opportunity to request a further internal review of the content of the response if you choose, even though you have already exercised your right to a review in view of our extension under the FOI Act.

Therefore, when received if you are not satisfied with the final response to FOI-0292-1920 please contact [TfL request email].

If you are dissatisfied with the internal review actions to date you can refer the matter to the independent authority responsible for enforcing the FOI 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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FOI, Transport for London

4 Attachments

Dear Ms Mulaisho

 

TfL Ref: FOI-0292-1920

 

Thank you for your emails received on 26 April and 12 May asking for
information about bus routes on Chamberlayne Road.

 

Your request has been considered in accordance with the requirements of
the Freedom of Information Act and our information access policy.  I can
confirm we hold some of the information you require. You asked:

 

1) The full written copy of this review along with the passenger demand
data relied on to inform the decisions made in respect of the 7
Chamberlayne Routes;

2) All written emails, minutes, and documents relating to the decision to
reduce services on route 52 and not the other chronically underutilised
routes - 452 and 28;

3) Loading profiles for each bus along and for each of the seven
Chamberlayne bus routes. I want to understand the average passenger loads
at each stop along each bus route - where passenger demand really occurs.

 

There has not been a recent comprehensive review of bus routes 52, 187,
28, 452, 302, 6 and 316 serving Chamberlayne Road. The changes to route 52
were part of a retendering exercise which focussed on route 52 (and
included route 452 due to the long parallels it shares).

 

Route 52 was revised as part of a tendering programme - tranche 664 and
the frequency reduction was approved in late September 2018. Therefore the
information we have provided in response to your email relates to this
tranche only, specifically route 52. Please also note the loading profile
data does not exist as a review was not undertaken of routes 52, 6, 452,
28, 187 and 302.

 

The only loading data we hold are in the attached single files which were
used to assess capacity on routes 52 and 452, which is also summarised in
the BSM paper which we are providing. No other loading profile type data
was used.

Please find the attached emails, bus services meeting (BSM) paper and
minutes relating to the reduced service on bus route 52. However, we are
not obliged to provide you with the operator’s financial information, as
it’s subject to a statutory exemption to the right of access to
information under section 43(2). In this instance the section 43(2)
exemption has been applied as disclosure would be likely to prejudice ours
and the operator’s commercial interests. Bus routes come up for regular
retendering and releasing this information could jeopardise TfL’s ability
in obtaining the most competitive rates possible.

The use of this exemption is subject to an assessment of the public
interest in relation to the disclosure of the information concerned. We
recognise the need for openness and transparency by public authorities,
particularly where the expenditure of public money is concerned, but in
this instance the public interest in ensuring that we are able to obtain
the best value for public money outweighs the general public interest in
increasing transparency of our processes.

Furthermore, 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’.

 

This exemption to the right of access to information is an absolute
exemption and not subject to an assessment of whether the public interest
favours use of the exemption.

 

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

 

Eva Hextall

FOI Case Officer

 

FOI Case Management Team

General Counsel

Transport for London

 

 

 

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FOI, Transport for London

1 Attachment

 

 

From: FOI
Sent: 02 July 2019 15:47
To: '[FOI #571328 email]'
Subject: Part 1 of 2 - Freedom of Information request - Request for
Chamberlayne Road Bus Review Report (Summer 2018)

 

Dear Ms Mulaisho

 

TfL Ref: FOI-0292-1920

 

Thank you for your emails received on 26 April and 12 May asking for
information about bus routes on Chamberlayne Road.

 

Your request has been considered in accordance with the requirements of
the Freedom of Information Act and our information access policy.  I can
confirm we hold some of the information you require. You asked:

 

1) The full written copy of this review along with the passenger demand
data relied on to inform the decisions made in respect of the 7
Chamberlayne Routes;

2) All written emails, minutes, and documents relating to the decision to
reduce services on route 52 and not the other chronically underutilised
routes - 452 and 28;

3) Loading profiles for each bus along and for each of the seven
Chamberlayne bus routes. I want to understand the average passenger loads
at each stop along each bus route - where passenger demand really occurs.

 

There has not been a recent comprehensive review of bus routes 52, 187,
28, 452, 302, 6 and 316 serving Chamberlayne Road. The changes to route 52
were part of a retendering exercise which focussed on route 52 (and
included route 452 due to the long parallels it shares).

 

Route 52 was revised as part of a tendering programme - tranche 664 and
the frequency reduction was approved in late September 2018. Therefore the
information we have provided in response to your email relates to this
tranche only, specifically route 52. Please also note the loading profile
data does not exist as a review was not undertaken of routes 52, 6, 452,
28, 187 and 302.

 

The only loading data we hold are in the attached single files which were
used to assess capacity on routes 52 and 452, which is also summarised in
the BSM paper which we are providing. No other loading profile type data
was used.

Please find the attached emails, bus services meeting (BSM) paper and
minutes relating to the reduced service on bus route 52. However, we are
not obliged to provide you with the operator’s financial information, as
it’s subject to a statutory exemption to the right of access to
information under section 43(2). In this instance the section 43(2)
exemption has been applied as disclosure would be likely to prejudice ours
and the operator’s commercial interests. Bus routes come up for regular
retendering and releasing this information could jeopardise TfL’s ability
in obtaining the most competitive rates possible.

The use of this exemption is subject to an assessment of the public
interest in relation to the disclosure of the information concerned. We
recognise the need for openness and transparency by public authorities,
particularly where the expenditure of public money is concerned, but in
this instance the public interest in ensuring that we are able to obtain
the best value for public money outweighs the general public interest in
increasing transparency of our processes.

Furthermore, 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’.

 

This exemption to the right of access to information is an absolute
exemption and not subject to an assessment of whether the public interest
favours use of the exemption.

 

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

 

Eva Hextall

FOI Case Officer

 

FOI Case Management Team

General Counsel

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 'Request for Chamberlayne Road Bus Review Report (Summer 2018)'.
The documents you sent in response to my FOI are completely unaccessible to the ordinary person, the information provided unintelligible. Realms of spreadsheets have been provided with no explanation or narrative on what the data means. Can you rectify and provide a sensible response which answers my request for specific pieces of information and provides an explanation on what the data means and refers to.

Thanks,

Fiona

FOI, Transport for London

Thank you for your request for an internal review which was received on 10
August 2019.

 

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://content.tfl.gov.uk/internal-revie...

 

Every effort will be made to provide you with a response by 9 September
2019. 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.

 

Yours sincerely

 

Lee Hill

Information Access Manager

FOI Case Management Team

General Counsel

 

 

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We don't know whether the most recent response to this request contains information or not – if you are Fiona please sign in and let everyone know.